EPA 910/9-84-119
&EPA
             United States
             Environmental Protection
             Agency
             Region 10
             1200 Sixth Avenue
             Seattle WA 98101
June, 1984
             Water
             EPA-10-OR-Eugene/Springfield-Lane-WWTW-84
Environmental        Final
Impact Statement

Metropolitan Wastewater
Management Commission
Sludge Management Plan
Eugene-Springfield, Oregon



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         U.S.  ENVIRONMENTAL  PROTECTION  AGENCY

                               REGION  X

       ^                   1200 SIXTH  AVENUE

        g              SEATTLE .WASHINGTON  98101
REPLY TO    ._ ..0
ATTN OF:  M/S 443
  June 15, 1984
  TO:  All Interested Agencies,  Public Groups and Citizens

  Enclosed for your review and comment is the Final  Environmental  Impact
  Statement (EIS) for the Metropolitan Wastewater Management  Commission
  (MWMC) Sludge Management Plan, which is a plan  to  reuse sludge  from  the
  Eugene-Springfield, Oregon regional  wastewater  treatment  plant.

  This EIS was prepared in compliance  with the National  Environmental  Policy
  Act and implementing Agency regulations (40 CFR Part 6, November 6,  1979).
  Availability of the EIS will  be announced in the Federal  Register on
  June 15, 1984, which will be the start of a 30-day public comment period.
  EPA will take no administrative action on this  project until  the close of
  the comment period on July 15, 1984.  Following close  of  the  comment
  period,  EPA will issue a Record of  Decision on the federal grant
  assistance to be provided for long-term handling of the sludge  produced
  at the regional treatment plant.

  Your review of this document will  be appreciated.   Any comments you  may
  have should be addressed to Norma Young, M/S 443,  at the  above  address.

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                    Final
        Environmental^  Impact Statement

Metropolitan Wastewater Management Commission
           Sludge Management Plan
          EPA Project  No. C-410624
                Prepared by:

    U. S. Environmental  Protection Agency
                  Region 10
         Seattle, Washington  98101
       With technical  assistance from:

       Jones & Stokes  Associates, Inc.
                2321  P Street
        Sacramento, California  95816
                                    Responsible Official:
                                    Ernesta B. Barnes
                                    Regional Administrator
                                             May  3,  1984

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h'rtal
FACILITY:
Municipal Sludge Storage, Conveyance,
Treatment, Drying, and Disposal
Facilities
LOCATION:
Eugene-Springfield, Oregon
DATE:
June 1984
SUMMARY OF ACTION:
A Draft  Environmental  Impact Statement
 (EIS)  was  distributed in  October  of
1983   to  discuss   the   environmental
implications   of  managing   municipal
sludge   in   the   Eugene-Springfield,
Oregon   area.     It   considered   four
alternative   facilities   and   process
combinations  for storing, drying,  and
reusing  sludge,  and  looked  at  four
locations to house the physical facil-
ities.  The plan being proposed by the
Metropolitan    Wastewater   Management
Commission   (MWMC),  which   represents
Eugene,  Springfield  and  Lane  County,
Oregon,  includes a  5.5-mile  digested
sludge conveyance pipeline,  mechanical
sludge conditioning,  facultative sludge
lagoon  storage, air  drying  beds,  and
reuse   of   the  sludge   on   local
agricultural land.   This  Final EIS has
been prepared to respond to comments on
the Draft EIS.
FOR FURTHER
INFORMATION:
Ms. Norma Young
Environmental Evaluation Branch
EPA Region 10
1200 Sixth Avenue M/S 443
Seattle, Washington  98101

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                        TABLE OF CONTENTS
OVERVIEW AND SUMMARY                                           1

PUBLIC HEARING SUMMARY                                         7

RESPONSE TO COMMENTS                                          11
     Introduction                                             11
     Groundwater                                              1.7
     Bird Strike Hazard                                       21
     Surface Water/Flooding                                   22
     Soils and Farmland                                       23
     Agricultural Reuse of Sludge                             24
     Public Health                                            26
     Odors                                                    27
     Energy                                                   28
     Sludge Quality and Treatment                             28
     Project Costs and Property Value Effects                 29
     Alternative Technologies and Sites                       31
     Landfill Disposal                                        33
     Location of Facilities                                   34
     The Coburg Hills Site                                    35
     Land Use                                                 35
     Project Design                                           36
     Errata                                                   37
     Other Comments and Questions                             38

BIBLIOGRAPHY                                                  41
     Literature Cited                                         41
     Personal Communications                                  41

ACRONYMS AND ABBREVIATIONS                                    43

LIST OF REPORT PREPARERS                                      45
     U. S. Environmental Protection Agency - Region 10        45
     Jones & Stokes Associates, Inc., Sacramento, California  45

APPENDIX A - LETTERS OF COMMENT                              A-l

APPENDIX B - COST ESTIMATE OF PLASTIC LINER FOR SLUDGE       B-l
               LAGOONS

APPENDIX C - EIS DISTRIBUTION LIST                           C-l
                                 111

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                         LIST OF TABLES
Table                                                       Page

  1     Recent Population Trends and Projections in the        3
          Eugene-Springfield Metropolitan Area

  2     Log of Comments                                       12
                                v

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                    and.  Nummary
     The planning for long-term sludge management facilities in
Eugene-Springfield began in 1977 when MWMC contracted with Brown
and  Caldwell  to prepare a  sludge  management plan  for  its  new
regional wastewater treatment plant  (RWTP) .  After several years
of considering  a  variety of sludge  management technologies  and
facilities locations, and  receiving  considerable  public input,
MWMC issued a sludge management plan in 1980.  Further action on
the plan's recommendations  was delayed because of the project's
low standing on the state priority list.   In August of 1982  EPA
announced  its  intention to  prepare  an  EIS  on  the plan.   In
response to these delays, MWMC authorized Brown and Caldwell to
investigate  interim  sludge management measures  that could  be
implemented in  time to  be  available when the RWTP begins full-
time operation in the fall  of 1984.   An interim plan was devel-
oped and published in December of 1982.

     After considerable review of  the interim  (Phase I)  plan,
EPA issued a Finding of  No  Significant Impact  (FNSI) on a 5-year
sludge management proposal  in July of  1983.  The environmental
evaluation of the long-term (Phase II) proposal continued, and a
Draft EIS  was  released  for review  at the end of  October 1983.
The  Draft EIS  considered  a  full  array  of  sludge management
alternatives  for  Eugene Springfield  (see  pages  47-60   in  the
Draft EIS) .   The  public hearing on  the  Draft EIS  was  held in
Springfield,  Oregon on  December  6,  1983.   Before  EPA can take
action on  a request for funding for the long-term plan,  it must
respond to comments on the  Draft EIS  and discuss the resolution
of significant  environmental  issues.   This  Final EIS has been
prepared to meet those requirements.

     EPA's proposed  action on the long-term  sludge management
plan  for  Eugene-Springfield is to  approve  the MWMC  preferred
Alternative  2  at  the off-site location  Site C,  which  is  an
environmentally  acceptable  solution  if   certain  mitigative
actions are incorporated into the project;  it is  also the most
cost-effective  alternative.   The  Draft  EIS  impact evaluation
indicated that Alternative  3  (on-site mechanical dewatering  and
agricultural reuse)  is  the  environmentally  preferred  alterna-
tive, but EPA has  determined that Alternative  2 is an acceptable
plan for the following reasons:

     1)  Alternative 2  is the  cost-effective  option, with  an $8.3
        million present worth  cost  advantage over  the  on-site
        sludge handling alternative  (Alternative  3) ;  this cost
        differential cannot be  justified since EPA  finds  that
        the  potential   impacts   of  Alternative   2   can   be
        sufficiently  mitigated   to   make   the   alternative
        environmentally  acceptable.

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     2) Alternative 2 provides a significant energy savings over
        Alternative 3.

     3) EPA will  require  that  the  Site C storage lagoons be in-
        stalled with an impervious seal  so that full protection
        of the groundwater is provided.

     4)   The  treated  sludge  to be  stored and  dried at Cite C  is
         not   considered  putrescible  or  of   a  nature   to  be
         considered a  food  source  for birds or waterfowl;  after
         thorough  review,  EPA  believes Site C facilities should
         not   significantly  increase the potential for  a  bird
         strike  to occur in the vicinity of  Mahlon Sweet Field
         and,  therefore,   a bird hazard to aircraft would not  be
         generated.

     5) The impact analysis contained  in the Draft EIS indicates
        that  mitigation measures recommended  by EPA are capable
        of  alleviating Alternative  2's  potential  adverse im-
        pacts,  including  groundwater  contamination.   In  the
        unlikely  event  that  local  water supply wells were to be
        degraded  by the  project,  however, MWMC would  have  to
        accept  responsibility  for  provision of  a potable water
        supply for all affected residents  until the  contamina-
         tion  is corrected.
     Although EPA proposes  to  approve  the MWMC preferred alter-
native  at  Site C,  it intends to  strongly recommend  that  MWMC
delay  implementation  of  Phase II of the  Sludge Management  Plan
until it has investigated the sludge composting program underway
in the City of Portland.   Composting was considered in the early
stages of the MWMC facilities plan development, but Portland has
made considerable progress  since that time and expects  to  have
its  facility  on-line  in  May or  June  of  1984.   Also,  there are
indications of population decline in the Eugene-Springfield area
since  1980;  these declines have  not  been reflected  in  projec-
tions of wastewater  and  sludge handling  needs  in MWMC planning
documents.  The population  declines (see Table  1)  suggest  that
the  interim  sludge  handling solution  (Phase  I)  may be adequate
to service the area beyond the planned 5-year period.  With MWMC
on the funding priority list for fiscal year 1985, there is time
to reinvestigate  this promising  sludge  management technology.
EPA  recognizes that there could  be  financial  savings to  MWMC by
proceeding with  the  Phase  II plan as soon  as  possible  since
dewatering costs  could be  reduced, but  EPA  believes that the
Portland sludge handling  plan deserves reevaluation.  MWMC has
reviewed  .a   reasonable   range   of  other   sludge  processing
technologies.

     The October 1983 Draft EIS  provides  a detailed description
of potential impacts associated with the MWMC preferred alterna-
tive.   The  public  review  of  the  Draft  has  indicated  that  a
number of these impacts are of special concern.  These include:

     o  Potential contamination of local drinking water supplies
        in the  vicinity  of  Site C if sludge  components  leach

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u>
Table 1
Recent Population Trends and Projections in the
Eugene-Springfield Metropolitan Area

1980
1981
1983
1985

(actual)
(actual)
(actual)
(projected)

SPRINGFTKTD1
41,621

39,925
46,127
MWMC
EUGENE SERVICE AREA METRO. AREA LANE CO.
105,664 147,245 193,511 275,226
147,640
103,100
124,206 159,810 221,100 270,867
         Actual numbers are from the  1980 census and LOOG; projections for 1985 were made by the cities.

         Actual numbers are from LCOG; the projected number was developed by EPA using the 2 percent annual growth
         rate assumed by Brown and Caldwell  in  its Predesign Report.

         Actual number is  from 1980 census;  the projection was made by LCOG.

         Actual number is  from 1980 census;  the projected number  is from the Portland State University Center for
         Population Research and Census.

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        through storage  lagoons  or  are carried off-site through
        surface drainage.

     o  Potential surface water  quality degradation from sludge
        components carried off of Site C during periods of high
        groundwater or heavy rain.

     o  Potential groundwater and surface water contamination at
        sludge reuse sites if  sludge  is applied at greater than
        agronomic rates.

     o  Conversion of 125 acres of farmland from crop production
        to storage, treatment, and drying of sludge.

     o  Possible  cropping  restrictions  in  the future  on  lands
        receiving  sludge,  especially  if sludge  is applied  at
        greater than agronomic rates.

     o  Change in bird  use  patterns at  Site C,  increasing fall
        and  winter  use  by  waterfowl   and decreasing year-round
        use  by  passerines,  with  an  accompanying change  in  the
        potential  for   bird  strikes   to aircraft  using  Mahlon
        Sweet Field.

     o  Detectable odors likely to occur within 1,000  feet  of
        sludge lagoons/air drying beds 10-15 days per year.

     o  Local user cost increase of $8.33 per year in property
        tax and service  fees by 1990.

     o  Project's  consistency with  local  and  state   land  use
        planning uncertain due to current state of  flux in Lane
        County Comprehensive Plan and Zoning Code.

     o  Property  values of  land adjacent  to  Site C  possibly
        adversely affected if sludge facilities are not properly
        operated and maintained.

     EPA  proposes requiring  that MWMC undertake  a number  of
mitigation measures  that would control  the  potentially adverse
effects of the project.  These include:

     o  Complete  the  groundwater  monitoring  effort  that  is
        currently underway at Site C.

     o  Install an impervious seal/liner in the  sludge  storage
        lagoons.

     o  Contain  all   surface   runoff   from  sludge  drying  beds
        on-site year-round.

     o  Regularly monitor groundwater  on the perimeters of Site
        C once the Phase II  facilities are  placed in operation;
        if local domestic water wells  become  contaminated  from

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        Site C  facilities (this  is  not anticipated),   provide
        affected residents  with  an alternative  water    supply
        until the contamination  is corrected.

     o  Comply with all  DEQ  water quality standards and sludge
        land disposal guidelines,  especially as they relate  to
        sludge application rates.

     o  Maintain  a   regular  groundwater   quality  monitoring
        program at  representative sludge  application  sites  to
        detect changes in groundwater quality.

     o  Develop sludge spill or pipeline leak contingency plan.

     o  Maintain  and  utilize  sludge  lagoon  aeration  system
        year-round to control  odors; if frequent  odor  problems
        develop, implement additional odor control procedures as
        described in the Draft EIS.

     o  Continue  to  coordinate   with   Lane  County  regarding
        General Plan and zoning status  of  Site C (MWMC  received
        a Conditional Use Permit in February, 1984 for  Site C).

     The EPA Record of Decision on the Eugene-Springfield Sludge
Management Plan,  which  will be issued  after the Final  EIS has
been circulated for a 30-day public comment period, will contain
a final  listing of  conditions EPA plans to  attach  to  the issu-
ance  of a  Phase  II  construction grant  to  MWMC.   This  will
include mitigation measures  for potential  adverse environmental
impacts.

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       id   Hearing
     On  Tuesday,   December   6f  1983,  EPA  conducted  a public
hearing on the MWMC Sludge Management Plan Draft EIS in  Spring-
field, Oregon.  The purpose  of the hearing was to  solicit  local
citizen  comments   on  the  Draft   EIS  and  the  proposed Sludge
Management Plan.  Approximately 120 persons  attended.

     Richard Thiel of EPA Region  10 acted as  hearing  officer and
led the attendees  through a  three-part program.  The first part
included  presentations   of   the   findings  in  both  the Sludge
Management Plan and  the Draft EIS.   Steve  Krugel  of Brown and
Caldwell, the  Sludge  Management  Plan  engineers,  described the
MWMC  preferred  alternative  and  its   various  sludge treatment,
storage,  and reuse  components.   Michael Rushton  of  Jones   &
Stokes Associates, EPA's EIS consultants, then briefly  reviewed
the potential environmental  impacts  of  the  MWMC preferred plan
and compared them to the impacts  of alternative plans.   This was
followed by  statements  from  attendees regarding the content of
the Plan  and the  Draft EIS.  Twenty-five  persons made formal
statements.   The  third  part  of the program  was  a question and
answer session, with  representatives  of  EPA, Oregon DEQ, MWMC,
Brown and Caldwell,  and Jones &  Stokes  Associates acting  as  a
panel to respond to comments  from the  audience.

     The  entire  hearing proceedings  were recorded  by  a  court
reporter and  subsequently  published  in  the  form  of a  147-page
hearing  record.   The hearing  was officially  in  progress  from
7:35 p.m. to  12:00 midnight.  Due to the extreme  length of the
hearing record,  EPA decided not to publish it in its  entirety in
the Final EIS.  Instead, a brief  summary of  the major questions
and concerns raised during the hearing has been compiled and is
presented below.   The  complete hearing  record  is  on file with
EPA Region  10 in  Seattle.   Any  person  wishing a  copy of the
hearing  record  can  remit  $29.50 to  the  U. S.   Environmental
Protection Agency and request the  document from:

                       Norma  Young M/S 443
              U. S. Environmental  Protection  Agency
                        1200  Sixth Avenue
                       Seattle, WA 98101

     Of the  25  persons  making  official   comments  on the Draft
EIS, the vast majority voiced opposition  to use of  either Site  C
or  the  Coburg Hills  Site as  a   location for long-term sludge
storage and drying facilities.  One  person  spoke  in support of
the MWMC  preferred  plan.    Many  of   the persons  opposing the
preferred alternative  indicated   a preference for  another al-
ternative,  including  the  on-site  storage  and  drying option

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 (Alternative 3) or an enclosed drying/incineration option (Judco
Dryer and O'Connor Incinerator).

     The major concern expressed about the use of Site C was the
potential  for  polluting  the  groundwater  underlying the  site.
The  local  groundwater is the  source  of all domestic water for
the  farms and  rural  residences in  the  area and also the City of
Junction City, which is downgradient  from  the site.  Questions
were asked  regarding the nutrient, heavy  metal,  bacterial, and
viral  content  of  the  sludge  and the effectiveness of  design
measures at keeping these materials out of surface runoff or the
groundwater  near  Site  C.   The   effectiveness  of  groundwater
monitoring and the ability to clean up the groundwater if it did
become  contaminated  was  also  questioned.   Many  of those  who
commented about  the  use of  Site C or  the  Prairie  Road  Site are
residents and/or farmers in that area.

     Approximately seven  people  from  the  Coburg  area commented
on  the  Draft  EIS, and all  expressed  opposition to  locating  a
sludge storage and drying facility in  that area.   This  included
the  President  of the City Council, the water  commissioner, and
an attorney representing the City, the City Council, the Chamber
of Commerce, and the Muddy Creek  Irrigation  District.   Several
persons questioned why the Coburg site was analyzed in the Draft
EIS  when it  had been  reviewed and  subsequently  dropped  from
consideration  in developing  the   Sludge  Management Plan.   The
other concerns expressed about  the  use  of this  site  included
aesthetic  impact,  groundwater  contamination,  site  flooding,
odors, economic  impact, and  adverse  influence  on local  property
values.  Several persons also felt that the cities of Eugene and
Springfield should not be considering placement of an urban-type
land use outside the metropolitan  area urban  growth boundary in
a rural  setting.   Conflicts  with  state land use  planning goals
 (agricultural  lands,  public  facility, urbanization,  and  energy
conservation) were claimed.

     In addition  to  the statements opposing the  MWMC preferred
alternative  and  the  use of  an  off-site  location for  sludge
storage  and drying,   a large  number  of  specific  questions  or
comments were  made  regarding  the  content  of  the Draft EIS.   A
listing of the more  significant and/or commonly raised  concerns
is presented below:

     o  The latest research  on the fate of bacterial and viral
        wastewater   contaminants   should   be   considered  when
        assessing the  public  health  impact of  land disposal  of
        sludge.

     o  The Draft EIS failed to adequately describe why  off-site
        locations other than  Prairie Road,  Coburg Hills,  and
        Site C were not considered in the  impact analysis.

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o  The  range  of  alternative  sludge disposal  technologies
   considered in the Draft EIS should have been greater.

o  The  agricultural  reuse market  for  municipal  sludge is
   not adequately documented in the Draft EIS.

o  Air-drying of  sludge in the  Eugene area does  not seem
   possible; other methods of drying should be considered.
   Sludge  incineration  should  also  be  considered  more
   fully.

o  Much  of  the  groundwater data used  in the Draft  EIS is
   inaccurate, especially the data  from  the Sweet, Edwards
   & Associates River Road/Santa Clara  study.

o  It will be impossible to avoid sandy or gravelly subsoil
   lenses when excavating ponds at Site C or Prairie Road.

o  The cities of Eugene and Springfield should  handle their
   sludge management  needs within  their own urban  growth
   boundaries.

o  How can MWMC  consider using Site C or  Prairie Road for
   long-term sludge storage and drying  when local residents
   are not allowed to put additional septic tank/leachfield
   systems on their property?

o  Why  is  it more  expensive  to  dewater  sludge at  the
   regional  wastewater  treatment  plant  site   than   at  an
   off-site location?

o  The Site C storage lagoons will attract birds and create
   a hazard to air traffic using Mahlon Sweet Field.

o  The Delta  Gravel  Pits should be considered  as  a  sludge
   disposal site.

o  Site  C's  value as  industrial property  should be con-
   sidered before it is used for sludge processing.

o  Valuable farmland should not  be  removed from production
   for sludge processing purposes.

o  Seasonal  flooding  on Site C  and  Prairie  Road  should
   eliminate their consideration for sludge processing.

o  What  course  of  action would be taken  if  groundwater
   monitoring at Site C shows contamination is  occurring?

o  What are the land costs at Site C?

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                          Introduction
     EPA received  32  written comments and recorded  oral testi-
mony from  28 persons during  the official public  review period
for the MWMC Sludge Management Plan Draft EIS.   Materials  were
also received regarding  the  Agripac  wastewater spray irrigation
project and  the  Eugene  RWTP  project; these were  not considered
relevant to  a review of  the  Draft EIS.   Some of  this  material
was submitted to  EPA before  the  Draft  EIS  was  published  and
therefore does not specifically address itself to the content of
the Draft  EIS.   This material has been  reviewed by EPA  and is
retained in the project files in Seattle.

     A log of all  written and  oral comments  received during the
official 45-day  comment  period  is  presented  on  the  following
pages.   The  name  of the agency or individual  that commented is
presented,  and the subject  matter of the relevant comments has
been indicated  by  placing  an  "X"  in  the  appropriate  column.
Responses  to  the  comments have been organized into  a number of
subject matter categories, as  indicated  in the log of comments,
because of the duplicative nature of many of the comments.  Each
individual comment has been  carefully  reviewed and subsequently
addressed  in the  text  of  the  general  comment  sections  that
follow.   For  example,   if   a  commentor  voiced  a  groundwater
concern regarding  the proposed project,  that  person may review
the Groundwater  section to  find  a response.  All written  com-
ments  received on the Draft EIS  are included as  Appendix  A to
this Final EIS.   Oral  comments  that received responses  during
the  question-and-answer  part  of  the public  hearing  are  not
addressed again in this document.
                               11

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                                                         Table 2.   Log of Comments
                                                 MWMC  Sludge Management Plan Draft EIS
                                                                              BS
WRITTEN COWENTS
                         i
                                                   a
3   I
                                       CQ
U. S. Dept. of the Army
Corps of Engineers,
Portland Dist.
U. S. Dept. of Housing
and Urban Development
U. S. Dept. of the
Interior, Office of
Secretary
U. S. Dept. of Trans-
portation, Federal
Aviation Administration
U. S. Dept. of Trans-
portation, Urban Mass
Transit Admin.
Oregon Dept. of Fish &
Wildlife
Oregon State Executive
Dept.
Oregon State Historic
Preservation Office
Lane Council of Govern-
ments
12/23/83
12/9/83
2/3/84
12/19/83
11/3/83
12/5/83
2/24/84
2/24/84
12/21/83

X
X





X



X













X








X
























































































X




















X



X













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                                                        Table  2.   Log of Comments
                                                  MWMC Sludge  Management Plan Draft EIS
WRITTEN COMMENTS
                          I
E
a
§
                                                                                             en
    HQ    3



S   §1
§
                                                                                                                     1
Metropolitan Wastewater
Management Commission
Springfield Area Chambe
of Cormerce
Melva Barnes
Brown and Caldwell
J. Kyle Clinkscales
Mr. and Mrs. William
Cook
Robert Dooley
Gordon Elliott
Joyce Engels
Larry Engels
Ernest Garrett
Howard Humphrey
Donovan Kendall
12/18/83
12/21/83
12/19/83
12/21/83
12/8/83
12/13/83
10/29/83
12/21/83
12/15/83
12/19/83
11/6/83
12/10/83
12/6/83


X
X
X






X



X

X






X













X



X








X


X
X







X



X
X

X





X





X



X







X











X












X












X
X

X

X



X

X










X

X

X



X



X





X





X


















X













X











X
X










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                                                         Table 2.  Log  of  Comments
                                                   MWMC Sludge Management  Plan Draft EIS
                                                                                                   Ui
                                                                                                   M
                                                                                                   Q
                                                                                                       a
                                                                                                       M
                                                                                                       EH
                                                                                                       a
WRITTEN COMMENTS
                          I
§
M
ffl
                                                                                                   fe   fc!
a
Dan & Ann Klemp
Lois Lund
Richard & Sadie Lyon
Nathaniel D. Mase
Jim Melamed
Bob Meltebeke
Lucille Moyer
John Neely, Jr.
Harold & Lois Schrenk
Chester Swenson
ORAL COMMENTS. AT PIBLIC
Fred Simmons
Jere Christner
Jim Melamed
Bob Bryson
12/21/83
12/16/83
12/8/83
12/16/83
12/6/83
1/9/84
12/21/83
11/7-12/19/i
12/9/83
12/83/83
lEARTNG (12/




X
X
X



X
3 X
X

6/83)
X



























X










X

X








X







X








X
X





X







X

X
























X







X





X

X








X







X

































X
X






X
X




X







X








X




























X


X



-------
                                                           Table 2.   Log of Comments

                                                      MWMC Sludge Management Plan Draft EIS
   ORAL COMMENTS
                                                                                                J£    S
                                                                                                W    OT
                                                                                               i a    a
                                                                                               • H    B
                                                       a
                                                       H

                                                       8
                                                                                                                   W

                                                                                                                   B
Donald Dickey
John Buttner
John Mehringer
Wanda Simnons
Marie Gray
Bob Kaiser
Bob Nelson
Tom Heintz
Chris Coglietti
Herman Bodenroeder
Pat Bohanan
Warren Jacquenod
Katherine Bowder













X
X
X
X
X

X



X
X
X











X



X













X



















X





X









X


X



































X









X



X
X




X


X

































X


X














X

















X



















X



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-------
                                                       Table 2.  Log of Comments
                                                 MWMC Sludge Management Plan Draft EIS
OPAL COMMENTS
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                                                                                                     a
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                                                                             [2
Melva Barnes
Gordon Elliott
Judy Wullenwaber
John Neely, Jr.
Ernest Garrett
Bob Parker
James Anderson
Laura Heintz
William Connor
Marlin Franssen
Kirk Poth











X

X

X
X

X



X























X




X

























X




X



X




























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X

X

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X


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-------
                           Groundwater
     The  groundwater  quality issue was  by far the  most common
subject  of  comment  on  the  Draft  EIS.   Thirteen  letters  of
comment  and  fourteen oral presentations specifically  addressed
the impact of the MWMC project on groundwater quality.   The most
prevalent concern was that storage and  air-drying of  sludge at
Site C  or the Prairie Road  Site  might  contaminate local wells,
which provide the sole domestic water source for area residents.
Others indicated that the sludge transport pipeline and the land
application  of  sludge were  likely sources of  groundwater con-
tamination.  Several questions were raised about the assumptions
made in  the  EIS groundwater analysis, and  the  validity  of some
of the data used in that analysis was questioned.   Another major
topic of  comment was  the range  and effectiveness  of groundwater
contamination control measures  planned  as part of the project.
A variety of other specific, less  easily categorized  questions
were raised  about groundwater  in  the vicinity of  the proposed
project.

     The  response to  this  diversity of  groundwater comments has
been organized  into  three sections.  The  first  addresses  all
questions about the technical  detail of the Draft  EIS  ground-
water analysis.  Description  of existing groundwater conditions
is the major topic of this section.  The second section address-
es questions about  the design of  the sludge handling facilities
and  their effectiveness in  controlling  groundwater contamina-
tion.   The  final  section  addresses  a  number  of  miscellaneous
questions.

     The  groundwater quality   analysis  in  the Draft EIS  was
lengthy;  it  summarized a  considerable   volume  of  data  and  an-
alyzed groundwater  conditions at  a large number of  sites.  The
sources  of  background  data for   this   analysis  are  existing
reports  and  monitoring  data.   No  original data collection  was
undertaken by  EIS  preparers, but  efforts were made to  use  the
most recent, most site-specific data  available.   Sweet,  Edwards
& Associates  (1982)  data  from the Agripac site  were  used  in
reference to Site C and  Prairie Road because it is  both recent
and  site-specific.   EPA  has  not  received   any  substantive
evidence  that this  data  is inaccurate or invalid.   If there is
specific  reason to  question this  data,  EPA  would  appreciate
being informed  of what is  inaccurate  or  misleading.   In several
instances, background data that are 10 to 15 years old  were used
(Frank  and  Johnson  1970;  Frank  1973).   This  was  considered
appropriate where more recent or more specific data is  not found
in the  literature.   Most  of the older literature  provided only
general  groundwater flow  direction data.   It is  unlikely that
this has changed significantly in recent years.  The groundwater
flow rate at Site  C has  not  been measured by  MWMC;  the  EIS
preparers,  therefore,  relied  on  data  developed  by  Sweet,
Edwards & Associates for a nearby section of the aquifer.
                               17

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     A  question  was asked  regarding  the migration  of leachate
out  of  the  sludge lagoons  if  some  failure  occurred  during
periods of  high  groundwater.   The EIS  contention  that leaching
would "virtually cease" in  the  fall and winter  due to a rise in
the water table was questioned.   The  commentor  felt that mound-
ing would occur and horizontal  leachate migration  would contin-
ue.  We agree that leachate migration probably would not totally
cease.   Migration  would  be  greatly  reduced,  however, if  the
general groundwater level  reached the bottom of the lagoons or
the surrounding ground surface level.  Mounding could occur if
the groundwater level remained some distance below the bottom of
the  lagoons.   In   this  situation,   some  lateral  movement  of
leachate could be  expected.   The  significance of lateral migra-
tion would  depend  on the  volume and quality  of the leachate and
its  rate of  movement  and  mixing.   Off-site  effects  probably
would be  detected  sooner  in  the mounded  groundwater situation
than  if the  underlying groundwater  level  was  at or  near  the
surface.

     Several commentors asked about the depth of the clay soils
at Site C.  Concern was expressed that excavation for the sludge
lagoons might  intercept coarser sand or gravel,  increasing the
risk of eventual groundwater contamination.  As indicated in the
Draft EIS  (page 84) ,  there  may be locations  where  the depth of
clay  soil  is  less than  5  feet  and coarser  material may  be
encountered.  The  project engineers planned  to  cover such areas
with a  minimum of  6 inches  of compacted clay material excavated
from some other  location.   EPA is requiring  that  an impervious
seal  be  installed in  all  lagoons to ensure that leachate mi-
gration is  controlled  even  if  coarse  subsoil layers are encoun-
tered during  excavation.   Soil borings made  in  the  Site C area
to date indicate that  clay  soils  extend from 4  to  18 feet below
the surface,  with  gravelly silty  sand  found at the surface in
one well boring (Geotechnical Consultants,  Inc. pers. comm.).

     Many  of the  groundwater  comments indicated  a  fear  that
contamination would occur  in  spite   of  features that  would be
designed  into  the  proposed  project  to  protect  groundwater
quality.  Two  persons   felt  that the  ponding of  surface  water
that often  occurs  in  the  area in winter  months would  lead to
groundwater contamination if the  sludge facilities were located
in  this area.   The project  design,  however,  calls  for  con-
struction of  5-foot high berms  around  all  sludge  lagoons,  and
air-drying beds would  not be  used in  the winter months.  Ponded
or  flowing  surface water,   therefore,  should  not  come  into
contact with sludge.

     EPA  is aware  of   fears  that a  6-inch   clay  liner in  all
sludge lagoons might not be sufficient to avoid eventual ground-
water contamination.   Because  there  is a  significant number of
persons that  rely  on  shallow groundwater  for domestic consump-
tion in the Site C area and coarse subsoil  layers may be encoun-
tered in  lagoon  construction,  EPA is requiring  MWMC to install
an impervious  seal in the lagoons.  This should provide maximum
                               18

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groundwater protection.  MWMC has  estimated  the additional cost
of a  plastic  liner would be approximately $960,000  (see Appen-
dix B).  Other types of liner or seal may be  possible.

     The dual  force mains  that would  carry sludge and super-
natant between  the RWTP and  the off-site facilities  were also
sources of  concern.   In its comments, Brown  and  Caldwell noted
that the dual nature of this line could reduce the likelihood of
serious groundwater contamination.   If  a leak (or break)  was
detected in one  line,  the second line could  be used for trans-
port  of materials while the  damage in  the  other line  was  re-
paired.   Problems  of  exfiltration  from  unsealed  joints  or
vibration damage can  be  controlled  through proper design  and
construction;  these problems  can be located, if  they  do occur,
through periodic pressure  testing.   It  will be  MWMC's  respon-
sibility to ensure  that pipelines are  properly designed  and
constructed.

     Several persons questioned the need for  groundwater quality
monitoring  in  the  vicinity  of Site  C if the  project  was  not
expected to contaminate  the  groundwater.    Others  asked  what
would happen if monitoring detected some contamination.  Ground-
water monitoring  is an  essential part of plans  for sludge reuse
in  the Eugene-Springfield  area;  it  will   serve  a  number  of
valuable functions.   First,  ,a monitoring  system will  provide
background water quality data, whether it be  at the  storage and
drying  site,  at  Short Mountain  Landfill,  or  at sludge  reuse
sites.  If  all  facilities  and  operations perform as  expected,
the monitoring  data will act  as an  indicator  that  groundwater
contamination is not occurring.  If for any reason, however, the
sludge management  operation  does cause a change  in  groundwater
quality, the  monitoring  program  will  allow  early  detection.
Modification of  facilities  or  changes in operational procedures
can then be undertaken to  control the source of  the contamina-
tion.  The  nature of  these changes  would depend upon  what is
found to be the source of contamination.

     The nature of the aquifers at Site C make it unlikely  that
groundwater contamination  in  the area  would be  corrected  by
extracting and treating the water.   An  extraction barrier might
be created,  but rapid location and correction of the source   of
contamination would be  the critical action.   If  local domestic
water supply wells were to become contaminated,   MWMC  would  be
responsible for  procuring an alternative  water supply  for the
affected residents  until the contamination had  been corrected.
Control of the source  of contamination and dilution of the con-
taminants in the groundwater as  they  move  with   the  general
groundwater  flow  may  be  the  only effective remedial action.
The same general remedial procedure would apply at Short   Moun-
tain Landfill if a change in groundwater quality were detected.

     Groundwater monitoring at  sludge reuse sites  would serve
the same function as at the storage and drying  site.  Any  change
in groundwater quality  caused  by sludge reuse would be  detected
                                19

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and a  change  in application would be  initiated.   If the source
of the problem  was an  excessive  rate  of application, an adjust-
ment in  rates could be  made.   If the  problem was  found  to be
associated  with site  drainage or  permeability  conditions,  or
excessively low soil pH, it might  be necessary  to  halt sludge
reuse at that particular site.

     In summary, there are numerous features designed into MWMCs
preferred  sludge  management  plan  to  reduce  the  chances  of
adversely affecting  groundwater.  Every effort will be  made to
guarantee that  all of  the  features  are constructed and operated
as  designed.    The  groundwater monitoring  system will  provide
back-up protection.  EPA will  not require  MWMC to  post  a bond
for correction of water supply contamination, but MWMC will have
the responsibility  for correcting problems  associated  with its
sludge management facilities.

     The final  section of this groundwater discussion deals with
several  specific questions  that could not  be  answered  in  a
collective  response.   These questions  and  their  responses are
presented below.

Why has MWMC not considered use of government land south of Fern
     Ridge Reservoir for sludge reuse?  The land is not over the
     aquifer  supplying domestic wells.  MWMC intends  to apply
     its sludge to  agricultural lands to take  advantage of its
     nutrient value.  If the government land south of Fern Ridge
     Reservoir  is  used  for  agriculture and  can meet  DEQ land
     application criteria, MWMC would consider its use.

Why are the Delta Pits unacceptable for sludge storage, yet Site
     C  is  acceptable   even though   gravelly  subsoils  may  be
     encountered?  The  reasons for rejecting use of  the Delta
     Pits is stated on pages 56-57 of the Draft EIS.  Lagoons at
     Site C would  not be  placed on  a large  expanse  of open
     gravel as  would be  the  case  at the Delta Pits.   Only small
     lenses  are expected  to  be encountered  at  Site  C.   The
     lagoons would be lined with impervious material.

What  is  the  depth  to  groundwater  at  Site  C  at  this  time?
     Groundwater  monitoring at  Site  C shows  that  depth  to
     groundwater has fluctuated between less than one foot to 11
     feet below the surface in the  last  year  (Peroutka pers.
     comm.).

Would  agitation  action  from  train-related  vibrations  cause
     groundwater to intermix with sludge lagoon leachate at Site
     C or Prairie Road?  The sludge lagoons  are  not expected to
     generate leachate, as an impervious  seal is being required
     by EPA.  With an impervious liner, train-related vibrations
     are not  expected  to have  any effect on  leakage or ground-
     water.

The EIS contention on page 84 that ammonia-nitrogen moves freely
     through  the  soil  is  inaccurate.  It  is readily  bound up
                               20

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     with  soil.   EPA agrees  that the  statement  on page  84  is
     inaccurate.  Reference  should  have been  to  nitrate rather
     than ammonia-nitrogen.

A  North Carolina  study  indicates  that  sludge  should not  be
     applied to  soils with a  pH  less than 6.5.   Low  pH allows
     heavy metals  and other  materials  to move  rapidly through
     the soil.  The  Oregon DEQ recognizes  soil pH is a signifi-
     cant factor in  the movement  of heavy  metals  through soils.
     Its  sludge reuse  guidelines have  accounted  for  this  by
     allowing  lower  cumulative  application  rates  where pH  is
     less than  6.5   (see page  F-20  of the Draft  EIS) .   DEQ has
     reviewed the literature  on this  subject,  and does not feel
     that  sludge  reuse  should be totally eliminated  on  soils
     with a pH less than 6.5.


                       Bird Strike Hazard

     Several commentors voiced continued concern over the hazard
that the project might  create if it  becomes  a bird attractant.
This included local  residents and the Federal Aviation Adminis-
tration.   The  principal  issues  raised  in these  comments  were
addressed in the Draft EIS on pages 140-157,  but will be restat-
ed here briefly.

     The concern  over the bird  strike hazard  is based on FAA
Order 5200.5, which  discourages the location  of any solid waste
disposal  facility  that might  act as  a bird  attractant within
10,000  feet of  airport  runways used by turbo-jet aircraft.   EPA
has adopted  a  similar policy regarding the  processing  or  dis-
posal  of  putrescible  wastes  within  10,000  feet  of  a  runway.
Residents have  stated that  the  planned sludge  storage lagoons
and sludge drying beds, which are located  less than 10,000 feet
from Mahlon Sweet Field Runway 3-21,  are likely to act as a bird
attractant  and  therefore are in  conflict   with  FAA  and  EPA
policy.

     EPA researched this issue thoroughly in  preparing the Draft
EIS.   Persons  with  considerable knowledge  of  local  bird  use
patterns,  bird use at similar sludge facilities, and bird strike
hazards at airports were consulted.   This included FAA represen-
tatives  in Seattle,  Minneapolis,  and Washington,  D.  C.,  and
treatment plant operators  in  Corvallis  and Sacramento.  The two
critical questions  addressed  in  assessing the hazard  were:  1)
would the new facilities  act  as a bird  attractant, and 2)  would
any project-related  change  in bird use constitute an  increased
risk of bird strikes to aircraft using Mahlon Sweet Field?

     After  reviewing all  aspects of facility  design  and  the
relationship  of Site  C  to  the  Runway   3-21  flight  pattern,
several important factors  came to light.  First,  the  sludge  to
be stored and dried  at Site C would be  digested and essentially
stabilized before arriving  at the site.   The  material will not
                               21

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be  putrescible  (containing  organic  matter  capable  of  being
decomposed by microorganisms)  and,  therefore,  should not act as
a  food source  to  birds.   Further,  operation of  the  facility,
including  use  of  aerators  and control  of  aquatic vegetation
within  the  lagoons,  should  further  discourage  bird use  of the
site.   Finally,  aircraft using Runway 3-21 would  pass approxi-
mately  400-600  feet  overhead of Site  C,  considerably  above the
normal  flight elevation of most birds presently known to inhabit
the area  (waterfowl are an exception).

     Based on this review  of information,  we  concluded that the
sludge  facilities  would not act as  a  significant  attractant to
birds,  although  waterfowl  may occasionally use  the  lagoons for
resting.   There are already numerous open water  areas  in the
vicinity  that  provide  resting areas  and  also a source  of food
for  waterfowl,   and  it  is  unlikely that  waterfowl would use
"poor"  quality  water   (sludge)  for  resting,   given  abundant
alternatives.   The  project-related  change  in  local  bird use
patterns is not expected to  significantly increase the probabil-
ity of  a  bird strike occurring in the vicinity  of Mahlon Sweet
Field.

     In order  to ensure that  any  facilities  located  at  Site C
would not act as a bird attractant, EPA has recommended a number
of control measures.   These include control  of  aquatic  vegeta-
tion in the  lagoons, day-time  use  of aerators and  monitoring of
bird use  patterns.  In  the  unforeseen event  that birds  may be
attracted  to the lagoons  and  create a bona fide hazard,  it will
be MWMC's  responsibility   to  mitigate the problem.


                     Surface Water/Flooding

     Surface  water  quality  and   site  flooding  concerns  were
indicated in a  number  of comments.  The  chief  concern was that
runoff  from  or  flooding at Site  C  would contaminate  surface
water or  groundwater to the north.   Reference  to  Federal Emer-
gency Management  Agency (FEMA)  flood hazard  boundary maps was
made by two  individuals.   The February  1981  flood  hazard maps
show a  Zone  A  flood  zone along the  drainage  that  traverses the
portion of Site C analyzed  as part of Alternative  1.   It does
not cross  the  southern portion of  Site  C analyzed  as  the MWMC
preferred alternative (Alternative 2).

     Lane County was contacted to determine if more recent  flood
hazard maps  showed any  change  in  the boundaries of flood hazard
at Site C  or Prairie Road.  FEMA maps of  Lane  County published
on September  16,  1983,  indicate that  the  drainage channel that
traverses  Site  C  (the northern  portion)   from  southeast  to
northwest  is still classified  as  a  Zone  A  flood hazard area.
This suggests that if  MWMC wishes to  use  this  northern  portion
of Site C for sludge handling  facilities,  the  drainage  channel
must be diverted around the facilities.   EPA   would    require
                               22

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that   the  facilities    be flood-proofed   for    the 100-year
flood event.  This would be required as a condition of construc-
tion grant approval.

     The  possibility  of surface  water contamination  at  Site  C
has  been  taken  into  consideration  in  the proposed  design and
operation of  the lagoons and drying beds.  Runoff and flooding
control measures are discussed  on  pages  111-113 of  the Draft
EIS.  Rerouting  of  the  surface drainage around  Site  C,  collec-
tion of runoff  from those areas  likely  to  come  in contact with
sludge, and fall washdown  of sludge drying beds  are  several of
the project features planned to control surface water contamina-
tion.  If off-site  drainage from the  lagoons,  drying beds, and
sludge transfer  facilities  are  contained on-site as planned and
pumped  back  into the  lagoons,   and if  the  existing drainage
channel is  diverted around Site  C,  surface water contamination
should not occur downstream from  the site.

     The  Lane  Council  of  Governments  expressed concern  that
there  is  a  lack  of water quality  data  for the  surface  waters
near Site C,  the Prairie Road Site, and  the  Coburg Hills Site.
This lack of  data is typical when the local  surface  waters are
intermittent  streams.   Very few  intermittent streams are moni-
tored throughout  the United  States.  It  is likely that agricul-
tural  runoff  now contributes  nutrients, bacteria,  and  perhaps
pesticide or  herbicide  residues  to  these waters  when they are
flowing.  If  Site C is  developed for sludge storage and drying,
a  surface water  sampling  program  must  be  initiated prior  to
construction.    These data  will  be essential  as a  background
comparison  for  future monitoring results.  The  lack  of  data on
existing  surface water  quality  conditions,  however, need not
influence the decision  on whether  or  not to proceed with con-
struction of  off-site sludge handling facilities.


                       Soils and  Farmland

     Five persons  indicated their opposition to the conversion
of  prime  farmland  for  construction of off-site  sludge  storage
and drying  facilities.   In  contrast, the Sludge Management Plan
engineers (Brown and Caldwell)  indicated that the land at Site C
should not  be considered prime farmland because  of  the  complex
patterns  of Class  II  and Class IV soils that exist  on the site
and the poor drainage conditions present on the site.  Brown and
Caldwell  contends these  conditions  limit the use  of  the  entire
site as prime farmland.

     It is  EPA's policy to consider protection  of the nation's
significant agricultural  lands from irreversible  conversion to
nonagricultural  uses.   In  the  case  of  Site C, the  land  has not
been categorized as prime  or  unique  farmland  under  the  U.  S.
Soil  Conservation  Service  Land  Inventorying  and  Monitoring
Memorandum  (LIM) criteria.   Lane County,  however, has mapped the
site as a combination of prime  and  unique  farmland.   EPA recog-
                               23

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nizes  that  poor drainage conditions on the  site  and the alter-
nating pattern  of well  drained  and poorly drained soil restrict
the  range  of  farming   practices  that  are  undertaken on  the
property.  The  site  is  currently  used  for grass seed production
rather than  a food crop.  Nonetheless, EPA  feels  that the loss
of 80-100 acres  of Class II  soil  at Site  C is an adverse impact
of the MWMC preferred project,  although  it  is  not an irrevers-
ible  and  irretrievable   loss. The  significance  of this  loss  of
soil  resources  has been weighed  against  the environmental  and
economic  implications  of other sludge  management alternatives.
If MWMC  pursues grant  funds  for  use of  Site C,  EPA  will fund
purchase of  only that acreage needed to accommodate  the 20-year
design capacity of the  facilities.  EPA will also recommend that
the  facilities  be  located on  the site in a manner  that  least
interferes   with  continued  agricultural  use   of  surrounding
parcels.


                  Agricultural Reuse of Sludge

     A major component  of the MWMC Sludge Management Plan is the
reuse  of  liquid  and  air-dried   sludge   on  Willamette  Valley
agricultural  lands.   A demonstration  reuse program  has  been
underway  for several years  now,   using  sludge  from  the  Eugene
wastewater  treatment plant.  Estimates  prepared  by  Brown  and
Caldwell  indicate  that   up to  2,050 acres of agricultural land
will be needed by the year 2000 to reuse all sludge generated by
the  new  Eugene  RWTP.   A  number  of persons  commenting on  the
Draft EIS felt that there was insufficient evidence of the local
farmers'  willingness to  accept the sludge.

     A number of reasons why local farmers might  not be willing
to accept  the sludge were  expressed.   This included  such con-
cerns as heavy  metal  accumulation, low nutrient content,  future
restrictions  on crop  types, competition for  land  from  urban
uses, potential for changes in regulations, and general mistrust
of local city government.  Several persons requested proof of a
demand for the product,   including a list of names and numbers of
acres committed to accepting the sludge.

     EPA has  had considerable  experience  with  municipal  sludge
reuse proposals  throughout the  U.  S.,  including projects  in the
Northwest.   This experience  shows  that  there  is  usually  an
initial hesitancy  toward sludge reuse, but in the  majority  of
cases agricultural reuse programs  have  proven  successful  in the
long term.   There is  a  wide  array of control measures available
to protect soil resources and the public health from ill effects
of  agricultural reuse  of  sludge.  The  MWMC  has  initiated  a
pretreatment program to limit the  amount  of potentially harmful
materials that  enter the  RWTP.   DEQ  and MWMC regulations  and
guidelines  restrict  the amount  of heavy metals that may  be
applied  to   a  given  parcel  of  land.   The  sludge  may not  be
applied to  land  being used to raise food crops.   Therefore,  no
land will be taken out of  food crop production.  Other  guide-
                               24

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lines  restrict  public  access  and   grazing  activity  on  land
receiving  sludge.   A  comprehensive  soil monitoring  program is
also required.

     EPA has  not required  MWMC to provide a listing of individ-
uals or specific acreages that would receive the sludge product.
Experience with other  projects and an independent review of the
agricultural  reuse market  in the Eugene  area  (see  pages  G-6 to
G-ll  in  the  Draft  EIS)  indicate that  the sludge  should  have
sufficient value as  fertilizer and soil  conditioner to attract
users, as long as the reuse is closely monitored by both DEQ and
MWMC.  EPA  also feels  that  subsidiary markets  in  forestry and
speciality fields  (nurseries,  landscapers) could  be acceptable
outlets  for  sludge in  the Eugene area.   EPA does  not believe
that  there will  be  a lack  of  reuse  opportunities  after the
storage and drying facilities  are constructed.

     Several  other questions were raised regarding the agricul-
tural reuse of  sludge.  One  person asked if the reuse aspect of
the plan would  make  MWMC eligible for  an additional 10 percent
federal funding as an  innovative or alternative technology.  As
an  alternative  technology,   the  sludge  reuse  aspect  of  the
project makes MWMC  eligible  for an additional  10  percent grant
funding.   However,   this   extra  10 percent  is  subject to  the
availability  of federal funds.

     Two persons  questioned the  public  health  consequences of
agricultural  reuse and  wondered  why the sludge could be applied
to agricultural land but not to urbanized settings such as parks
and greenbelts.  There  is  sufficient  evidence in the scientific
literature  to  indicate  that  the  controlled  application  of
treated municipal  sludge  to  nonfood  crop agricultural land can
be  accomplished without  significant  risk  to  public  health.
Agricultural  lands are typically not subject  to general  public
entry,  and  access  can be  closely  controlled.   Farmers  will
receive sludge  on  a  voluntary basis  only,  after being informed
of  any  potential  health  risks.   This  controlled   access  and
implied consent cannot be achieved where  the sludge is placed on
public parks  or greenbelts.    Sludge  is being applied  to agri-
cultural  land  in  many  parts  of the   United  States  without
apparent adverse health effects.

     Brown and  Caldwell  questioned  the  conclusion  in the EIS
that  use  of  air-dried sludge  on agricultural  lands  (Alterna-
tive 2) would create  more significant heavy  metals  problems in
surface  waters  than  would  use  of dewatered sludge   (Alterna-
tive 3) .  EPA bases  its contention on  the fact that  the  total
amount of heavy metals applied per acre  would  be  less annually
using  dewatered  sludge than  using air-dried sludge.  This is
because  the  ratio  of  heavy  metals to nitrogen  is  lower  in  a
sludge  that   has  not  been  subjected  to  thorough  air-drying.
Soils  should  be able  to  absorb the   smaller amounts  of  heavy
metals more rapidly under the dewatering mode, thus reducing the
risk that the metals could be  washed  into surface waters before
being assimilated into the soil.
                               25

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                          Public Health

     The public  health risks associated with  sludge processing
and  disposal have  been  a  dominant  issue in  the  MWMC  sludge
management  planning  effort.  The  comments received  during  the
Draft  EIS  review process focused  on a  continuing concern—the
health  hazard  associated with  applying sludge  to agricultural
lands.   Several  commentors  specifically identified  the cadmium
content  of the  sludge as  a health  hazard.   Others  felt  that
viruses, bacteria, and heavy metals  in  general pose a threat to
human health and should be kept off the land.  Transfer of toxic
materials  to humans  through consumption  of  plants  or animals
raised  on  the  land was also  expressed  as  a public  health  con-
cern.

     Both  EPA  and the Oregon  DEQ are  aware  of  the potential
health hazards associated with agricultural reuse of sludge.   In
order  to  provide  for maximum  public   protection while  still
taking  advantage of  the fertilizer and  soil  conditioning value
of municipal sludge,  EPA and DEQ have established rigid controls
on  agricultural  reuse.   These controls  have  been  established
through  review  and   analysis  of  the  numerous  public  health
studies  that have  been conducted by  universities  and state  and
federal  agencies.  The public health analysis  contained  in  the
Draft EIS  (pages 124-136) was prepared  after review of the most
recent public health literature and was compiled by a specialist
in bacteriology and public health.   After considering the degree
of  treatment  the sludge will receive,  the expected  quality of
the  sludge,  and the  high degree  of  control and  monitoring of
agricultural  reuse  required by  DEQ,  EPA  concludes  that  the
sludge can be applied  to the  land in the Eugene-Springfield area
without creating a significant public health threat.

     Bacterial and viral  levels in  the sludge will  be greatly
reduced  by  the  digestion,  storage,  and  air-drying  processes
proposed for use.  Heavy  metal  content,  which is relatively low
in  Eugene-Springfield  sludge,  will  be closely monitored  and
limits will be established  for  each  land area receiving sludge.
Sludge will not  be applied  to food crops, so  plant uptake  will
not be  a public  health risk.   The  heavy metal limits, including
limits for cadmium, will provide a 100-1,000  fold safety factor
for any  given  year.   It will take an estimated 65-167 years to
reach the maximum allowable  heavy  metal  loading on reuse sites,
assuming maximum allowable  applications of  sludge.   If cadmium
levels  are  found  to  be twice as high as  expected  by Brown  and
Caldwell,  this  life  expectancy could  be  reduced  to 32 or 33
years.   In  any event,  soil  monitoring  will ensure  that heavy
metals  are  not  allowed to  build up to hazardous  levels  on  any
sludge disposal site.

     Two persons indicated  that studies have  shown  septic  tank
treatment of human wastes poses less of a public  health threat
than activated sludge  treatment in a central  wastewater treat-
ment facility.  There  are numerous studies that indicate septic
tank/leach  field  systems  are  effective  wastewater  treatment


                               26

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systems  when  soil  and  groundwater conditions  are appropriate,
but  these  systems cannot be  used effectively  in  densely popu-
lated  areas.   Sludges generated  in activated  sludge wastewater
treatment plants  can  be disposed  of or  reused  without a serious
health risk  if properly digested and treated  prior to disposal
or  reuse.   Septic  tank/leach field  systems  are  not  a  viable
alternative to MWMC's proposed Sludge Management Plan.

     Several persons  also expressed the  fear that  toxics  in the
sludge applied to agricultural  land would be taken up by plants
and  subsequently pose  a  health  hazard  to  humans.   As  stated
earlier, DEQ regulations (adopted by MWMC) do not allow applica-
tion of  sludge  to food crops.  An 18-month  waiting period must
be  observed between  sludge  application and  planting of  food
crops.   This  is  expected  to  provide sufficient  time for  any
pathogenic agents  to  die off;  soil and  plant tissue samples can
be  taken to ensure that hazardous  levels of  potentially toxic
materials are  not transferred to crops  that may be consumed by
humans.  It  is unlikely,  also,  that  lands  receiving  sludge in
the  Eugene-Springfield area  will switch from growing nonfood
chain crops to growing food chain crops.

     One commentor questioned  the  statement  in  the  Draft  EIS
that composted sludge would have a lower  level of pathogens than
air-dried, dewatered, or liquid  sludge.   EPA agrees that patho-
gen  die-off in  facultative  sludge  lagoons  can   approach  that
achieved through composting, given an adequate retention time in
the lagoon.
                              Odors

     A  concern  about odor problems  in the Site  C/Prairie Road
area was  expressed  by seven commentors.   No  specific questions
or comments  were  made about the  odor  analysis in the  EIS,  but
the  commentors  felt  that  odors  would  significantly  affect
persons  living  near  the  facilities.   One commentor  felt that
odor problems would  occur more  frequently than indicated in the
Draft EIS.

     EPA  agrees that odors  are likely to  occur at times in the
vicinity  of  the  sludge lagoons and drying beds.   The frequency
of these  problems will  depend  in part  upon  the frequency  of
inversions, the distance from the facilities,  and the effective-
ness  of  operating  techniques  designed to minimize odor  gen-
eration.  It is impossible to predict the absolute frequency and
significance of odor problems.  This is one reason for selecting
a  rural  setting  for  the  facilities.   EPA  has  recommended  a
number  of actions that  could be  taken by MWMC  if  significant
odor problems develop in the vicinity of the off-site facilities
(see pages  179-181  of the Draft EIS  and  page 5 of  this docu-
ment) .
                               27

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                             Energy

     Brown  and  Caldwell indicated  that the energy  analysis in
the Draft EIS did  not  consider several secondary energy demands
associated  with  mechanical  dewatering alternatives   (Alterna-
tive 3  and,  to a  lesser degree, Alternative  2).   These energy
demands include polymer  production  and recycle treatment of the
liquid  removed  from  sludge.   The  energy  saved  by  replacing
commercial  fertilizers with sludge  was also  not  considered in
the Draft EIS.

     These  secondary energy use factors are legitimate elements
of  the EIS  analysis.   While  specific numbers  have   not  been
generated here,  the energy  demands for Alternative 3  would be
even greater  in  relation to Alternatives 1 and  2  than is shown
in Table 3-14 of the Draft EIS  (page 169) if the polymer produc-
tion  and  recycle  treatment  energy  demands  were  considered.
Alternatives  1   and 2  would  also   show  a  greater energy  use
advantage over Alternative  3  if the energy value of fertilizers
were  considered.   The consideration of these  secondary energy
factors  reinforces EPA's  contention  that  Alternative 3 has  a
very distinct  energy consumption disadvantage  when  compared to
Alternatives  1  and 2  (see  the Overview and Summary  section at
the beginning of the Final EIS).


                  Sludge Quality and Treatment

     The sludge  quality  and sludge  treatment  processes assumed
in  preparing the  Draft  EIS  were  questioned  in  two  letters.
Several  specific  questions  were  asked  about the  levels  of
cadmium, PCBs,  mercury,  and  other  potentially hazardous  sub-
stances that  would be in the  sludge  when it  reached off-site
storage lagoons.  The question was also raised as to whether the
sludge  should be considered putrescible or nonputrescible  when
it reaches the off-site facilities.

     The most  detailed analysis  of sludge constituents  in  the
Eugene-Springfield  systems  was  conducted  by  MWMC  in  April
through  August   of  1978.   The  results  of this  analysis  are
reported in Tables  B-l and B-2 of the  Draft EIS (pages B-3  and
B-4) .   These numbers  are  expected  to  be indicative of  the
quality of  sludge that will  be produced  at  the new  RWTP,  al-
though  some  variation will  occur due  to  changes over  time in
influent concentrations and  the change in  wastewater and sludge
treatment processes.   The  MWMC pretreatment  program  has  been
approved and will  cause  some  reduction  to  occur in  certain
sludge  constituents.   This  includes metals and  salts.   Much of
the metals  and  salts  that,  in the past, were  discharged to  the
sewer system by industrial  sources,  will be removed at the  site
of use  prior to discharge  to  the sewer system.  These  materials
will, in turn,  have to be  recycled, treated on-site,  or trans-
ported  to an acceptable  land  disposal  site. This  could include
Short  Mountain  Landfill  if  the materials  are not  considered
hazardous.   If  the materials are considered a hazardous waste,
                               28

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they  must  be  transferred  to  the  hazardous  waste  disposal
facility at Arlington,  Oregon.   The exact nature  of  the sludge
produced  by the  new RWTP  will  not  be  known until  it is  in
operation.  Extensive sludge  testing will occur once  the plant
is on-line.  The     sludge   may  continue  to  contain   small
amounts of heavy metals  (cadmium,  mercury,  lead,  zinc)  and some
chlorinated hydrocarbons from uncontrolled disposal of materials
through residential sewer hookups.  No radioactive materials are
expected in the sludge.

     Two persons  questioned whether  the  sludge stored  in  off-
site lagoons should be  classified as putrescible.  A  review of
the proposed sludge digestion and lagoon  storage  processes and
consultation with EPA personnel in Cincinnati, Ohio indicate the
sludge  to  be  spread on  drying  beds  at  Site C or  any off-site
location would  be  nonputrescible.  The materials  stored in the
facultative sludge  lagoons may be in part putrescible, but would
be covered by several feet of clear water and, therefore, would
not be available to birds.

     In response  to a question  about sludge  retention  time in
digesters, the average retention time will be 17 days at the new
RWTP.

     Finally,  a question was  raised  regarding the  safe level of
cadmium in sludge.  The Oregon DEQ sludge application guidelines
indicate  that  25  mg/kg of  cadmium  is  acceptable for  general
application to agricultural land.  Testing of Eugene-Springfield
sludge  in  1978 indicated  6.1 to  7.7 mg/kg  of cadmium  in the
sludge.   The  annual application rate cannot exceed  2.0  kg/ha
according to DEQ and EPA guidelines (for further discussion, see
pages 108 and 109 of the Draft EIS).


            Project Costs and Property Value Effects

     Five persons  commented on  project-related costs.   Informa-
tional requests included the cost of dewatering equipment at the
treatment plant and Site C; clarification of user costs, partic-
ularly those related  to River Road/Santa  Clara residents;  land
acquisition costs, and the effect on project economics; the cost
of certain  drying and incineration  technology; and the  use of
federal funds for  MWMC projects.   Four  individuals commented on
the project's  effect on property values.

     With respect  to  the relative cost of dewatering equipment
at  the  treatment  plant  and Site C,  the  proposed  treatment
processes  are  substantially  different,   thereby  making  cost
estimations and comparisons  difficult.   At  the treatment plant
site, dewatering would occur  primarily with  the use of capital-
and energy-intensive  centrifuges.   As described  on page  58  of
the Draft  EIS,  significant  on-site  improvements  would  be re-
quired for this alternative.  As shown  in Table 2-4 on  page 59
of the  Draft  EIS,  the  present  worth capital  costs  associated
with Alternative 3  (treatment at  the existing plant)  are  $9.1
                               29

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million.   Dewatering  equipment at Site C  consists  primarily of
centrifuges  to  be relocated from  the  existing treatment plant,
air  drying beds,  and lagoons.  Under  this alternative, centri-
fuges would not be used to produce a final dewatered product but
rather  for initial  dewatering.  This would significantly reduce
centrifuge  energy costs at  Site  C.   The  present  worth capital
costs of the Site C alternative are estimated to be between $4.5
million  and $4.9 million.   In summary,  the capital  and energy
requirements  of  relying  only  on  centrifuges  for  dewatering
significantly increase project costs.

     With  respect to  user  costs,  the $10.50 per month currently
charged  to Eugene and Springfield residents covers only opera-
tion  and  maintenance  costs  of  the  Lane County  Metropolitan
Wastewater  Service  District  and  of  the  Cities  of  Eugene  and
Springfield.  Funds for servicing of the bond debt  for the local
share  of  capital  costs  of the  regional  wastewater treatment
system  are provided by  local property tax revenues.  User costs
to   future   service   areas   such   as  residents  of  the  River
Road/Santa  Clara  area will be the same  as costs  to other users
within  the service  area.   By the  time residents  of these areas
are  connected  to  the  system, however, user costs  are likely to
increase above their current levels.

     According  to the  project engineer   (Krugel pers.  comm.),
land acquisition  costs  at  Site C were assumed  to be  $4,900  per
acre in the analysis  of project  costs.   Actual estimates which
were made prior to cost projections were somewhat less, but were
adjusted to current dollars by the Engineering News Record (ENR)
index.

     During  preliminary stages  of  the  project,  a  variety  of
alternative  technologies  were  evaluated  by  the project engi-
neers.  Although the Judco Dryer and O'Connor solid waste burner
combination  was  not  looked  at  specifically,  incineration  of
sludge was evaluated.   On-site incineration of sewage sludge was
dropped  from  further consideration  because   of  the  following
problems:  air pollution, poor economics,  resources consumption,
exclusion  of existing uses  and  nonuse of existing facilities,
inflexibility and unreliability, and public image.  It should be
noted  that  because  all   sludge   management  technologies  have
certain  advantages  and disadvantages  which may  or may  not  be
appropriate  for a particular area, EPA does not  require use of
specific  technologies;  rather,  the  local  management authority
and  their  project engineers are  responsible for  evaluating  and
selecting technologies most suitable for their sludge management
needs.

     The purpose of EPA's  construction grant program for waste-
water  facilities  is  to  improve   the  quality  of  the  nation's
waters  through more  effective treatment and disposal of waste-
water and  wastewater  products.  As mandated by the Clean Water
Act  of  1977, this program  distributes funds  to the  states  for
                               30

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facility  planning  and construction.   The states  then allocate
these funds based on a priority list.

     The  potential  effect of  the  project on  adjacent property
values  involves the  interaction  of a  variety  of  potentially
important factors.  Operating conditions at the facility and the
type  of  adjacent  land  uses,  however,  are  two  key  elements.
Because uncertainty regarding  the  potential  effects  of a sludge
management  project  is   greatest  at  the  outset,  some  initial
market reaction  to  the  project can  be expected.   Over the long
term, however,  the  key  factor  likely will be whether the sludge
management  facility  turns  out  to be  a  "good neighbor."   Condi-
tions imposed  on the project regarding  odor control and visual
and  noise buffers  are designed  to minimize potential  land use
conflicts and to ensure  land use compatibility.

     Unfortunately, property  value  effects  can only  be  accur-
ately determined over  time.   Based  on other local experiences,
however,  such  as  in Salem,  the siting of  this  type  of facility
in  areas  predominantly  agricultural  has  not  resulted  in  an
adverse  effect on property values.   With proper  operation and
maintenance of the facility,  and  assuming  that  adjacent  lands
remain  predominantly  agricultural,  the  long-term  effect  on
property values from the project should be negligible.


               Alternative Technologies and Sites

     A wide range  of comments was made  regarding the alterna-
tives analysis  contained in  the  Draft EIS.  An attorney repre-
senting  the City of  Coburg felt  the EIS  did not  consider  an
adequate  range  of alternatives.  He  also questioned the process
adding the  Coburg  Hills Site  to  the list of  alternative  sites
analyzed  in the EIS.  A  number of  conunentors voiced support for
alternatives not studied by MWMC, including the Judco dryer with
incineration.  Alternative 3 (on-site mechanical dewatering with
agricultural reuse and landfill disposal) also received support.
Other questions were raised regarding septic  tanks,  dedicated
land  disposal,  the Four  Corners  off-site  location,  and  the
no-action option.

     The  range of  alternatives  analyzed  in  the Draft EIS was
determined  by  a thorough review of  the  Sludge  Management  Plan
alternatives development and  screening process,  in-house  anal-
ysis  of  sludge  reuse  options  in  the Eugene-Springfield  area,
numerous  discussions  among  EPA,   DEQ,   MWMC,  and  Brown  and
Caldwell  staff.  Pages  29-60  of  the  Draft  EIS describe  the
alternatives development and screening process used by  EPA and
the  project engineers and  identify  the  range  of alternatives
finally  considered  in the  EIS.    Rationale  for  elimination  of
alternatives is  presented on pages  56 and 57  of the Draft EIS.
The  EIS   analyzes  two  sludge  processing alternatives  (lagoon
storage with air drying  and mechanical  dewatering) ,  five sludge
disposal/reuse   options   (landfilling,    agricultural   reuse,
                               31

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forestry reuse, home and garden reuse, speciality market reuse),
and four sites  for  sludge  processing facilities (the RWTP site,
Site C, the Coburg Hills Site, and the Prairie Road Site).  This
represents  a  reasonable  range  of   feasible  options   for  the
Eugene-Springfield area.

     The  range  of  alternative  locations   for  facilities  was
established  after  a thorough  staff  evaluation  of all  sites
considered in the sludge management planning process.  Seventeen
sites  were visited  in  the  field  and  the MWMC  criteria  for
rejection were  reviewed.   As a result,  the  MWMC preferred site
(Site C) and three sites rejected by  MWMC (Prairie Road, Coburg
Hills, RWTP site) were  retained for  full evaluation in the EIS.
The Four Corners Site was rejected after it was learned that the
City  of Eugene  held title  to  a portion of  the  site  and  was
actively considering development of the area as a regional park.
This  was  considered  a  legitimate  rationale  for dropping  the
site.   The Coburg  Hills  Site  was  retained  for  consideration
because it appeared  to  offer a  degree of remoteness and lack of
visible land use conflicts  compared  to the  MWMC preferred site.
The landowner and the Mayor of Coburg were notified early in the
process (Spring  1983) that  the  site was  to  be  considered in the
Draft EIS.

     A  number  of  people suggested  the Judco  dryer system  or
Alternative 3 should be  considered as replacements for  the MWMC
preferred plan.   EPA's  role in reviewing the  Sludge Management
Plan  and  preparing this EIS is to act  as  a  funding  agency as
outlined in the  Clean Water Act.  The environmental evaluation
is not  a  facilities planning effort.  It is the responsibility
of the  entity  applying  for  .federal  grant funds  (MWMC)  and  its
engineering consultants (Brown  and   Caldwell)  to  identify  and
consider  viable  options  for  handling  wastewater  and  sludge
facilities needs.  The local entity is responsible for consider-
ing  any  technologies  of   interest   to   local  residents.   EPA
normally does not reject or request  modifications in the alter-
natives evaluation  process  unless the range of  options consid-
ered is obviously lacking  in relation to the range of technolo-
gies known to be effective.  EPA has  seen no  grounds  to reject
the alternatives  evaluation and selection process used  by MWMC
or to require MWMC to pursue use  of  the  Judco  dryer system.   As
indicated in the Overview  and  Summary section of  this  report,
EPA has  determined  that Alternative  3  is   the  environmentally
preferred alternative.   Because of its  considerable  extra cost
and  extreme  energy  demand,  however,  EPA  has determined  that
Alternative 2 is an acceptable plan if potential adverse impacts
are properly mitigated.

     Use of septic  tanks and the Delta  Pits was recommended by
commentors.  As  indicated  in an  earlier section,  septic  tanks
are not  an acceptable  wastewater treatment option in  densely
populated urban  areas,  and  they  are  not a  feasible option  for
handling the  sludge that  will  be generated at the new Eugene
RWTP.  The Delta  Pits have  also been  considered by  EPA  and  are
                               32

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not  considered  an  acceptable  sludge  disposal  solution.   The
rationale for  rejection of  the  Delta  Pits  is presented on pages
56 and 57 of the Draft EIS.

     Two  persons felt that  MWMC would  eventually resort  to  a
dedicated land disposal  (OLD)  method of sludge  disposal  if the
air-drying  and  agricultural  reuse  system  did  not  function
properly.  There also was fear that this DLD would be located at
the  off-site  storage  and drying  site.   EPA does  not  intend to
fund a DLD project for MWMC, nor is DLD at the off-site location
proposed for the project.

     One commentor stated that if a no-project option were truly
implemented by MWMC,   the  water  quality implications  would be
much more  severe than described  in the Draft EIS.   EPA  agrees
that the  implications of  the  no-project option  are  rightfully
questionable because it is not known what action MWMC would take
by 1989  if  no long-term sludge management  solution  is selected
now.  It  is  unlikely, however, that  the existing  facilities at
the  RWTP  would  be  allowed to  reach  capacity and subsequently
cause a direct discharge of liquid sludge to surface waters.


                        Landfill Disposal

     Two comments were made on the landfill  disposal  aspect of
the  proposed  project.   The  MWMC  stated   that  the  Draft  EIS
description of the  drainage system at  Short  Mountain  was inac-
curate or  at  least unclear.   Another  commentor  felt  that the
existing leachate control  system  at the landfill was inadequate
and  that sludge going  to  the  landfill  was  poorly  handled.
Overflows to the Willamette River were predicted.

     The  description  of the drainage system at  Short Mountain
Landfill  should  be  revised   to  indicate  that   the  permanent
ditches which  discharge directly  to  Camas  Swale  Creek  do not
receive runoff from the exposed, active landfill area.  Drainage
from the  active  fill  area  is carried into  the  leachate lagoon.
A leachate collection  drain exists at  the  southern  edge  of the
active landfill area.

     The concern about the  capacity and operation of the  leach-
ate lagoon at the landfill should be allayed by actions taken by
the County in  the summer of 1983.   Problems with overtopping of
the lagoon had been identified  during the wet winter of 1982-83
and  subsequently DEQ  requested  improvements in  the  leachate
collection  and  irrigation  systems.   The   lagoon  capacity  was
expanded  in  the summer of 1983  and  is  expected  to have  no
further capacity problems  in the foreseeable future.   The MWMC
preferred long-term sludge management plan calls for a cessation
of landfill disposal of sludge by 1989.   The project, therefore,
would not contribute  to leachate control problems at  the land-
fill.
                               33

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                     Location of Facilities

     Comments regarding the  specific  location  of sludge manage-
ment  facilities  focused  on  the  facilities  planned  at Site C.
Questions were raised  about  what part  of  Site C would be used
for sludge storage and whether the pipeline to Site C would have
any connection with the Agripac site.  Others questioned the use
of Site C for sludge processing when septic tanks were not being
allowed in the area.

     The specific location of facilities within Site C was shown
in Figures 2-5 and 2-8 in the Draft EIS.  The Draft EIS analyzed
the southern  portion  of the  site as part  of  the MWMC preferred
plan  (Alternative 2) , while  the  northern portion was considered
as part  of Alternative 1. MWMC  has since indicated  that while
the southern  half  of Site C may be preferable, it  has not yet
selected a specific site  and will eventually identify a 125-170
acre parcel  for  use from within the 295 acres contained within
Site C.  If  the  facilities were laid out  as  shown  in the Draft
EIS in Figures 2-5 and 2-8,  sludge drying beds would be approxi-
mately 7,500  feet  from the  end  of  Mahlon  Sweet Field crosswind
runway 3-21 if the northern half of the site were used, or about
8,000 feet from the runway if the southern half of the site were
used.

     EPA's evaluation  of the MWMC  preferred plan was  based on
the use of the southern half of Site C.   If MWMC  now wishes to
reconsider and leave open its options on the location of facili-
ties within the 295-acre parcel, EPA will not be able to reach a
decision on  MWMC grant  requests until  a  specific  location is
selected.  Also,  the facilities  plan  engineers have indicated
that  125  acres  are sufficient  to contain the  off-site facili-
ties; EPA's  grant  participation  would  therefore be  limited to
this scope of project.

     Site C  is   considered  acceptable  for  sludge  storage  and
drying, given local drainage  and groundwater conditions, because
all facilities will be lined to avoid transfer of  sludge con-
stituents  into  the groundwater.   The  facilities  will  also be
surrounded by berms to avoid  surface flooding.  EPA is not aware
of specific grounds for  septic  tank system denial  in the vicin-
ity of Site  C.   Septic tank  and leach field  systems,  however,
require an aerated  soil  layer with  adequate drainage conditions
to provide a natural filtering  of nutrients  and other materials
prior  to  leachate  reaching  groundwater.   The  seasonally high
groundwater and  occasional  coarse  subsoils  in the  vicinity of
Site C would not allow  the  necessary soil  filtering action to
occur year-round.   This may  have been  the basis for denial of
septic tank  systems.   Site  C facilities  are not designed as  a
waste disposal system, discharging to surrounding soils.

     One commentor  questioned  whether there was  any connection
between the sludge transport pipeline to Site  C and the Agripac
                               34

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site.  There  is  no  planned connection between these two facili-
ties.
                      The Coburg Hills Site

     One of the four locations for sludge facilities analyzed in
the Draft  EIS  was the Coburg Hills Site.   This  site is located
north of Eugene  and east of Interstate 5,  slightly  over 1 mile
northeast of downtown Coburg.  A number  of persons living in or
representing the  City  of Coburg expressed  concern over the use
of  this  site.    This  included City  Council members,  the water
commissioner,  and  an  attorney  representing  the  city  and  the
Muddy Creek  Irrigation District.   Opposition  to  the  use of this
site  was  based  on fears  of groundwater  contamination,  odors,
property  devaluation,  visual  detraction,   and  land use incom-
patibility.  These are essentially the same concerns voiced over
use of Site  C  and the Prairie Road Site.   One  commentor voiced
support for the use of the Coburg Hills Site.

     EPA has evaluated  the  use    of   the Coburg  Hills  Site
through preparation of the  Draft EIS.   The evaluation disclosed
that  the  pipeline route to  the  site would possibly impact two
archaeological sites  located along the  route (see  page  166  of
the Draft EIS),  and that use of  the  Coburg Hills site would not
provide a  significant  economic or environmental  advantage over
the MWMC preferred Site  C.  EPA  concluded, therefore,  that the
Coburg Hills site would be dropped from  further consideration
for grant  funding purposes.   Because the  site will no longer be
pursued,  questions  regarding  its  analysis  in  the Draft EIS will
not be responded to in this Final EIS.  EPA  feels the analysis
contained  in the Draft  EIS was  sufficient to  warrant  the re-
jection of this alternative site.

                            Land Use

        Three land use issues were raised in review of the Draft
EIS.  One  commentor felt that  the land use  zoning  consistency
issue associated with Site C had not been adequately resolved in
the Draft EIS.   Two others felt that Site  C  should  be reserved
for industrial uses, which would be more consistent with current
zoning and with  the site's easy rail, air, and  highway access.
A  final  concern  was  that  use  of the Coburg Hills  Site would
violate a number of state land use planning goals.

     The land  use consistency issue at Site C was resolved,  at
least on a local basis,  when  Lane County  issued  a  conditional
use permit  to  MWMC in February  1984  for  use of  Site C.   This
permit allows  MWMC to  use  the  site  for sludge  processing,
contingent on  MWMC complying with a large  number of conditions
placed on the  permit.  The County has determined  that this use
is  consistent  with current  land  use  and zoning  policy for the
site.
                               35

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     The  County Comprehensive  Plan for  the area  was recently
revised and adopted by the County.  It has now been forwarded to
the  Oregon  Land Conservation and  Development Commission  (LCDC)
for  approval.   The revised  plan  designates  the land  north of
Awbrey Lane  in  the Site C area  as  agricultural  and it is zoned
EFU  (exclusive  farm  use) .   LCDC  is  not  expected  to make  a
decision on approval or denial of the revised Comprehensive Plan
until at least July.

     The  future  use  of the Site C  area  for industrial develop-
ment is apparently not being considered by the County, as it has
rezoned the  area from M-3  (heavy  industrial)  to EFU  (exclusive
farm use).

     Regarding  the land  use  consistency discussion  for Coburg
Hills,  EPA  feels  that   the  discussion  on  pages  160-161  and
163-164 of the Draft EIS was an accurate portrayal.  Because the
Coburg Hills Site  is  no  longer  being considered as an off-site
location,  further  review of this  issue  has  not  been undertaken
in the Final EIS.
                         Project Design

     Two persons who  reviewed  the  Draft EIS made comments about
the design  of the Eugene RWTP  (now  nearing completion)  and the
design  of  the  proposed  facilities  at  Site C.  The  questions
about the RWTP design were related to hydraulic capacity of that
plant  and  the  possible use  of secondary  clarifier  space  for
sludge  storage.   Regarding  Site C,  one  commentor  wondered  if
transfer of sludge  processing facilities from  the  RWTP  site to
Site C  would result  in construction  of duplicate facilities.
The  question was   also  asked  whether  Site C  design  included
acreage for dedicated land disposal  (OLD)  of sludge.   Finally,
one commentor asked what safeguards or guarantees for protection
of surface  and groundwater were designed into the facilities at
Site C.

     The questions about RWTP design are not directly related to
the impact  analysis contained  in  the  Draft EIS, but  are more
appropriately  facilities  planning  questions  that  should  be
directed to MWMC.   EPA  investigated  these questions briefly and
found  that   the  decision  to  construct  eight  rather  than  ten
secondary clarifiers at the  RWTP did not  result in  the freeing-
up of  a significant amount of  space.   The  design layout of the
plant with  eight clarifiers  does not  leave  sufficient  space for
additional  on-site  sludge storage, in  the opinion of the Sludge
Management  Plan  engineers,  (Krugel pers. comm.).   The question
of hydraulic  capacity at  the RWTP  is based  on  a  comment in the
Draft  EIS  regarding  the  need  to  expand wastewater treatment,
sludge  thickening,  and  digestion capacity if on-site mechanical
dewatering  were  continued  as a 20-year  sludge  management solu-
tion.    Further investigations  of this matter found that imple-
mentation of Alternative 3 would not create a hydraulic capacity
                               36

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problem  at  the RWTP;  the continuous  recycle of  centrate  from
sludge centrifuging on-site would  eventually  tax RWTP treatment
capacity in terms of BOD and suspended solids removal.  The RWTP
20-year design did  not anticipate a continuous  loading  of fine
suspended matter  and  BOD loading  from centrifugating of sludge
(Krugel pers. comm.).

     The transfer of centrifuge facilities from the RWTP site to
an  off-site storage  and  drying  location  will  not  result  in
significant  duplication  of  facilities.   The  centrifuges  and
their containment structure are designed to be mobile.  The only
facilities that would  be  abandoned at  the RWTP with transfer of
the centrifuges would  be  the  centrifuge  building foundation and
some buried piping.

     The question of OLD  of sludge at  the off-site location was
addressed in an earlier  section.   No OLD  will be allowed at the
off-site storage and drying location.

     Numerous  safeguards  have  been   planned as  part  of  the
off-site facilities in order  to  protect  people from surface and
groundwater contamination.  These  have been  described in detail
in  the  Draft  EIS.   Lining  of  storage   lagoons,  control  and
recycle of drainage from  drying  beds,  construction of perimeter
berms,  and  water  quality monitoring  are  the major  pollution
control  features.   EPA is further requiring  that  an impervious
seal be  installed in  all  lagoons  to  prevent  leaching  of mate-
rials  into  the groundwater (see  the  Overview and  Summary sec-
tion) .  As was indicated  in response to  a question at the Draft
EIS public  hearing, however,   EPA  cannot guarantee  the  perfor-
mance  of each  of these design  safeguards.   Proper construction
and  operation  of the  facilities  are  critical to  their proper
function.
                             Errata

     This section lists  minor  changes to the text  of  the Draft
EIS  that are  needed  to  respond  to  comments.   The  page  and
paragraph of  the change is  indicated,  followed by  the  revised
text.

Page 165,  second paragraph:   ..."less  than one percent  of  all
     County  prime  farmland"...   should  be   revised   to  read
     ..."less than one-tenth of one percent of  all County prime
     farmland"...

Page 142, first  and  last paragraphs:   The  statements  that bald
     eagle  nest  sites  are  located  in  the hills  east   of  the
     Coburg Hills Site  should  be  revised to indicate  that bald
     eagles are  known to winter in  the vicinity of the  Coburg
     Hills Site.
                               37

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Page  40,  last paragraph:   The  word  "conditioned"  should  be
     replaced by the word "thickened".

Page  84,  third paragraph:   The  statement  ..."composed of  6
     inches  of compacted  clay"...  should be  revised  to  read
     ..."composed of a minimum of 6 inches of compacted clay"...

Page 78,  Figure 3-5:   The boundary shown  on  this  figure as the
     northern  extent  of the River Road  and  EWEB Water District
     is  in error and should be deleted.
Page  101,  third paragraph:  "(this  does  not include  any  of the
     exposed, active landfill area)." should be added to the end
     of the second sentence.
                  Other Comments and Questions

     A  number of  the  comments and  questions  received  during
public review of the Draft EIS were not readily categorized into
the  broad  subject  areas  discussed  on  previous  pages.   This
section  addresses those questions and  comments.   Each question
has been summarized and followed by a response.

Is the existing  sludge lagoon at the Eugene  RWTP  compacted and
     lined  with  clay?  The  RWTP sludge  lagoon was  lined  with
     clay and compacted prior to receiving sludge.

How  can  EPA  allow  violation  of PL  92-500  and PL  95-217  with
     implementation of  the  proposed project?   EPA  does antici-
     pate violations of PL 92-500 or PL 95-217 if proposed water
     protection safeguards are built into the project.

Was a public  hearing  held on the southern  125 acres of Site C?
     The EIS public hearing conducted by EPA on December 6,  1983
     considered the southern  125-acre portion  of  Site C.   This
     area  was identified  as   the  MWMC  preferred  location  for
     off-site facilities  and  was analyzed  as part  of Alterna-
     tive 2 in the Draft EIS.

Who initiated consideration of  the  southern  125 acres of Site C
     in the Draft EIS?  In a meeting held in Portland, Oregon on
     February 2,  1983,  MWMC requested that the  Site C location
     be expanded to include the additional 125 acres.

Was  there  a  public  hearing   on the  Prairie  Road   Site?   The
     December 6,  1983  EPA hearing  on the Draft EIS considered
     the use of the Prairie Road Site.

Did EPA know  that wells in  the Site C area show 0  coliforms in
     water  quality  monitoring?   EPA found  several  sources  of
     data  on  local  groundwater  quality.    Sweet,   Edwards  &
                               38

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     Associates (1982) reported 0 coliforms in a number of local
     wells.

Is EPA responsible for funding the proposed project and also for
     protecting  the   local  environment?   EPA  is  the  principal
     funding  agency   for  the proposed  sludge management  plan,
     through  the  grant  program  authorized by  the Clean  Water
     Act.  EPA  is also  responsible  for assuring  that environ-
     mental impacts are considered in the grant funding program,
     and adverse impacts are mitigated where possible.

Would a tertiary treatment  plant  at  the  RWTP  site have resulted
     in less  risk  from pathogens at the Site C  or Prairie Road
     sludge handling  sites?  When wastewater is  treated beyond
     what  is  typically referred  to as secondary  treatment,  the
     goal  is  usually  to increase the removal of  nutrients from
     the wastewater  (nitrogen and phosphorus compounds).   This
     can be  accomplished in a variety  of  ways,  but  these ter-
     tiary processes  usually  generate a  larger volume of sludge
     than  do secondary  processes.   The  numbers  and types  of
     pathogens  in  the sludge are not necessarily  reduced,  but
     their concentrations may decrease.   It is unlikely that the
     addition of tertiary treatment processes at the Eugene RWTP
     would  result in a  significant  change  in  the  pathogen-
     related  health risk at the  off-site  sludge  handling loca-
     tion.

Is  it  too late  to construct dewatering  equipment at the RWTP
     site?   There is sufficient  space  at  the   RWTP  site  to
     construct mechanical dewatering  facilities  for the  20-year
     design  load  of   sludge.  MWMC  and its engineers,  however,
     have  indicated   that  there is  not  sufficient  space  to
     construct sludge  storage lagoons  and  air-drying facilities
     for the  20-year  design load  of  sludge.   This is one reason
     that off-site facilities have been sought by MWMC.

How much clay (in  inches) is  normally  required  to seal a sludge
     storage  lagoon such as tha,t suggested for Site C?  How many
     inches  does  the  EIS  indicate  will be  placed  at  Site C?
     There is no specific requirement for  the  thickness  of clay
     liners  in  sludge storage lagoons  in  the State  of  Oregon.
     These design  decisions are  made  on a case-by-case basis.
     The  general  design  rule used  by  DEQ  for  sewage  lagoons
     (including sludge lagoons)  is that  permeability  should not
     exceed  one  fourth inch  per  day.   More  stringent require-
     ments are possible.  In the Draft EIS groundwater analysis,
     the liner  was considered to be a minimum  of 6  inches  of
     compacted  clay   with   a  permeability  rate   less  than  one
     fourth inch per day.

Did  EPA  know  that   Sludge Management  Plan  progress  reports
     indicate that dedicated  land disposal  of  sludge  is  planned
     at Site C or Prairie Road?   EPA is aware that some  OLD was
     planned  for  the  off-site location  in  the early  stages  of
                               39

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     Sludge Management Plan development.  EPA, however, does not
     consider this solution appropriate, and it is not a part of
     the MWMC preferred plan as reviewed in the Draft EIS.

If  sludge  will not  be allowed  at  the Short  Mountain Landfill
     after  1989,  will  some other  DLD site  be  identified  and
     approved by EPA after 1989?  Under the MWMC preferred plan,
     all sludge will be dried and go to agricultural reuse after
     1989.  No  DLD is  planned  after  1989  and EPA will  not be
     considering authorization of a DLD site.

How will  vibration from the  adjacent railroad affect  the clay
     liner  at  Site C?   Clay is naturally  a resilient,  flexible
     material  when it  contains some  moisture.   Sludge  lagoon
     clay  liners  should not  be damaged  by vibration  from  the
     railroad as  long  as they  are  not exposed to  the  open  air
     for extended periods, and  thus  allowed to dry.  The design
     of the sides of the  lagoons  should  take  into account  the
     possibility  that  vibration could encourage  slumping along
     steep  slopes.

Although the EIS indicates there are no airports near the Coburg
     Site,  there  are  three private  landing  strips  within 6,000
     feet of the  site.  During  review of  the bird strike issue,
     EPA identified  the private landing strips in the vicinity
     of the Coburg Site.  The investigation found, however, that
     the strips were  infrequently  used, and were  never used by
     turbojet aircraft.   They were  not  considered a  factor in
     the bird strike issue.

Would not the off-site  sludge facilities  at Site  C detract from
     potential investors'  first impressions of Eugene,  if they
     arrive via Mahlon Sweet Airport?  If  the off-site facil-
     ities  are located at  Site C,   they  will  not be  highly
     visible to travelers  moving from the  city to the airport.
     They will  obviously be visible  from the air.   It is also
     possible  that odors  generated  at the facility may occa-
     sionally reach  the airport  area.   The frequency  of this
     occurrence is expected to be quite low, however, unless the
     facilities are poorly operated or maintained.

The Draft  EIS  inaccurately portrays  the  opponents of  the MWMC
     plan as primarily  residents of  the area between Eugene and
     Junction City,  while  the  supporters  are  from the farming
     community.   In  truth,   many  of the  opponents  are  also
     farmers.   EPA agrees that  the description of those voicing
     concern over the  project  is  not all-inclusive.  Many  of
     those persons living in the vicinity  of Site C and Prairie
     Road are from the  farming  community  and are  opposed to the
     MWMC preferred plan.
                               40

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                        Literature Cited
Frank, F. J.  1973.  Groundwater in the Eugene/Springfield area,
  southern Willamette  Valley,  Oregon.   U. S.  Geological  Survey
  Water Supply Paper 2018. 65 pp.

Frank, F.  J. and  N.  A.  Johnson.   1970.  Selected  groundwater
  data  in  the  Eugene/Springfield  area,  southern  Willamette
  Valley, Oregon.  Oregon  State  Engineer Groundwater Report No.
  14.  Salem, Oregon.   20 pp.

Sweet, Edwards  &  Associates.    1982.   Agripac irrigation  site
  groundwater  study;  unpublished  report  for  the  Metropolitan
  Wastewater Management Commission, Springfield,  Oregon.


                     Personal Communications
Geotechnical Consultants,  Inc.   October 19,  1982.   Unpublished
  letter report  from Charles Kendall  to  Steve Krugel  of  Brown
  and Caldwell, Eugene, Oregon.

Hudzikiewicz, Joe.   April  3,  1984.  Planner, Lane  County  Plan-
  ning Division, Eugene, Oregon.  Telephone conversation.

Krugel, Steven.  March  30,  1984.   Engineer,  Brown  and Caldwell,
  Eugene, Oregon.  Telephone conversation.

Lowenkron,   Larry.   April  3,  1984.   Regional Engineer,  Oregon
  Department of Environmental Quality, Salem, Oregon.  Telephone
  conversation.

Peroutka, Alan.   April 4,  1984.   Civil Engineer,  Metropolitan
  Wastewater Management Commission, Springfield,  Oregon.  Letter
  (with attached groundwater data)  to Michael Rushton of Jones &
  Stokes Associates, Inc.

Thomas,  Jack.   March  26,   1984.   Lane County  Land  Management
     Division,   Eugene,    Oregon.     Telephone    conversation.
                               41

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     mtd.
BOD
DEQ
OLD
EFU
EIS
EPA
FAA
FEMA
FNSI
LCOG
LCDC
LIM
mg/kg
MWMC
M-3
PCB
RRSC
RWTP
biochemical oxygen demand
Oregon Department of Environmental  Quality
dedicated land disposal
exclusive farm use zone
Environmental Impact Statement
U. S. Environmental Protection  Agency
U. S. Federal Aviation Administration
U. S. Federal Emergency Management  Agency
Finding of No Significant Impact
Lane Council of Governments
Oregon Land Conservation and  Development Commission
Land Inventorying and Monitoring  Memorandum
milligrams per kilogram
Metropolitan Wastewater Management  Commission
heavy industrial zone
poly-chlorinated biphenyl
River Road/Santa Clara
Regional Wastewater Treatment Plant
               43

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         0$
        U. S. Environmental Protection Agency  -  Region  10


Richard Thiel - Chief,  Environmental Evaluation  Branch,  Seattle,
  Washington.

Daniel  Steinborn  -  Chief,   EIS  and  Energy  Review   Section,
  Seattle, Washington.

Norma Young - Project Monitor, Environmental  Evaluation Branch,
  Seattle, Washington.


                 Jones  & Stokes Associates,  Inc.
                     Sacramento,  California


Charles R. Hazel - President,  Program Management.

Michael Rushton - Environmental  Scientist,  Project Manager, All
  report sections other than economics.

Thomas Wegge - Environmental Specialist III, Economics.
                               45

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        Appendix A
Letters of Comment

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                    Index of Comment Letters
Commentor                                                  Page

Barnes, Melva                                              A-19
Brown and Caldwell                                         A-29
Clinkscales, J. Kyle                                       A-32
Cook, Mr. & Mrs. William                                   A-34
Dooley, Robert                                             A-36
Elliott, Gordon                                            A-38
Engels, Joyce                                              A-41
Engels, Larry                                              A-42
Garrett, Ernest                                            A-44
Humphrey, Howard                                           A-48
Kendall, Donovan                                           A-55
Klemp, Dan and Ann                                         A-61
Lane Council of Governments                                A-13
Lund, Lois                                                 A-63
Lyon, Richard & Sadie                                      A-65
Mase, Nathaniel D.                                         A-66
Melamed, Jim                                               A-67
Meltebeke, Bob                                             A-88
Metropolitan Wastewater Management Commission              A-14
Moyer, Lucille                                             A-89
Neely, John Jr.                                            A-90
Oregon Dept. of Fish and Wildlife                          A-10
Oregon State Executive Dept.                               A-ll
Oregon State Historic Preservation Office                  A-12
Schrenk, Harold & Lois                                    A-110
Springfield Area Chamber of Commerce                       A-18
Swenson, Chester                                          A-112
U. S. Dept. of Army, Corps of Engineers,
   Portland District                                        A-2
U. S. Dept. of Housing and Urban Development                A-3
U. S. Dept. of the Interior, Office of the Secretary        A-6
U. S. Dept. of Transportation, Federal Aviation
   Administration                                           A-7
U. S. Dept. of Transportation, Urban Mass Transit
   Administration                                           A-9
                              A-l

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               DEPARTMENT OF THE ARMY
            PORTLAND DISTRICT. CORPS OF ENGINEERS
                      P. O. BOX 2946
                   PORTLAND. OREGON 97708


                  December 20, 1983
Planning Division
  (PL-NR-EQ)
Ms. Norma Young
M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington  98101

Dear Ms. Young:

     We have reviewed  the Draft Environmental Impact
Statement (DEIS) on  the  Metropolitan Wastewater
Management Commission  Sludge Management Plan, and
have no comments.

     Thank you for the opportunity to review this
document.

                          Sincerely,
                          Patrick/TJ.  Keough, P.E.
                          Chief,  Planning Division
        r\\           •- '
        U U
             DEC 23 1983
                  L EVALUariON
               BRANCH
                        A-2

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                    DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                                SEATTLE REGIONAL OFFICE
                         ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
                                SEATTLE, WASHINGTON 98101

REGION X                                                                 |N REPLY REFER TOl

       DEC " 7 I983


      Ms. Norman Young, M/S 443
      Environmental Evaluation  Branch
      Environmental Protection Agency
      1200 Sixth Avenue
      Seattle, WA  98101

      Dear Ms. Young:

      SUBJECT:  Draft Environmental  Impact Statement
                  Sludge Management  Plan
                   Eugene-Springfield,Oregon

           We have reviewed the draft statement submitted with your October
      28, 1983 letter.  The proposed  action would not adversely  impact  any HUD
      assisted projects, thus we  find no objection to your preferred  sludge
      management plan.

           Our Portland office  has  reviewed your statement in detail  and  they
      have some suggestions which are attached for your consideration.

           We thank you for the opportunity to review and comment  on  your
      draft statement.

                                       Sincerely,
                                        y Tanino
                                    "/Regional Environmental Officer,  10CE
                                                           DEC 9
                                                       ENVIRONMF"™ ""• '*•• '•"• - •*
                                       A-3

                                    AREA OFFICES
                      Portland, Oregon - Seattle, Washington - Anchorage, Alaska

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     Aesthetics are addressed by landscaping and somewhat remote locations and
odors appear to be controlled by operating and maintenance features.

     The report addresses significant environmental issues in a responsible
manner and appears to have minimal impact on residential uses and water
quality other than what is projected in the comprehensive plan.

     I believe one typographical correction should be made on page 165 in the
second paragraph.

     Prime farmland lost seems to be one-tenth of one percent rather than one
     percent.

     Equipment under the BPA power lines may need to be shielded from ice
forming and dropping from lines and from radiation and leakage.  Appropriate
grounding of metal objects is necessary.  Ground-fault interupters are also
recommended.

     Thank you for the opportunity to comment.
                                     A-4

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                                           U.S. Department of Housing and uroan Development
                                           Portland Area Office, Region X
                                           Cascade Building
                                           520 SW Sixth Avenue  -_ _
                                           Portland. Oregon 972oflFfVr;U;:^  ^^
                                                              *-"—' I  '• j' - - I ' i
  2 9  1983

MEMORANDUM j^:^Jtobert c- Scalla, Director, Regional  CPO,  IX

THROUGH: /^mfc^^ar^ef, 10.3S
FROM:   Clifford T. Safranski, Environmental Clearance Officer,
          10.3SE

SUBJECT:    Draft Environmental Impact Statement  - Sludge Management
             Plan, Eugene/Springfield, Oregon


     We have reviewed the subject EPA-10-OR-Eugene/Springfield -  Lane-WNTN 83
Draft Environmental Impact Statement  (DEIS) and concur with  their treatment of
secondary impacts as they effect HUD  programs.

     We would, however, suggest the following:

     Short Mountain Landfill

     Definition of what actions would be undertaken if the monitoring  wells
     reflect a problem would be helpful.

     Forge Main Routes

     The statement that periodic pressure testing can determine leakage but
     not the location of the leakage  could be refined to alleviate concern.
     Perhaps sequential closing of valves would permit pressure testing of
     pipe segments in a manner that would isolate the leakage for locating it.

     Agricultural Sites

     Since flood-irrigation practices appear to be a problem perhaps trickle
     irrigation or a more acceptable  method may be introduced to  owners of
     effected sites to reduce erosion and control run-off.

     Mitigation

     The use of the treatment plant site which is on the edge of  the 100 year
     floodplain and the other sites which can effect creeks  and drainage areas
     appear to be addressed by use of berms, dikes and ditches and impervious
     lining for lagoons and drying beds.
                                    A-5

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            United States Department of the Interior

                         OFFICE OF THE SECRETARY
                           PACIFIC NORTHWEST REGION
                 500 N.E. Mullnomah Street, Suite 1692, Portland, Oregon 97232
ER 83/1412
Environmental Protection Agency
Environmental Evaluation Branch
Attn: Norma Young M/S 443
1200 Sixth Avenue
Seattle, Washington  98101

Dear Ms. Young:
January 12, 1984
            D(
                  FEB  3
              ENVIRONMENTAL EVALUATION
                     BRANCH
The Department of the Interior has reviewed  the  Draft  Environmental State-
ment (DES) for Sludge Management Plan,  Eugene-Springfield,  Lane County,
Oregon.  We ask that the following comments  be considered for  the  proposed
project.

Water Resources

The U.S. Geological  Survey reports the  following:

Page 84, Site C;  It is indicated that  "leaching would virtually cease"
in fall and winter because of a high  water table that may,  in  places,
reach the ground surface (p. 97).  However,  we believe that ground-water
mounding beneath the area of infiltration  would  create a gradient  for
the lateral movement of leachate and  that  leaching will still  occur if
the rise in the water table results in  saturation of the sludge.

Page 127, Sludge Disposal;  We note that the Metropolitan Wastewater
Management Commission's guidelines require monitoring to water-supply
wells near sludge reuse sites.  The environmental statement should ad-
dress what actions will be taken if the monitoring reveals  significant
degradation of drinking water in those  wells.

Thank you for the opportunity to review and  comment on this DES.
                                   Sincerely,
                                   Charles  S. Polityka
                                   Regional  Environmental Officer'
                                     A-6

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U.S. Department
of Transportation
Federal Aviation
Administration
Northwest Mountain Region
Colorado. Idaho, Montana,
Oregon, Utah, Washington,
Wyoming
17900 Pacific Highway South
C-68966
Seattle, Washington 98168
December  16,  1983

Ms. Norma  Young  M/S 443
Environmental  Protection Agency
1200 Sixth Avenue
Seattle,  Washington  98101

Dear Ms.  Young:

We have reviewed the draft EIS for the Eugene, Oregon Sludge  Management Plan
and have  the  following comments:                                             i?

    a.  Site  C would be located less than 10,000 feet from  Runway 3-21 at
        Mahlon Sweet Field.  Runway 3-21 is used by turbojet  aircraft.  FAA
        Order 5200.5 establishes 10,000 feet as the distance  within which the
        facilities  of the type proposed may be incompatible with  safe flight
        operations.  The EIS agrees that the selection  of the distances
        specified in Order No. 5200.5 represents a reasonable determination of
        the danger  zone around an airport.

    b.  Given  that  sludge facilities within 10,000 feet  of  a  turbojet runway
        represents  a reasonable determination of danger  we  cannot find
        anything in the EIS analysis which would indicate that  construction of
        these facilities within this area would lessen  this danger.  Indeed,
        the EIS  agrees that waterfowl use on Site C or  Prairie  Road would
        increase, albeit, slightly.

    c.  The above notwithstanding, should the proponents persist  in
        constructing these facilities within 10,000 feet of Runway 3-21 at
        Mahlon Sweet Field the following mitigation actions should be taken:

        (1)   Support structures for a wire or screen system above the FSL's
              should be designed and incorporated in the  initial construction
              of  the facilities.  If wires are used they  would be  installed on
              10  foot centers over the entire lagoon.  The height  would be such
              as  to  allow adequate facility maintenance.  The  actual
              installation of the system could then be more  economically
              accomplished at a later date if it became  necessary.

        (2)   A waterfowl monitoring study at the proposed FSL's would be
              conducted for a period of one year following construction of the
              facilities.

        (3)   Should the study so indicate, the following measures would then
              be  taken as appropriate.  Aerators would be operated
              continuously, day and night, to discourage  waterfowl from feeding
              during the fall, winter, and spring.  The  above  described wire or
              screen system would be installed if continuous aeration failed.
                                     A-7
          Edward Warren: First American Aloft

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    Whatever decision  is  made regarding  construction  of these facilities,
    it  should be clearly  understood that the Metropolitan Wastewater
    Management Commission bears  the responsibility for correcting any bird
    hazard problems  that  are created as  a result of this project, should
    it  be  developed  contrary to  the guidelines  described in FAA Order
    5200.5.
                                 cerely,
                                    <7
                              George L.  Buley
                              Manager,  Planning and Programnfoag/Branch
cc:
Mr. Paul Burket
Mr. Bob Shelby
                               A-8

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US Department
of Transportation

Urban Mass
Transportation
Administration
Region X
Alaska. Idaho.
Oregon, Washington
                                                                 91 5 Second Avenue
                                                                 suite 3142
                                                                 Seattle, WA 98174
November 2,  1983
 Norma Young  MS/443
 Environmental Evaluation Branch
 Environmental Protection Agency
 1200 Sixth Avenue
 Seattle, WA   98101

 Dear Ms Young:

 The Urban Mass Transportation Administration has no comments with respect
 to the Environmental Impact Statement  for the Sludge Management Plan for
 the Metroplitan Wastewater Management  Commission, Eugene-Springfield,
 Oregon.

 Thank you for the opportunity to comment.
                                           arey Davis
                                        Regional Administrator
                                     A-9

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VICTOR ATIYEH
  OOVEBHOB
Department of Fish and  Wildlife
NORTHWEST REGION
3150 EAST MAIN STREET, SPRINGFIELD, OREGON 97477  PHONE 726-3515
                                        December 1, 1983
       Ms. Norma Young  M/S443
       U.S. Environmental Protection Agency
       Region 10
       1200 Sixth Avenue
       Seattle, Washington  98101

       RE:  Draft EIS, Eugene-Springfield Sludge Management
            Plan

       Dear Ms. Young:

       On page 142 of the Draft EIS I am quoted in two different
       paragraphs (first and last) as saying there are several
       bald eagle nest  sites in the Coburg Hills area.  This
       information is erroneous.  What I did say was there are
       observations of bald eagles wintering and roosting in the
       Coburg Hills area.  I know of no  nesting sites.  Please
       correct the final copy of the EIS to reflect this change.
       Thank you,
                                     Sincerely,
                                     Brian T. Ferry
                                     Asst. Dist. Wildl. Biologist
                                     Lane District
       BF/mw

       cc:   J.  Fessler
                                                       DEC  5  1983

                                                    ENVIRONMENTAL EVALUATION
                                                          BRANCH
                                   A-10

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VICTOR ATIY6H
  oovEmo*
Executive  Department
155 COTTAGE STREET NE., SALEM, OREGON 97310
              February 21, 1984
              Norma Young M/S  443
              Environmental Evaluation Branch
              Environmental Protection Agency
              1200 Sixth Avenue
              Seattle, WA 98101
              SUBJECT:   Sludge Management Plan
                        PNRS  # OR840112-020-4
              Thank you for  submitting your draft Environmental Impact
              Statement for  State of Oregon review and comment.

              Your draft was referred to the appropriate state agencies
              for review. The State Historic Preservation Office offered
              the enclosed comments which should be addressed in preparation
              of the final Environmental Impact Statement.

              We will expect to receive copies of the final  statement as
              required by Council of Environmental Quality Guidelines.

              Sincerely,

              INTERGOVERNMENTAL RELATIONS DIVISION
              Dolores Streeter
              Clearinghouse Coordinator

              DS:bm
              Enclosure
                                        A-ll

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          OREGON PROJECT NOTIFICATION AND  REVIEW  SYSTEM


                           STATE CLEARINGHOUSE
                   Intergovernmental Relations Division
                    155 Cottage St NE     ,  Salem,  Oregon,   97310
                        Phone Number: 373-3732


                P  N  P.  S     S  T A T F    o F V  I F '-/


 Project  *.;.-,    .  •" '   '. .. . " \..  .''. '•.'• "       Return Date;            	
           -m , 1*-*

              ENVIRONMENTAL IMPACT REVIEW PROCEDURES

               If you cannot respond by the  above  return date,  please
          call to arrange an extension at least one week prior  to  the
	review date.	


                    ENVIRONMENTAL IMPACT  REVIEW
                          DRAFT STATEMENT

 (  )  This project has no significant environmental impact.

      The environmental impact is adequately  described.
 (  )  We suggest thaf the following points  be  considered in  the
      preparation of a Final Environmental  Impact Statement.

 (  )  No comment.                             c
                                              «.

                              Remarks
                n                                FOR FURTl-tfJ INFORMATION
Agency  "• ' ' r"  --''	  3y	Pi'APF ^P'T^T :rUMT
                                    A-12

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              Lane  Council  of  Governments
 NORTH PLAZA LEVEL PSB/125 EAST EIGHTH AVENUE / EUGENE. OREGON 974O1 /TELEPHONE (5O3) 687-4283
  December 15,  1983
  Ms.  Norma Young M/S 443
  Environmental Evaluation Branch
  Environmental Protection Agency
  1200 Sixth Avenue
  Seattle, WA 98101

  Dear Ms. Young:

  As its regular December 8,  1983 meeting, the  Lane Council of Governments  Board of
  Directors discussed the Draft Environmental  Impact Statement for the Metropolitan
  Wastewater Management Commission Sludge Management Plan.

  The Board of Directors voted unanimously to  express  concern over two  aspects of
  the Draft EIS.  The first concern of the Board was about the relative lack of water
  quality information for all three off-site sludge handling  facilities.  The Board
  also expressed concern about the  possible long-range impacts on soil and water
  quality resulting from the application of sludge and  the failure  of the draft EIS
  to address this.

  If you have any questions,  please feel free to contact me.

  Sincerely,

'' ""'"'' '/' ; '  •-' '

 / John Replinger, Program Manager
  Transportation  and Energy

  JR:jwcl

  cc:   Metro Wastewater Management Commission
"BRANCH
                                                                    .
                                                                    -i
                                    A-13
                SERVING CITIZENS OF LANE COUNTY FOR MORE THAN A QUARTER OF A CENTURY

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Metropolitan
fV/l
1V l
          COMMISSION MEMBERS
 Christine Larson—Springfield Councllperson
  Gerald Rust—Une County Commissioner
  Pat Hocken—Eugene Uy Representative
     Betty Smith—Eugene Councllperson
 Steve Allen—Springfield Uy Representative
 Mark Westling—Eugene Uy Representative
Gary Wright—Une County Uy Representative
225 NORTH 5TH ST.  —  SPRINGFIELD CITY HALL  —  SPRINGFIELD, OREGON 97477  TELEPHONE (503) 747-4551


                                 December 15, 1983
   Ms.  Norma Young, M/S 443
   Environmental Evaluation  Branch                                                 •»
   Environmental Protection  Agency                                                 *
   1200 Sixth Avenue
   Seattle, WA  98101
   SUBJECT:   COMMENTS ON DRAFT  ENVIRONMENTAL IMPACT STATEMENT  FOR
             EUGENE/SPRINGFIELD SLUDGE MANAGEMENT PLAN
   In  pages 42, 43 and 44 of the draft EIS for the Eugene/Springfield sludge
   management plan there are references to the relocation of the  preferred Site
   C facilities to a location south  of the position previously  proposed in the
   1980  Brown and Caldwell facilities  plan.   We would like to point  out that
   the Commission's official position  on this subject is spelled  out in a
   resolution which was adopted by the Commission on October 27,  1983 (Resolution
   No. 83-26; attached) which recognizes that the additional area identified
   south of the original area at Site  C may be a more desirable location for
   the Phase II sludge management facilities.  Thus, this area  was included as
   an  alternative site for the sludge  management system but was never designated
   a preferred site.  It is the Commission's preferred alternative to locate
   the sludge management facilities  within the approximately 295  acres identified
   as  Site  C in Figure 2-6 of the draft EIS and to acquire the  approximately
   125-170  acres necessary from within this  expanded identified parcel  of land.

   We  would also like to pass along  some comments received from the  Lane County
   Public Services Division concerning the information presented  in  pages 101
   through  103 on the Short Mountain Landfill.  They have pointed out that
   contrary to Figure 3-11 in the EIS, that  water generated on  the site is
   routed away from the active fill  area and that the ditching  shown in Figure
   3-11  is  actually outside of the landfill  area so only uncontaminated water
   is  discharged to Camas Swale Creek.  A subsurface leachate collection line
   is  maintained along the south edge  of the active fill areas  and this line
   is  designed to collect leachate from the  fill areas and discharge into the
                                         A-14

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Ms. Norma Young
December 15, 1983
Page Two
leachate lagoon.  Lane County has expanded the size of the leachate lagoon
to assure that no discharge of leachate occurs.  Lane County Public Services
Division has passed along to us the attached modified Figure 3-11 which they
feel more closely represents the actual patterns of drainage at the Short
Mountain Landfill.

Thank you for this opportunity to comment.  We hope to have our consultant's
comments in shortly.

                                     Very truly yours,


                                     C
                                     EDWARD BLACK
                                     Environmental Affairs Supervisor
EB:AP:sh

cc:  DC
     BCS

Enclosure
                                     A-15

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          METROPOLITAN WASTEWATER MANAGEMENT COMMISSION

RESOLUTION NO. 83-26                    (IN THE MATTER OF THE
                                        (NECESSITY TO ACQUIRE
                                        (SITE C)


    WHEREAS, the Commission at its March 12, 1981 meeting unani-
mously adopted a motion approving action to acquire Site C as the
sludge management site.

    WHEREAS, an additional site immediately south of Site C and
west of the Southern Pacific right-of-way may be a more desirable
location for the sludge management site.

    WHEREAS, the draft Environment Impact Statement recognizes
both the additional site and Site C as a potential location for
the sludge management site.

    WHEREAS, it is the desire of the Commission to reaffirm its
motion of March 12, 1981, and include the alternative site as an
alternative location for the sludge management site,

    NOW, THEREFORE, BE IT RESOLVED BY THE METROPOLITAN WASTEWATER
MANAGEMENT COMMISSION:

    1.   That it is necessary for the Commission to acquire
approximately 125 to 170 acres for the sludge management site for
the permanent sludge management program.

    2.   That the Commission proceed with action to acquire the
approximately 125 to 170 acres for the sludge management site
from that property identified as Site C in the draft Environ-
mental Impact Statement consisting of approximately 295 acres and
located north of Awbrey Lane, south of Meadowview Road, east of
Highway 99, and west of, and adjacent to, the Southern Pacific
right-of-way.

    ADOPTED BY THE METROPOLITAN WASTEWATER MANAGEMENT COMMISSION
of the Eugene-Springfield Metropolitan Area this ^T^day of
      ^«X>A->^>     , 1983.

                                  'President

ATTEST:
                               A-16

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                                                 a
                                    COAST FORK
                                    WILLAMETTE RIVER
FIGURE  3-11.   SURFACE DRAINAGE FEATURES  AT SHORT  f
MOUNTAIN LANDFILL                                 |
	  A-17	"

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                spRiNGFieiD aRea CHameeR OF commeRce
                223-H NORTH A STREET P.O. BOX 155  SPRINGFIELD. OREGON 97477 PHONE (503) 746-1651
December 19, 1983
Ms. Norma Young, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA  98101

SUBJECT:  Draft Environmental Impact Statement on MWMC Sludge Management Plan,
          Eugene/Springfield, OR

The Springfield Area Chamber of Commerce has gone on record supporting the
Metropolitan Wastewater Management Commission's (MWMC) preferred long-range
sludge plan calling for transportation of digested sludge frora the treatment
plant to Site C where the sludge will be stored, dried and used for agricultural
purposes.

The MWMC Sludge Management Plan is necessary for the strengthening and diversifi-
cation of the local economy.

Clearly, the regional sewage treatment plant cannot operate without a reliable
dependable sludge facility.   We believe MWMC's sludge plan will prove to be
the best solution to our community's sludge management requirements.
Sincerely,
C. Robert Smith
Executive Vice President
                                                                  21 1983     --'
                          GATEWAY TO THE MCKENZIE RIVER
                                    A-18

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 I    Only One Law would be necessary  - Thank God  - the Golden  Rule  -  "Do unto others as you
     would havo them do unto $ou"        What have the people  of Site "C" or Prairie Rood or
     people of Junction City done to  tho city of  Eugene or MWKC.

     City of Eugene and MBMG-through  their agents havo* if Site "C" or prairie Road is used
\    as storage of Eugene's sewage sludge which hao lead, lindano,  andorin, methodic
, I    chlorate, technical chlordane, toxiphine, PCB's 2-4-D, silver, copper, berium, *oron,'
J    cadmium, chromium, selinium, mercury, arsenic, zinc, and  othersj

     Eugene/MWMC t
     Violates the public Laws 92-500  and 95-21? confine pollutants  so they won't contaminate -
          placing heavy metals, toxic pollutants  directly over the  known domestic water supply
          for Junction City and residents of Site "C" and Prairie Road site is in violation
          of these laws.

     Violation of EPA Law - not to create Bird Strike Hazard within 10,000 feet of Airport.
          Southern Pacific Railroad line is 10,000 feet away from the Airport - all of Site
          "C" is by EPA Law not lawful for sewage storage.  Violation of EPA Law.

     Violation of FAA 5200.5 Aircraft Safety Advioory -
          placing sewage that attracts Bird - potential Bird Strike Hazard within 10,000 feet
          Airport.  If map presented  by MWMC of the area is activated sludge would be located,,
          as close as ^,000 feet approximately to Runway 21 which flies  directly over Site "C
          on take off and landings.   Violation of Law I  EPA -  HB 3171* &  FAA
          Placing sewage on Site "C"  or prairfe Road considered (by  FAA as the same concern -
          FAA believes it could cause Bird Strike Hazard and warned Eugene and MWMC not to
          locate;;th> sewage on those  sites!  violation of LawJ  HB  317^  & EPA & FAA
        ' " Lbcatlngj jthe Airport directly between Fern Ridge Lake - roosting for waterfowl,
          and sefeagfe attracting disposal on Site  "C" or Prairio Rood sites - violating the
  DEC  19 $&k advisory 5200,5*     By Eugeno owning the Airport to not eliminate such potential
          for Bird Strike Hazard they would be putting themselves in non-compliance with
     rNTAL^.d°Ar!yilfun
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    What right do you have to operate outside the Law?  How does Eugene have the right
    to condemn property In the county, outdide their urban growth boundary, outside their
    urban se»lce area, what law # allows that?
    We have tried through letters, meetings to stop tho POLLUTION of our WATER and LAND
    by Eugene's toxic, heavy metals, hospital infections sewage sludge,  in response
    we learned of Shirley Ditch project where Eugene injected high ammonia nitrate
    injections into the aquifer in north Santa Clara area on April 12, 1979, not getting
    the reading they wanted they doubled the ammonia nitrate injections on April 30, 1979.
    On April 26, 1979 they introduced 440 million ESCHERICHIA Coli bacteria, opportunistic
    strain intt the aquifer to check water flow.  Was EPA aware of this action?  Was
    there other injections made in other areas?  Was this the area where the 70 mg/1 nitrate
    was reported by DEQ?  Was that 70 mg/1 injected by Eugene?  Could this be the back-
    ground for the comment between Freeman and Million Pye when Freeman asked about
    River Road/Santa Clara health - William Pye responded "OH. WE'LL BLOW EM RIGHT OUT
     OF THE WATER"?   Because we have been trying to bring to EPA attention and officials
    of the government what we believe to be illegal acts against the people's water and
    health by writing and sending information from their MWMC meetings, documents,
    Brown & Calawell, CH2M Hill - did comment by KVAL-TV Skip Lindeman after apparently
    conferring with William Pye - "He thinks the whole thing is going to far. 'He used
    to think only residents were concerned about this.  Now we have our hands full with
    a whole bunch of crazies_."
    If we are wrong Aor-trying to mako federal officials aware of crime against the
    people's water, health, very lives, found in their own reports, meetings projects
    funded by FEDERAL money - then I guess you would consider us crazy.  We believed
    Federal money was obtained to protect the water, not destroy ours.  Public Law
    92-500 and 95-217?      Locating a toxic, Industrial heavy metals, hospital diseases,
    over a known domestic water supply for junction City is a violation of law! Ours and
    Junction City's SOLE SOURCE water supply.    Wells have been tested and our water is
    good.  The information given out by MHMC ought to be questioned.
    please see Legislative Bulletin page 2 - No 29/79 January 10, 1979
    GAP SAYS OK TO SEPTICSt The General Accounting Office (GAO), in a report to
    Congress, called septic systems, "environmentally sound, technologically feasible,
    and cost effective" alternatives to costly sower and central treatment facilities,
       The report concluded that, if properly constructed and operated, septic systems
        * can be ao permanent as central treatment facilities;
        * are often more ecologically sound than sewers and central facilities\ andj
        * can provide a high degree of wastcwater treatment, as good or better than
          effluent from central treatnent plants.
    Also checkANorth Carolina Septage Study - which infers that there is no proof
    that properly working septic tanks systems put out any disease causing pathogens.
    yet North Carolina Septage study stated that activated sludge from treatment plants
    when put on land has caused endenic and epidemic conditions.
    I believe MWMC has informed the federal government that they have so many farmers
    wanting that sewage sludge they can't meet the demand for it.  The farmers in the
    Site "CH and prairie Road have signed petitions that they won't use sewage sludge
    on their land, what farmers names do they have to get additional 10% funding for
    as alternative and Innovative sewage use?  Did putting sewage sludge on Marquess
    land in Crepwell cause pollution of the neighboring wells?  Was the lagoon 
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 They have criminally trespassed on our land where they had no right to be.   Through
 the Eminent Domain Law they took us to Circuit court and Oregon Supremo Court condenning
 the east 25 feet of our property for an easement to put in the Agripac Pipeline.   The
 east 25 feet of our poropty is on tho east side of prairie Road.  Where did  they  put
 the Agripac pipeline?  They put it on the west side of Prairie Road - not where they
 took us to court overt  fiur attorney notified them before they started digging that
 they were in error.  We told the workmen if they kept on digging they would  be committing
 Criminal Trespass.  They went right ahead.  It is recorded on Video Tape of  the Criminal
 Trespass I  Now in front of all these wittnesses - I order you to get this illegal Agripac
 line off our Proparty right NOW!  You have clearly demonstrated to us for the last five
 years you have no regard for the Law or for Human Rights.  It is my belief that "God"
 and a lot of others know why Eugene .Oregon is called "Little Russia" by other parts of
 the country - and no business or people would ever locate here - the way the people who
 get in your way are treated!  Human rights are a Joke to you!

 As  the Senator of Idaho said tn the Register Guard - "There has been more people  killed
 over water than over women or horses".

 For tho same or less money all the sludge and Industrial wastewater (all toxics)  could
 have been taken care of at the treatnent plant.  When CH2M Hill estimated to build a
 third stage treatment plant with tertiary treatment for $6? MILLION.   Brown & Caldwell
 built a second stage treatment plant without tertiary treatment, without River Road/
 Santo Clara Intercoptoro, without 2 secondary clarifiers, without recycle loads,  without
 an  effluent pump station (that were included in CH2M Hill bid).  Those items removed
 by  Lane County tax values, CH2M Hill estimate totaled about $29 million REMOVED.   Brown
 and Caldwell building that second stage treatment plant for $104 MILLION. Why did you
 pay twice as much not to get third stage treatment?

 Since you didn't build alternative plants that were offered to further treat the  sewage
 and make by-products, proved equipment by Judco dried sewage sludge to 5% to send for
 proof it would burn without being lost in uptake.  Also in process of combining with
 proven equipment that incinerates sewage after that % drying had taken place. It was
 found that drying by that systen to $Q% it could be burned apparently with solid  waste
 thereby answering two nation-wide problems without loss to atmosphere - but  return in
 steam byproduct,  I know I don't know technically the right words to descrbie it  but
 have tried to so that EPA will investigate the potential for nation-wide answer to solid
 waste and sewag sludge.  The way Brown & Caldwell and MWMC have the sewage sludge answered
 is  to take at this time WHAT - 3»500 acres out of food crop production to put sewage sludge
 on  to start out with - what amount needed for 20 years?  Is the map in 208 Plan adjoining
 area of Agripac Federally financed site containing 10,000 acres described for 20  years
 needs of 49 MGD dewage plant Intended for use without the Public being made  aware of it?
 How many more laws are you going to let be broken before you ACT? to PROTECT the  Environment
 and the People?

 Can you prove that Bill Larson's mother's cancer wasn't caused by sewage, heavy metals
 contamination of their well?  Can you prove that Bill Larson's death by cancer wasn't
 caused by sewage, heavy metals contamination of their well?  It appears that the  report
 of  Gary fflewis prothero Thesis showed heavy metals concentrations - zinc reported  4400 when
 limit is 2000.  William Pye says there is no heavy metal to worry about. How does Cadmium
 given by Gary Lewis prothero Thesis as 11 — Cadmium given by Brown & Caldwell or MWMC
 on  Marquess settago report as 16 PPM - correspond to anount that can be put on land and when
 it  would reach life use of the site?  By CBE report - Illinois - Cadmium is  a tumor producing
 substance, crosses placenta causing birth defects, causes chromosomal damage, when cadmium
 is  mixed with soil and leafy vegetables are raised in soil cadmium multiplies 978# in the
 leafy vegetables, 2,41?$ in legumes (I believe that describes clearly leafy  vegetables
 were mentioned" by B&C not to grow on sludgeed soil).
               ',"*.-'-                                                         I
 How many of the .ones receiving part of the $104 Million Federal funds and Local are going
tto use sewage sludge on their own land?  The farmers when agreeing to take sewage sludge
 on their lad sign an agreement that releases Eugene, MWMC from damages if the farmers land
 is permanently destroyed, if someone becomes sick from contact with sewage on his land,
 the farmer is the only one in danger of ^_"21 sued.  Where is the farmer's protection?
 who will stand up and be counted to prow,,,, 0unction City's and our water supply from
 these fraudulent acts by Eugene and MWMC?  Brown & Caldwell report says once It becomes
 contaminated there is no way to correct it !I

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 page 192 of EIS - 43 dry tons year initial use.   Assuming Cadmium 7  mg/kg  (B&C 1979)
 Cadmium loading rate would be 0.7 kg/hat  which is over the 0.5 kg/ha level set by EPA
 for soils supporting leafy vegetables  crops grown for  human consumption.   This loading
 would result in exceedance of maximum  cumulative  Cadmium standards for agricultural land
 within 8-33 years depending on soil pH.,  CEC.  Annual  nitrogen addition to the site
 would exceed those recommended to control leaching.  In summary  DLD  of sludge would limit
 future agricultural use of the soils to nonfood chain  crops on the site.       As 16 ??M
 mentionod In Marquess sludge report for his land  - wouldn't this be  excessive as much as
 his land is expected to take of the sewage sludge.  As Lowenkron inferred  - could Marquess
 property receive that sewage for over  50  years without cadmium build up in his land?

 EIS report infers that microbial pathogens,  heavy metals,  toxics are not removed by the
 new sewage treatment plant - infectionsJ  virus, hospital diseases - did anyone check
 with the Federal Government and the over  1,000 acres owned south of  Pern Ridge Lake
 for Bird reserve - not land over water wells for  domestic use, not land used for leafy
 vegetables,  summer human food chain crops,  dxiry  cattle,  if land disposal  is the answer?
 Why was cemented gravel pits at  river site considered unsuitable, yet pits of sewage in
 open gravel,  sand,  some areas of Site   "G"  and Praire  Road have  gravel to  surface to
 ground over a known domestic water supply where people all depend on their wells was
 considered suitable sewage sludge disposal  site?
 As  I was Informed by Norma Young - Agripac  was funded  for dual lines - then it changed,
 how do we know  that the dual 8* lines  for Site "C" or  or prairie Road or whereever won't
 change?  CH2M Kill estimated dual lines for Agripac  and all for  $3,678,000 - yet Brown &
 Caldwell are  putting in one line and all for $8,000,000 approximately - where is the
 Value Engineering to that project or was  CH2N Hill estimate considered false?  If so,
 then the  evidence spoken to the public at public  hearings  has also been false.
 Eugene has violated the  citizens  of Springfield's rights by denying  them right to vote
 on  sewage rates  - with this  millions of dollars variance in Engineer estimates - who
 can protect the  people's  rights?   The  $10.50 per  month charge doesn't pay  any on the
 bonding does  it?   One paper found  in the  DEQ files showed  River  Road/Santa Clara residents
 when added to the treatment  plant would pay  terrific costs - is  that true?

 As was reported by  Pye pers  comm  in the EIS  - was legislation Introduced or passed
 that  allows condemnation  without  show  cause?
 page  186  - accumulation of metals & toxic substances through forest  food chain & transmission
 of disease, such  as  Giardiasis  &  Salmonellasis, by game animals.   - areas that might
 eventually be used to  grow human food  crops  would be of concern,  (isn't it odd, some of
 these concerns didn't  seem to apply  directly depositing these diseases & toxics into a
 already existing known domestic water  supply without miles of travel to penetrate that
water supply  - how are laws  allowed  to be VIOLATED?)    fcage 190  risk without further
 disinfection -pasteurization,  irradiation - reduction of  pathogens  - risk unacceptable
health risk - prevent use for production of  food  crops.
DLD - substitute for processing & reuse or disposal  of sludge beyond initial digester
stage - pathogen levels are  often high
page 19o DLD must be isolated - from any potentially useful groundwater aquifer & be
designed to prevent any possibility  of contamination of surface water? DLD potential
contamination groundwater & surface.    pH 6.5 or above could prevent significant migration
 of pathogens, metals, toxic organixi to groundwater.    (sewage reduces pH  - DE3 waiver ing
6.5 pH requirement)  Brown & Caldwell report stated  migration be  known so  that no present
or future wells /be located in path of  such a flow.   DLD given as  greatest  pollution.  See
 June, 1979 Progress report stating dedicated land disposal adjacent  to lagoon on permanent
sludge site???????   WHERE IS THE PROTECTION?
 page  191  DLD  -;38-40 dry  ton year  - 10 times agricultural application injecting DLD - result
 20  times  agricultural  rate  for  nitrate -  groundwater beneath DLD - result  unsafe levels of
 nitrate  to downgradient drinking water supplies.   Must be prevented  by locating site where
 leachate  cannot travel to potentially  useful groundwater aquifer.


                                             A-22

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 x      Reading the EIS shows throughout the proof of the potential for contamination of Sole
£\     Source water supply for Junction City & us residents if Site  "C" or Prairie Road is used.
/J     Violation of our Civil Rights?  - A septic tank request south of Site "C" and North of
        Site "C" were denied - yet City of Eugene entering the county received approval of
        large pits of sewage with toxic, radio-active,  heavy metals,  diseases from the hospitals
        to put into the people's domestic water supply?       When the city attorney was asked
        if they would supply clean drinking water to these people after they contaminated their
        water - the response was NO - that was TOO EXPENSIVEl

        The article fron the newspaper says "There has  been more people killed over water than
        over women or horses'." - Senator of Idaho.
        FAA was assured that sewage- would not be closer than 8,000 feet from the airport - that
        would let a narrow strip be used 2,000 feet wide along the railroad tracks to comply
        with the information given to F/LA.??

        Bob Shelby was assured that sewage would be covered with water thereby birds would not
        be attracted to it - what about the 60 to 80 acres of sewage drying beds?

        FAA has sent letters to MWMC and Eugene advising not to locate the lagoons on Site "C"
        or prairie Road - you are aware of it now if MWMC had not so informed you before by
        MWMC or Eugene!

        Site "C" as stated by Brown & Caldwell cannot take dedicated land disjgosal - air drying
        only!      Dedicated land disposal is greatest potential for groundwater pollution.
        Progress Report No. 7, dated Jv>e 1, 1979 - page 2** - "Well stabilized sludge from
        the bottom of the lagoons will: .be removed for disposal by means of a floating dredge.
        Sludge will be pumped to adjacent air-drying beds for subsequent agricultural use,
        citizen giveaway, or landfill disposal.  The .rest will be disposed of in liquid form
        on agricultural land or on dedicated land also adjacent to the storage lagoons."
        2 dedicated land sites were dismissed near the river for flooding potential - yet MWMC
        in their meeting minutes statement was made at the commission's option they could be
        used??  Remembering Site "C" by Brown & Caldwell report cannot be dedicated land
        disposal only air-drying. The public was never told of dedicated land disposal on "C"l!

        I believe FALSE INFORMATION has been presented to the Federal Government to obtain
        Federal Financing - which is a Violation of Law!

        Did Eugene report to Federal Government for Federal financing that they owned the
        land for the addition to the sewage plant?  Did Eugene own Larson property, or do they
        yet own it?  As of September 13, 1982 Bill Larson filed suit against Eugene for the
        return of his property and damages as Eugene had not paid Judge Allen's decree from
        1981 to September 13, 1982.  County records were changed to show Eugene the owner
        in 1980 - as of 5-13-82 county records showed improvements of $35,000,000 on Bill
        Larson's tax lot.  As reported by TV Bill Larson was wringing money out of the city -
        with l*£ years in court huge attorney fees, jury awarded him about 2/3 of the appraised
        value as determined by Blinkhorn.  I heard another property was condemned for public
        use for $5,700, that was on county records as being valued now at $150,000.00 - yet
        trying to sell it for $1*50,000.00, apparently not having used it for the condemned use??
        That property was not condemned for sewage plant - but other public use.

        Did Eugene report to the Federal government officials that the treament plant had been
        in compliance with discharge permits and had no problem complying?  DEQ file showed
        repeated violations from 1969 to the date DEQ and Eugene agreed and signed agreement
        admitting they would be in violations of discharge from 1977 to 1982 - was that a permit
        or a violation. of law.  Also November 1, 1982 when taking us to court to condemn for
        Agripac pipeline and Agripac last piece of disposal site - Eugene was operating the
        sewage plant without a discharge permit it had expired, if it was lawful, in 1982 August.
        In court Eugene showed applying for the permit.

        Our land in Site "C" or prairie Road site can not take more water than GOD gives us of
        that clean water as rain.  Our water wells have been tested and shown to be good water
        for drinking, but that pollution Eugene plans will destroy all these people's water -
        if you allow this pollution to take place are you also willing to deposit in the BANK
        money to give these people to replace A- 2 3  wells if they become polluted or replace
        their land if those heavy metals and toxins destroy farm land and it can no longer grow
        their leafy vegetables or raise dairy cattle?  if you aren't willing in writing to place
        that money in the BANK for these people's protection - GOD is WITTNESS!  '>..-/t~-

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Questions regarding Sewage proposed for Site  "C" or prairie Road Site- as permanent
sludge management site  j

1.   How can the Violation of Public Law 92-500 and 95-21? be allowed when federal
     money was obtained from the government to protect the water not polute it?

2.   What did the digging of monitoring wells on the additional 125 acres show
     as to depth of gravel from the surface of the ground?

3.   When the lagoons are dug to 5 foot depth in the 125 acre area how many of them
     would be in the groundwater level of water when dug?

4.   Does the report by Brown & Caldwell acturately answer what happens when ground-
     water is made to become contaminated on pages 3-2-/3-3/3-^ - as indicated in
     Progress Reports discussing permanent sludge management dedicated land disposal
     of the remaining sludge adjacent to the lagoons is intended,  what are your
     protections against this occuring?

5.   How long is the sewage to be treated in digestors before being stored in lagoons
     on Site "C"?

6.   Was there a Public Hearing on the additional 125 acres added to the Site "C"
     area?

7.   Who initiated the additional 125 acres to be studied in the EPA EIS Draft
     Environmental Statement?

8.   Was there a public hearing on Prairie Road site?

9.   What owners of Prairie Road site were contacted about soils samples being taken?

10.  What are the results of the Cadmium level in the Eugene/Springfield sewage
     sludge to be put on Site "C" or Prairie Road in lagoons?

11.  Was Mercury or PCS, 2-4-T found in the Sewage sludge to be placed in lagoons
     on Site "C" or any radio-active readings in the sewage sludge?

12.  The movement of water flow in the Site "C" area was given by Brown & Caldwell
     Krugel as 200 feet a year - how does that correspond to the testing of U40
     Million Escherichia Coll bacteria injected into the aquifer on Apr 26, 1979
     when observed flow was 20 feet in 3.5 hours?

13.  How would you answer the difference in report by Brown & Caldwell as to Cadmium
     reported in Eugene/Springfield sewer sludge as being tested to 5 - 10 PPM, when
     sewage sludge from Eugene placed on Marquess farm under sludge agreement contained
     testing results of 16 PPM - more than twice the amount reported being there in
     Eugene sludge at that time; since that sewage sludge is intended to go on Site "C"?

I1*.  Did EPA know that the drinking water wells that were tested in the area
     that were in use reported 0 coliform?

15.  Mr. Burd,  am I correct in the letter written to me earlier that EPA is the
     agency providing the funding and is responsible to see that no environmental
     damage occurs on these projects - or did I misinterpret the letter?

16.  Would a third stage treatment plant have made a less hazard of pathogens, mlcrobial
     pathogens to be put on Site "C" or prairie Road?

17.  Is North Carolina Septage Study accurate that if sewage sludge having been through
     activated sludge process then land applied might cause endemic or epidemic conditions
     might occur on Site "C" or Prairie Road - or can you provide a guarantee in writing
     able to be backed up in court that it won't?
                                          A-24

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      18.  What is the cost of dewater equipment for Site  "C"?

      19.  What is the cost of dewater equipment for treatment plant site?
s

      20.  Since you have stated that it is more expensive to place the dewater equipment
           at the sewage plant we have to know the cost differences - closer to the electrical
           power and river if emergency overspill - why would it be more costly near power?

      21.  Was Mr. Pye's statement to MAC meeting accurate when stating it was too late
           to build in the dewater equipment at the treatment plant it had been built
           past that point?
                                     9
      22.  If your answer is yes to that question^ it was  said in March 1980 or 81 I believe -
           when the option was presented in letter to cover Bird Strike hazard question as
           alternative to dewater at treatment plant - how could it have been too late then
           to build it in - and now it is possible?  I further believe Mr. pye said the plans
           to dewater at plant would have to have been made before June 1978 to do so.

      23.  How many persons from FAA by name were contacted about Bird Strike Hazard
           potential by placing sewage sludge lagoons in Site "C" or Prairie Road sites?

      2**.  Since you have indicated that you will not make sure that mitigative measures
           are in place - what assurances for Bird Strike  Hazard prevention if sewage
           attracts as FAA believes it will?

      25.  Are you, EPA, aware that FAA advised the City of Eugene and MWMC not to locate
           sewage lagoons on Site "C" or Prairie Road?

      26.  What is the depth of groundwater to surface of  ground at Site "C" area at this
           time?

      27.  How much clay lining is usually required to seal a lagoon in inches as at
           Site "C" or Prairie Road?

      28.  How many inches of clay are Indicated in the EIS report intended for the Site "C"
           or Prairie Rod lagoons?

      29.  Is EPA aware that the Site "C" area is directly over a known domestic sole
           source water supply for Junction City and residents of the area?

      30.  Does EPA law allow placement of sewage ludge with toxics, microbial pathogens,
           diseases, mercury, cadmium, chromium, arsenic, selenium, PCS directly into a
           known city's water well supply?

      31.  Can sewage sludge being put or planned to be put on Site "C"be considered
           nonputrescible?  Doesn't B&C report Indicate further treatment of sewage by
           lagoon storage further stabilization?

      32.  Was EPA aware that FAA was informed that Site "C" sewage sludge was to be
           nonputrescible - wouldn't that indicate that it would not decay or further
           degrade?

      33*  What would make soils at Site "C" area that Eugene has stopped residents of
           the area north and south of site refused a septic tank approval because it
           would contaminate the groundwater - be able to be approved for lagoons dug
           below the groundwater level with known toxic, pathogen, diseased, industrial
           toxics possible radio-active (stipulation handed to us in court Nov 1, 1982)
           be possible to be handled by this same soil?
           Is EPA aware that any sewage «i«"»4 on Site "C" area would be in violation
           of EPA law regarding Bird StiA-^Sizard potentfe. 1 - Southern Pacific railroad
           at east side of site is 10,000 feet from airport by Brown & Caldwell report?

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    :    35*   Was EPA aware that the public had not been informed at public hearings
             about  the additional 125 acres being added to Site "C"?

        36.   Did EPA Seattle know that dedicated land disposal as indicated by  Progress
             Reports for permanent sludge management had not been brought to '' public
             hearings on Site "C" or Prairie Road site?

        37.   Was it indicated that dedicated land disposal of sewage sludge from Eugene
             and Springfield could not "be taken to Short Mountain landfill after 1989,
             if  so  did that mean dedicated land disposal would be placed  on permanent
             sludge management site decided on by EPA?
                                           *
        38.   AS  I believe in the EIS concern for the game animals if sewage sludge  with
             pathogens were in place on forests,  where  is the concern for a known domestic
             sole source water supply with those pathogens placed directly into the lagoons
             into that depth of groundwater at first introduction of diseased,  toxic sewage?

        39.   Would  you pltase provide the names of the  farmers wanting the sewage in the
             area of Site "C" or Praire Road as indicated at the public hearing,  and was
             that list of farmers sufficient to obtain  10$ innovative and alternative funding?

        40.   Has any of the toxic,  dioxin industrial discharge been placed into the sewage
             sludge  that is planned for Site "C"?

        41.   Is  there any safe level of Cadmium and what effect does Cadmium overload
             on  a human body show up as?

        42.   Is  there  any connection points between the planned Site "C"  sewage pipeline
             and the already installed Agripac  pipeline?

        43.   Evidence  has been given in forming decision for Site "C" regarding a 70 mg/1
             nitrate reading found  south  of Site  "C" area -  where is that location  indicated
             by  DEQ  -  was it the cause for the  moritorium of this area?

       44.   Was  the location just  asked  about  the  sane location of Injections  of high
             ammonia  nitrate loading to  aquifer  on April 12,  1979 and doubled  dose Apr 30, 1979?

       45.   Was  EPA Seattle aware  that the  Gary  Lewis  Prothero Thesis showed uptake of
             heavy metals from Eugene Sewage sludge from treatment plant  site - same sewage
             intended  for Site "C"  or Prairie Road?

       46.   Drainage  is  indicated  flowing from the prairie  Road side of  area through the
             Site "C"  site  - won't  the drainage be  blocked by the construction  of the lagoons
             berms as  Agripac  site  blocked drainage which caused Lane County road department
             to be concerned for road bed softening?

       47.   Not  only  the blockage  of normal drainage - but  contamination introduced to that
             Site "C" would be  intermixed with  the  groundwater of area by the action of the
             pumping of the railroad  when washing machine action of the train tracks take
             place - wouldn't  that  intermix  the groundwater  with contamination  all  directions
   \J        by that adgitation?

  j   v  48.   AS our house  has  cracked windows and plaster from the railroad  vibrations
 J( >J\      how  is that  movement going to affect sewage  lagoon clay lining?

H* \!  **9»   As per your  EIS report -  was  the Indication  that  Site "C" lagoon lining would be
 ' '•-•!        6 inches of  clay lining  instead  of 12  to 18  inches indicated  at public  hearings by
 K Jp\        Krugel?
 1  v    5°*   What P*0*60*10118 ls EPA willing to put in  writing for Junction City's  water supply
. J  '^        and  ours  of  the residents living around Site "C" or Prairie  Road and that our
   ^        land won't b« contaminated by thJA-26 nanent sludge management  site  storing Eugene-
   "\        Springfield's  industrial toxic,  diseased pathogen sewage sludge with heavy metals
            and  that  our water won't become contaminated by this sewage  project?

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    1.  From your EIS report seems it's not OK to use sewer sludge as a soil, conditioner



   • in the city except very limited use - but a farmer is supposed to put the- sewage on his



    land repeatedly for years as a soil conditioner and EPA and MWMC thinks; its OK, is



    that true?



(L  2.  Do you believe city people can be sickened by effects of sludge where the farmers



    wont?  Most city property is not used to raise leafy vegetables and summer vegetables



    such as a farmers land is expected to do.  What do you believe will be the total amount



    of land required to take out of human food production to use it for a sewage disposal



    to handle all of Eugene's sewage needs for the next 20 years - the TOTAL ACEHAGE?



(7_  3.  In EIS mention was made where city users of sewage leaching of sludge constituents



    into the groundwater - but city has piped water supply no potential for contamination



    of their drinking water.  What about the farmer's family water supply with sewage



    leaching into their only source of water?  What protection have you written down to



    protect the farmer's water or land or health?



C  ^.  Is Site "C" the only site that was notified by the county for a public hearing



    on conditional use?  Was Goburg Site considered for a conditional use?   Was Prairie



    Road Site considered for a conditional use?
                                            A-2 7

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1.  What other alternative has the EFA been presented by the MWMC or Eugene to



study or consider other than composting?  Were any other alternatives ever mentioned



that had been presented to William Pye to be considered in sewage sludge treatment?



2.  Statements have been made of energy recovery - please explain - if only 11# of



plants energy can be reclaimed out of the methane produced?  Wasn't it told to the



public that the Brown & Caldwell new idea of activated sludge - would take 1/2 the



energy that the trickling filters took?  Why the extreme amount of electricial



energy demanded by this Brown & Caldwell plant now that it is being built?



3.  Industrial pretreatment was to remove the heavy metals and toxics wasn't it?



So that there would be no pollution discharge by 1985 - are you considering that by



putting that pollution of heavy metals on the farmers land and water you have met



1985 deadline?   We asked if MWMC had checked with other towns that had pretreatment



programs and I believe the response was they hadn't.   Has the pretreatment program



been implemented and if so, where is the heavy metals and toxics going now?  Where



will they be going when sewage sludge is put on a permanent sludge location?



**.  Have you used the initials so long you forgot what they stand for?  They are to



protect the environment of other people besides the city of Eugene - the ones you



choose to dump oni
                                       A-28

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            BROWN AND CALDWELL
            CONSULTING ENGINEERS
                               D. H CALDWELL. PE Chairman
                                 T. V. LUTGE. PE Pfesidenl
                              E. F. MISCHE. PE Exec Vice Pros
                                0. P. MORRIS. PE Vice Pres
 December  19,  1983
 Environmental Evaluation Branch
 Environmental Protection Agency
 1200  Sixth Avenue
 Seattle,  Washington 98101                                   13-112-82

 Attention:   Ms.  Norma Young, M/S  443

 DRAFT ENVIRONMENTAL IMPACT STATEMENT  ON THE
 METROPOLITAN WASTEWATER MANAGEMENT  COMMISSION'S
 SLUDGE MANAGEMENT PLAN

 On behalf of our client, the Metropolitan Wastewater Management
 Commission (MWMC), we have completed  our review of the Draft
 Environmental Impact Statement (DEIS)  on the MWMC Sludge Management
 Program.   In addition to and in support of the comments we conveyed
 to you in our meeting of September  22,  1983, the following comments
 are offered:

     1.  On pages 9 and 154, the DEIS  states that no airports are
         within 10,000 feet of the Coburg site.  It should be noted
         that three private landing  strips are within 6,000 feet of
         the site, although they are used infrequently.

     2.  On pages 10, 12, 18, and  158,  the DEIS states that Site C
         is  prime farmland.  The soil  types found on Site C include
         Awbrey Silty Clay Loam (SCS 280 A, Capability Class IV w)
         and Coburg Silty Clay Loam  (SCS 270 A, Capability Class II w)
         A small  portion of the entire tract consists of Malabon
         Silty Clay Loam.

         Prior testimony at the Industrial Triangle public hearings
         in December 1979 by Mike  Stoltz of the Lane County Extension
         Service  indicated the tract must be farmed as Class IV wet
         lands because of the combination of soils found on the
         tract.  Thus, in reality  the  property is hardly prime
         farmland, although it is  comprised of Class II soil in
         part.

         Although Coburg Silty Clay  Loam is listed as prime farmland,
         the working paper on agricultural lands recognizes that
         some soils which would otherwise qualify as prime farmland
BROWN AND CALDWELL
                   P.O. BOX 11680 EUGENE, OREGON 97440
2300 OAKMONT WAY SUITE 100 EUGENE, OREGON 97401  (503) 686-9915
ATLANTA i' DALLAS-FT. WORTH i .DENVER; EUGENE: , PASADENA. SACRAMENTO ; SEATTLE: TUCSON: WALNUT CREEK! ; WESTWOOD

                                 A-29

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 Environmental Protection Agency
 December 19, 1983
 Page two


         may be excluded as  prime farmland when there is inadequate
         drainage.   (Working Paper;   Agricultural Lands, Lane
         Council of  Governments  Research Division, November 1981,
         pages 10-11.)  Thus,  it is  not unreasonable to exclude this
         property from  the inventory of prime farmland, because its
         mix of soils dictates that  it be farmed as if it all were
         poorly drained.

     3.  On pages 13 and 114,  the DEIS states that with dewatered
         sludge there is a lower chance of metal contamination than
         with air-dried sludge.   We  believe this is untrue.  Although
         application rates are lower with dewatered sludge because
         it has a higher nitrogen content, the sludge is spread over
         more land and  the same  mass of metals is applied.

     4.  The summary of Alternative  3 on pages 13 and 14, as well as
         later discussions in  the text,  does not mention the land
         resource impact of  using up the landfill sooner.  We
         believe the DEIS also greatly underestimates energy use,
         failing to account  for  energy used for dewatering chemical
         production  and for  treating recycle loads.

     5.  On page ,15, the DEIS  states that the impact of the "no
         action " alternative  on surface water is unknown.  If it is
         truly a "no action  "  alternative, it is clear that major
         degradation of effluent quality would occur as a result of
         inadequate sludge handling  capability.

     6.  Page 19 does not mention that the use of the Coburg site
         would require  longer  haul distances and probably would
         require trucking through the town of Coburg.

     7.  On the bottom  of page 40 the word "conditioned" should read
         "thickened."

     8.  The discussion of the clay  liner on page 84 should refer to
         "a minimum of" 6 inches as  the thickness of the clay liner.

     9.  On page 84, the DEIS  states that ammonia-nitrogen moves
         rapidly through the soil.   We disagree.  Ammonia-nitrogen
         is fixed or adsorbed  to clays and organic colloids in the
         soil.  This is the primary  reason why little ammonia is
         found in groundwater  under  septic tank drainfields.  The
         ammonia is retained in  the  soil until it is nitrified.

    10.  On pages 86, 95, and  111, it should be noted that since a
         dual force main will  be constructed,  if a leak were detected
         in one force main it  could  be taken out of service and the
         other used until the  leak is repaired.
                                               P.O. BOX 11680 EUGENE, OREGON 97440
BROWN AND CALDWELL  	2300 OAKMONT WAY SUITE 100 EUGENE, OREGON 97401 (503) 686-9915

ATLANTA; I DALLAS-FT. WORTH ! i DENVER: EUGENE PASADENA: SACRAMENTO: ; SEATTLE I : TUCSON I : WALNUT CREEK: WESTWOOD

                                 A-30

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 Environmental Protection Agency
 December 19,  1983
 Page  three


     11.   Page 168 does not mention energy use for polymer production
          and recycle treatment  with the mechanical dewatering
          alternatives, nor does it relate the large  amount of energy
          saved by replacement of commercially produced  fertilizer
          when sludge is used for agricultural purposes.

     12.   On page 188, the DEIS  states that from the  standpoint of
          pathogens, use of composted sludge would be safer than
          air-dried, liquid, or  mechanically dewatered sludge.  We
          disagree.  We have found that long-term storage  of sludge
          in a facultative sludge lagoon results in pathogen die-off
          comparable to that found in composting.

 We  appreciate the opportunity  to comment on the DEIS.  Please call
 me  if you have any questions regarding these comments.
 BROWN AND CALDWELL
 Steven J.  Krugel
 Project Manager

 SJKrdrc

 cc:  William V. Pye, MWMC
      Arl Altman, BCS
                                                P.O. BOX 11680 EUGENE, OREGON 97440
BROWN AND CALDWELL	2300 OAKMONT WAY SUITE 100 EUGENE, OREGON 97401  (503) 686-9915

ATLANTA! I DALLAS-FT. WORTH i i DENVER; • EUGENE, i PASADENA:  SACRAMENTO, i SEATTLE I : TUCSON ! .' WALNUT CREEK; ) WESTWOOD
                                   A-31

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                          A-33

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                A-37

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  Eugene,  Oregon

  December 18,  1983
 Norma  Young  M/S  443                                         &$>.•• «d
 Environmental  Evaluation  Branch
 Environmental  Protection  Agency                     """"
 1200 Sixth Avenue
 Seattle, Washington   98101

 Comments re  Environmental Impact Statement re Metropolitan Wastewater Management
 Commission Sludge Management Plan  Eugene-SpringfieId, Oregon

     I think H. J. Buttner's sludge dryer hooked to the O'Connor combustion boiler

 is  by  far the  most practical and cost effective solution to our sludge disposal

 problem at the Eugene-Springfield Metro plant.  Buttner estimates 1/4 acre of land

 will accomodate the units for the whole Metro area.  (Eugene owns enough land at

 the Metro plant site  to double their treatment capacity)  I've been told it will

 produce roughly four  times the amount of steam energy as it takes to dry the sludge

 down to 50%  moisture where it burns Oder tree and all the emissions therefrom are

 way below Contra  Costa County's (California) emission standards which are lower

 than E.P.A.'s.  I am  told detailed information about it has been sent to you.

     I'm anxiously awaiting Buttner's development of a smaller size model which I

 can use for my Angwin, California shopping center and adjoining developable land

 that at present has no public sewers.  I've been interested in alternative sewer

 systems since  1968 and this is the most practical solution I have found.

     Whether Buttner's dryer-boiler is used or not at the Metro treatment plant

 I believe the Avon Babb families's land and their Delta Sand & Gravel Co.'s pits

directly across Beltline Highway  from the Metro treatment plant has many options

and advantages now and in the future not available at any other location that has

been proposed or about which I have knowledge.

     I've been around this area about 65 years and been interested  in development

since 1960 and attended almost all the M.W.M.C. and M.A.C. advisory commission

                                        A-38

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 meetings since their inception, and others before them, and other related meetings.


      The Babb family have approximately 500 acres of level land (gravel pits, gravel


 resource land, orchard and farm land) from BeItline Road north to the confluence of


 the Willamette with the McKenzie Rivers, about 1^ mile north of Beltline Hwy. with


 a dike and roadbed on top of it for about 3/4 miles.  It is better protected from


 a 100 year flood than the Metro treatment plant or the land on the east side of the


 Willamette River.


      Lee Babb has told me the pit adjoining Division Ave.  and Beaver streets


fdirectly across from the Metro plant is about 85-90 feet deep and it is still


 cemented even in the bottom and up the walls to within about 15-20 feet of the top


 and it is about 99.9870 water tight where it is cemented.  They have to use a power


 shovel to dig it lease and then crush and wash it before it can be used.   All"their


 roughly 100.acres of gravel pits are about the same and are cemented.   I think if a


 bench was dug around the pit with an open trench in the top of the cemented layer


 the surface .water could be directed around the pit and pumped if necessary into an


 adjoining pit, lake or the river^


      Large .holding reservoirs so close to the treatment plant could hold the flow


 during a malfunction at the treatment plant and peak flows,  and then be pumped  back


 across Beltline for treatment as desired.


      I would  like to see a Hercules,  California type Solar  aquaculture green house


 type plant tried  on the Babb  property that could  recycle most of  the waste and  be


 pure enough  for at least industrial reuse  or to recharge the  ground  water.   The fish


 in the lagoon could also recycle food waste from  the larger  food  processors,  restaurants,


 etc.,  in the  area.   The Babb  property is at the Division St.  exit  from the Beltline


 4-lane Highway about 4  miles  from  downtown Eugene.   I  have  seen information from


 knowledgeable engineers  that  Solar heat will  work even north  of our  latitude at


 Eugene in a plant of the Hercules  type, contrary  to  what some less  informed people  say.


      It is my belief that even  the much more  cost effective  (capital cost  and operation


 and  maintainence)  overland flow type  plant the  WMWC  engineers  first  recommended for


 the  Agripac plant could have  been  located  on Babb's  property  with several  miles

                                           A-39
                                 Page 2

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 shorter pipeline and  less  damage and  maintainence, not  being  subject  to  the

 vibration from S.P.  trains and  trucks on  the Northwest  Expressway on  each side

 of the pipeline and also  the  projected parallel  pipeline route  to Site C or the

 Prairie Road  Sludge disposal  sites MWMC prefers.  Even  the sludge disposal sites

 would  be more cost effective  and environmentally safe at the  Babb site.  Even if

 a  100  year  flood washed out the  dike  it would be close  to the river with much

 swifter flowing water, much greater dilution factor, further  from developed land,

 and  on mostly gravel  resource land instead of good crop land.  Any discharge to the

 river  at the  north end of  the Babb property at the confluence of the Willametter and

 McKenzie rivers  would give a  lot  better dilution of the discharge.

     Babb's location  is a  choice  commercial or industrial site if the buildings

 were built on top? of concrete vaults above the 100 year flood plain.   Even if the

 dike should wash  out  the river wouldn't damage or move the large concrete tanks on

 a  cemented base  full of liquid, sludge or anything else.

     The view of  the river  nearby would be an attraction and the sand, gravel  and

 concrete for  construction would be a very short haul.   The land would  then be

 reclaimed and very valuable to compensate for any extra cost for the foundations

 or supporting pillars in the concrete tank.   Odors could be a lot less offensive

 than those from  the new Metro treatment plant across  the road.

     If  you have any questions or would read more of my suggestions  let me know.

 There  is a lot more I would like to say.  I'm always  told to be brief, and that

 is extremely difficult for me.


 Sincerely yours,
GORDON W. ELLIOTT
938 Jefferson Street
Eugene, OR  97402
  Message phone 686-0905
                                Page  3

                                         A-40

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Norma Young    M/S 443
Environmental Evaluation Branch
U. S. £. P. A.,
1200  Sixth Ave.,
Seattle, WA  93101

Dear Ms Young:
                                             DEC.  14,  1933
RE:  EIS per Eugene-Spring-
     field-Lane County Metro-
     politan Wastewater Com-
     mission plans
I"would hope that the enclosed personal  views per  the MWMC  plans  will
be considered in the decision to be made as to  funding,  and"the choice
of site location.   I was ill "at the  time~"of the Dec. oth hearing at
Springfield, and unable"to prepare a  statement  in  time to "be"read,  vo-
cally.  I appreciate the"timing of this"hearing, staged  between Thanks-
giving~and Christmas, the worst possible time for  most of us,  but"'that
is expected when public input is not  very desirous—especially when it
is negative in the majority.

I am a"resident,"living North of the  "Prairie"Road" site directly,  and
adversely affected by"any possible water-table  change or contamination
from both it and"""Site C"—and even more so, due to the  acquife'r  flow
direction, by the under-construction  "Agripac"  site.  The latter  was
once"the farm of my grandfather, purchased by"him  in 1900.  I  and my
father are both^retired, now, and w°  only have"173 acres, but"it  is
"home."  Father"has resided most of his"life here, and I since 1936._
Having^farmed here, we both know all  the nuances of farming, the  topo-
graphy7 and th° ground and acquifer~fyater)assets and problems.  In  re-
cent y^ars, since~this plan first became public knowledge,  I have been
involved withhseveral gfroppsopposing  it.  I still  oppose it7 ~ Evon
more since, as~a director of the pioneer Luper  (Irving)  Cemetery"board,
I was, with the "unlcnown heirs" of three early  settlers, condemned  so
that MWMC could take"our deeded roadway, purchased over  100 years ago.
In_an action still deemed ""unusaljp*, "we" were included in the  condemna-
tion of the properties owned by Donald and Joseph"Cersovski, and  families.
The City of Sugane'did tfie job on us, as a representative of MWMC7  I    .
might note that tfie"condemnation suit"wording"as to the  REASON th«y had
to"take all of these properties ( some 9 parcels are involved  ) was thai-
they had th° right (?)"to take it, and that they planned erecting a facil-
ity with wMch to process "agricultural" industrial AND  SANITARY  SSWAG^
wastes."   At"the time of the 2nd of  these suits,  they introduced into
the "court a new "interpretation" of "what "S3WAG-&"  WAS—including  solid,
gaseous, and radioactive waste matter.   This AFT3R acceptance by EPA &
D^Q hearing processes.  Now, the plan and"facility use does not comply
in anytfiigg"but site"with wnat was considered by the so-called "protec-
tion agencies."   Due to the" many changes and marginally legal actions,
I"finally was forced to hire a lawyer, thus this process is, ami  has,
been a constant financial"drain."J When it was_illegal, or blocked by a
regulation"or statute, tfiey (Eugane"^  Lane"County DSpts., and MWMC)  had
them changed or set aside.  Now, tfiey have the power of  "quick-take,"
and most of us have run out of money.  It is ill advised"to try anS figll
your own tax moneys^ especially wfien  the"agencies  designed  to  prevent it
do'not address these irregularities.  The EPA is among thosa whose  actia||S
are a disservice to their meaning and objective.   Non-action is include^

But—I digress	As a lad I"workecl for the former  owner  of  the two  sitea
at £his location, during the Summers  in harvest, anH in  Winters"plowing|
levelling, and planting_.  Thus, I and my father have an  intimate  know- J
le^ge of both soils,"problems, anH advantages."" I  cleplore the  lack"of
actual farming knowledge among the heads of agencies which  have th^ pow*l
                                 A-48

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                                             /
to affect the very lives of those whose lands decisions  are made  or
modified upon.
     _.       —4     —I                                  *_1           _J      --*

Of the proposed  site locations,  I and all I*"know  oppose  all but"one  of the
"alternatives.^  I^cannot  say much  about the "Coburg"Hills" site  as  it
was nev^r introduced puBlically  until this BIS was  r«quired."  As"a matter
of fact^ neither was^the "Prairie Road" site, until FAA  guidelines came
into tfie picture as per^distance, when one of the Advisory Council had
accepted a flip  comment"by Steve Krugel, engineer with Brown and  Cald-"*
well as" a useful consideration.  Sirrce^_it has apparently^ come into  tfie
running.   This  council"was, as  was the 1st advisory council,  dismissed
by MWMC--rather, MOST were,_wnen the^present MAC  was formed, with a  ma-
jority being City, or County employes or consultants, thus assuring"fdr
a time at least  that no more objections to MWMC^s plans"would  be  faced,"
by having a majority at all times.  I will^state  for the^re-cord that the
MAC has, in tHe  main, performed  outstandingly well  in formulating an in-
dustrial^waste prog rain. _Not that" it"" will ever be implemented, but it is
a good base upon which" to^validate^restrictions on  industrial  users  of
the^system.^ _I  have reservations and oppositions to all the OTH^R^plans
which arose^from MAC since...and before. (SXcuse  the typing—the  «e» has
come unsoldered.)

Alternative IV ("No Project) would  be personally  preferred,"but is an
obvious ploy, and therefore unacceptable.  It is  not my  intention to
play games with~a problem  as direct as this one is.  Being one of those
directly affected by the actions of alternatives  (phase  two)"which are
of value, I cannot supply  affirmation for any but Alternative  III—and
base tfiis on the prior study done by a firm still used in various ways
and areas now by MWMC—CH  2 M ^Hillt  Comparing these two studies, tHe
prior one having been""thrown out due to lack of"public "input," I see
too many variations between"the graphics and the  technical input  of  the
studies to validate the later conclusions by Brown  and CaldwallTs many
studies^  Tfie prior study"indicated that the draft  (final) by  MWMC has
been prepared"using altered facts and figures^  In  plain language, too
many "sharp"pencils" have  changed marginal"areas  into acceptable  ones,
and poor ones into "useful" onest "You have the copies,  and^I  submit
you are remiss in not calling these flagrant changes of  data in order"1
to reach tfie conclusions that MWMC WANTS." It^is^unfortunate,  but^true,
that if one^hires a consultant^?)  —I~"use the term wi th" tongue-in-
cfieek,"as I"3o not o^ten agree~"with these^so-called "experts"—one can
get the answers  requested..Tone way or another.   But—to carry into the
heart of the matter: ~" I feel the fiis^is 'xactly  what"it was intended-to
be, the result of hired "consultants"^to summarize  the data^submitted,
with itfs impacts. "'Unfortuantely']' when you start^with misleading data,
your conclusions are bound to^be erroneou:§1  Let  us^take~"the main area
of controversy:  ^Agricultural'Use of Sewage Sludge""as fertilizer for
farm use, and the need to have it near the lands^where it will be util-
ized, if at all.  Again, you have to BB a^farm^r^to  know that_it  cannot
work, nor will it EV^R, as :?anners~canaot"utilize anything that liw  in
nitrogen^profitably, and Hu® to the"weather factors, and haste required,
cannot be expected to^accept it except on "call^"   Then again, it^has
been said that by spreading it on grass"crops it  wi],l not get  into"the
food^chain.  U  submit to you that there Has been and will continue  to
T>e use by farmers of grass straw as supplemental  T&ed/hay —which can
ent£fr the food chain via both milk and meat^,  i leei^that anyone"wh~cT~
now u§es tl}is, Qr Elans on uging it, noi only do,eg  SQ out of greed.  or_
for some ot^er hoped-for profit motive.  Wh«n "sludge" WAS available
at the River Avenue^plant, meticulous records were  kept. I studied  thfm
for a two year span7 and the most ANY "farmer" took was  a pickup  load,
in contrast to statements  by MWMC's manager, William V.  Pye...those
                                 A-49

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--or w°re, available to verify my  statements,  should you be astute*
enough~to check them.   I am not sure. but"suspect  tRe most recent
statements that "22 farmers"  (Mr.  Pyej" are interested in applying  tHe
sludge may also be a fabrication.  I"leave that up  to you, as Mr. Pye
rarely opens himself up to public  question now7  Now to facts and figures
—which are as strong AND as frequent as applies the drawbacks  of this
"product."  "                    ONS        "                "
Th.3 use of sewage sludge for"agricultural use,"or as fertilizer for other
areas of use, as timber,_^foresf, or nursery^use is  not"recommended  at this]
time, though it may be in future.  One nurseryman (name on request) wHo^got
a small amount of-it to experiment with, found to his Hismay when mixed"
withTpotting s&il, and watered,"it became like solid c^m^nt.  Just"one  ex-
ample, I"grant you, but most are^afraid to use it,  after seeing the reieas
they have^^o sign to_obtain it7
  A.  Farmers will not b* bothered with anything this time consuming and
low in needed nitrogen.^
  B.__ Scientists, and agronomists, still have  concerns about the~35ng term
hazards of sewage sludge, depending on"~itTs content and use.   (gee  Dr.
Darren Turner's data, W.S.U. soil scientist,  Salem "Capitol"Press" of
wk" of 19-25 Augt, 1979;  Oregon State Univ.*xt3nsion Service Special Bul-
letin #499 (page 24] and the"6omBined Studies  of the Universities' of MD,
NJj, CONN, & MASS" (1977) for reservations and  warnings about potential
hazards to public healtK.) These studies also  note"that_there would be
needed"( for a two-stage (limit) application!  per each"lo7000 persons,
45 acres  ( to start,)  and that_"furtHer^research is~needed."
  C.  Following this (B7)"l submit the statement made in the advisory
committee mating of Steve Krugei  engineer for Brown and Caldwell, that
(June"lO, 1930) "W^ WILL N^D 3,000 acrss"as backup land" (^"agricultur-
al use/appiication^TO STA^T.)  The proposed 203 plan for the^y%r 2040
regarding land uses and^needs by then is graphic in noting some~10jOOO
acres will be needed ( and is outlined) North  of Beacon Drive West, and
an additional 1,900 acres"in the "Industrial Triangle"—thus taking from
farm and/or industrialize and tax-personal use-production this much...
at a time^when both Sug9ne and Lane County are "looking" (?)_for addition-
al lands^of 100 or more acres"to that"end. " This does_jnot make s°nse,
in the overall view..t.but then, sens6 is secondary as^motive^  in this  pla
  D.  Th° major problem with this^"product" is it's ov^rabundance." Land-
fill dumping will have to^continu- in any approved  alternative  —perhaps
not by choicej but until better methods of handling are found,  which ^Rs
"saf9^"   The glants^of^ear-conformity in Oregon are"those in  Salem and
Portland.  They too have no adequat^ alternative._  Th°y simply  produce  more
sludge than they~have suitable agricultural lands"upon which to apply it.
Portland sugg^st^d barging it^up the"Columbia  River to Morrow County, whict
perHaps solved TH3IR immediate problem, only to compound it in  Morrow Co.
Salem is no better.  Refer to "Sunday, Oregonian"  July 13, 1980:  "Cities
worrying"as_sludge piies"upt» (Portland and Saiem) 5""Reluctance  of farmers
and growers"to use sludge; "  and  "Del Mgnte r°fuses crops growg on lands
where^sludg*? was applied."
 £. "Obviously, if_this alt8rnative is expanded, it means either farmers"
or^"dedicated" lands will have^to be utilized.  As  of May, 1982, signature^
of 63_farmers, large and small, w^re obtained  in areas surrounding  th^s6
"alternative"_sites"nearby,_piedging_jt5at they would NOT apply  it on any
°^ their 12,415 acres. " For obvious reason,Sj  again.
  FlDedicated lands become "white elephants" and  a source of  an answer,
but this^method^aEj in Sacramtnto, CA ( wt}ere  agricultural us^  is banned )
is^non-productive and costly.  §houid Oregon follow in ttjis restriction^
and there are those lobbying for that type of  legislation, it would be, as
th^s6 facilities, a loss.  Losses are not unknown^to Lane County, as^h^
Solid Wast- Facility"^ which is to "Be scrapped  after years of controversy &
great losses„. d^KT the "plans" failed to pan outo
                                    A-50

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                                _                              ^
If th2 foregoing factors, all negative overall,^ affect such an in-
stallation, on*5 might ask^WHY they continue with it;?  ^The answer is
simp!9, yet complex, as too many officials~are ^mbroil^d, along with
the off^r of too much money.   As one former^MWMC number  ( and EX-
County Commissioner ~) stated at the 19g£TLane County Fair "I don't
GIVS a Damn what they cto with the sludge7 so long as^they get it out
of -?ugene and Springfield. ""  TRis is the_obvious reason for" carry ing
this fiasco~ab.ead, to remove the problem from the "Metro" a?ea and^put
it in^an area of low population.   In other words, "Damn the residents^
as long as W& g^t^rid of tRe (visible} problem."   And^that is just how
Ws sSe it- in, the main. _ Never mind iegallitj.es, change the laws if they
hinder us^ and the zoning regulations, if TH^Y slow us down.  This th&y
have already accomplish-dj with not a ltttie"angry opposition.  To sum
it up^the "product" is in overabundance^ the money was slow in coming,
so the^plant was "compacted" and some facilities for processing w^re cut
out— leaving a plant that cannot adequateiy^V^R hand!6 the sewage that
has b^en'projected^f which, by the way, is already over projections in
                  ^
Springfield's plant, passing the 19#5 figures during an accident which
was measured by thQ D^Q — axceeding 19#5's projection now, what will it
          ar? )                 _                    "
be NBXT year?

Now to some of our persona"! concerns:  The attitude and the methods"by
whi€h MWMC^has reached the present point of getting the problems they "
have shifted over on~to US; lies, fabrications, violations for both the
SPA-and th« DEQ guidelines never acted upon, as^well as state laws...
and, in particular, one law which refuses anyone or any commercial firm
contaminating, "or planning to contaminate, any single-source supply of
water, which means US."  Our gnly "access is^our present acquirer, and the
rain.   Most of us^have shallow wells ( under 9$ feet  ) in the farm, rur-
al, suburban, areas, and deep wells in th^ cities, as" Junction City's.
How"can the SPA oven CONSIDER a plan that will, "as th«W (AtiUC^ngineers
piqjectj^ contaminate ^northerly^wells?"   Eealcage or seepage, or eyen
leaching, is^possibie from lagoons , an3 especially, drying beds, and
the scientists are ALlTconsistent in their views that  the agricultural
use of sludge or sludge facilities are prone to health hazards in areas
of "HlSH YEARLY RAlftFALL."  That^s us, againt^ (This y®ar we have"al-
ready exceeded 5 fee^ — only one year of three"to meet  or nearly meet
records — -and this year IS the record in 90 years of measurements.)
I was not"at the Sis hearing, but^caught part of a statement by a_man
at ^Ehat hearing on TTV--in which Re said that (wording^may be inaccurate)
"the s^udy was in result of concerns^by the puBlic, and it enlarged^the
picture to focus on determination of "whicH -alternative would b^st
               "                                       ^
    MAJORITY."    If this IS the objective, and funding^will be made on
the"basis of the plans OTH% THAN ALT^-RJlATIV^ ill, I f«ei 3pA^n«eds to
take a good look'at it's^responsibilities0  After all, MOVING a problem
is not a valid^reagon to"be given Federal Funding, and only tUflds to
shift the burden^from one area to another, and solves NOTHING/ " How, in
all good consci§nee^can SPA fund^this fiasco?  * in fact, considering the
application^ already mad? , do th^y actually comply with a validity that
prior_grants afforded?    In Bother words, I would ask for a "refund "^if
what we have se^n is said by^MWMC to Bs a valid program.   If^this can-
not be done, then go with th- "No Project," and prevent further losses.
                              TWO
As to "Hetermining" who is to gain, and who is to lose, (benefit) I am
not sure that I want to Ls? ANY GOVERNMENTAL JUR^AUCRACY make such a
dejjisipn for me.   What efer J>ecame of our "fights" unde"r law?  -This
eventually  wi],l affect  the  environments,  lives,  an3 more Jor  30.000
people  living  from the  planned  facilities Sorth ttf5 Monrpe  and  Junction
City.   To date, it^only a^THR^AT.   The  threat is R3AL,  and  if "M«tro"
wants to dump"their problems  on US,  Only  YOU  stand-in  their way.   WitRout
tfie  FUNDS,  they wm handl6 it  as  it SHOULD be  handled, by  and  for them-
selves.                           A_51

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                                                                        5.
              t)-

0f/TV,Recently, th*  HaAD  of  th9 EPA  was  queStioned  on. matter^concerning
    industrial waste  stSrage problems.   He  stated that there was NO way
    of protecting  completely any such  man-made  system, and that  there  IS
    no "fail-sHfe" laggons"" to  fits knowledge."
      A   There  is no present ne.Sd for "sludge" as an  encl product.
      B   Landfills should be used"' and checked  for any leaching.
      C   Adequate" and  suitable areas  for expansion were"found to be"easily
    obtained in  the CH  2 M Hill stufly  ON TH3 SITS (p'resftftt RWTP)  The  later
    study by Brown and  Caldwell noted  some  area owner's did "not  wish to sell"
    their land.  So how come WE get ^ofidemned ancl they 3k> NOT?  We  don't  want
    tS sell EITHER!   Inasmuch  as  Slements  of the planned facility, -as"the
    centrifuges  and cll'rifiers  (tfiey brag about that "saving, *)  have been re-
    moved from the ^i&W* they have THAT land upon which to erect the facili-
    ties they want" to foist on  US.           "  "               "   ""
      D"  There  are NO  ^failsale"  monitor processes.   What^we^have  seen,  and •
    have documented,  are sludge drying beds overflowing^on"to"adjoining lands,
    a~laclc of any  lagoon sludge/liquia ( 1979 — after the wettest August on
    record|-and  three MONTHS after the  last Sried sludge was taken" to^ the
    landfill at  Short Mtn., and the hauling equipment  was"sold,"there"is  no
    question aBout^what 3  months of builH-up did — it pumped itself over^the
    edge o? tfie  lagoon  via an £ inch pipe and pulsating motor, into the""
    Willamette River?  f D^Q said nothing.)  "Finally, liquid sludge  hauled to
    the"" landfill was  handled^ so "Badly  that  even DSQ had to admonish MWMG  &
    hav« it cleaned1 up.  After" re ad ing about D^Q's actions and th*ir failure
    in the"Deschutes  County chemical dump,  I would not TRUST them to monitor
    MY water supply.

                           -

    Last but not least, "the "Bird-Strike* Problem.  I^will not  elaborate  on
    the material included  in the"BJs except to  point; out tHat on the Sacramen-
                      ^                                                  "
    to Study only 22 ^s^agulls^w^r^ noted  in  the  entire  area in all,  and"that
    only a PART of the study done  in Corvallis By JBaftv«3aB is  in elude d^   T^he  main
                                                               ^
    point made , and NOT included was his  statement  (  also  in a^news it^m in
    th^ Junction City Times, 1   TKat:  ''If^you're going  to"have  more birds,
    then obviously you're mOre  likely to  have  a ^ird  strike." ^This after:
    "--a sludge facility WOULD  attract  more birds,  and more  VAgI^TIES^of spe-
    cies --- " at a lagoon thaQ woulcj any g^ass  fie^ds.  Ygu already §ust know
    that Brown & Caldwell, MWMC.^and officials, including  thos®  at th^. 3ugene
    Airport  (Matron Sw?et Fild] w^i-e giv^n notic®  by  th«  FAA's  Chief of Air-
    ports Planning Branch, Georg® L.^Buley, TWIG2-,  and .by  Robert Brown;  FAA
    Regional Director, ONCB that they fully expect  hazards and strikes,  and
    r^ferring th@an to their guidelines. . .as to distanc®, from runways where
    jet aircraft land and take off.    MWMC says NO problem will occur,  as it
    plans only a "facultive" lagoon." This is hogwash — it  cannot BS a"facul-
    tiv«"lagoon when the plan includes continual dumping of raw  sewage over1
    the entire year.   Living as I do"^ right down the  "slot1* and seeing  the
    end-of- runway lights from my driveway, this scares me  no end...an3 not" to
    say any possible crew and passengers using tfie  pattern.   5 airlines  are
    also concerned, and have so stated their objections to "Site C."
    I regard" the Eis^to be"a  "Monument to Waste."   I and  others have  opposed
    the system's^moving "Metro's^ problem^into flUR' backyard,  as it  was,  for^
    FOUR iSARS". ^BuWtaucrats, consultant^ lawyers^ an d^ contractors have en-
    ricHed" themselves or justified their"existance  oyer"this  "goldmine." "We
              them almost completeiy"take^the whole mine, "while W2  got tfie
    "SHAFT,"  as in the SOng Jerry Reed  sings....  We have  fac^d  condemnation,
    endless and futile hearings,  incompetent consultants,  lying politicians,
                                      A-52

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                                  "*-.,-"      -          6.
illegal or fraudulent^ testing,  som^ of which^were h§zarclous,
using livq virus -without advising the residents  ("Shirlsy^Ditch")
the continual haras sm^nt,"th° tension, and" he art ache ,  none  of
which" we re or will ever b° address^d.  ^Th* point of attack from
the beginning maintain*5 d^by th°J"Metro"  officials and  ^ugen^ in
particular, was, if damage occurecU "Sue U§."   That has  been  dgn° ,
but to little avail.  One who rqcRntly died of cancer  of  the liver^
claimed both h^ and his mother  w°rs poison^d^by th° wat^r,  as  he
us°d a w-11 adjoining th*" drying b°ds on Riv^r Av^nu*5  wh^n^cond^^mn^d, 4-
was never, to my knowledge, fully compensated for tRe  payments,  and"
died short some $107000 of what Sugone owed Rim.  He had  already sp^nt
nearly that in lawyers fees.  Another has  spent about  $£,000 so~far.
This is an area which Has~'no_t been addressed in the SIS,  "But on« which
affects all of us.  One neighbor was in  tfiQ nursery business,  and was_
also condemned (adjoineS th=< plant on River Ave. also^then^moved out
here, and now THIS property lies within  300 feet o?_the r^c^nt purchase.
by MWMC of 123 acr^s adjoining_j"Sit^"C" , so has been^DOUSLY injured^
All of us Hav^ s^^n our properties de value d_^with^ the"" advent of the
plans alone.  None of us will eyer s^e^this^in justice  remedied.  ~"0ne
member of^MWMC brought this up, but the^others were not inter^sted^
I would feei this inequity, inasmuch as^non^ of us, benefit  from  this
and future damage s,_SHOULD be'compQnsated  for this financially. _ VP5^
should NOT hav- to pay to have  "Metrotstt problem" dumped on  us  so th^y
do not.    Th^re ar*5 many ways  this could  be don   and SHOULD  bp done.
With but 55^ of a"heart left, I will doubtless die  before  the  worst of
the Samage^is done^but hate it will happen, as happen  it  will should
it be funded"?  I^feel^now that I did all I could, wasting  £ y^ars  of
my life, "in enclless hearings and meetings, ranging  fronf^he regular
7 AS "eye openers" of MWMC to tRose set up as special^mee tings and
advertise^ 4 hours before in the papers. . .another illegal  ( State  )~"
action, designed to prohibit public input."" I pity  the  poor ratepayers
saddleo. with this fiasco for the next 60 years or more^ and MWMC has
not even included retirement of bonds^sold by the "Service District"
(in actuallity, the County'Commissioners) to date.  Due to this and
the direction and" inequities , and  just plain political^ramifications
anct/or possible legal responsibilities, our commissioners  now  state
th^y "want out."  Already, "Springfield ratepayers and users have found
the cost too high, and rebelled.^

Those who oppose MWMC's plans^are  degraded, with"t°rms  ranging from
"crazies,1* "Paranoid,1*  "hysterical1*, and all^the way to "stupid"  and
"uninformed."   yfi are none^of^tTigse, but suspect we WILL  be paranoid
before this is^over.  l"note
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    SPRINGFIELD — The Metropoli-
 tan Wastewater Management Commis-
 sion has expanded its search for a per-
 manent site for disposal of sludge from
 the Eugene-Springfield regional sew-
 age treatment plant

    The commission two years ago des-
 ignated an  area north  of Eugene
 known as  "Site C" as its preferred lo-
 cation for the 170-acre facility. The
 site would be used to dispose of solids
 left from  the sewage treatment proc-
 ess.

    However,  public  protests against
 the location forced a federal environ-
 mental impact study, which meant the
 agency would be unable  to complete
 the facility before the new regional
 plant goes into operation next year.

    The delay caused the commission
 to  develop an interim sludge disposal
 program  using  the  county's  Short
 Mountain  landfill near Creswell and '
 various agricultural lands during  dry
 weather.

fin an  action taken Differ a closed
 discussion Thursday, the commission '
 adopted a resolution designating an ad-
 ditional 125 acres south  and west of
 "Site C" as a potential location for the
 sludge disposal facility.J

    The properties are located south of
 Meadowview  Road,  north of Awbrey
 Lane, east of Highway 99 and west of
 the Southern  Pacific railroad right of
 way.                  ,   -••,

    Project director Bill Pye said the
 decision will afford an opportunity to
 consider  locating part of the facility
 under Bonneville Power Administra
 tion  transmission lines,  if the  BPA
 gives its approval.

    Pye said bothJ'Site C" and the_ad-
        125 acres have been judged
 acceptable in the federal environmen-
 tal impact study completed earlier this
 year.

    While  Thursday's decision provides
 290 acres in which to choose a loca-
 ' tion, Pye said, the agencyjaay.be able
 to fit its sludge disposal facilities in as
 little as 125 acres, if it is able to use
 equipment it is acquiring for the inter-
 im disposal program.
    In another action earlier in Thurs-
 day's meeting, the  commission  ap-
 proved nearly $2.9 million in construc-
 tion  and  equipment  contracts, nearly
 $1.8 million of them for sludge facili
 ties and equipment to be used in the
 Interim disposal program.
    The largest contract for $1,320,000
 for the construction of the Terry Street
 pump station in west Eugene went to
 Marion Construction Co. of Salem, the
 lowest of seven bidders.
 '^QfcKU-f^
 Sludge  site

still   sought

by^agency
i
I    page 15C    r
                                        n^nn-Friday. October 28.1983^

                                             ±—

              A-54

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        Site "C" PotentialSludge Management Area



I would like to voice ray concerns about Site "C" and the influence it will
                                                       »
have on the surrounding land, people and cities.

First, the topography of the land is of low elevation, starting with the

Enid Station Road for it is only 365 feet in elevation.  Moving on to the

north we find Meadow View which has an elevation of only 350 feet.  This

means that there is more standing water in the Winter and Spring on these

lands.  Any use of these lands for sludge management sites would cause

pollution on the surface water and damage to the lands within its boundaries.

The numerous small intermittent streams which run through the area would be

polluted by any liquid sludge being transmitted into the surface waters.   Most

of these small streams run toward Junction City.  This would cause environmental

problems for the people who live north of the site "C".  Everyone who had a

well would have water problems plus any birds and wildlife would suffer for

lack of suitable habitat, food and water.

Second, I feel the area is subject to general flooding.  The latest information

from Federal Emergency Management Agency on FloodHazard dated February 10, 198l

shows parts of site "C" in special flood hazard area.  See Exhibit I.

Third, the land was designated for agriculture use in 197^ by the Lane Council

of Governments in their comprehensive area-wide planning program.  This land

falls into two categories, Class I - High Intensity Agriculture which is row

crops, berries and orchards and  Class II - Medium Intensity Agriculture which

is small grains, grass crops, fall and winter pastures, some orchards, row

crops and berries.  See Exhibit 2.

In closing, I cannot see land which in 197^ was designated for high and medium

intensity agriculture use, will be proposed as a potential sludge management

site.  It is a direct contradiction of the many goals and ideals and I quote

from the Lane Council of Governments:

         "Large areas of Class I agricultural soils within and bordering
          the Eugene-Springfield Metronol i.tan Area and in the lower
          McKenzie River Valley ha^i A-55  converted to urban uses and no
          longer available for farming.  Demand for further urban develop-
          ment on the county's best agricultural land is certain to continue

-------
       in the future*  However, this demand must be weighed against the
       importance of retaining the agricultural land for food production
       and open space."

Then is the land which is to be site "G" sludge management area is to be

taken out of agricultural use the governmental system which made these

policies have failed to make clear and unbiased policies and failed to

serve the people of this county.
                                   A-56

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I
    >'/
    •. i
   J\

I
   ; rnfflf*
   PACIFIC R
 I
 I
   ONE A
                                  . V
                           APPROXIMATE SCALE
                      2000
                                           7000 FEET
                          NATIONAL FLOOD INSURANCE PROGRAM
 FHBM
 FLOOD HAZARD BOUNDARY MAP
 LANE
 COUNTY,
OREGON
UNINCORPORATED AREA
                          PANEL 13 OF 33
                          (SEE MAP IN Of X (•ORf'AMLSNOtPH'NTtC
    COMMUNITY-PANEL NUMBER
             415591 0013 B

              MAP REVISED:
         FEBRUARY 10, 1981
                         federal emergency management agency
                            federal insurance administration
                                          A-57

                                                                      *

-------
uf
                                                                                                                              KEY TO MAP
                                                                                                             SPECIAL FLOOD HAZARD
                                                                                                                     AREA
ZONE A
                                                                                                              Nole These maps may not include all Special Flood Hazard
                                                                                                              Areas in the community After a more detailed study, the
                                                                                                              Special Flood Hazard Areas shown on these maps may be
                                                                                                              modified, and other areas added
                                                                                                             TO DETERMINE IF FLOOD INSURANCE IS AVAILABLE IN
                                                                                                             THIS COMMUNITY. CONTACT YOUR INSURANCE AGENT.
                                                                                                             OR CALL THE NATIONAL FLOOD INSURANCE PROGRAM.
                                                                                                             AT (8001 638-6620. OR (8001 424-8872
                                                                                                              February 10. 1981 Panel Revised To Reflect FEMA Title Block. -

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                  33
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                                           A-59

-------
*
:   AGRICULTURE
  X
 Uj
     I
    m
    o
                         K PEOPLE, 1970
                          CUSS I HIGH INTENSITY AGRICULTURE:  ROM CROPS, BERRIES,
                          AND ORCHARDS

                          CLASS II MEDIUM INTENSITY AGRICULTURE:  SMALL GRAINS. GRASS-
                          CROPS . FALL AND WINTER PASTURE, SOME ORCHARDS. ROW CROPS.
                          AND BERRIES                            '•

                          CLASS III LOU INTENSITY AGRICULTURES:  PERENNIAL GRASS CROPS,
                          FALL PASTURE
                          CLASS IV VERY LOU INTENSITY AGRICULTURE: PASTURE LAND AND
                          INTERMITTENT FORESTRY                   '

                          • CATEGORIES ARt BASED ON THE DOMINANT CHARACTERISTICS OF
                            SOILS ASSOCIATIONS.  NOT OH INDIVIDUAL SOIL TYPES

                          • FOR ADDITIONAL INFORMATION SEE "LAKE  COUNTY SOILS ASSOCIATION
                            MAP UITH INTERPRETIVE GUIDES* LANE COUNTY 1971
                                OOUQIAI COUNTY

-------
                                                   c
                                             9
                 0    '
6  .
                          A-61

-------
          ,
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               A-62

-------
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                                         \>&x>' &L£.

-------
***
   A-64

-------
                                    Junction City,  Oregon
                                    December 6,  1983
Norma Young
M/S 443,1200 Sixth Ave,
Seattle Washington 98101

In relating to the impacts of the  proposed  sludge  Management plan
for the Eugene-Springfield area, Oregon.

We are opposed to the location  of sludge   in the  area North
of Eugene and South of Junction City  along  Prairie Road and
East of the Southern Pacfic Railroad.  This  area is subject to
flooding during the winter when rain  fall is  heavyy such as
this year. The runoff from the sludge  will  contaminate our
wells for drinking water.

                         Yours very truly,

                         Richard fo.&  Sadie  A. Lyon
                         91884 Prairie Road
                         Junction  City,  Ore.  97448
                                                DEC  8 1983
                                             ENVIRONMENTAL EVALUATION
                                                   BRANCH
                              A-65

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                               November 1, 1983

     I have "been in "business in Springfield for 15 years
and I'm real disgusted with our MWMC management.
     To me and many others we have really "been ripped off.
I spear headed a petition drive and received more than
enough signatures to put our sewer charge up to a vote of
the people but a county judge ruled against us.
     The City of Springfield has forced their sewer services
upon us through the use of bancrofting funds which itself
has proved very questionable.  The project itself in our
case was illegal, yet the Qity of Springfield and MWMC was
able to force their wishes upon us.  I personally can point
out at least 300 senior citzens on fixed incomes that are
faced! with a foreclosure of their homes.
     Why can't we have a complete investigation and tyring
to light many of the high pressure tactics that were used?
     The wastewater plant and sewerage lagoon itself is a
public disgrace.  Many small businesses within a 10 mile
radius of this monstrosity are symptomatically being
eliminated.  How can these things happen in democracy?
                      A-66

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ATTORNEY
   AT
   LAW
 JIMMELAMED
 259 E. Fifth Avenue
Eugene, Oregon 97401
   (503) 345-1456
 MEDIATION
    AND
ARBITRATION
                                      December 6, 1983
      Norma Young M/S 443
      U.S.E.P.A., Region 10
      1200 Sixth Avenue
      Seattle, Washington  98101

      Re:  Metropolitan Wastewater Management Commission
           Sludge Management Plan DEIS

      Dear Ms. Young:

          Here enclosed are Comments to the MWMC Sludge Management
      Plan DEIS submitted on behalf of the City of Coburg, Oregon,
      the Coburg Planning Commission, the Coburg Chamber of Commerce,
      the 102 members of the Muddy Creeks Irrigation Project and
      more than 60 individuals and businesses residing or  located
      in the greater Coburg area.

          I trust that the Environmental Protection Agency will give
      full consideration to these written comments along with  the
      oral presentation that I will be making this evening in
      Springfield, Oregon.

          Please feel free to call or write with any questions that
      you may have.
                                      Very truly yours,
      JCM/ss
                                    A-67

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COMMENTS TO DRAFT ENVIRONMENTAL IMPACT STATEMENT
 METROPOLITAN WASTEWATER MANAGEMENT COMMISSION
             SLUDGE MANAGEMENT PLAN
Submitted to the Environmental Protection Agency






                December 6,  1983
                     A-68

-------
        COMMENTS TO DRAFT ENVIRONMENTAL IMPACT STATEMENT

         METROPOLITAN WASTEWATER MANAGEMENT COMMISSION

                     SLUDGE MANAGEMENT PLAN


I.  INTRODUCTION

    These  Comments  to  the  Metropolitan Wastewater Management
Commission Sludge Management  Plan  Draft  Environmental  Impact
Statement  are  submitted  on  behalf of the City of Coburg, the
Coburg Planning Commission,  the  Coburg  Chamber  of  Commerce,
the  102  members of the Muddy Creeks Irrigation Project (listed
in Exhibit "A" hereto), and  more  than  sixty  individuals  and
businesses residing or located in the greater Coburg area (listed
in Exhibit "B" hereto).  A copy of a  joint  resolution  of  the
City  of  Coburg  and  the Coburg Planning Commission supporting
these Comments is attached hereto as Exhibit "C"  and,  by  this
reference,  incorporated  herein.   All of these parties express
their appreciation to EPA for this opportunity to provide  mean-
ingful written comment on this proposed sludge management plan.

     In  brief,  the  individuals,  businesses, associations and
governmental  entities  represented  herein:  (1)  question  and
challenge  the  analysis and assumptions which lies behind EPA's
selection of the DEIS "preferred alternative" sludge  management
system; and (2) are united in their opposition to the establish-
ment of any proposed remote sludge management  facility  at  the.
"Coburg Hills Site."

    The  fact  that  EPA has resurrected the "Coburg Hills Site"
for consideration in the DEIS,  without  due  notice  and  after
this site has been firmly rejected by the Metropolitan Wastewater
Management Commission (hereinafter MWMC)  in  its  comprehensive
1980  Sludge  Management Program, can only be explained by EPA's
obligation to analyze a set of alternative  sites  in  the  EIS.
This  resurrection  of  the  "Coburg Hills Site" is improper and
fails to fulfill this statutory  and  regulatory  obligation  to
examine  a  reasonable  range of alternative sites.  This resur-
rection creates the dangerous  possibility  of  EPA  locating  a
massive  sewage  facility  not  by reasoned choice, but, rather,
by unlawful default.

    The DEIS also fails to  thoroughly  evaluate,  as  it  must,
all reasonable technologies for managing Eugene and Springfield's
waste,  including "state of  the  art"  technologies  that  would
not require the development of any massive remote site.  Further-
                            A-69

-------
more, the DEIS preferred alternative system  has  been  selected
based  upon  the assumption that there will be a sustained agri-
cultural sludge reuse market.  This assumption is not documented.

    There are numerous  additional  reasons  for  EPA  rejecting
the  resurrected  "Coburg  Hills  Site"  as the location for any
MWMC remote sludge lagoon/drying beds  facility.    Among  these
are  the five reasons that MWMC's 1980 Sludge Management Program
did not even include the "Coburg Hills Site" in its  final  site
analysis:

         1.   Less  favorable drying conditions—less sun, wind,
         more rain than central valley.

         2.  On slope—high bed construction cost.

         3.  Force main 2 miles longer than Site C.

         4.  Away from Agricultural lands of minimum  limitation
         for sludge use.

         5.   Poor  road access.  Trucks must go through Coburg.
(MWMC Sludge Management Program, 1980, p. A-ll)

    While MWMC did not even  include  the  "Coburg  Hills  Site"
in  its  final analysis of five potential remote sludge facility.
sites, EPA has seen fit to resurrect this  incompletely  studied
alternative  for  its  final  analysis  of  only three potential
remote sludge facility sites.  EPA has done this without adequate
notice  or  explanation.   Nowhere in the DEIS does EPA directly
confront the factors that led MWMC to reject the  "Coburg  Hills
Site"  as  one unfit for final analysis, nor does EPA adequately
explain its failure to resurrect or  develop  other  alternative
sites.

    Having  been resurrected, the danger exists that the "Coburg
Hills Site" will be selected by EPA by  default.   As  the  only
other  two  remote  sites  under  consideration by EPA, "Site C"
and "Prairie Road,"  are  literally  just  across  the  railroad
tracks  from  one  another,  the  risk exists that both of those
sites could be rejected by EPA for a  single  reason.  With  the
"Coburg  Hills Site" being the only other remote site considered
in the DEIS, the risk of the "Coburg Hills Site" being  selected
by default,  rather than reasoned choice, is substantial.

    Furthermore,  any  selection  of the "Coburg Hills Site" for
the proposed MWMC remote facility would violate state and  local
land  use law,  particularly state land use goals for the preser-
vation of agriculatural land, the timely orderly  and  efficient
development of public facilities, energy conservation and urban-
ization.  The DEIS also fails to  adequately  evaluate  potential
DEIS Comments  Page 2

                             A-70

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 ground  and  surface  water  impacts  at  and around the "Coburg
 Hills Site" and fails  to  address  the  true  economic  impacts
 of  this potential development on businesses in the Coburg area.

    For  these  reasons  and  others discussed below, the above-
 named parties are compelled to submit these Comments  in  oppos-
 ition  to  EPA's designated preferred alternative sludge manage-
 ment system and to the potential location of any proposed sewage
 facility  at  the  "Coburg  Hills  Site."   As is discussed, the
 establishment of any  proposed  sludge  management  facility  at
 the "Coburg Hills Site" would be both unreasonable and unlawful.


 II.  INADEQUATE NOTICE AND ALTERNATIVES


    A.  EPA's Notice of "Coburg Hills Site" Alternative Inadequate

    EPA  has  failed  to  take  required efforts to allow public
 participation by those potentially affected by the establishment
 of  a  sewage  facility at the "Coburg Hills Site" in and before
 the "Scoping" process for the  EIS.   As  described  in  40  CFR
 6.400,  EPA  must  "make  diligent efforts to involve the public
 in  the environmental review  process  .  .  .."   It  is  futher
 required  that  "[a]s  soon  as  practicable  after the decision
 to  prepare an EIS and before the scoping process, the responsible
 official  shall  send  the  notice  of  intent to interested and
 affected members of the public . . .."

    Despite this  obligation  to  make  "diligent  efforts"  and
 to  give  the  earliest  possible notice to potentially affected
 persons, the first  time  that  those  potentially  affected  by
 the  location  of  a  sewage facility at the "Coburg Hills Site"
 reasonably heard of its  resurrection  was  when  the  DEIS  was
 delivered to their mailboxes in mid-November, 1983.

     An  examination  of  the  November 17, 1982 Scoping Meeting
 Mailing List for this project (attached hereto as  Exhibit  "D")
 reveals that not a single person from the Coburg area was included,
 The owner of the proposed  "Coburg  Hills  Site"  was  not  even
 notified.  Newspaper notices and the News Release to the scoping
 meeting (also attached hereto as  Exhibit  "D")  do  not  remedy
 this  situation.  At best, this press release and these articles
 indicate that the proposed facilities would  be  located  "north
 of  Eugene."  Truly,  these  newspaper  articles are misleading.
 For example, the Springfield News article of  Thursday, November
 11,  1982,  indicates  that  the  facility would be in the Santa
 Clara area.   The  Eugene-Register  Guard  article  of  November
 10,  1982,  implies  that  the  facility  being considered would
 be in the Mahlon Sweet Airport area.  There was, thus, no reason-


DEIS Comments   Page  3

                             A-71

-------
 able,   much   less   "diligent,"   notice   to   people  in  the  Coburg
 area that  any "Coburg   Hills  Site"   was being   considered   for
 resurrection  by  EPA.

      This  failure   to   reasonably   allow   early  input  into  the
 EIS process by affected citizens in  the  Coburg   area  helps   to
 explain certain deficiencies  in the DEIS.   This notice failure
 probably resulted from   the   reasonable  initial  conclusion   by
 EPA  that  the "Coburg  Hills  Site" would simply not  be an  alter-
 native  in  the  DEIS.    Regardless,   by  subsequently  including
 the "Coburg Hills Site" in the  DEIS,  EPA has  breached  its  public
 participation and notice obligations.


     B.  EPA*s RANGE OF  ALTERNATIVES  IS NOT  REASONABLE

     As  briefly  described  in   the   Introduction above, EPA  has
 also failed to include  a reasonable  range of   alternative  sites
 and  systems   in the   DEIS.    The National  Environmental  Policy
 Act requires  a "detailed statement .  . . on  .  .   .   alternatives
 to  the  proposed  action  .  . .."   42 U.S.C. 4332(C).   In addition,
 agencies are  commanded   to  "[s]tudy,  develop,   and    describe
 appropriate   alternatives  to   recommended   courses  of action  in
 any proposal   which involves   unresolved   conflicts   concerning
 alternative uses of available resources."   42  U.S.C. 4332(E).

     The duty to   discuss  alternatives has  been  described  as
 the  "lynch   pin"   of   the  entire   impact   statement.   Natural
 Resources  Defense   Council   v.   Callaway.   524   F.2d  79,  92  (2d
 Cir.  1975).   An  in-depth discussion  of   a   reasonable  range   of
 alternatives   insures   that   the decisionmaker,  as well  as  the
 public, has before  it all reasonable  approaches   to  a   project.
 At  the  very least,  the  range  of  alternatives  should  be sufficient
 to  permit  a reasoned choice.    Brooks  v.   Coleman,  518  F.   2d
 17,  19  (9th Cir. 1975).

     The applicable  Council on  Environmental  Quality regulations
 also require  a "rigorous  exploration  and   objective   evaluation
 of   the  environmental   impacts   of   all reasonable alternative
 actions ....   In  each  case, the analysis  should be sufficiently
 detailed   to   reveal  the agency's comparative evaluation  of  the
 environmental  benefits,  costs,  and risks of  the proposed   action
 and  each  reasonable   alternative."   40 CFR  1500.8(a)(4).   "If
 the  environmental statement   fails   to   explain   the   basis   for
 its  range of  alternatives, or  why other reasonable  alternatives
 were not considered, then it  fails   to  meet  the   mandates   of
 NEPA."   State   of   California   v.   Bergland.  483 F.  Supp. 465,
 488  (D.C.  Cal. 1980).


DEIS Comments   Page  4


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    Despite this obligation for EPA to evaluate all
reasonable alternative sites, the agency has failed to adequately
explain its resurrection of  the  "Coburg  Hills  Site"  to  the
exclusion  of  other  previously  considered MVMC sites. EPA has
also failed to explain its failure to develop additional  alter-
native  sites  for consideration that have never been considered
by MWMC.  In short, EPA has not considered all reasonably avail-
able  alternative  sites for a proposed remote sludge management
facility in the DEIS.

    The net result is that the DEIS only proposes  three  alter-
native  remote  sludge  facility sites, with two of those sites,
"Site C" and "Prairie Road," only a "stone's  throw"  away  from
one another. Thus created is the situation where a single factor
might eliminate both of these  sites,  with  the  "Coburg  Hills
Site" being selected by default.

    For  example,  when  comparing  "Site  C"  with the "Prairie
Road Site" concerning the  "bird  strike"  issue,  the  FAA  has
stated  "obviously  there  would be no difference in that impact
between these two sites."  (Letter to William Pye of  MWMC  from
Robert  Brown  of  FAA,  February  20,  1981).  This possibility
of the "Coburg Hills Site" being selected not by reasoned choice,
but  by  default,  because  of a particular- problem with the two
other considered sites, illustrates the inadequacy of the  range
of alternative sites presented in the DEIS.

    EPA  has  also failed to consider all reasonable alternative
technologies in selecting the DEIS preferred alternative system.
For  instance,  EPA  has  failed  to consider "state of .the art"
on-site dewatering systems  such  as  the  JUD-CO  heated  screw
dryer.  (See  Exhibit  "E"  hereto).  Such technology is cabable
of reducing sludge water content as low as  5%.   The  resulting
dried  sludge  product  can be used for either energy production
or agricultural application. This technology is in  use  at  the
Terminal  Island  Sewage  Plant  in  the  Los Angelas area. Best
of all, utilization of such  technology  could  be  accomplished
on-site  at  the RTWP and eliminate the necessity for any remote
site facility.  Other  modern  technologies,  such  as  that  in
San  Diego  where  a  private  contractor  hauls sewage away for
incineration  at  its  plant,  have  also  not  been  adequately
addressed in the DEIS.
III.  EPA's PREFERRED SYSTEM IS BASED UPON UNKNOWN ASSUMPTIONS

         EPA's  selection  of  the  DEIS  preferred  alternative
system, where sludge is piped off-site  for  storage  in  winter
and  agricultural  application  in  summer,  is  based  upon the


DEIS Comments  Page 5

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inadequately studied assumption that there  will  be  sufficient
demand by farmers for sludge reuse through the year 2004.

    The  DEIS*  discussion of this issue, on page 46, is limited
to the following:

         (1)  an estimate that 2,050 acres of cropland will
         be needed annually to accomplish total reuse of the
         sludge by the year 2000;

         (2)  MWMC had 490 acres in its 1982 reuse program;

         (3)  Specific locations for actual reuse have not
         been identified; and

         (4)  4,500 acres that meet DEQ requirements for sludge
         reuse have been identified.

    Missing from this discussion  is  an  adequate  analysis  of
the  assumption  that  there  will  be willing farmers to accept
sludge for reuse through the year 2004, the end of the  planning
period.   Thus,  EPA's preferred system is dependent upon a con-
tinuous private market to accept the sludge,  yet  there  is  no
adequate  analysis of long-term agricultural interest in filling
this need.

    This is critical, because,  if  there  is  not  a  sustained
agricultural  demand  for  the  sludge,  then,  under  the  DEIS
preferred alternative system,   greatly  increased  use  of  the
Short  Mountain Landfill, as a backup depository, will be neces-
sary.  This  possibility  has  not  been  adequately  considered
in  EPA's  selection  of  its  preferred  system.  For instance,
sludge could accumulate beyond the capacity of the  FSLs  within
two years.  Under EPA's preferred system, this would then require
disposal at the  Short  Mountain  Landfill,  including  dispo.sal
during  the  wet winter months.  Such wet weather disposal could
result in  dangerous,  contaminated  runoff  from  the  landfill
site. (MWMC Sludge Management Plan, 1980, p. 9-18).

    Furthermore,  the  DEIS  has  failed to consider and discuss
the following situations identified  by  the  1980  MWMC  Sludge
Management  Plan,  at  page  5-21,  as  potentially . interrupting
market acceptance for sludge:

         (1)  Uncooperative relationship between the urban
         and  farming  communities,  stemming from an issue such
         as field burning.

         (2)  Crop damage attributable to sludge, or the rumor

DEIS Comments  Page 6


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         of such damage.

         (3)  Toxic spills in the sludge.

         (4)  Reaching application limits for heavy metals.

         (5)  Emergence of a better product.

         (6)  Change in DEQ or EPA regulations.

    These and other such forseeable occurances must be addressed
in the DEIS in selecting a  sludge  management  system  that  is
dependent upon agricultural reuse.  EPA's analysis must consider
the very real possibility of  a  severely  limited  agricultural
reuse  market  and  the  economic  and  environmental impacts of
virtually complete reliance on  year-round  landfilling  at  the
Short Mountain site.  It would be unreasonable for EPA to finance
the construction of a 5 or  7  mile  pipeline  and  remote  site
facility  without  virtual complete assurance from those farmers
who might reuse sludge that they  do,  in  fact,  intend  to  do
so.
IV.      THE ESTABLISHMENT OF ANY SEWAGE FACILITY AT THE "COBURG
         HILLS SITE" IS INCONSISTANT WITH STATE LAND USE LAW
    The  establishment  of  the  proposed remote sewage facility
at the "Coburg Hills Site"  would  be  inconsistant  with  state
and  local  land  use  law.  The DEIS's discussion of this issue
is inadequate, stating, at page 157, that "no definite conclusion
is  made  regarding  conformance  with  local and state land use
law and policy."   EPA's  endorsement  of  a  sludge  management
system  without  a comprehensive determination of the respective
legality of the alternative sites for that system is  irrational
and  illegal.   As the DEIS recognizes, at page 26, EPA is obli-
gated under 40 CFR 1506.2  to  identify  inconsistancies  of  an
action  with  state and local plans and laws.  This deficit must
be remedied in the Final EIS.  It is  illegal  and  unreasonable
for  EPA  to  endorse  a  sludge  management system which it has
not determined, at least to a reasonable  degree  of  certainty,
can be legally constructed.

    A land use analysis of the potential  establishment  of  the
proposed  sludge  management  facilities  at  the  "Coburg Hills
Site" follows and  indicates  that  no  such  establishment  can
be legally accomplished under state and local land use law.
DEIS Comments  Page 7
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     A.   The Establishment  of  a  Sludge  Management  Facility
         at  the  "Coburg  Hills  Site"  Would  Violate  the  State
         Agricultural  Lands Goal

     The  establishment   of the  proposed remote  sludge management
 facility at the "Coburg Hills Site" would   violate   State  Land
 Use  Goal  #3:   "To   preserve  and  maintain  agricultural  lands."
 This goal further  states that:

          Agricultural lands shall be preserved  and maintained
          for farm  use,  consistant with existant and future
          needs  for agricultural products, forest  and  open space.
          These   lands   shall  be inventoried   and  preserved by
          adopting  exclusive farm use zones pursuant to ORS
          Chapter 215.

 The  "Implementation"   section   of  the state Agricultural Lands
 Goal further declares:

          Non-farm  uses  permitted within farm use  zones under
          ORS 215.213(2)  and (3)  should be minimized to allow
          for maximum  agricultural productivity.

     The "Coburg Hills Site" is   currently  zoned  for  exclusive
 farm use and is slated  to also  receive this protective designa-
 tion in the impending   Lane  County Comprehensive  Plan.    Land
 within   an   exclusive   farm  use zone  "shall be used  exclusively
 for farm use except   as  otherwise  provided in  ORS  215.213."
 ORS  215.203.    The   Goal   2  Exception Process,  as described in
 OAR 660-04-000,  establishes how  land identified as  agricultural
 land may  be zoned for  other than  exclusive farm use.  OAR 660-
 05-010(5).   Thus,  any use  of  the "Coburg  Hills  Site" for  any
 sewage   management  facility,   notwithstading   the non-farm uses
 permissible under  ORS   215.213,  would require  an   "Exception"
 to   the  state   Agricultural  Lands Goal.  This necessity for an
 Exception to Goal  3 for  any  remote   facility  located   on  EFU
 land has  been recognized by a member of the  Lane  County Planning
 Department.   (MWMC  Advisory  Committee  Minutes,  February  11,
 1981, p.  6).

     Any  "Exception"  to   the   state Agricultural Lands Goal for
 the "Coburg Hills  Site"  would need  to  be supported  by "compel-
 ling reasons and facts," OAR  660-04-000, including an explanation
 why it  is "not  possible  to  apply the  Goal  to  the   particular
 properties   or   situations."   OAR  660-04-020(1).  This analysis
 would also  need  to include  consideration  of alternative   sites
 and  an  analysis  of  why  the  proposed use  cannot be located on
 non-resource land  that   would   not  require  an  exception.   OAR
 660-04-020(2)(b)(A)(i).    For   the  reasons  discussed above,  the
 DEIS1 restricted consideration of   alternative  sites certainly


DEIS Comments Page 8

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could not serve as the basis for an Exception to Goal 3.

    It is extremely doubtful that an Exception to the Agricultural
Lands Goal could be obtained so as to establish a sewage manage-
ment  facility at the "Coburg Hills Site."  Perhaps the greatest
reason for this is the reasonable and  MWMC  recommended  avail-
ability  of  "Site C," which is zoned for industrial use.  There
is no "Industrial Lands" or other state land use goal  requiring
an  Exception  to  establish  a  remote sewage facility at "Site
C."  Even if "Site C" were determined to be unfit for the proposed
remote  sewage  facility, a far more searching inquiry of alter-
native non-agricultural sites than that presented  in  the  DEIS
would  be  necessary  to  establish  the basis for any Exception
to the state Agricultural  Lands  Goal  for  the  "Coburg  Hills
Site."
    B.  The Establishment of a Sewage Management Facility
        at the "Coburg Hills Site" Would Violate the State
        Public Facilities and Services Lane Use Goal

    The establishment  of  any  sewage  Management  Facility  at
the  "Coburg  Hills Site" would also violate State Land Use Goal
#11:  "To plan and  develop  a  timely,  orderly  and  efficient
arrangement  of  public  facilities  and  services to serve as a
framework for urban and  rural  development."   This  goal  goes
on to state that:

         Urban and rural development shall be guided and
         supported by types and levels of urban and rural ,
         services approprite for, but limited to, the needs
         and requirements of the urban,  urbanizable  and  rural
         areas to be served.

    The Guidelines to this goal include:

         1.  Plans providing for public facilities and services
         should be coordinated with plans for designation of
         urban boundaries, urbanizable land, rural uses and for
         the transition of rural land to urban uses; and

         2.  Public facilities and services for rural areas
         should be provided at levels appropriate for rural
         use only and should not support urban uses.

    As is  further  discussed  below  concerning  the  excessive
costs  of  locating  any  sewage  facility  at the "Coburg Hills
Site" and the inconsistancy of doing so with  the  State  Energy
Conservation  and  Urbanization  Goals, the establishment of any


DEIS Comments  Page 9

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 Coburg Hills  facility  would  not  be  "timely,  orderly  and  efficient."
 The  fact  that  the  proposed  system  is  not  planned  for  implement-
 ation until 1989  is reason for EPA  to  take  a   patient  approach
 to  this   project to ensure  that the best  practicable  technology
 is implemented. This  goal   requires   that  any possibility   of
 centralizing  all  facilities  at the  RWTP must be probed  to  its
 limits.  The  "efficiency" of a system   which  first  centralizes
 all  sludge   for  treatment,  then pumps it  to a remote  site, then
 seeks to spread the sludge throughout   the  southern  Willamette
 Valley,  and  then  remotely  landfills  sludge not so  applied must
 be questioned.  There  is great danger  that MWMC's  rush to  secure
 state and  federal funding will result  not  in the required  "timely,
 orderly and   efficient"  public   facility,   but,   rather,  in  a
 "Conastoga Wagon" for  sludge management in the Eugene/Springfield
 area.


     C.  The Establishment of a Sewage  Management Facility
        at the  "Coburg Hills Site"  Would Violate the State
        Land  Use  Goal  of Energy  Conservation

     The  establishment  of   any   sewage facility  at the "Coburg
 Hills Site" would also violate state   Land  Use Goal  #13:   "To
 conserve energy."  This goal further states  that:

         Land and uses developed on land shall be  managed  and
         controlled so as to maximize  the  conservation of  all
         forms of energy, based  upon sound economic  principals.

     The  DEIS recognizes  that  establishment  of a remote  sewage
 management facility at the "Coburg  Hills  Site" would  be  most
 energy consumptive  (at page  170):

         If the Coburg Hills site were used, electrical  energy
         consumption would likely increase somewhat  because
         sludge would have to be pumped a  greater  distance
         from the RWTP.  ...   It  is  likely that  the  overall
         haul distance [to reuse sites]  would  be greater
         from Coburg Hills because  it  is not centrally located
         to the grass seed growing  areas of  the upper  Willamette
         Valley.

     Thus, in  the  case of the "Coburg Hills Site,"  as  the  force
 main would need to  be at least 2 miles longer  than that  required
 to  either "Site C"  or the "Prairie  Road Site," operating   energy
 consumption   would  greatest.  Because  of the additional  pipeline
 that would need to  be built  to the  "Coburg Hills   Site,"   energy .
 consumption   during  construction would also be greatest.  While
 such energy consumptiveneas  might   be   justified   to  bring   the
 sludge  closer  to   the  agricultural  application  areas, this is
DEIS Comments  Page 10
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not  the  case  with the "Coburg Hills Site."  This site is most
remote from not only the  RWTP,  but  also  from  the  potential
agricultural  sludge  reuse  areas.  To build such excess energy
consumptiveness into the MWMC  sludge  management  system  would
be a violation of State Land Use Goal #13.
    D.  The Establishment of a Sewage Treatment Facility
        at the "Coburg Hills Site" Would Violate the State
        "Urbanization" Land Use Goal
    The establishment of any sewage treatment  facility  at  the
"Coburg  Hills  Site"  would  also  violate  state Land Use Goal
#14, which provides in  part:  "Urban .growth  boundaries  shall
be  established  to  identify and separate urbanizable land from
rural land."  "Rural lands"  are  defined  to  be  "those  which
are  outside  the  urban  growth boundary and are: (a) Non-urban
agricultural, forest or open space lands  or,  (b)  Other  lands
suitable for sparce settlement, small farms or acreage homesites
with no or hardly any public services, and which are not suitable,
necessary  or  intended  for  urban  use."   A map outlining the
Eugene/Springfield  Metropolitant  Urban  Growth   Boundary   is
attached  hereto  as  Exhibit  "F".  In commenting on this urban
growth boundary, the 1982  Metro  Area  General  Plan,  at  page
1I-E-14,  states:  "The separation between urban and urbanizable
lands and rural lands formed by the urban growth boundary creates
a sharp distinction between ultimate urban uses and agricultural
uses on rural lands."

    The location of any sewage management facility at the "Coburg
Hills  Site"  would  breach  this  required  "sharp distinction"
by imposing upon an area that is unquestionably rural  an  urban
facility  so  massive in scale that it is larger than the neigh-
boring City of Coburg itself.  The imposition of such a  clearly
urban  use  far  beyond  the  metropolitan urban growth boundary
would, thus, violate state Land Use Goal #14.  This is especially
true  as  the  Coburg  rural  area  here potentially burdened by
this facility will not be directly  benefitted  by  it.  Neither
the  City  of  Coburg  nor  the Coburg Hills area is planned for
inclusion in the MWMC wastewater  management  system.   This  is
in  contrast  to  the  River  Road/Santa  Clara area, which lies
within the planned service area for the MWMC  sewage  management
system.   (1980  MWMC  Sludge  Management  Program,  pages  3-1;
3-10.
DEIS Comments  Page 11
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 V.   THE DEIS  INADEQUATELY  EVALUATES  AND  UNDERSTATES  THE  ENVIRONMENTAL
     AND ECONOMIC  IMPACTS UPON  THE  CITY OF  COBURG AND COBURG  HILLS  AREA


     The DEIS  inadequately  evaluates  and  understates  the  environ-
 mental  and   economic   impacts  of  the  proposed remote  sewage
 laggon/drying bed facility upon  the City  of   Coburg   and   the
 Coburg  Hills  area.    The  impacts   most  inadequately addressed
 in  the DEIS are the  potential  for   surface water   and  ground
 water  contamination   at   and  around the "Coburg Hills Site" and
 the visual/economic  impact that  development   of   the  massive
 sewage management facility would have on the Coburg  area economy.


     A.  The DEIS  Inadequately  Evaluates  and  Understates  Potential
         Surface and Ground Water Contamination  At and Around
         the "Coburg Hills  Site"


     The DEIS  fails   to adequately  evaluate and understates the
 potential  for  surface  water  and  ground  water contamination
 at   and around  the   "Coburg  Hills  Site."  A significant  reason
 for this is EPA's failure  to   perform any  analysis  whatsoever
 of  the specific soils  underlaying  this proposed site.  As  stated
 on  page 7  of  the  DEIS,  "subsurface conditions  at Coburg  Hills
 relatively unknown."   The DEIS, at  page 86,  more bluntly  states
 with regard to  the "Coburg Hills Site,"  "subsurface  soil  condi-
 tions  have   not   been  explored."  This  is of especially great
 concern because,  had EPA contacted the owner of proposed "Coburg
 Hills  Site," he  could  have informed the agency that  substantial
 amounts of gravel  exist   at  this   site.    This significantly
 increases  the risk of  contamination  of surrounding water supplies.

     The importance  of  such  missing   information  is magnified
 by  the DEIS1  recognition,  at   page  81,  that  groundwater  flow
 at   the "Coburg  Hills  Site" trends toward the City of Coburg.
 As  discussed  in the joint   resolution of  the   City  of  Coburg
 and  Coburg   Planning   Commission,   attached hereto  as Exhibit
 "C",  the City has recently had substantial problems  with contam-
 ination of its water  supply.  This  fact and the possible  incre-
 mental impact of  locating  the  remote sludge  management   facility
 at   the "Coburg  Hills Site"  is not even  discussed  in the DEIS.


     Additional  problems with the DEIS1 consideration  of  ground-
 water   contamination   include  EPA's  reliance on well  monitoring.
 Well  monitoring is not  documented  in the  DEIS  to   be  capable
 of   eliminating,  much  less reversing, groundwater contamination.
 The  DEIS also fails to  discuss  any contingency  plans   should
 ground  water   contamination   at the "Coburg Hills Site,"  or any
DEIS Comments  Page 12

                             A-80

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other site, be greater than anticipated.    This  is  especially
significant  in  the  case  of  the  "Coburg Hills Site" as cuts
of up to 7 feet will be required  to  provide  level  areas  for
drying  beds,  thus  "increasing the possibility of encountering
adverse soil conditions, such as a  permeable  sand  and  gravel
aquifer at shallow depths."  (DEIS, page 86).

    The  potential  contamination  of  surface  water sources by
the establishment of a sewage management facility at the "Coburg
Hills  Site"  is  also  significantly  understated.   The  first
potential source of such  contamination  is  from  the  proposed
seven mile long force main route.  As the DEIS recognizes:

         The force main route to the Coburg Hills Site
         crosses the Willamette Main Stem, the McKenzie
         River, and the upper portion of Muddy Creek.
         Due to the McKenzie's high water quality and
         use, any large spill that entered the river
         would significantly alter water quality.

The DEIS further recognizes  that  "[r]upture  or   leakage   of
the  sludge  supply  or  supernatant  return  pipes could result
in a significant impact  on  surface  water  quality,"  at  page
110,  and  that  the  force mains would be above ground at river
crossings, at page 134.

    Despite this recognition of the potential for  contamination
of  the  Willamette  Main  Stem, McKenzie River and Muddy Creek,
from either a low-level undetected leak  or  a  major  break  in
the  pipeline  to  the  proposed  "Coburg  Hills Site," the DEIS
fails to  adequately  assess  the  potential  environmental  and
economic  costs  of  such  direct  contamination.  For instance,
the DEIS fails to specify what the  economic  and  environmental
costs  would  be  of  a  major rupture proximate to the McKenzie
River.  Nor does the DEIS recognize the  possibility  that  such
a  rupture  could  be  caused by a vandal's single sludge-hammer
blow.  By running the force main,  exposed,  directly  over  the
Willamette  and  McKenzie  Rivers  and Muddy Creek, EPA would be
exposing not only those in the immediate vicinity of the "Coburg
Hills  Site" to contamination, but also untold numbers of people
and wildlife downstream to great risk.  Such  potential  impacts
must be fully analyzed in an environmental impact statement.

         Additionally,  although  recognizing  that  the highest
risk to surface water quality exists at the "Coburg Hills  Site"
due  to  the  presence  of  the Muddy Creek Floodplain, the DEIS
fails to assess at a  reasonable  level  of  detail  the  likely
impacts of contamination of the Muddy Creeks Irrigation Project.
Muddy Creeks Irrigation  Project  has  an  extensive  irrigation
network  that  irrigates approximately 6,000 acres.  The Project
DEIS Comments  Page 13

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 originates at Armitage Bridge on the McKenzie River  and   finally
 empties  into  the  Willamette  River  at Corvallis.  One of  the
 laterals to this Project is Daniels Creek, which runs immediately
 adjacent  to  the proposed "Coburg Hills Site."  The 102  members
 of  the Project grow a diverse variety of crops, many  for human
 consumption.   Despite  this,  the  health  and economic  impacts
 of  any significant contamination of the Muddy Creeks  Irrigation
 Project have not been addressed in the DEIS.
    B.  The DEIS Inadequately Evaluates and Understates the
        Visual and Economic Impacts of any Sewage Facility
        at the "Coburg Hills Site"

    The  DEIS  also  inadequately  evaluates and understates the
visual and economic impacts of any sewage facility at the "Coburg
Hills   Site"   upon   nearby   landowners,  businesses  in  the
Interstate 5/Van Duyn Road Interchange area,  and  the  City  of
Coburg itself.

    The  high  visibility  of  the  proposed "Coburg Hills Site"
from homes along Van Duyn  Road  is  shown  by  the  photographs
attached  hereto  as  Exhibit  "G".   In  failing to specify the
number of homes so impacted, the DEIS fails to recognize  recent
county  zoning  approval  for  a  cluster  subdivision along Van
Duyn Road to include an additional 30 homesites.  All  of  these
residences  will  be south of the proposed Coburg Hills facility
and, thus, directly subject to the odors emitted from the sewage
lagoon/drying bed complex.

    The  DEIS also fails to even consider the potential economic
impact of the proposed facility on businesses in the  Interstate
5/Van  Duyn  Road  Interchange  area  and  on the City of Coburg
itself.  As the DEIS states at page 171, "[t]he   Coburg   Hills
site  is  easily  visible  from Interstate 5."  Somehow, despite
this clear recognition, the DEIS absolutely ignores the economic
impacts  of  this  fact.  Drivers  heading south on Interstate 5
pass the proposed site, including  35  to  50  acres  of  sewage
lagoons  and air drying beds, approximately one-half mile before
the Van Duyn Road/Coburg exit.   It  is  certain  that  viewing,
and  quite  possibly  smelling,  such  a massive sewage facility
will directly affect the decisions of a  significant  percentage
of south-bound drivers as to whether or not to take this highway
exit.  The resulting impact on interchange and  downtown  Coburg
businesses  is  obvious,  yet  the  DEIS  does not even mention,
much less discuss and  analyze,  this  direct  economic  impact.
This is a major failing of the DEIS.  This potential for placing
a huge economic burden on the Coburg area  by  the  locating  of
a massive sewage lagoon/drying bed facility immediately adjacent
DEIS Comments  Page 14

                             A-82

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 to Interstate 5 cannot  be  ignored  by  EPA.

     Similarly,  the  City of   Coburg   itself   would   be   directly
 impacted  by  the   establishment of  the  proposed  facility  at  the
 "Coburg Hills Site."  There  would  not only   be  a  lessening   of
 interchange  traffic  through the city, and consequently  a  reduc-
 tion in downtown business, but  also   a   change  in   the  overall
 livability  arid attractiveness of  Coburg.   This impact,  though
 perhaps not readily quantifiable,  is   nonetheless  real.    Large
 truck  traffic   through downtown Coburg  during  both construction
 of the sewage facility  and as part of the  planned   agricultural
 reuse  program   would also undoubtedly result from  establishment
 of the proposed Coburg  Hills sewage  facility.  The   DEIS   cannot
 simply  ignore   or  superficially  mention these impacts. EPA  has
 an obligation to thoroughly  analyze   the social,   economic  and
 environmental  impacts   of   all alternatives  under its consid-
 eration.
 VI.   SUMMARY  AND  CONCLUSION
     The  DEIS  fails  to  consider  a  reasonable  range  of  both  system
 alternatives   and   alternative  sites   for   the  proposed  remote
 sewage  lagoon/drying bed   facility.     EPA's  selection  of   the
 preferred   alternative system  is   also   flawed   because  of  its
 undocumented  assumtion that  there will  be  a  continuous   market
 for   agricultural reuse of sludge.   The locating of the proposed
 remote  facility  at  the  "Coburg  Hills Site"  is inconsistent
 with state  and local land  use  law and,  for  this reason, would
 be illegal.  The DEIS   fails  to  adequately  address  potential
 surface  water   and  ground   water   contamination  and the costs
 of such  occurences.    Finally,   the DEIS   grossly   understates
 the   visual  and economic   impacts  of locating  the  proposed
 facility at the  "Coburg Hills Site."

     Once an initial agency   decision has  been  made,  such   as
 that to  implement MWMC's  and  EPA's preferred alternative system,
 there is a  tendancy for all  subsequent  investigation  and analysis
 to   tend justify   that  decision.   The   danger in this is that
 all  possibilities are  not  then  vigorously  explored.   The parties
 to   these Comments  urge EPA  to  thoroughly  investigate all  avail-
 able technologies for  the  MWMC  sludge management system, partic-
 ularly  those  technologies  that  can manage  Eugene and  Springfield's
 sludge  "on  site," without  unnecessarily   intruding   upon  lands
 and   people  not benefitted  by  the proposed  system.   It is only
 after such  a   comprehensive   inquiry has  identified  the  best
 practicable  technology  for  managing  Eugene and Springfield's
 waste that  any site for any  remote   MWMC   facility should  even
 be considered.


DEIS  Comments   Page  15

                              A-83

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      Should  that  consideration   become   necessary,   the remote
 site  should be located on non-exclusive farm   use   land,  unless
 impossible,  within  the  urban   growth   and   system  boundaries.
 It would only be appropriate  to consider   a   site   such  as  the
 "Coburg  Hills Site" for a MWMC facility  after  such a  comprehen-
 sive  analysis and  this  consideration  would   legally need  to
 include  the  consideration   of   numerous other  potential remote
 sites.  The DEIS, thus, prematurely  and   inadequately  considers
 the   "Coburg  Hills Site" for the  potential location  of the pro-
 posed  sludge  lagoon/drying  bed  facility.    Locating  such  a
 facility  at  this  site will be  firmly and continuously opposed
 unless and until all other reasonable possibilities are exhausted,
 as is required by the law.
                                Respectfully Submitted,
                                Jim Melamed
                                Attorney at Law
                                259 E. Fifth Avenue
                                Eugene, Oregon  97401
                                (503) 345-1456
DEIS Comments  Page 16
                            A-84

-------
 A  RESOLUTION  opposing the  location of a sewage -facility on the "Ceburg
 Hills  Site" as  proposed  by the  United States Environmental Protection
 Agency and  the  Metropolitan Wastewater Management Commission.

                                     V                '
 WHEREAS the City  o-f  Coburg Planning Commission and City Council finds
 that:                                                      •'..-..'

 1.  A-fter  public notice and hearing o-f the citizens of the City of
 Coburg,  there  is  substantial  and concerned opposition to the location
 o-f  a sewage facility on  the "Coburg Hills Site" and NO support
 •therefor  was  received.
        *

 2.  The City of  Coburg may  be  adversely affected both physically and
 economically  by the  potential location of & sewage sludge storage
 facility  near  the  City 
-------
 •facility  should not be within Coburg's  area  of  influence,  but rather
 within  the Wastewater Service District.

 Specifically,  the proposal:
 a)  has  not addressed Coburg's planning  process  in  terms of
 coordinating  the MUJMC's objectives and  programs with  those-of our
 local jurisdiction;
 b)  recommends  the growth of urban services from the Eugene/Springfield
 area  into Coburg's area of influence without  any benefit to Coburg's
 urban service  programs and plans;
 c)  thus suggests essentially unplanned  urban  growth within the Coburg
 area without adequately addressing the  issue  of local  livability;
 d)  has  inadequately addressed potential adverse affects to the
 preservation of scenic and natural resources  as well  as Coburg's
 ongoing program of highlighting historic heritage  goals; and
 e)  has given  inadequate consideration to the  compliance of this
 proposed  land use with Oregon's statewide goals and guidelines.


 5.  Loss of commercial appeal: Certain existing  businesses  and
 potential future businesses which contribute  tax revenues  to the City
 of  Coburg rely heavily upon freeway traffic for trade.  Anything that
 might jeopardize this trade and subsequent present and  future revenue
 to  the City and School District is of concern to the  Planning
 Commission and City Council. The acknowledged visual  impact  (per the
 EIS) from the freeway, as well as the unknown but  potentially serious
 odors caused by the sewrage operation, might have  an  adverse  influence
 on  the attractiveness of those businesses serving  the travelling
 public. This could have an adverse affect on both  the businesses-
 individually and the City.     •

 Specifically, the proposal  has inadequately addressed:
 a)  the probable adverse economic affects on Coburg businesses
 depending on the traveling public and hence on  job opportunities
 within the Coburg area;
 b>  the reletec! adverse affects on City revenues; and
 c)  potential  adverse affects on local  property  values.


 6. The plan  has further made inadequate assessment of potential
 problems  associated with:
 a>  increased mosquito and rodent populations; and
 b)  increased truck traffic in an already conjested Coburg  area both
 during construction of the facility and in sludge removal/dispersal.


 7. There has  been insufficient consideration given to alternative
 sites  end se-Jeoe  disposal  methods.



J.'Ol-v THEREFORE the City cf  Coburg Planning Corrrrsi  ss i on and City Counc i !
RES.OL'-'E AS FC'LLO-'S:
                          "C" - 2
                             A-86

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1. The proposed location of a sewage sludge storage facility  on  the
"Coburg Hills Site" by the United States Environmental  Protection
Agency and the Metropolitan Wastwater Management Commission  is hereby
strongly opposed.


2. The City of Coburg shall lend its name and support  to comments
being drafted by attorney Jim Me lamed,  in addition to  those made
above, in opposition to the establishment of any sewage facility at
the "Coburg Hills Site", as described in the Draft Environmental
Impact Statement to the Metropolitan Uastewater Management Commission
Sewage PI an.


This resolution was read once in full and once by title at the
December 1, 1983 joint meeting of the Coburg City Council and Planning
Commission whereupon it was put to a final vote. -
                                                    r

The vote of the City Council  was:

Yes: 6
No:  0
Abstention: 0

The vote of the Planning Commission was:

Ye=: 6                                         ''-...
No:  0                         •
Abstenti on: 0


SIGNED AND APPROVED this 2^   day of December,  1983.
C.W. Brought'on, Mayor
Tom R. Boi-.'erman,  Planning Commission Chair-man


ATTEST:
      Connor, City Feeorder


                          "C" - 3



                             A-8 7

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December 12, 1983
COUNTRYVIEW INVESTMENTS          '••:+
3324 Regent
Eugene, Oregon 97401
Mr. Richard R. Thiel, P.E.
Environmental Evaluation
U.S. Environmental Protection
    Agency
1200 6th Avenue
Seattle, WA  96101

Dear Mr. Thiel:

For the past year most of our effort has been towards
gaining approval for developing 250 acres for cluster
housing in the Coburg Hills area.  During all of the
numerous discussions and meetings there has been no
comment made with reguard to the. sludge location on
property adjacent to that under consideration for
development.  In October we finally received notice of
the proposed site.  By this time approval and the
plat had been completed.

We hereby register our objection to the Coburg Hills
site for the sludge since it is directly adjacent and
upwind to the approved 30 cluster home sites.  These
sites are ready for construction.

The Lane County Commissioner, Bill Rogers reported in
the first week in December that he had no knowledge of
the development site for the sludge in our area.

Any communication should be directed to us at the above
address and return communication will be handled through
our attorney Thomas Hoyt and the attorney representing
our zoning, Al Johnson.
Sincerely ,
Bob Meltebeke
President-Owner
                         A-88

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                                            December 14, 1983
Mrs. Young, EPA
I am much concerned about the planned placement of
Eugene's sewage sludge on Site "C" or Prairie Road sites
because of the danger of groundwater pollution from that
sewage into our well water supply and that for Junction
City wells.   I strongly urge you not to place that
toxic sewage on our water supply!
Ve have found no place where EPA or NWMC have any
protection provided for the people of this area for
either their water supply or their land being permanently
destroyed by the toxic effects of the sewage.
                                   Sincerely,
                                              DEC  U l..j
                                       S
                                       •>•  .
                            A-89

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 lane County Local Government Boundary Commissioni new city.     November 4,1983

 Ms. Nona Young -EPA  Region X, ret Eugene-Springfield-MWMC "Site C" Phase II EIS.

 U.S. EPA -.Local* efforts to have this area in Oregon become more than three tines the
    h*x*rJ>:-c.m national average from waterborne diseases, which Oregon is now said to be
              by Associate Health Professor William Andermsn, Oregon State University.

 U.S. G A 0 - The wasting of federal funds in consolidating two old treatment plants
              shortcomings to.beowimg concentrated in only one outfall of sewage wastes
              into the Willamette River, north of Eugene and outside its its UGB on land
              and into the only potable groundwater source for many rural households,and
              for Junction City.

 U.S. Department of Justice - The methods being employed to have trespasses be made against
                              STATE OF OREGON STATEWIDE COALS and the local METROPOLITAN
                              FLAN adopted by Eugene-Springfield-Lane County, both of
                              which include protecting the environment in those goals •
                              and plans.* »«
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                                                                    November *, 1963
LCLGBC, H Y, U.S. SPA, U.S. GAO, U.S. Dept. at Justice,  page 2i continuing 2, B , l),a),

      However, staff qualifies both tha 150 gped and the less than 100 gpcd as being
      "average".. This says that peak dry weather flows could be 300 gped or the later
      200 gpcd, respectively. Bfcge B-I-2 of staff's report says the Maxima dry weather
      day is 68 agd, and this 66 agd.divided by 293,700 population in year 2000 is
      231 gpcd for design year of the new plant. This is very conservative when HH-SC
      is figured for 266 gpcd and CH2M Hill figured. 265 gpcd. This essentially 25 gpcd
      would alter the design year peak flow against  the new plant by 9.38 mgd.
      b) Or, this 25 gpcd could be the additional infiltrations from leaking sewer lines.
3. The RR-SC Urban Facilities Flan Citisen Advisory Teaa (CAT) Meeting ainutes of
   September 27, 1983 have that The new plant is being built because the existing plants
   cannot aeet the increased hydraulic deaand caused by infiltration (This is substantiated
   by the Eugene old-plant builder having been reported as saying that the plant should
   have aore capacity at the time the old plant's problems started - several years ago.).*;
   and "House connections between the house and the right-of-way have 60-90$ of the leaks."
   A. Including the 1975 *tudy inforaation that Eugene had infiltration and inflow (I/I)
      of 1,000+ gpcd(and Springfield had 850+ gpcd of I/I'),and this say not have been
      known to~"the builder-engineer of the old Eugene plant, could account for the old
      plant not having treating capacity during winter rain and rainstorms. These are
      the tiaes when the old Eugene plant  was and does becoae overload, and during the
   .  cannery waste load in the late summer and fall.
   B. The present Eugene population of over 100,000, aultiplied by its I/I of 1,000+ gpcd,
      would have the old plant's capacity-being washed-out with 100,000,000 gd, which is
      additional to the. old plant's normal treating needs. Ne wonder the raw sewage is
      so extensively bypassed to the Willaaette River from Eugene's three bypass puap
      stations to the river.
   C. "The river elevation is the single sost important thing affecting our storm and
      sanitary sewers..." is credited to Mr. Allen, who was associated with the old
      Eugene plant. During moderately high river level,  even several feet below flood
      stage, the river backs up into the  outfall pipeline frem th»;plant.
      l) CH2M Hill oust have known this to have had a primary effluent pump station in
         the new plant plans, and the new plant's outfall pipeline has the same installed
         bottoa-of-outfall-pipeline elevation as the old plant's outfall line. The MHMC
         has ignored this singularly important fact because that primary effluent pump
         was removed from the plant plans.
         a) This is varified in the June 11, 1983 MWMC minutes, page 5» "Mr. Pye explained
            that CH2N Hill has submitted a proposal for design of increased capacity for
            the West Irwin Pump Station (built and in use since 1965) and force main.
            This system was impacted by raising the headworks of the (new) treatment
            facility when the primary effluent pump station was eliminated because of
            value engineering cost saving design recommendations." CH2M Hill would appear
       '     to have not been proposing the design "recommendations" for the elimination
            of the primary effluent pump station which.was included in its plans.
         b) Eliminating this primary effluent pump station from.the plant plans has been/
            is the largest influence in the new plant being not able to force effluent
            from the plant to the river when the river level restricts or stops the
            effluent from going to the river. This is a major "error".
         c) CH2M Kin's 1975 study gives Springfield's I/I, adjusted to 1980 - as is
            Eugene's I/I, at 850+ gpcd. Springfield has the population of approximately
            
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                                                                    November **, 1983
  LCLCBC, N T, U.S. EPA, U.S. CAO, U.S. D«pt. of Juatico, page 3« continuing 3.D.l)t

        Eugene's tost site K DC test site shows hlgeat sulfate La December,  as does its
        K VIII2 test site, but its K VIII test site shows highest oulfate in Kay.  These
        are wet season months.
     2) RH-SC test sits J IX shows highest sulfate in March. It is down-gradient from K X.
        RR-SC test site J VI shows highest sulfate in December, down-gradient from K VII.
        RR-SC test site H VII shows high sulfate in Kay and July, down-gradient fro* K X
        and J IX.
        RR-SC test site G VIII shows high sulfate in January and July,  down-gradient from
        K X, J IX and Eugene's trunk sewer line to the sewerage plant.
        RR-SC test site G VI shows high sulfate 'in April and July, down-gradient from
        the above listed test sites.
        RR-SC test site G V shows high aulfate in March and declining in May toward the
        sulfate reading of February, down-gradient from the foregoingly listed test sites.
        RR-SC test site F VII2 shows high sulfate in April and July, down-gradient from
        the foregoinuy listed test sites in the north-northwest aquifer flow.
        RR-SC test site F VIIuhcsa. hi^h sulfate in January and July.
        RR-SC test site EVIIlfchows high sulfate in June, down-gradient  from  the sewer plant.
        RR-SC test site E VII shows high sulfate in July,  *     *       *   »    *     *   .
        RR-SC test site E VI shows high sulfate in October and August,.down-gradient in
        the main aquifer flow channel.
        RR-SC test site D VIII shows high sulfate in June, down-gradient from the  old plant.
        RR-SC test site D VH shows high sulfate in November and May.
        RR-SC test site D VIoshows high sulfate in April and Kay.
        RR-SC test site D VIg shows high sulfate in January and Hay.
        RR-SC test site D VI shows high sulfate in Kay.
        RR-SC test site D IV shows high sulfate in November and June.
        RR-SC test site C VIII shows high sulfate in November and July.
        RR-SC test site C VII shows high sulfate in November and July.
        RR-SC test site C Vl£ shows high sulfate in January and March.
        RR-SC test site C VI shows high sulfate in October, November and July.
        RR-SC test site C V shows high sulfate in October and Kay.
        RR-SC test site C IV shows high sulfate in November and July.
        RR-SC test site C IV£ shows high sulfate in January and Hay - a surface site.
        RR-SC test sits C III2 shows high sulfate in March - a surface  site.
        RR-SC test site C II shows high sulfate in November.
        RR-SC test site C I shows high sulfate in November. The location is  Just east of
        the airport.
        RR-SC test site B VII2 and B VH show high sulfate in January and May.
        RR-SC test site B VI  and B VI show high sulfate in October, May and July.
        RR-SC test site B V shows high sulfate in February.
        RR-SC test site B IV shows high sulfate in October, November and June.
        RR-SC test site B I shows high sulfate in November and Kay.
        RR-SC test site A IV shows high sulfate for every month tested, except August. It
        is close to a cow barn.
        RR-SC test site A III shows high sulfate in November.
        RR-SC test site A l£ shows high sulfate in November and May.
     3) The above listed surges or crests of sulfate flow  through and  via the aquifer
        channels flows do indicate two and some areas three surges or crests during the
        one year test, with monthly readings/testings. - when they VERB tested. The crests
        do indicate two to three sources of sulfate. The B IV test site is in the  aquifer
        channel which has the highest changes in water level between the wet and dry
        seasons. It is also in the north-northwest flow pattern of the  aquifer. This does
        indicate the sulfate is from RR-SC AND EUGENE'S leaking sewer lines.
     
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                                                                     November 4,  1983
LCLGBC, N Y, U.S. EPA. U.S. CAO, U.S. Dept. of Justice, page 4, continuing 4. A

      Obviously, the installed septic tanks are the more environmentally acceptable
      alternative to the conventional and leaking of raw sewage sewer systems, which
      Eugene's system definitely does do, as does Springfield's sewer system.
5. The Eugene-Springfield-MWMC has provided a new plant with doubtful treating abilities
   and aore doubtful peak hydraulic flow capacity.
   A. RR-SC is "planned" to be sewered with a peak hydraulic flow of 12 ngd.  RR-SC now
      has approximately 25,000 residents; it is "planned" to have 80 percent  increase in
      sewered population by year 2000. Its year 2000 is then approximately ^5,000, as
      part of the total metropolitan area sewered population of new growth of 1^7,500.
      RR-SC is then 1 (one) part of its ratio to'the total "planned" growth of 3.16 times
      the total RR-SC year 2000 population. RR-SC peak hydraulic flow of 12 mgd,  when
      multiplied by 3.16, should provide the peak hydraulic load increase against the
      new plant at of 37.92 ngd.
      l) However, the new plant's peak hydraulic flow capacity is said by a Eugene
         Public Works employee, the same one who is on record pertaining to the extensive
         infiltration of house to right-of-way sewer pipelines and who appears to be
         substantially correct in that the plant is being built for the purpose to allow
         for such extensive infiltrations, to be 153 ogd. And, the new plant  is to need
         191 ngd peak hydraulic capacity by year 2000. 191 mgd minus 153 »gd  is 38 mgd.
         a) The new plant being short 38 mgd for a peak hydraulic load increase of 37.92
            mgd says that the growth since the plant was engineered at 153 mgd to-date
            should be into overload against the new plant, even before it goes on-line.
         b) The increasing infiltrations fron the further deteriorating now installed
            swer lines fron the house to street right-of-way should also further  overload
            the plant's peak hydraulic capacity.
         c) The INSTANT peak flows from rainstorms should also further overload this  new
            plant's peak hydraulic capacity. This may have been the considered factor
            which has prompted the installation of a diffuser at the Willakenzie  pump
            station, at the end of the East Bank Interceptor which transports -or it  is
            supposed to transport all of Springfield's sewage to this pump station. The
            diffuser spreads the raw sewage bypasses for dilution in the river, just  as
            the plant's outfall line diffuser will do.
            The cost of this bypass diffuser and the fact in its being placed at  all  does
            create the impression in which bypassing of raw or primary trated sewage  is
            anticipated to be much more regularly utilized than MWMC's spokespersons  are
            admitting. This indicates no-growth in all areas now sewered.
6. The October 1983 EPA Region X EIS,pertaining to the MWHC's Phase II sludge handling,
   discusses four options. The option/alternative 3 has the least environmental impacts.
   This alternative 3 is the same Phase I sludge handling which has been forced upon  the
   MWMC with the delay caused by the need for the ELS.
   A. The persons involved in promoting this EIS appear to have protection of their
      environment in mind and actions, while the HVMC did not have environmental  protection
      in mind when considering that MWMC is already on record as believing the Phase  II
      Site C is OK with which to proceed. Site C is the more environmentally  susceptable
      of the four alternatives. Hopefully, EPA Region X will make its dissatisfaction
      with such an erroneous conclusion become known to HVMC in the immediate future.
      l) The Phase I sludge handling equipment is understood to be moved to the Site  C
         location, if MWMC is allowed to misuse that site. The misuse of Site C seems to
         include extra costs of land and utilities service which are now available on the
         plant-site. These extra expenses are considered to be the costs required by
         MWMC to have MWMC be in position to further assault our environment. If  DEQ  and
         EPA allow and fund this further fiasco against our environment, both should  be
         rendered asunder or would deleting both agencies be sufficient? Not sufficient!
      2) This EIS also has that continuing Phase I through the design; year =2000 would
         cause "..., the RWPT (new plant) wastewater treatment, sludge thickening, and
         digestion capacity would also have to be expanded." This is translated to mean
         that the new plant is net now even built to do the job of treating and peak
         hydraulic flow capacity,being dispensed to the public as being now in place.
         This translates to Site C and/or any other site being environmentally assaulted,
         other than on-site. Soil and water conservation has not yet included that farm
         land would be taken out of production and off the county tax rolls.
         a) Any off-site move would cause the county residents, who are not receiving
            "benefits" from MWMC's fiasco,   to  be in the position of involuntarily
            supporting the Eugene-Springfield-MWMC sewering complex/ tKe F«'vrco.
         b) MAC minutes for March 1981 contain the statement that the dewatering  at the
            plant would have been necessary to decide before June 1978. Now,  here is  the
            Phase I intended to do the dewatering at the new plant-site. Some THINGS  do
            NOT compare well. This is the condition which seems to dominate this  plant
            project.
         c) This condition also appears to be operant to the Terry Street force main
            extension to the new plant. This force main is not needed; the existing-
            since-1965 Vest Irwin pump station and force main, while the pump is  straight-
            line more than 50 percent worn out, is pumping more than 16 mgd.             a
                                                                                         ~

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                                                                        November b, 1983
       LCICBC,  N Y, U.S. EPA, U.S. CAO. U.S. DEFT, of JUSTICE, page 5. continuing 6. 2 . c)»

                  This existing force main is capable in transporting approximately .33 agd.
                  All which is needed is to nave the new puapa and the rebuilt pumps have...
                  the saae scalier  solids-clearance than the old pump(s) had and protect
                  them with a screen snail enough in aesh to prevent oversize solids froa
                  getting into the  pumps(s). This would offset the error  in the higher
                  headworks.. Logical,   reasoning provides the conclusion that CH2M Hill
                  had this type of  solution for avoiding the costs for the Terry Street
                  force rain. After all, the total aaount of sevage to be transported to
                  the plant is 25 mgd, not 33 *-«d» from the west Eugene sewer project.
                d) This EIS has on page 8 that Site C would take 125 acres of agricultural
                  land from use. The Register-Guard's October 28, 1983 page 15C article has
                  that "...The commission (KWMC) adoped a resolution designating an additional
                  125 acres south and west of 'Site C' as a potential location for the sludge
                  disposal facility." This "additional" land uore than doubles the lo.-.s from
                  agriculture which the EIS considers necessary, ar.d this r.ora southern l~nd
                  is closer to the  families who have been ItMers in opposing M'.-.'HC's locating
                  any facility for  sewage over their only water supply source.
                e) No logical reason exists to have permanent (ll more years) facilities be
                  built on-site, when "temporary (5 years)"facilities on-site has  been so
                  environmentally the least objectionable. Use the old plant remaining components
                  for storage over  the winteri those remaining components could have been used
                  for the seasonal  wastes processing and avoided the potential misuse of Site
                  A-l for industrial toxics. The cannery waste single-line, not the required
                  dual-line which was NOT installed, has large cylindrical components along
                  that line which look as though they could be used as Junction boxes for
                  later connections from the industries which are in the area west of the line
                  now, and more could be connected further north.
                f) Using the old plant would have saved all of the funds wasted on Site A-l,
                  which was not cost-effective, compared to overland flow, when it was built.

          CH2M Hill was supposed to  be the primary engineering firm for the sewer plant project.
       It has in the  208 Plan that land application of sewage sludge is too expensive and
       should not be  considered further. Its admonition has not been utilized; this helps to
       explain how the old Eugene sewer plant's problems have been so exorbitantly costly to
       have continued in this new plant. Economic growth would have depended upon reliable
       sewer service  all year around, and not having this is saying that no economic growth
       can occur and  abide by state  and federal requirements, when they are enforced.      '•.
          Sewering HR-SC to this total mesa would assure no economic growth in this whole
       metropolitan area. If RR-SC is not required to sewer to this new plant, its becoming a
       new city will  give it the necessary chance to investigate and select alternatives which
       could lead to  one area, at least, being able to attract economic growth. The Judco dryer
       is able to dry sewage and septage sludge. Connecting it to the O'Connor solid waste
       burner and converting the solid wastes and sewage/septage sludge to heat exchange gain,
       with steam turning turbines to power electric generators and the hot water condensate
       heating homes  and greenhouses, would provide the cost-efficiencies necessary to attract
       more economic  growth.
          As was said by Mr. Jake Jacobaon at the meeting last night, the new city of Santa
       Clara could not do worse than Eugene is doing. Perhaps better understanding of his
       references would be of value  toward making correct allowance to have the incorporation
       process proceed.
       1. Eugene charges three separate times on land square footage charges for storm and sewer
          system. Three times on development charges, which are for square footage of the total
          floor area  and the square  footage of the eapermeable-to-downward-penetration-of-water
          surf acesi normally, the thought would occur that the floor area of the improvement
          charge would be sufficient, but the roof over the improvement-also may be considered
          as being an impermeable surface, as would be the parking lot, sidewalks, etc. The
          funny-damn  in all of these charges is that they are listed in Eugene Code as user
          charges, while the usual county property taxes are considered as "user" charges, which
          are also still charged against the land and improvement(s).
       2. Where, -outside Russia and  such "backward countries",would the chairman of a boundary
          commission  be challenge^for ex parte contact with neighbors,who did not even know
          that he is  a commisioner,  on a subject of such import to all persons in the area being
          considered  to fora the new city of Santa Clara, where this commissioner lives?
          A. This was travestied by  a boundary commission staff member, who is hired on contract
             for commission work from the Lane Council of Governments, which includes Eugene
             and Springfield. This appears to have the Eugene and Springfield members of the
             boundary commission to  also be challenged.
             l) All of those members and staff, who live in Eugene or Springfield,also stand to
                become relieved of part of the new sewerage plant's costs, if the incorporation
                petition is denied,  thus leaving the area subject to being annexed to Eugene
                and have to pay approximately $1,500 per householdjfox the plant costs, plus a
                sewer system cost of $3,900 to $10,000 for a sewer system,to save them $200.
       John C. Neely. Jr. - 1600 Horn Lane - 97*K*
A-94

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                                                              for December 6, 1983

SPA meeting in the Springfield City Hall,
Re: Metropolitan Wastewater Management Commission's (MWMC's) Phase II Sludge
    Management Plan's Environmental Impact Statement (EIS).

   Page 5 of this EIS on Phase II of MWKC's Sludge Management Plan has, "EPA could
offer funds for ... some combination of processing and reuse/disposal methods not
considered in a single alternative described in the EIS or Sludge Management Program.
Although this is unlikely, it could be done for environmental or econmic reasons."
If this is not double-speak, EPA is saying the likelihood of such alternative(s)
would be substantially increased when environmental AND economic reasons are
correlated.
   This correlation exists via combining the O'Connor solid waste burner with the
Judco Dryer. O'Connor's solid waste burner is structured to utilize the heat from
burning solid wastes to heat water to steam, which is then available to turn a
generator for production of electricity or perform other work from heat exchange for
economic gain. The ash from the burning should also provide for recovery of the heavy
metals which are in the sewage sludge. This would avoid their hazarding the land and.
aquifer potable water supplies under that land.
   This process is most economic for local bonds payers and federal taxpayers. It
will also serve to protect the environment. Mr. Jud Buttner and Mr. O'Connor are
teaming their expertise and inventions for the purposes in attaining the environmental
AND economic recovery of resources. These two engineers are directly and indirectly
assembling the solution to many of EPA's present and future impasses in environmental
protection with providing this process for utility economically. All which is needed
is to have the EPA burn its biases, which produces open-mindedness, before starting
to study this correlated mechanical combination.
   Mr. Buttner has said that EPA is relaxing its public domain requirement. This is
a late correction, but it is better than no correction. EPA Region X should also
make every effort to obtain their new, correlated brochure when it becomes available,
which is expected to be soon. Study it, see the record of low particulates, non—wear
and reliable performace characteristics, then invest a few thousands of dollars to
save many millions of dollars and save our environment for US.
   This mechanical combination, which was portable as just the Judco Dryer and could
be portable in a smaller combination, could be put to work at any solid waste dump
site, such as Short Mountain, for its initial testing and performance verification.
While it is there, process the whole mountain of landfilled solid wastes.
   All thinking persons are able to associate the fact that this process will
displace need for the very expensive sand filtration, which was removed from this
activated sludge process plant's plans because it does not retain heavy metals and
toxic chemicals. These can now be recovered from the ash residue, those which have
not recombined to non-harmful substances via pyrolysis and incineration.
   Incineration is an end-product of pyrolysis: chemical decomposition or other
chemical change brought about by the action of heat regardless of the temperature
involved. Pyrolysis and incineration are both listed in this EIS's page 3-5's chart
for Base Sludge Utilization/Disposal Options as being acceptable as base alternative
components.
   These two engineering specialists are innovative, so the funding for this machine
they are combining for utilization of wastes should be at the extra 10 percent for
innovative and alternative technology. It is an excellent solution to present and
anticipated trespasses against our economy and our environment.
   Kr. Buttner and Mr. O'Connor are congratulated for their expertise and their
cooperation producing the solution for protecting our environment and our economics.
   Naturally, their solution eradicates need for any further grants for application
to land and, because the soils in this area are not sufficiently acid to hold the
pathogens nor sufficiently alkaline to hold the heavy metals or toxic chemicals from
sewage sludge in the soil mantle, penetrating laterally and vertically to polluting
the potable aquifers. This means that Site C, Prairie Road site, Coburg site are not
necessary to become contaminated.
                                     £\~~ .7 J

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                                   for EPA's meeting, MWMC EIS. 12/6/83. page 2

    This perspective definitely does  recommend  continuing Alternative  3  until the
 Judco Dryer and O'Connor solid waste burner is installed and  becomes  operational
 AT THE PLANT SITE to then obviate need  of any  further grants  from EPA,  from the
 federal taxpayers money. Eugene's and Springfield's MWMC has  sufficient bond funds
 remaining to install this unit, rather  than dissipate more funds  to further attack
 the land, the aquifers and the peoples'  environment.
    EPA could withdraw its funding of the Terry Street force main  project beyond its
 extension to and connect into the pressure side of the  existing West  Irwin force
 main as a funding source for installing the Judco Dryer and O'Connor  solid waste
 burner on the new plant site. Page A-3  has in  paragraph three that, "NPDES permits
 for wastewater treatment plants include sludge disposal conditions where possible,..."
 This is possible, and Alternative 3  should be  continued until this becomes reality.
    Funding the Terry Street force main  beyond  tying into the  existing West Irwin
 force main appears to be extraneous  because the repair  of the West Irwin pumps, which
 are straight-line now worn more than 50 percent, and the new  pumps could also  be  with
 the next size smaller solids-clearance  with smaller mesh grids ahead  of them to stop
 solids larger than will clear the solids-clearance, are pumping more  than  16 mgd  in
 this condition. One hundred-percent-function pumps of the smaller solids-clearance
 would be expected to move more than  33  rogd through the  existing force main even with
 the fifteen-foot more pressure head  from the elevated plant headworks.  Only 25 mgd
 is planned to be needing transport to the year 2000, leaving  approximately 7»5 to 8
 mgd reserve capacity even under the  most optimistic anticipated growth.
    The comparison for the existing West Irwin  force main's 30-inch diameter being able
 to transport 25 to 33 mgd is in the  East Bank  Interceptor's 103 mgd engineered to go
 through the Willakenzie pump station 5t*~inch force main to the new plant and its  15-
 foot higher headworks. The blue MWMC pamphlet  just  received  in the mail says  that,
"The objective of the improvements (West Irwin  Pump Station) is to increase pumping
 capacity." MWMC-Eugene appear to be  using the  more expensive  means to do the job.
    The pumping capacity increase will be accomplished with reducing the rebuilt and
 new pumps to the smaller solids clearance than was used for the transport  of sewage
 to the old Eugene plant. The West Irwin force  main's 30-inch  diameter pipeline has
 the cross-sectional area/25 mgd of 28.*f to the EBI's Willakenzie  force  main's  5^f-inch
 diameter pipeline cross-sectional area/103 mgd of 22.2, which indicates that the  West
 Irwin force main, now in use,will transport 25 mgd with less  friction-loss than would
 be active when the Willakenzie force-main-to-the-new-plant is transporting 103 ragd.
 Keep in mind that the 5^-inch diameter  Willakenzie force-main has an  additional 14-
 to-l6 years more engineering experience-level  for design capacity than  had the West
 Irwin force-main.
    This engineering experience-level-more also indicates the  new  plant's original
 plans were more accurate for the job than would the plant be  after it had  several of
 its components removed. This EIS's page 139, paragraph  3 has  that Facultative  Sludge
 Lagoons (FSLs) function as secondary digesters. The two secondary clarifiers,  which
 were removed from the plant's original  plans,  could have been utilized  as  secondary
 digesters on-site, rather than having to have  the extra costs and environmental
 hazards involved in having to go off-site to construct  FSLs/  secondary  digesters.
    Obviously, the EPA has accomplished  a commendable job with its EIS showing  that   '
 Alternative 3 has the least environmental impacts and it must be  utilized  to fulfill
 the requirements for which the local and federal funds  were intended  to accomplish -
 protect the environment. However, at the 7 to  8 AM MWMC Advisory  Committee (MAC)
 meeting, just yesterday, the majority of members present did  vote to  recommend that
 Site C be recommended to EPA. Those  persons voting for  this have  transgressed!
 1. The EIS page 132's "All reasonable attempts should be made to  avoid  any additional
    nitrate and bacterial contamination  of the  groundwater and to  control existing
    sources of contamination if groundwater is  going to  be a continuing  source  of
    drinking water for residents in this area." The groundwater definitely  is to be
    the ONLY continuing source of drinking water for residents in  this area and in any
    other off-site area.
 2. The EIS page 133's "The drying process tends to concentrate nonvolatile substances
    in a given volume of sludge, including heavy metals  and some toxic organics."
                                      A-96

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                                 for EPA's meeting, MWMC EIS, 12/6/83, page 3

   When considering the bar graph Industrial Flow (MGD) CONCENTRATION INCREASE to
PRESENT FLOW of the eleven listed toxics on this page, which accompanied the MAC
minutes for April 15, 1981, and to the estimated domestic flow dilution, this off-
site drying process would compound those toxic pollutants concentration by the same
ratio as that of the removal of moisture, which then pricipitates environmental
hazard increase against that sole source drinking water supply.  And:
"More serious health threats to these water supply wells would come from flooded
septic systems and leaky sewers that contain raw sewage." Septic tank systems do
NOT emit raw sewage because they are air and water tight. The septic system's
effluent is treated anaerobically and, according to the July 1982 North Carolina
Septage Study, there is considerable doubt that septic systems emit sufficient
organisms to cause disease conditions. This is in sharp contrast to this study's
conclusion as it pertains to the activated sludge process, which is that activated
sludge process does create endemic to epidemic disease conditions when this sludge
is land applied.
   This EPA EIS does substantiate this study's conclusion. Yet, the MWMC majority
of MAC-person representatives present at yesterday morning's meeting have indicated
extensive disregard for their down-gradient neighbors' continuing good health. This
also applies to Eugene not repairing its leaking sewer lines, of which the house to
street right-of-way sewer pipelines infiltrate "60 to 90# of the leaks" and which
are considered to be not cost-effective to repair. They are in the highest pipelines
of the gravity flow sewer systems, so they only infiltrate during the rainy and high
groundwater seasons. They exfiltrate raw sewage during the dry and low groundwater
seasons. Therefore, these exfiltrating sewer lines non-repair are causing "More
serious health threats to these water supply wells..." This ongoing and can-only-
worsen situation is to be compounded with land application of sludge from an activated
sludge process plant.
   To what extent are the majority persons in the agencies and other promoting of
environmental hazards placements organizations liable as accessor!es-after-the-fact
when violence by the persons being hazarded results in injury or death to any of
those hazards placements promoting persons? In the past, many deaths have occurred
over disputes which pertain to water. When a sole-source potable water supply is to
be threatened, whose life or health is hazarded becomes a factor to be considered in
all decisions adversely affecting that water supply. The federal funds are meant to
reduce this additional hazard, not increase it.
   EPA's funding only the Alternative 3, until the Judco Dryer and the O'Connor solid
waste burner combination is installed and operational, will certainly reduce the
potentials in adverse reaction potentials which could accompany funding any of the
off-site locations being considered in this EIS.
   Those of us who are active in this process of selection, and who live in this
River Road area where the new plant is located, did not want to have this new plant
be located in our residential area. However, now that the new plant IS in our area,
the general consensus is to have the "... wastewater treatment plants include sludge
disposal conditions where possible,..." This is possible; it is even probable. The
complimentary result will be the numerous residents surrounding this plant-site area
will be the ones who are in the most advantageous position to assure that the plant's
performance potentials are fulfilled,and that its pollutants are not hazarding our  f
down-gradient neighbors' sole supply of potable water.
   Even Eugene's residents, since the plant site has been recently annexed, will also
help assure the environmental factors are fulfilled. This is the primary function for
which local and federal funding were intended by U.S. Public Laws 92-500 and 95-217.
The-chicken-will have-come-home-to-roost when the EPA only funds the Alternative 3
and the Judco Dryer and O'Connor combination, all AT THE PLANT SITE.
   EPA may contact MR. Jud Buttner at (503) 7*4-7-3315. His mailing address is 40303
Deerhorn Road, Springfield, Oregon 97^77 for his soon-to-be-delivered new brochure
pertaining to details on these two engineers combined efforts to help solve the
ongoing and worsening pollution problems which hazard more and more now healthy
people.
                                     A-97
   John C. Neely, Jr.
                       - l600 Horn ^ne ~ 2ugene, OR

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      Ms. Ernesta Barnes,                                               December 7. 1983
      Administrator,
      Ms. Norma Young,
      BIS Coordinator,
      Mr. Thiel,
      Hearings Chair, Draft SIS  on MUMC's Sludge Management, last night.
      1200  Sixth Avenue
      Seattle, Washington 93101

      Res M/S 443

         Last night's hearing's  Bart One went as-usual, its Part Two's public testimony
      is ALL in opposition to off -site  sewage sludge handling - placing - treatmenti the
      only  ones favoring flinging-»the~"M8tuffw-over-the-»fence were the 6a«* Tgje/^aj^pear
      to be trying  to convert a  "bed pan" to a  "potty-with-bail-for-flinging1*. Part Three,
      quest!on-suggestion-answar period, developed more questions than for which answers,
      satisfactory  ones, were provided. Some answers provided were not satisfacory nor
      accurate.
         One question asked was  related to the  rate of groundwater flow in the Site C-
      Prairie Road  Site. The  answer given by Brown and Caldwell's representative was
      200 feet per  year. This answer by him appears to be based in some relationship to
      nitrates-plume flow in  the general River  Road/Santa Clara area from Sweet's reports.
      Using or misusing  the 1978-1979 RR/SC Groundwater Study's nitrates-plume flow is one
      more  of the major  errors being employed to arrive at very faulty conclusions. This
      study's Raw Data sheets,':the information  in them being the basis upon which Sweet's
      reports should have been based -  as well  as that of B ft C's representative, provide
      extensive contrast information.
         Sweet's RR/SC Groundwater Final Evaluation's Plate B map of test sites  locations,
      having the scale of 1,000  feet equal 7/32s of one-inch, were transferred to a map
      of the general area which  has the scale of one mile equals 1 5/8s inches.  The Raw
      Data  shows aulfate as one  of the  other-than-nitrate components of the groundwater
      for which quality  numbers  are provided. Sulfate is integral in the groundwater with
      nitrate. However,  sulfate  speed of migration with the groundwater flow definitely
      does  disclose a much faster groundwater rate of flow than does nitrate-rate-of-flow.
         From Eugene-area K, X test-well-to*RRt»-* IX test well is 3A-inch, which is 6/8ths-
      inch  or 6 x 5,280-ft/13(8ths-inch), or 6  x 406.1-feet, or 2,436.6-feet. Sulfate did
      travel this distance, from its high reading in August £a- dry month) from K X to J IX's
      high  sulfate  reading in April (a  wet month; in approximately 6 months, or  sulfate did
      travel in the groundwater  for a distance  of approximately 4,873 feet in one year.
      However, only one  sulfate  reading is listed in the Raw Data for the whole  year of
      testing (only two  readings for nitrate for J IX are listed for the whole year of
      testing - for excuses said on its test sheet, which are extraneous to this point),
      so iroa EugeneBs K X test  well to Eugene's K VUI2 test well is 5/8ths-inch on this
      same  general  area  map.  Sulfate moved from August at K X to December at K VIII2 high
      reading a distance of 2,030.5 feet in four months, or approximately 6,061  feet in
      one year, or  more  than  one mile.
         Obviously, the  groundwater flow is much more than 200 feet in one year. This does
      cause the question of why  does nitrate-plume only move 200 feet in one year?*and why
      is there a nitrate-nplume" at all? This DEIS says in several references that nitrate
      moves freely  with  the groundwater flow. However, the nitrates in this groundwater
      test  do not move-freely-with-the-groundwater-flow, or so the Sweet Reports indicate.
      The accurate  answer for both questions reason to be based in the fact that the July
      1982  North Carolina Septage Study, which  is conspicuous by ITS ABSENCE from the list
      of references stated for this DEIS, says  that heavy metals are not retained in the
      soil, mantle  when  the soil mantle's pH is 6.5 or less, which says that heavy metals
      are held in the soil mantle when  pH is greater than 6.5. And other studies show that
      sands hold heavy metals and toxic organics.
         This DEIS  shows that the groundwater is more alkaline than 6.5 pH, and  core samples
      show  gravel and sand to be in the groundwater aquifer channels. This DEIS  also shows
      that  heavy metals  and toxic organics remain with the nitrates in the sewage sludge.
      So, the grondwater aquifer channels' sand  and higher-than-6.5-pH are retarding nitrate
      movement to 200 feet per year, which forms the ^plume" and says that heavy metals are
A- 98 in tn* groundwater, which  question is theni what is the source of the heavy metals?

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                                             Ms.  Young.  EPA'a DEIS,  MWMC,  12/7/83,
                                                                           Page 2
   The answer is, again/ obvious. The fact in the choice in the Raw Data being the
nitrate precipitate method with cadmium, and the cadmium precipitate method then
producing higher nitrate readings of 5.5 percent to 100 percent more than has been
produced with the alternate and comparable method for establishing nitrate in water,
definitely proclaims and establishes that cadmium was in the groundwater AT THE TIME
OF TESTING. When both test methods were used on the same well or test site on the
same date, the obvious answer is that both tests were made from the same sample of
water from that test well or site.
   Domestic sewage does not contain measurable amounts of cadmium. Industrial wastes
do have measurable quantities of cadmium. Cadmium is in the urban industrial sewage
wastes in Eugene, together with ten other known toxics of concern. This says that all
eleven of these tested-for-in-the-sewage-from-Eugene are in this domestic on-site
system groundwater, because these toxics are from the sewer lines exfiltration places
in the dry and low groundwater level as are the infiltration places in the sewer lines
during the rainy and high groundwater seasons. The fact in the September 27, 1983
River Road/Santa Clara Urban Facilities Plant Citizen Advisory Team (CAT) minutes
saying that the new plant is being built because the two old sewerage plants do not
have peak hydraulic flow capacity for all of the infiltration and inflow,*and that
60--£-90# of the I/I is from the toilets, and the* other normal inlets of waste to the
sewer system - such as industrial toxics and heavy metals, to the street right-of-
way do establish that domestic sewage - raw - and toxic industrial wastes migrate
into the RR/SC groundwater. The sands in the aquifer channels and the groundwater
pH being more than 6.5 then hold the heavy-metals-laden nitrates and have formed the
so-called "nitrates-plume" in this RR/SC area's groundwater, together with the lesser
amount of nitrates normal to domestic sewage effluent from on-site systems.
   Prothero's 1975 Thesis says that on-site anaerobic systems produce less nitrates
than do the aerobic systems, such as are the trickling filter and activated sludge
systems of central sewage and industrial wastes processing plants. This_DEIS also
says that anaerobic digestion of sewage produces less nitrates than anaerobic sewer
plant processes. This DEIS also says that nitrates are added as odor control, which
would then produce more nitrates in the groundwater under the land upon, which such
sludges are land applied, together with the heavy metals and organic toxics in that
urban, industrialized sewage sludge. Nitrates are supposed to be the concern of EPA.
   Mr. Lowekron made the remark that,when pH is less than 6.5 in the soil, less of
the sludge is applied. This does not agree with the North Carolina Septage Study.  It
does indicate that NO heavy metals-content sludge shoud be applied to land with less
than 6.5 pH. Again, the North Carolina Septage Study is conspicuous by its ABSENCE
from this DEIS's references. Prominent in this DEIS's references are statements made
by the persons who have caused the affected and concerned citizens to have caused
this DEIS to be performed.
   Would Mr. Lowenkron, if asked, have said that less sludge would be applied to land
which has a pH of more than 5*0 when the sludge contains pathogens, etc.? Probably.
If so, this would appear to be another "error", particularly when considering the
presentation made by Springfield City Councelor Fred Simmons. His admonition to
reevaluate methods now employed has more recent knowledge than appears to have been
employed by this state's authorities to have Oregon be at three times the national
average hazard from waterborne diseases. This DEIS also refer* . to no harm coming
to healthy persons. This DEIS says that harm can come to those persons who are not
healthy. How would they have become unhealthy? Via the groundwater becoming so
polluted as the result from inefficiencies and/or indifferences of authorities?
   "Government is a trust, and the officers of government are trustees; both the
trust and the trustees are created for the benefit of the people - Henry Clay.1*
Please notice that Henry Clay does not say for officers of government to tryst to
the detriment of the people.
   Dry sewage sludge to 50 percent solids in the Judco Dryer and then burn it, with
other solid wastes,in the O'Connor solid waste burner to produce heat exchange gain
"... for the benefit of the people.", their health, their environment.
   The B & C representative responded to Mr. Elliott's favoring this burning of wastes
with the remark that it is not cost-effective. He also said that heat exchange gain
of up-to four times the heat required to dry the sewage sludge and other solid wastes
prior to burning it to produce energy would defy the first law of thermodynamics.

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                                           Ms. Young, EPA'o DEIS, MWMC. 12/7/83,
                                                                         fage 3
Is Mr. Kreugel (?), the B & C representative, a bit confused? Is the first law of
thermodynamics that energy is not destroyed, that it is Just transformed? If this
is not so, then many scholars have studied the wrong references. He, as an employee
of a company which is employed by officers of government, is acting in the stead of
officers of government or in conjunction with officers of government. This does say
that he is supposed to be bound by the trust assigned to officers of government and
that all decisions are to be "... for the benmfit of the people." His perspectives
appear to be very similar to those of Mr* fye. This DEIS has been promoted by the
people, so they appear to be objecting to the perspectives of Mr* fye and to the
similar perspectives of all other employees of officers of government*
   Neither of these two employed-by-officers-of-govenment persons taure been read to
have utilized a more realistic rate of RR/SC-Site C or Prairie Road Site or even at
the Site A-l groundwater flow with comparing the groundwater flow zaite indicated in
the newspaper articles pertaining to the spilling of toxic formaldehyde in the
Russian River, northern California, on March 26, 1982. On March 2?, 1982, "Officials
urged people not to use water from wells within 100 feet of the Russian River until
they are tested for formaldehyde,..." On March 28, 1982 the AF article has, "About
1.000 residents in Guemeville were asked to close private wells within 400 yards of
the river..." This change in groundwater rate of flow expectation was increased by
1,200 percent, for a difference of 1,100 feet more in tone-day-. 1,200 x 365 - 538,000
feet in one year, or more than 100 miles in one year. Viruses and bacteria are also
reported to have fast movement in groundwater.
   At the meeting last night, Mr. Richard Thiel commented that pollutants could be
removed from slow-moving groundwater by pumping it out, cleaning it up and return it
to the aquifer, but this could not be done with fast-moving groundwater. Therefore,
the actual, rather than assumed, rate of groundwater flow must be established before
any resulting decision could be valid for pumping-to-clean an aquifer. This aquifer
being pumped out would be a waste of money and create a false sense of security when
the causal factors of exfiltrating sewer lines have not been terminated. They are to
not be repaired because their repair is said to be not cost-effective.
   The exfiltrating of raw sewage and toxics of several known named kinds, plus the
probability of those unnamed, because MWMC requested that only the eleven listed
toxics be tested for, being hazards to the groundwater during the dry and low ground-
water seasons, would continue to degrade the aquifer as a drinking water source. This
is very similar to applying activated sludge process sludge to land in this general
area, which has the pH ranging from 5.0 to 6.5. It acts as a "funnel" for all of the
pollutants to go through the soil mantle and into the aquifer. This amounts to there
being a major "leak" in a sewer line to the groundwater, or many such "leaks".
   This DEIS also calls the sludge from this activated sludge process "digested",
while it also addresses odors from the product of this process. Saying it is "digested"
is not a fact- when odors are associated with it, because it is not even near the humic
status of a digested-anything. Activated sludge is the just prior step to fulvic acids
in the "Ultimate analyses of organic materials in the fossilization pathway-(in dry,
ash-free weight percentages).", while humic acids are midway between activated sludge
and the ultimate increase in carbon content of 96 percent in anthracite coals.
   "Fulvic and humic acids consist mainly of complex hydrophilic polyelectrolytic
polymers of benzene rings that are variously substituted, partially to completely
(which can be equivalent to saying fulvic as partially and humic as completely), with
either or both phenolic and carboxyl groups, together with large amounts of aliphatic
earboxylic acids; up to about 70 percent of humic and .fulvic acids may be made up of
these subunits (which could explain their similarities but not their odors differences),
which form water-soluble and water-insoluble complexes with metal ions and hydrous
oxides and interact with clay minerals and hydrophobia organic compounds such as
alkanes. About 10*8 stable free radicals are found per gram of humic or fulvic acids.
Fragmentation patterns derived through mass spectrometry reveal remarkable similar-
ities between soil humic acids, model humic acids, composted straw, peat, and
melanins (humic substances secreted by fungi). Many of the chemical and spectroscopic
properties of model humic acids are also indistinguishable from those of soil humic
acids and melanins	the reaction period required for the production of humus in
nature is unknown. Humic acids differ from fulvic acids in having larger molecular
weights and from humins(the alkali-insoluble component of humus) in having smaller
molecular weights.                       A-100

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                                           Ms. Young, EPA'3 DEIS, MHMC, 12/7/81,

   "Fulvic acids undergo a considerable amount of demethanation(posaibly preferential
losses of methylene) in Doing derived from foodstuffs. Moreover, in the event that
they are precursors of humlc acids, they lose an appreciable amount of car boxy 1 ea
routei this is in line with the analytical data. Pulvic and hundc polymers are linked
with aadno acids, carbohydrBtes, peptides, and amino sugars, probably through bonding
of nitrogen to carbon on a phenol or by quinimine formation, as well as possibly
through peptide linkages, and by way of the thioether linkage .of sulfur to ring
carbon."(rei Sludge Decomposition and Stabilization - Roy Hartenstein, SCIENCE, May
15, 1981, Volume 212, Number 4496, pp. 7*0-748)
   And, "In view of this and because humified material appears to be nonamenable to
putrescence, it appears proper to say that sludge is stabilized when it becomes
humified." This is far down the carbon cycle from "digested" sludge, so the use of
the terb "digested", that of reduction for ready use or application, or to subject to
or transform by digestion, is most misleading when not sufficient negative ions have
been returned or transferred to the results of such "digestion" to prevent reverting
to putrescence. This "digested" sludge has not progressed from the stage of putrescence
and the misuse of polymerization as a "packaging" of putrescence at the plant is then
transferred to land application, and misuse the land as part of treatment plant and
expose the people to this harming of their potable water aquifer; this is all most
foreign to-benefit-of-the-people.
   The thioether linkage of sulfur to ring carbon would be expected to occur in the
groundwater's reduced oxygen ion transport after exfiltrating raw sewage has reduced
the negative ion concentration of the rain and river recharge from nearly one hundred
percent dissolved oxygen ion transport. This should explain why the groundwater tests
showed sulfate movement to be much faster with the groundwater flow than nitrates flow,
particularly when considering the nitrates to be "tethered" to the sand via the heavy
metals.
    That "Pulvic acids undergo a considerable amount of demethanation in being derived
from foodstuffs." is evidence that the B 4 C representative appears to have ignored as
a. source of additional heat exchange gain when burning the "digested" sludge. This is
also a form of testimonial as to the only-partial-digestion derived from activated
sludge process. Additionally, as the plant's capacity becomes further overloaded, the
only-partial-digestion is further reduced, which leaves more methane in the sludge,,as
being more indicative toward putrescence occurring upon land application. If this type
sludge is dried and then burned, the heat exchange gain would be increased via the
presence of the additional methane-producing potential. The dryer could be "hooded" to
capture this methane for work conversion, if it is shown to vent during the drying
process. This would also contain reasons for processing the cannery wastes at/in the
old Eugene sewerage plant.) the residual sludge, only-partially-digested, should be .
an increased source of heat exchange gain and reduction of costs from operation of the
old plant for the few months during which the cannery produces fractions from food-
stuffs.
    The "engineers" on this new-plant .project and components appear to not have had
the benefit of chemists nor physicists in this plot, plan or project. Opportunities
for heat exchange gain should have been explored and be incorporated with components
which do provide heat exchange gain,such as the Judco Dryer and the O'Connor solid
waste burner. When opportunities for protecting the environment and make the whole
processing of sewage less exorbitantly expensive to the users-public and the federal
government are ignored, the officers of government are not performing the trust to
the benefit of the people.
   The domestic sewage is derived from foodstuffs and it is planned to be approximately
one hudred percent more by the year 2000, so heat exchange gain would be incremental.
A hand written note is included with the Raw Data of the 1978-1979 RR/SC Groundwater
Study. Above the listing of eleven toxics and their characteristics is a blocked-in
"Notei Total present industrial flow - 2.6 mgd. Year 2000 projected industrial flow
- 5»1 ngd. Projected industrial flow increase - 2.5 mgd."f which compares satisfactorily
with domestic flow increase for dilution. It would, however, provide for doubling the
mass of toxics going through the plant, to the land, and into the aquifer - a sole
potable water source. Dry the sludge, burn it, obtain heat exchange gain, and help to
protect our environment. Protecting our environment is supposed to be THE requirement.
                                      A-101

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                                          Ms. Young, SPA's DEIS, MWMC, 12/7/83,
                                                                        Page 5
   This hand written note is titled "Effluent limits comparison7; Its [Toxic, Arsenic
(As), is listed as Present Qp (mgd) being 0.14- and Present Qp, + 2.5 mgd, as being
2.64; this shows an increase in As of 2.6^/0.14, or 1,885 percent. Its Toxic, Cadmium
(Cd), is listed as Present Qp (mgd) being 0.05 and Present Qp, + 2.5 ngd, as being
2.55; this shows an increase in Cd of 2.55/0.05, or 5*100 percent. Its Toxicsi £ead,
(Pb), Nickel (Ni), and Cyanide (Gn) are listed as Present Qp (mgd) being 0.13 for
each of then and Present Op,* 2.5 ngd, as being 2.63t this shows an increase in Pb,
Ni, and Cn of 2.63/0.13, or 2,020 percent. These are examples to compare to the bar
graph,of these same Toxics, which accompanied the MWMC Advisory Committee (MAC) minutes
of its April 15. 1981 meeting.
   These minutes have on page 2 that, "..* Al Peroutka had written the report, and
that it had come from their research in trying to develop a logic for establishing
pretreatment standards or limits.
   "Cook then directed the Committee to a chart which had been handed out (attached
and made a part of these minutes). He explained that this showed the method used to
take the arbitrariness out of the development of standards. He said that by selecting
a flow (those shown were based on the year 2000) one could pick off a concentration
that will utilize 100 percent of the allowable industrial mass. Cook added that it
was a good tool is to see where to establish a flow and see how it affects the con-
centrations.
   "He further explained that the table assumes the growth from 1980 to 2000 will be
approximately 2,5 million gallons per day (mgd), and reiterated that half of that
growth will occur in each of the toxics. This amounts to 1.25 mgd in each of the toxics.
Rather than have industries adjust every year, Cook said the engineers thought it best
to plan for anticipated growth. Assuming all projections are maintained, the figures
should be valid until the rear 2000. Cook noted that the figures shown in the handout
material used current data.
   "A concern was expressed about the engineers' ability to accurately forecast the
future in terms of industrial growth, and Cook said that responses received from
industrial representatives indicated that they would prefer a reasonable guess on
concentration and mass limits rather than new figures every year.
   "Cook noted that the Eugene-Springfield metropolitan area is probably one of the
first to use a logical approach to create limits and standards. Most other cities •:..
use what other cities are doing. Ed Wilson added that a lot of cities adopt drinking
water quality standards or use 10 or 100 times that figure as their standards for .'-.,- '.
industry. He said he felt the MWMC engineers' approach was very well done, as there
was a 50 percent growth pattern built into the program.
   "Jeff Siegel questioned whether concentrations would drop as the flow increases,
and Cook said that was correct because the mass is held constant. He said that Mass -
Concentration X Flow, so that anytime the flow is increased, to keep the mass constant.
the cudcentxution must be increased.                                             •
   "Cook explained that Peroutka's original concept for a pretreatment program had
proven infeasible as the it was too sensitive to flow; the engineers then tried a
'total flow* concept, on which their current recommendations are based. This concept
is based on actual industrial growth in the Eugene-Springfield metropolitan area.
   "In response to a question from the audience, Cook explained that in reality the
flows with the concentration shown on the table will utilize 100 percent of the
allowable mass. He reiterated that most industries*will be able to meet these limits,
and that they are technologically achievable." (end of jits page 2)
   This "table" or "chart" is titled "EFFLUENT TOXIC CONCENTRATION, A FUNCTION OF
INDUSTRIAL FLOW". Its line graph is for EFFLUENT CONCENTRATION (MG/L) of the eleven
Toxics out of 129 potential toxics of concern. Its bar graph, INDUSTRIAL FLOW (MGD)
has PRESENT FLOW marked in shaded units and its CONCENTRATION INCREASE is extending
those bars across the grid units without shading. "Present Flow"of Arsenic (As) is
one-half (l/2) grid unit} its "Concentration Increase" of As is twenty-five mora*c;~
grid graph    units. This results in As increase of $0 times its present flow,  or 5*000
percent, as compared to the hand written note's 1,885 percent.
   Its "Present Flow" for Cadmium (Cd) is approximately three-fourths (3/*0 grid unit;
its "Concentration Increase" of Cd is approximately (*4'/») twenty-four-and-one-half more
grid graph units. This results in Cd increase of 32.66 times, or 3*266 percent, as
compared to the hand written note's 5.100 percent.

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                                             Ms. Young, EPA'a DECS, MWMC, 12/7/83,
                                                                           Page 6
   Its "Present Flow" for Lead (Pb) is two and one-half grid units; its "Concentration
Increase" of Fb is twenty five (25) graph grid units. This results in Pb increase of
10.0 times, or 1,000 percent, as compared to the hand written note's 2,020 percent.
   Its "Present Flow" for Nickel (Ni) is the same as for Pb and its "Concentration
Increase" for Ni is the same as for Pb. This results in Ni increase of 10.0 times, or
1,000 percent, as compared to the hand written note's 2,020 percent.
   Its "Present Flow" for Cyanide (On) is one and one-quarter grid units{ its "Concen-
tration Increase" of Cn is twenty five and one-quarter more graph grid units. This
results in Cn increase of 20.2 times, or 2,020 percent, which is exactly the same as
comparing the hand written note's 2,020 percent.
   These four examples demonstrate that considerable adaptations have been rendered
between the twot hand written reference and the graph grid bars. Neither of these
references agree with any intent to limit toxics concentration or mass of toxics. The
"engineers" are correct in that "... most industries will be able to meet these 'limits',
and that they are technologically achievable." Anyone should be able to technologically
be able to qualify as an "engineer" just with pouring more toxic pollutants into a sewer,
or into anything elset such as on land and into the aquifer, which is the sole source
potable water supply for many now-healthy people. However, they will not be healthy for
much longer.
   Compare that Mr. Terry Smith, an employee of the Eugene Public Works Department, is
on meeting tape record of the CAT to have responded essentially that, if Cadmium was
in the groundwater to the extent indicated by the use of the Cadmium precipitation of
nitrates method produced 5»5 to 100 percent more nitrates than with the comparable other,
Bgl,method, deaths would occur. Consider the "100 percent" as that which would produce
deathi then Cadmium increase of 32.66 times, as is indicated in the bar graph, or 51
times, as is indicated in the hand written note, would produce death nearly instantly.
Keep in mind that the general consensus among scientists is increasingly tending toward
there not being a threshold at which Cadmium will not do harm to living cells and
organisms. The fact that animal and human life is comprised with-and composed of these
organic cells and other organisms should have caused decrease from PRESENT FLOW or
CONCENTRATION of TOXICS to protect these cells, organisms and human/animal life.
   Such dramatic increases of toxics concentration, as is foregoingly indicated and
compared, should be able to be easily traced to their causal factors from the sewage
sludge applied to that land and into the aquifer, and into the living cells and organisms
of animal and human life and cause them to instantly, or nearly instantly, cease to
function. These results would cause such exorbitant cost increases against the then-
sewer-users as to have been much more cost effective to have dried and burned the sewage
sludge as the base component of the sewage treating process. DRY IT AND BURN ITI
   And, "Cadmium is a toxic trace mineral that has many structural similarities to zinc.
There is no biological function for this element in humans....Dr. Henry A. Shroeder, a
trace mineral researcher, has developed a theory about cadmium being a major causative
factor in hypertension and related heart ailments... The liver and kidneys are storage
areas for ... cadmium..." (Nutrition Research, Inc.'s NliTKj.Tj.ON ALMANAC, pp. 62-63)
"The body's ability to use zinc is hindered by cadmium,...It is believed to contribute
to high blood pressure, cardiovascular disease, and kidney disease." (Robert D. Gutting,
Minerals, pg. 4)
   So, many humans, who would be drinking such heavily increased pollution of their
water supply aquifer, are now predisposed to cessation of cells and organisms functions
from even slight increase in cadmium concentration. This exists when just considering
.this one toxic mineral. How much more devastating will this be when all  of the adverse
reactions from the known toxics and heavy metals increases in this sludge are considered
together? Answer: much more devastating.
   Consider that the dilution with domestic sewage flow was figured from ah experience-
level constant, or nearly constant, from Eugene's 240 gallons per capita per day (gpcd)
in 1980-1981. Its gpcd is now .     said to be reduced to approximately 79 gpcd. This is
then concentrating the toxics by another six (6) times. This DEIS says that toxics do
increase more with the off-site drying-of-sewage-sludge process. MWMC is planning to
misuse any off-site location to cause such compounding of toxics hazard. EPA must NOT
allow this to occur. DRY IT AND BURN ITI ON THE PLANT SITE! This perspective should
cause EPA to demand refund of its grants funds and provide for finders-fee with such
recovery of those funds. They appear to be producing opposite to their origi1"31
                                                                            A-103

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                                            Ms. Norm Young, EPA1 a DEIS, 12/7/83,
                                                                          Page 7
   How the procession of events turned from benefitting the environment and economy
to harming both is explored chronologically. Page 2 of the April 15, 1981 MAC minutes,
quoted on page 5 of these comments, show that Mr* Peroutka had written the report and
that Mr. Cook is credited with having said that "...Peroutka's original concept for a
pretreatment program had proven infeasible as the-(sic) it was too sensitive to flow)
the engineers then tried a 'total flow* concept, on which their current recommendations
are based." This appears to clear Mr. Peroutka, except for possible participation in
developing this "total flow" concept presented by the engineers.
   Page 5 of the MWMC Newsletter for April-May 1981 has, "Peat, Marwick, Mitchell & Co,
the Commission's (MWMC's) pretreatment consultant (the word 'engineers' is not used
here), has asked for input from MAC and the Technical Advisory Staff concerning methods
for developing prohibitive discharge standards for local industries. MAC held a special
meeting on March 18 to consider these questions and will continue the discussion at its
regular meeting April 1 and at another special meeting April 15"(l98l). The quoted page
2 is from that April 15 meeting of MAC. This April-May 1981 Newsletter continues with
"Representatives from industrial firms in the Eugene-Springfield area are welcome to
attend MAC meetings and contribute to the discussions."
   Representatives from industrial firms in the Eugene-Springfield area participated
wih input, because this MAC meeting minutes page 2 has, ",...Cook said that responses
received from industrial representatives indicated that they would prefer a reasonable
guess on concentration and mass limits rather than new figures every year." How they
appear to have departed so radically from protecting the environment is also on this
quoted page 2 in "He (COOK) said that Mass - Concentration X Flow (this writer's back-
ground of reference indicates this chemistry-physics formula to be correct), so that
anytime the flow is increased, to keep the mass constant, the concentration must be
increased."
   Mr. Cook's explanation of this formulas Mass - Concentration X Flow, "... so that
anytime the flow is increased, to keep the mass constant, the concentration must be
increased." is faulty. The correct explanation is "... so that anytime the flow is
increased, to keep the mass constant (should read 'to keep the concentration constant'),
the concentration must be increased (should read 'the mass must be increased')." So,
the correct use of the formula, Mass - Concentration X Flow, would reads to keep the
concentration constant, the mass must be increased anytime the flow is increased.
   Amazingly and ALARMINGLY, Mr. Cook's explanation of this formula/equation appears
to have been misused to have the TOXICS CONCENTRATION be increased so radically and so
harmfully against people and their environment. This situation also brings forth the
subjects of experience-level, knowledge-background, intent and ethics of the participants
in such an astonishingly basic "error". However, even the misuse of this formula/equation
should not have produced 5,100 percent, 3,266 percent, nor even 2,020 percent increase
in TOXICS CONCENTRATION when the total increase in domestic flow dilution of the toxics
and the industrial flow of toxics are essentially equivalent at approximately one (one)
time, or 100 percent, increase from present (i960) flows to estimated year 2000 flows
of both domestic and industrial toxics/pollutants.
   Again, amazingly and ALARMINGLY, "Cook noted that Eugene-Springfield metropolitan
area is probably one of the first to use a logical approach to create limits and
standards.'' What is logical in "... that anytime the flow is increased, to keep the
mass constant, the concentration must be increased."? Logic requires knowing that the
mass-constant requires DECREASING the concentration when flow is increased. People-of-
letters should have learned this fact long before they became people-of-letters, which
they may not be, or they may possess ulterior motives In having bypassed their probable
knowledge.
   This consideration appears to be probable when including more of the MWMC Newsletter's
page 5> "Closer to home, controversy over the possibility of ground or (and) groundwater
contamination by land application of sewage sludge has emphasized the need to keep sludge
as free from toxic contamination as possible.
   "The MWMC is developing a local industrial pretreatment program designed to protect
the biological systems of the new regional treatment plant and maintain a toxic-free
sludge through regulating industrial discharges to the public-owned sewer system." This
TOXICS-FREE SLUDGE  maintenance program has been reversed to the TOXICS^COMPOUNDING
program. DRY THE SLUDGE, BURN THE SLUDGE, RECOVER THE TOXICS FROM THE SLUDGE. DO NOT
PUT IT ON LAND WHERE IT CAN SO SEVERELY ENDANGER LIFE CONTINUITY VIA THE GROUNDWATER.
                                          A-104

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                                            Ms. Young. SPA's DEIS, MUMC, 12/7/83,
                                                                          Page 8
   MHMC's Newsletter of August-September 1982 has on its page 5, "Industry accepts
pretreatment progxajti
   "Two representatives of local industrial firms testified in support of MVHC's
industrial wastewater pretreatment program at a June 28 (1982) hearing, stating that
they felt it was fair'to industry. They were the only persons who testified at the
meeting although eight other representatives from industry were present. The entire
hearing was conducted within a 50-minute period, much to the surprise of MUMC staff
present." Why would the MWMC be surprised that industry accepted a free-ride? The  rule-
of-thumb in establishing a functional balance is when both sides are still objecting to
some features in the proposal being considered for adoption. Industrie acceptance  of
this "pretreatment" program does indicate the industry representatives received from
MWMC a "cake" with multiple layers of "frosting". Christmas came early for industry.
   Also,   this August-September 1982 MWMC Newsletter's page 5 is continued witht
"A member of the Commission's staff reported that in casual conversation following the
hearing an  industrial representative explained that since industries had been involved
in the development of the program from the ba^innlnff,. they understood and accepted the
restrictions." What restrictions when MWMC'a "reasonable guess", preferred by industry,
has resulted in flow increase producing concentration increase to keep the mass of
TOXICS constant? The MASS of TOXICS will INCREASE when CCKCBHTHATICR is INCREASED,
whether the flow is increased or flow remains constant - the Mass - Concentration  X Plow
formula or equation says this will occur. Compounding coaceatrmtimr of toxics, as  has
been presented as planned to occur via examining the portents disclosed by the bar graph,
will compound the transport of TOXICS at any flow rate.
   The inefficiencies or designs of the MWMC and its subcommittees majority members,, in
these particulars referring to industry,'s_ "pretreatment" of toxics, produces extensive
questioning of the efficiencies and designs of the results in all components of this
new activated sludge process plant since CH2M Hill reported that land application  of
sewage sludge is too expensive and should not be pursued furtheri now exclusively  pursued.
   Mr. Richard Thiel reported that no compensation for damages to thexadversely affected
people would be forthcoming. He was asked about the "zero industrial pollutants discharge
to sewer lines by 1985". He responded that, although it is the result of legislation, it
is a GOAL that is not to be achieved by 1985* It will certainly not ever be achieved
when Mass - Concentration X Flow is so resoundingly mauled by promoters of industrial
development - and hang-the-consequences.
   Page *t and 5 of this writer's input for the DEIS meeting on 12/6/83, not presented
at that time, is attached to this series of comments on this DEIS. The conclusions are
related to the perspectives presented on these eight pages.
   John C. Neely, Jr.  •An.C.tKtfo&i. - 1600 Horn lane, Eugene, OR
F.S.t this bar graph copy is the one earlier presented to Ms. Ernestm Barnes by Mrs.
      Melva Barnes and Mrs. Eugene (Pat) Bohanan.
           Il4 Jj^pLp. INDUS
                                                .  ! aurl r	—?> • a'-f' T. I  Lz
                                                i  ,.,^,-^M  r/a».>TM
   I  i  l  i  l  !  i  I  ^Vj

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                                  for EPA's meeting, NVMC SIS, 12/6/83,  page *f
P St
   Page 6 of this EIS, Impacts of Individual Alternatives, has that "EPA win not
be responsible for implementing   all mitigations required. Local, regional, and
state agencies will be called upon to initiate those mitigations that are within
their functional capacities." Just reading this seems to allow this to be reasonable.
However, once comparative concentration is applied to this attitude, applying this
to so many inconsistencies discloses how so many illogical results have filtered-
through-the-cracks.
1. Page 7 shows Table S-l describing Alternative 2 (MWMC's Preferred Alternative),
   while page 11 shows Table S-2 describing Alternative 1 (Centrifuges abandoned,
   sludge stored in off-site FSLs(/secondary digesters) and air-dried, while Table
   S-3 shows Alternative 3 and page 15 shows Table S-4 describing Alternative *f.
   Considering general mental abilities to be as limited as they seem to be, the
   conclusion is that Table S-l description could easily be confused with the
   Alternative 1 and the Table S-2 description could easily be confused with the
   Alternative 2, while no similar confusing factor is evident between Table S-3
   description and Alternative 3» which also applies to Tabe S-4 and description -
   for Alternative *K
   The point being that this similarity was noticed in the new plant plans and their
   alternatives descriptions! when the description for one alternative was under
   consideration, it would be easy to associate this with the corresponding FLAN
   number. This appears to have occurred, because the upgrading of the two old,
   separate Eugene and Springfield trickling filter plants were said to be not-
   appreciably-less-in-cost than to build the single, regional-concept plant. The
   point being here is that this type of expression says that upgrading the two old
   plants would have been at less-cost. This implies that cost-effectiveness has
   been bypassed.
2. CH2M Hill's 1975 and 1977 studies provided definite information which was based
   on its experience-level, while Brown and Caldwell's studies appeared to offset
   much of CH2M hill's recommendations and directives. One of these, as ah example,
   is that CH2M Hill said that land application of sewage sludge was toaexpensive
   and it should not be .considered any further.
   Obviously, this expensive information has been bypassed. This EIS being a treatise
   on options for off-site land applications of sewage sludge are all which are
   being considered. This is not consistent with protecting the environment.
3. Page B-5 shows Table B-3's chart with Utilization/disposal options. This is for
   sewage sludge. The very similar conditions and mitigations are used on the Agripac
   site. This indicates that the deposits on that land will have properties similar
   to those in sewage sludge. And, the court decision pertaining to condemnation of
   property for Site A-l did allow the condemnation for depositing sanitary sewage
   on-the-site-being-condemned. Yet, DEQ's permit has only seasonal industrial/cannery
   wastes to go on that property. Again, a part of law appears to have dropped-
   through-a-crack because Oregon law only allows condemnation of property for three
   specific reasons or purposes. The only one of these reasons pertaining to this
   booboo, and a very expensive one, is that for sewage. So, no matter from which
   perspective this particular subject is considered, the seasonal industrial Site
   A-l should not have been allowed. It should not have had any financing from EPA.
   EPA's foregoing quotation,saying it will not be responsible for implementing all
   mitigations required, says that the local, regional, and state agencies are to be
   held responsible for initiating those mitigations that are within their functional
   capacities. DEQ is part of the state as an ag'ency. It should have stopped this
   series of condemnations. It did not; it appears to, have violated state law in the
   issuing a permit for any activity which required condemnation of agricultural use
   property in private ownership for agricultural use in public or quasi-public
   ownership. DEQ seems to be actively engaged in^byfassing its functional activities
   responsibilities. The local and regional agencies personnel also have bypassed
   their responsibilities when they need to have known, since they are also part of
   the state's delegation of authoity, that these condemnations are outside state law  .
   for the purpose of using seasonal wastes for agricultural purposes. This is a
   general failure of functional capacities of all personnel involved in this fiasco,
   because local and federal funds are di'sipated on a project which has become not
   legal. If no property owner had gone to condemnation, this would not have been known.

                                            A-106

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                                 for EPA* s meeting, MHHG £13,12/6/83, page 5

The fact in this being known as a natter of court record has the EPA participating
in violation of Oregon law. EPA's not being     .. responsible for initiating this
•itigating measure says that federal funds have been expended upon an illegal plot,
plan, or project.
Bat (Mrs. Eugene) Bohanan has said that she spoke by telephone to Ms. Nona Young of
EPA*s Region X and that one of the particulars mentioned to Mrs. Bohanan is a rule
or process used by the EPA on projects which is called engineering value or value
engineering. Her understanding, and that of this writer, is that the word "value"
has the direct connotation in ONLY price of a project is considered at that tine.
If this is so, then environmental considerations in protection are NOT considered.
This could explain how the 10-inch dual force-main has been deleted from the "Agripac"
plot, plan, or project, which deleted the three specific reasons which Mr. Burd had
repeated as being required. The repeating of the requirements followed the first
statement by approximately one year. This figures as the environmental factors give
way to cost-effectiveness. Yet, this cannot be so, because the Site A-l is being built
when even the MWMC's literature said that Site A-l was nearly $2,000,000 more to build
and $35*000 per year more to operate and maintain than the overland flow option, which
is also said in MWMC literature to be more environmentally acceptable.
This necessarily says that EPA and DEft are involved with federal money waste, because
neither cost-effectiveness nor environmental protection have been properly considered
in this whole treatment plant and components series of projects, plans, or plots.
Not sufficient supervision by state or federal agencies, or because of them, the local
plotters or planners appear to have been - and still are - running-the-show-or-hide.
   Since this whole sequence of events appears to have progressed to such a fiasco via
the local and generally unreliable authorities and-agencies - judging by the results
to-date, the EPA should now consider exercising its potentials in making corrections
by making sure that funding will only continue for the Alternative 3 &&<* the use of
the Judco Dryer and the O'Connor solid waste burner combination being installed ON
THE NEW PLANT SITE. This would achieve the environmental protection which can still
be attained. It should also be the cost-effectiveness solution, both with local and
federal funds.
   This BUS says that the EPA has performed the function for which an EIS is intended
to demonstrate. It does demonstrate that the objections by the persons,r-who,are
involved in helping to cause this EIS to be performed, have been correct in their
analyses of the worsening aituation(s). This EIS also appears to remove EPA from any
seeming-complicity in the down-hill-slide, away from cost-effectiveness and the
environmental protection for which all of the involved funds were origionally expected
to accomplish. Non-funding the Terry Street force-main beyond the pressure side of
the West Irwin pump station and tied into the West Irwin existing force-main at that
point would be an excellent means for acquiring the federal funds for the Alternative
3 continuation, with and for adding the combination of the O'Connor solid waste
burner and the Judco Dryer* ON THE NEW PLANT SITE.
   This arrangement would make the seasonal waste Site A-l obsolete, because the old
Eugene sewer plant could be used to process the cannery's wastes and the solids would
be on-site to be processed through the Jud Buttner's Judco Dryer and O'Connor solid
waste burner combination. The ash from this process in burning the seasonal wastes
should be acceptable for the Bag-market as fertilizer. And, as soon as the new law
becomes effective in 1985, to have ZERO INDUSTRIAL POLLUTANTS DISCHARGE TO THE SEWER,
the sewage-burning?-ash should also be acceptable for the Bag-market as fertilizer.
   Other functions will be automatically corrected, if EPA does elect this route for
future protection of our invironment. Getting the MWMC in the fertilizer business
should be the most and last which should be expected from EPA. The most important item
which can possibly come from EPA electing this suggestion as THE solution is in that,
while the local authorities may deserve to have the pollutants come back to them in
the food they eat, from the land upon which they had intended to spoil and waste with
sewage pollutants, the public,which had no part in all of this having occurred to-date,
will not be made to suffer illness or death as the result from the biases of the local
agencies personnel, or their lack of expertise, or their complete lack of regard for
their and others environment betterment.
   John C. Neely, Jr. & c.'-vx.
                                         A-107

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Ks. Norma Young                                                  December 16,  1983
EIS Coordinator
EPA Region X
1200 Sixth Avenue                   Ret M/S W}
Seattle, Washington 98101

   At the meeting last night, before a county hearings officer for the lane County
Commissioners, MWMC requested a Conditional Use Permit for what it calls "Alternative
1", which is the original Site C area and designated as Alternative 2 in the DEIS. Its
"Alternative 2" is the 125-acre site which adjoins Site C to the south of Site C,  which
is one of the sites designated as Alternative 1 in the DEIS.
   The "experts" told the hearings officer the same line of - ah, state-of-the-art as
was presented at the December 6, 1983 DEIS hearing. State-of-the-art, that which has
caused Oregon to be at three times the national average hazard from waterborne diseases,
is as an admission by those "experts" in not having included more recent references in
their considerations which demonstrate the shortcomings within state-of-the-art as it
is being practiced.
   An objector to land application of the sewage sludge asked the rate of flow of  the
groundwater. The response was, again, 200 feet per year. Mr. Edwards, of Sweet-Edwards
which made the reports on the 1978-1979 River Road/Santa Clara Groundwater Study,  made
this statement. He also said that, in the Dispersion and Decay analyses at the Shirley
Street site, a down-gradient test well was pumped down to create a groundwater rate-of-
flow acceleration of approximately ten times the normal rate of groundwater flow.  This
certainly does provide an admission in monkey-business with a supposedly scientific
experiment to establish, as a phase, a groundwater flow rate. This adapting of such a
test provides inexplicability  in accounting for that study's specific reference to
the participants SURPRISE in the injected bacteria having migrated up-gradient to  an
up-gradient test well. This may be indicative in the extensive deficiencies in the
presently practiced by them state-of-the-art, and against which people utilizing the
later references are so strenuously objecting.TV»*&*P»»»^-P»'*y«'»»tPct*<*»j»/.Ac»«y
   Their SURPRISE at this phenomenon of up-gradient travel of injected bacteria should
have indicated to them that the direction and rate of groundwater flow is a combined
functional relationship of the groundwater level, at the time of the testing,  and  the
myriad interties in the sand-gravel channels of the aquifer, which were laid down  so
many years ago, and in reference to which they will have to continue to be required to
just-guess, which is a sad reflection on their state-of-the-art and be an additional
indictment against their use of that older and extensively deficient state-of-the-art.
  "Another local-resident objector said his experience-level has demonstrated that the
clay soils in the area, that which is depended upon for a lining for the FSLs, is  not
impervious, but the clay soils are pervious to fluids. MWMC's literature and the DEIS
confirm this action, albeit indirectly, when they have expounded on the sludge being
a soil amendment which helps make the clay soils more and better workable in tilling.
Page 3t last paragraph of this writer's input on 12/7/83*quotes from the Sludge
Decomposition and Stabilization treatise by Roy Hartenstein, has that the fulvic and
humic acids "... form water-soluble and water-insoluble complexes with metal ions  and
hydrous oxides and interact with clay minerals...", which is a substantiation in the
soil-amendment perspective and is an accent on the validity of that local-area person's
objections to the misuse of local clay soils as a liner for FSLs. The presence of  the
fulvic acids,and humic acids 70 percent similarities to fulvic acids also being present
to act upon the pore perviousness of the local clay soils, which increases the speed of
the reaction of the acids in the pores of the clay soils to make the pores of the  clay
soils larger and more rapidly to provide for the clay soils to become more pervious.
   The "experts" appear to be providing in the sewage sludge the acids "moles" which
would be chemically "boring larger holes" very rapidly 'in an "impervious liner" which
is more pervious locally than the "experts" seem to include  in their guesstimates.
This was one of the conditions inferred in this writer's input in reference to Phase I
at Short Mountain. Mr. Burd tried to reassure this writer in a, response letter. He has
totally failed in thr.t effort. His effort may be considered as effective as the
transcience of the dual-force-main requirement in the seasonal wastes transport pipeline
to Site A-l, which became transcient as the result of value engineering - which also
appsars to have excluded all of the requirements for environmental protection, that for
which the federal funding is intended to be expended; a major item which seems to  have
been acted upon as local clays are acted upon by fulvic acids 30 percent unstable  ions.

                                            A-108

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                                                 Ms. Young,  M/S Wj,  12/16/83,  page 2

   Further reference to unstable ionst At the Coburg City Hall meeting by the Coburg
residents, pertaining to this DEIS reintroducing the Coburg  Hills site as an off-site
sludge disposal alternative, one of the audience asked an MWMC employee,  Mr. Peroutka,
if air could be pumped to the plant site, a major source-area for acquiring the negative
ion more nearly saturated air being from above the nearby Willamette  River. His response
was no. Does it reason to you, as it does to this writer, that pumping high negative
ionized air to the heavy fluids of sewage and aerating those fluids at the plant  site
would have been more energy-efficient and environmentally protective  than to instead
expend funds for an off-sit?location and expending expensive energy to pump the heavy
fluids to that off-site location for the same purpose in negative ion exchange  from the
air to reduce the putrescence of* the "digested" sewage? The  aeration  energy cost  is then
expended to facilitate the ion exchange and reduce the putrescence of excess unstable
ions to the stable ions characteristic in humified sewage sludge, and to  reduce the
numbers of birds attracted by such putrescence, which is indicated by so  many references
to odor in this DEIS.
   Had the new plant been of the anaerobic design, the trapping and use of methane gas
could have been utilized .to drive negative ion generators which could have been located
in the air transport pipelines from above the nearby river to the plant - a very  short
distance compared to the several miles of sludge transport pipelines  to any off-site
location to obtain the necessary negative ions exchange from the air  at the off-site
location(s). The negative ions are doing the job of reducing the amount of solids by
changing molecular structures of the components in the sludge/sewage. The high  positive
ion excess from industrial pullutants, including solvents which also  penetrate  soils
pores, including clay soils, more rapidly than does the capillary action  of pure  water,
would reduce the amount of solids of sludge.
   This DEIS, and repeated by the "experts" at last night's  meeting,  says that,when this
new plant goes on-line, the solids production will be manyfold more than  the two  old
plants produced. Logic requires considering that the two old plants had their separate
sources of negative ions for exchange, while their sewage will soon be combined at one
area and no increase in negative ions for the break-down of  solids.;  this fact  must be
included in any remarks which are intended to explain how the new plant will produce
such an excess of solids. The connotation would include that polymerization has become
the substitution for negative ionization at the plant site.  The polymers  being  the means
for "package" transport of solids molecules not broken down  at the, plant  site because the
limited air content of available negative ions has not been  sufficient for the  job of
work required to reduce the solids to their simpler molecular structures  which  would  be
characteristic of humification.
   The time required for nature to reduce putrescence to humus is said to be unknown,
in the treatise on Sludge Decomposition and Stabilization. However, the proposition is
becoming more often repeated that stabilization in warn climates would be approximately
one and one-half years for domestic sewage. This Eugene-Springfield area  must be  allowed
as being a colder climate, so the general reference is to double the  time needed  for
domestic sewage to become stabilized. The presence of industrial pollutants may then  be
considered to be compounding the time for the domestic-industrial mix of  sewage.  This
would reason to be a compounding of time to reach stabilization to be a near/y  dfr«xf
ratio to the amount of industrial pollutants in the domestic sludge dilution- of those
toxics.
   An elderly lady, an owner of land in the area of Site C,  presented the fact  that she
and her husband own land which is assessed at $52,000 per acre. If all of the- land at
the area preferred by MWMC is similarly priced and would have to be paid, together with
the cost of the improvements on such land, the cost for the  l?0-acr:e  site would be in
excess of $8,8^0,000; the cost for the-125-acre site would be in excess of $6,500,000.
This recalls that CH2M Hill said that land application of sewage sludge is too  expensive,
and it should not be further considered. CH2M Hill, as far back as 1975,  reasons  to be
absolutely correct in its ignored recommendation!.The Judco  Dryer and O'Connor  solid
waste burner combination su*ely would have ah installed and operational cost, even with
duplication for back-up units>      be considerably less than for just land costs for
MWMC's biased from state-of-its-art preference.
   John C.  Neely, Jr.

   1600 Horn lane u Eugene, Or 97^04

                                        A-109

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                         HAROLD S.SCHRENK
                           FOrSJ.SCHRENK
                           91736 Green Hill Road
                          Junction City, Oregon 97448

                             December 6, 1983

                                                                 u                  il"
                                                                     DEC 9 W83

E. P. A.
Norma Young
12^0 6th Ave.
Seattle, Washington 98101                                       '*•••••

Re:  E. I. S. Site C and Prairie Road Site

Dear Ms. Young:

Regretfully, we are unable to attend the meeting in Springfie'd, Ore as of this
date re the hearing for the location of sludge dumping ponds for the Eugene Municipal
system.  However, we wish to use this means of registering with your agency our
very deep concerns and objections to the above named sites.
We have a small  (5^ acres) farm just about three miles northwest of site C, and
the Pairie Road  site.  We have lived here for thirtyeight years and developed our
home and. business where we are trying to make our living in these trying times of
agriculture problems.  These two sites will be placed over the direction of the
ground water flow through our farm, as well as those of all our neighbors.  All
here in tnis area have shallow wells including the town of Junction City which is
in the pathway of the underground water flow on which site C and Prairie Road are
located.  Our conerns are contamination of our wells and devaluation of our land
and homes due to the sludge dumping on these sites.  Assurances by the management
of the 'A'aste Water Committee that all precautions will be taken to prevent such
contamination is not convincing the residents here this will not happen.  The
engineers reports and findings say that contamination is possible to our ground
water from these sludge ponds.  This would contaminate our living wells and drinking
water for people and animals alike.  Due to the cost of replacing the well and
extensive water  systems we now must have to operate our farm, replacement of such
an extensive system would be financially impossible.  There may be economic recovery
for some segments of this country's business clima'.e, but we in agriculture are
not yet included in this warming trend.  These sites chosen for the filth of the
sludge of Eugene are all on cultivated agriculture land.  The sites are also close
to small communities of density population.  The repugnant, odors, the flies, the
mos:iuito breeding facilities, the rodent problem—all will be paramount health
problems for human and animal residents.  The smell of field burning will seem like
Channel #5 compared to what we will have to endure every day of the year from
t hese acres of  filthy sludge.  There is. not,a knowledgeable individual who will
allow this so-called "fertilizer" (sludge) to dumped on his crop land to poison it
for all time.  The pathogens, hard metals, FCBs, put toxins into the soil to be taken
up by plants and thus ingested into the hu7>an body and animals that graz-s the plants..
or eat the products thereof.

There are some .questions we would like to have answered.
         . 1.  Is it not true the city of Eugene is trying to lure new clean
              industry to the area?
          2.  Would not many of these prospective investors be coming in by
              air via the Eugene airport?
          3.  Would not the airport be-considered Eugene's front door for the


                                        A-110

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Page 2
December 6, 1983:
E.. P. A.
Norma Young

              entrance  of these  visitors?
          ^..  Why would Eugene want to put  a cesspool in its front yard?
These: two proposed dumping sites are within; seeing and smelling distance; of the
npinicipal airport.,  The choice of eithe^ of the above two sites at Eugene's
front d'oor, in:, our opinion,, surely would raise some doubts as to the ability
of decision makers in charge in  our area.   None of the points put forth by the
Waste Water lyranagementgroup anc*  their engineers have assured us that we do
not have; reason toi be fearful of all the contamination afore mentioned.,  If
this, group is allowed' to use; this: clean agriculture land for the contaminated
sludge, the potential destruction it will deliver to the land,, water and air
is irrevocable.

It is our earnest hooe,, Ms. Young, that you and your agency will please consider
the fears and plight  of all of those who live in ttie areas and pathways of site
C and Prairie Roadv   Please do not let them have the land to build the sludge
ponds: on site C and Prairie Road.
Thank you very  much.
                                        Res
                                                  and Lois J» Schrenk

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                                                Chester Swenson
                                                91004 Prairie Rd.
                                                Junction City, Oregon

                                                December .6, 1.985
Ms. Horma Young M/S 445
U.S. E.P.A. Region 10
1200 Sixth Ave,
Seattle, Wash. 98101
Dear Madame:
     Concerning the E.I.S. for sludge disposal.
     I am opposed to the use of Site C or any adjacent sites.
I don't think any of our 160,000 acres of prime farm land
in Lane County should "be polluted by MWMC.
     Why should Federal Funds (our money) be -used .for MWMC'3
sewer, sludge, and industrial waste projects?  Is EPA going
to fund a new septic tank for my home?  What is the difference?
If not, wouldn't that be discrimination?
     Is a Federal balanced budget any concern of EPA?
     Is the rest of Eolo statement as misleading as Pye's
statement on page 165?
                     Y;ours truly,
                     Chester Swenson.
                                       y^p---•--"-
                                            DEC 8 1983
                                         CWVMWNMENTAL EVAU.iAi.GN
                                               BRANCH
                          A-112

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         Appendix B
Sludge Lagoon Liner
      Cost Estimate

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Metropolitan
                                                                          COMMISSION MEMBERS
                                                                Christine Larson— Springfield Councilperson
A/2|C'tp\A/£lf>£fcr                                 VH^V.I^LJ   LJ     Gerald Rust—Lane County Commissioner

Vlanagement

                                                               Gary Wright—Lane County Lay Representative
                                                                   Pat Hocken— Eugene Lay Representative
                                                                     Betty Smith— Eugene Councilperson
                                                                 Steve Allen— Springfield Lay Representative
f* f^YY+fri iccifltl                                               Mark Westling—Eugene Lay Representative
225 NORTH 5TH ST.  —  SPRINGFIELD CITY HALL  —  SPRINGFIELD, OREGON 97477  TELEPHONE (503) 747-4551


                                    February  21,  1984
   Ms. Norma A. Young,  Project Monitor
   Environmental  Evaljwrtion Branch
   U. S. Environmental  Protection
    Agency    /-"
   1200 Sixtff Avenue, M/S 443
   Seattle, WA  98101
   SUBJECT:  SLUDGE  LAGOON LINER COST ESTIMATE
   As you verbally  requested, enclosed  is  the  order-of-magnitude cost  estimate
   for lining the facultative sludge lagoons associated with the permanent sludge
   management system with the same type of liner as used in the Seasonal  Industrial
   Wastewater holding lagoons.  In using this  information, please  keep in mind
   that this cost estimate is based only on this one type of liner and that use
   of a liner of this type in this particular  application may in fact  be  inappro-
   priate.  Other methods of sealing the lagoons may be better suited  and/or
   less costly than this option.

   The specification of a lagoon liner  in  the  final lagoon design  should  be the
   result of a full  scale engineering design effort and based on the performance
   requirements of  the lagoon.  This design effort would include investigation
   of several options for lagoon sealing,  including possible use of native soil
   materials, importation of soil or clay  sealant materials, use of various types
   of plastic liners, or other options.

                                                    Sincerely,
                                                    AL PEROUTKA
                                                    Civil  Engineer
   APrbe

   Enclosure

   cc:   Dick Thiel,  EPA
        Mike Rushton,  Jones & Stokes
        AP
        BCS
        DC
                                         B-l

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            BROWN AND CALDWELL
            CONSULTING ENGINEERS
                               0. H. CALDWELL. PE Chairman
                                 T. V. LUTGE. PE President
                              E. F. MISCHE. PE Exec Vice Pres
                                D P NORRIS. PE Vice Pres
 February 1,  1984
 Metropolitan Wastewater
   Management Commission
 Suite  292
 225  North Fifth Street
 Springfield, Oregon 97477                                   13-112-82

 Attention:  Mr. William  V.  Pye

 ESTIMATED COST OF PLASTIC LINER FOR SLUDGE LAGOONS

 As you requested, I have prepared an  order-of-magnitude  cost
 estimate of a plastic  liner for the sludge lagoons associated with
 the  permanent sludge management system.   The cost is based on the
 same type of liner used  for the Agripac  lagoons, and in  fact, was
 derived using the unit costs associated  with the Agripac project.
 Our  estimate for the liner is $960,000,  including engineering and
 contingencies, and is based on a Seattle Engineering News-Record
 (ENR)  index of 4,800.  As you know, this type of liner represents
 only one of a variety  of methods for  lining lagoons and  is not
 necessarily the one we would consider best suited for the permanent
 sludge project.

 BROWN AND CALDWELL
 Steve Krugel
 Project Manager

 SJK:tab
BROWN AND CALDWELL
                   P.O. BOX 11680 EUGENE, OREGON 97440
2300 OAKMONT WAY SUITE 100 EUGENE, OREGON 97401  (503) 686-9915
ATLANTA  DALLAS-FT. WORTH DENVER  EUGENE, PASADENA. ; SACRAMENTO SEATTLE:: TUCSON :: WALNUT CREEK  WESTWOOD

                                   B-2

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     Appendix C
       Final EIS
Distribution List

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      METROPOLITAN WASTEWATER MANAGEMENT COMMISSION  EIS DISTRIBUTION LIST
CONGRESSMEN
FEDERAL AGENCIES
STATE AND LOCAL
OFFICIALS AND
AGENCIES
LIBRARIES
Senator Mark Hatfield
Senator Bob Packwood
Representative Jim Weaver

Advisory Council on Historic Preservation
U.S. Department of Agriculture
  Soil Conservation Service
U.S. Department of Commerce
  National Marine Fisheries
U.S. Department of Defense
  Corps of Engineers, Portland District
U.S. Department of Health and Human Services
U.S. Department of Housing and Urban Development
U.S. Department of Interior
  Fish and Wildlife Service
  U.S. Geological Survey
U.S. Department of Transportation
  Federal Aviation Administration

Governor of Oregon
Mayor of Eugene
Mayor Springfield
Mayor of Coburg
Mayor of Junction City

Oregon Department of Environmental Quality
Oregon Land Conservation and Development Commission
Oregon Department of Fish and Wildlife
Oregon Department of Water Resources
Oregon Health Planning and Development Agency
Oregon Department of Transportation
Oregon State Historic Preservation Office
Oregon State Clearinghouse
Lane Council of Governments
Lane Regional Air Pollution Authority
Lane County Health Department
Metropolitan Wastewater Management Commission
Eugene and Springfield Planning Departments
Eugene and Springfield Public Works Departments
Eugene Department of Planning and Community Development
Coburg Chamber of Commerce
Junction City Chamber of Commerce

Eugene Public Library
Springfield Public Library
Junction City Public Library
          A list of area residents receiving the Final EIS follows:
                               C-l

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Area Residents

Paul Adams
Agri pac
Claude Allen
Steven J. Allen
Mr. & Mrs. Allison
Arl Altman
Mr. & Mrs. Bud Andrews
Mr. & Mrs. Andrews
Mr. & Mrs. John Ankeny
Mr. & Mrs. Atkinson

Peter V. Baehr
Jerry & Nancy Balding
Melva Barnes
Gary Beck
Dora! G. Bell
Ral Berfory
Glen Berkshire
Richard Beverly
Charles Y. Blaine
Steve & Debra Blexseth
Arnold Bodtker
Mrs. Eugene Bohanan
Bohemia, Inc.
Richard Borgmeier
Katherina E. Bowder
Mr. & Mrs. Darrell Bowes
Kerry Brough
Ms. Dee Brown
Tim A. Brush
Kathleen Bruton
Bob & Jackie Bryson
Jay & Mabel Bugbee
Jud Buttner

Orin Campbell
Edith Carr
Dennis Cartier
Cascade Fiber
Cascade Plating Co., Inc.
Joseph Cersovsici
Mr. & Mrs. P. S. Chambers
Linda Christensen
Jere Christner
Ralph Cleveland
Chris Cogluth
Bob Coller
James L. Conner
William E. Connor
 Doug Cook
 William & Anita Cook
 Steve Cooper
 Christina Corelli
 J. Covington
 Clark W. Cox, Jr.
 L. B. Crayton
 Jim & Jan Cronk
 Gary Cruzan
 Ronald Curtright

 Dairy Technology
 Lynn & Jeffrey Davis
 Ruth I. Davis
 Eddie De La Vega
 Ernie Dennis
 Jeno De Piero
 Mr.  & Mrs.  Detato
 Donald C.  Dickey
 Carl  Dipaolo
 George M.  Dipprey
 Betty Donaldson
 Robert Dooley

 Gerald Edwards
 D. W.  Eisele
 Gordon Elliott
 Mr.  & Mrs.  Thomas Ellis
 Joyce Engels
 Emmet Engeman
 Dianna M. Ersinger
 Esther R. Everson

 Melody Faber
 C. C.  Fairbanks
 Michael  E.  Farthing
 Mr. &  Mrs.  Robert Farver
 Eric  Fischer
 Mrs.  Lyman  Fisk
 Jack  Flint
 Jeanette Flynn
 I. Forneel
 Mr. & Mrs. Herbert Fortner
 Faye Foster
 Everett Fox
Marl in & Shirley Franssen
Vance Freeman

F. E. Gallaher
Ernest J. Garrett
Howard Gay
                                  C-2

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William Gilliam
Earl Gingerich
Kinly Good
Terry C. Gould
Marie Gray
Charles Grimes
Gerald Grimes
Mr. & Mrs. J. E. Grove
Helen & Bob Gwozdz

Mr. & Mrs. David Haag
Mr. & Mrs. K. G. Hagdahl
Rick Hammond
Tim Hanley
Beverly Harper
Warren Harper
Ray Harrison
H. Harrold
Geneva Harwood
Rhonda Harwood
Jon Haterius
Tom & Vora Heintz
Lynn & Ron Heitz
L. Hellwege
David Henderson
Dean Hennigan
Charles Hepner
Rita Hepner
P. Sydney Herbert
Paul Hillwege
Randall Hledik
Pat Hocken
Edward Hoffman
H. L. Hostick
Howard Humphrey, Jr.
Howard Humphrey, Sr.
Liz Hunter

Elmer C. Ingle
J. R. Ireland

Mr. & Mrs. Warren Jacquenod
Derek & Diane Jaros
Richard Jenson
Miriam Jeswine
Al Johnson
Donald L.  Johnson
Kimber Johnson
Robert & Bessie Johnson
Coy Jones
Eric Jones
Robin Jones
Dr. William C. Jones
John Jurgens

Jon Kahananui
Bob Kaiser
Donna Kane
Ann & Douglas Kelsey
Donovan Kendall
Lorrayen Kent
Kelly Ketchum
A. J. Ketel
Mr. & Mrs. Clemens Kilwien
Maurice King
Phil L. King
Ed Kinser
Maria Kinser
Daniel & Ann Klemp
Dan Knapp
Bernice Koon
Tim Koon
James Kovack
Steven Krugel
Kathleen Kruse
Mr. & Mrs. J. Kulick

Robert Lacoss
Sharyl LaFleur
Sandra L.  Land
Mr. & Mrs. William Land
Christine  Larson
W. D. Larson
Larry R. Lee
Sandra & Gary  Lee
James M. Lemert
Genna Lemman
Donald & Margaret Lewis
Jim  Long
K. Loreman
Darrell Lowery
John  Lund

Bill  & Nancy MacDowell
Barbara McCormick
Mark  Madison
Grace & Raleigh Manley
Bob  and Amanda Marker
Stanley Martin
Ben  Masengil
Nick  & Maurene Maskal
Mr.  & Mrs. W.  C. Mateson
                                     C-3

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Mr. & Mrs. Leonard Mayer
Alton McCully
Jenny McDole
Melvin McNeill
John Mehringer
Jim Melamed
Julian B. Melerdroz
Bob Meltebeke
Richard Meltebeke
Mr. & Mrs. Dave Mills
Michael & Michelle Mi shier
Douglas Melevin
Cheryl Meng
Mr. & Mrs. Ralph S. Metz
James M. Montgomery, Consulting Engrs.
Hal & Patty Moore
Jim & Gladys Murray

Joel A. Naems
John C. Neely, Jr.
Garry Neil
Nola Nelson
Eleanor Newlan
W. L. Nichols
Mr. & Mrs. W. W. Nightingale
Kay Nordlund

Debbie Odell
Larry Odell
Pat Odermann
John C. Ohm
David 01 and
0. L. Olson
Michael J. Oths
Allen Outland

Dr. Robert Packwood
Greg Page
A. B. Palmitessa
Wallace C. Parker
Garry Patterson
Dan & Joan Payne
Roy Pederson
Richard E. Peterson
Mark Phelps
Rick D. Pieper
Tom & Mary Ann Potter
Laurie Power
F. Printz
Ruth Pritchard
 Paul  & Jonnie Randall
 Cheryl  Reedy
 Rich  Reiling
 Wes Reimer
 Eleanor Reynolds
 E.  R.  Reynolds
 Mr. & Mrs.  R. Richard
 Mr. & Mrs.  Herman  Ricketts
 Rebecca Ricksler
 Mr. & Mrs.  Ridgley
 Michael  Rife
 Milton  W.  Root
 Curtis  Roth
 Gerald  W.  Rust

 Everett G.  Sanders
 Herman  & Helen Sanders
 Sam Saunders
 Don Savoie
 Barbie  Schmidt
 Larry  Schoelerman
 John G.  Scott
 Ken E.  Scoville
 Linda Seals
 Jerry Shanbeck
 James M. Sniffer
 John Shuler
 John Siekert
 Fred Simmons
 Wanda Simmons
 Ben Simpson
 Betty Smith
 Mr. & Mrs.  Elroy Smith
 Lloyd Smith
 Marshall &  Alice Smith
 W.  H. Smith
 C.  Snellings
 El wood Soasey
 Ted & Elizabeth Soptelean
 Scott Spearman
 N.  W.  Spurgeon
 George Steele
Jack Stepp
 Nicke Stevenson
William Stevenson
 Mike Stoltz
 Ruby Stone
Mr. & Mrs.  Chester Stoner
John C. Stoner
Dave & Jocelyn Stram
Joel Strandlian
                                    C-4

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 Ken  &  Sylvia  Stursa
 Beryl  Sunderman
 Survival  Center,  Oregon  U
 Russell E.  Svingen
 William Swan
 Chester Swenson
 Vern Swenson
 Randy  Sweet

 Jack Thomas
 Carol  Thompson
 Charles W.  Thompson
 Lawrence  Thorp
 Barbara Tooley
 Daniel Tucker
 Myra Tucker
 Mary Tull
 Steve  A.  Tyler

 Gene Vaillancourt
 Agnes  Van Devender
 Mark Van  Valkenburgh
 Edward &  Ethel Vogt
 Van  Volk  Residence

 Jim  Wade
 H. H.  Waechter
 Rod  Wagner
 Dave Walker
 Don  Walker
 Ray  V. Walter
 Keith  Walton
 Dave & Page Walton
 Robert D. Warner
 D. Michael  Wells
 Steven Wells
 W. Wernicke
 Mark Westling
 Mr.  &  Mrs.  Mike Westrope
 Carl  A. Wheeler
Jeff White
Marie  Whitson
 Steven &  Nancy Wilhite
Darin  & Monte Wilson
 Don  Wobbe
John Wofford
Curtis Woodruff
John R. Woodruff
 Bill  Wooten
Gary Wright
Ken & Judy Wullenwaber

W. R. Yates
Harold Youngquist

Don Ziegler
                                      C-5
                                          * U.S. GOVERNMENT PRINTING OFFICE: 1984 795-611

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