FINAL
IMPACT ST/YTKMK NT
Sl/JtXSS DISPOSAL ALTERNATIVE
PROTECTION AGENCY
JOHN F. KENNEDY FEDERAL BUILDING BOSTON, MA. 02203
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
SLUDGE DISPOSAL ALTERNATIVES
SOUTH PARIS, MAINE
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
SLUDGE DISPOSAL ALTERNATIVES
SOUTH PARIS, MAINE
This Final Environmental Impact Statement summarizes
the analyses performed, the principal conclusions,
and the remaining areas of controversy which have arisen
during the study. No final recommendations are proffered
The EIS defers to the ongoing facilities plan 'for a more
definitive proposal.
Further information on this statement can be provided by:
Mr. Robert Mendoza
Environmental Protection Agency
Environmental and Economic Impact Office
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
617-223-4635
-LEAD AGENCY-
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region I
JFK Federal Building
Boston, Massachusetts 02203
Technical Consultant
Anderson-Nichols & Co., Inc.
Boston, Massachusetts
Approved by:
JAN-7 «80
V'
William R. Adams, Jr.(\ Final Date by Which
Regional Administrator VJ Comments on the Final
Environmental Protection Agency Must be Received
Region I
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TABLE OF CONTENTS
Section Page
SUMMARY ......................... ii
I. PURPOSE AND NEED .................... 1
A. Background ..................... 1
B. Characterization of the Sludge Disposal
Problem ....................... 2
C. The Draft Environmental Impact Statement ...... 3
D. The Need for Further Facilities Planning ...... 5
II. RESPONSE TO COMMENTS . ................. 6
A. Site Preference ................ ... 6
B. Maine DEP Comments ................. 6
C. Analysis of Other Alternatives ........... 8
D. Summary ....................... . 9
III. FACILITIES PLANNING STUDY
A. Short Term Sludge Disposal ............. 11
B. Long Term Sludge Management ............. 13
IV. CONCLUSION ....................... 15
APPENDIX: Comments to Draft EIS ................. 16
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SUMMARY
The South Paris, Maine Water Pollution Control Facility is a combined
Industrial and Municipal treatment plant serving the town and, primarily, the
A.C. Lawrence Company tannery. Consequently, the sludge produced by the
facility is chemically complex, containing high concentration of chromium
and other tanning agents and residues, and creates special disposal problems.
The purpose of this Environmental Impact Statement is to evaluate disposal
options for the potentially hazardous sludge.
During preparation of the statement, intensive investigations were
devoted to the A.C. Lawrence site, where sludge dumping from the tannery and
later sludge trenching from the treatment plant has occurred for many years.
This effort was intended to characterize the scope of environmental impacts
caused by historical sludge disposal and to determine probable impacts if
alternative sites and disposal methods were employed.
A detailed review was also conducted of the Ryerson Hill site, where a
preliminary design and plan of operation had already been proposed by the Paris
Utility District for sludge disposal. The review was based primarily on infor-
mation developed in Hearings conducted by the Maine Board of Environmental
Protection on the PUD's application for a permit to use the Ryerson Hill site.
In addition the study briefly reviewed the alternatives of incineration,
chemical sludge conditioning, surface spreading, and composting for feasibility
and cost. Only the first two were judged feasible given the sludge's current
chemical composition and water content.
Principal Conclusions
The Draft Environmental Impact Statement issued in October, 1977, offered
no recommendations for final sludge disposal. Instead, it concluded that both
the Lawrence and Ryerson Hill sites could be environmentally acceptable loca-
tions for sludge trenching.
The Lawrence site was judged to be lower in risks, both environmentally
and financially. Detailed investigations failed to show significant environ-
mental impacts from many years of historical sludge dumping and trenching. Esti-
mated costs for the site were also the lowest of the alternatives considered.
However, the site lies within the recharge area of a major aquifer serving as
the principal source of potable water for the region. Hence the consequences of
any future leaching of contaminants could be severe. In addition, the site con-
tains only a small amount of usable land and would have to be expanded to support
continued sludge disposal.
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The Ryerson Hill site would be much more complex and expensive to
operate, since a drainage system would be necessary to remove groundwater.
Because such a drainage system is unproven and artesian springs, if present,
might prevent its effectiveness, the site poses risks of inoperability and
of contamination of streams and brooks in the vicinity.
Incineration and chemical sludge conditioning were found to be much
more costly than direct land disposal options. In addition, both would
require land disposal of the resulting residue ash in the case of incinera-
tion and the treated sludge for chemical conditioning. Hence the potential
threat of water quality degradation through leachate formation would still
exist under these options.
Areas of Controversy
The principal controversy over the Draft EIS concerned the investiga-
tion of the Lawrence site. The Maine Department of Environmental Protection
disputed the geologic and hydrologic analyses and urged further work to
identify leachate plumes from the historical disposal areas. The DEP also
asserted that any potential threat to the nearby aquifer was unacceptable.
Consistent with this view, the Maine Board of Environmental Protection ordered
the Lawrence site closed as of June, 1979.
A second area of controversy concerned the assessment of alternatives
to land disposal, particularly incineration and chromium recovery. It was
noted that more efficient sludge dewatering could greatly reduce operating
costs of incineration by minimizing auxiliary fuel requirements. In addition,
new processes are under testing for recovery of chromium from incinerator
ashes, thus allowing further cost reductions and reducing problems of ash
disposal. Several respondents also identified chromium recovery or recycling
as the ideal means of conserving a valuable resource while reducing environ-
mental threats.
Resolution of Issues
The response to the Draft EIS has made it clear that further study of
sludge disposal options in South Paris is required. The Board of Environmental
Protection's closure of the Lawrence site, coupled with grave drawbacks of the
Ryerson Hill site, preclude recommendation of either as a sludge disposal option.
Indeed, the character of the sludge suggests any direct land disposal option
will pose some environmental threat to water quality in the region.
At the same time, it appears that emerging new technology for sludge
dewatering, incineration, and chromium recovery may soon alter the economics
of more complex sludge management options. These options, however, may require
modification of treatment facility operations, equipment, and inputs from the
tannery. They could not be considered in depth in this EIS.
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Consequently, a Facilities Planning study was initiated in December,
1978, to seek short term options for sludge disposal after the Lawrence site
is closed, as well as long term prospects that could be made environmentally
safe and economically acceptable with a combination of new technology and
altered operations of the treatment plant and the tannery. This study is
scheduled for completion in the summer of 1979.
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I. PURPOSE AND NEED
A. Background
Q>(ln 1973, the U.S. Environmental Protection Agency undertook to con-
struct a secondary wastewater treatment facility with the Paris (Maine).
Utility District^ The facility, ([intended primarily to alleviate water
quality problems caused by effluent from the A.C. Lawrence Tannery>,(£began
operation in June, 1975.
EPA's original environmental review of the treatment facility plans
concluded that the project would have net beneficial effects and a negative
declaration of environmental impacts was prepared. Subsequently, however,
the Maine Board of Environmental Protection refused the Utility District
permission to dispose dewatered sludge from the treatment facility at the
intended (and previously used) site. Construction of. the treatment plant
itself was approved and temporary permission granted to continue sludge
disposal at the original landfill while a new site was located^
t
The Paris Utility District initiated a study of alternative landfill
sites. A total of six locations were reviewed, including the original site,
although only three received detailed study. Based on this evaluation the
Utility District applied to the Board of Environmental Protection for per-
mission to dispose the sludge on a 52-acre tract in the Ryerson Hill area,
some eight miles from the treatment facility. Plans were submitted for
permanently lowering the perched groundwater table on this site (currently
at a depth of one to three feet) to insure that an adequate layer of dry soil
would underlie the sludge and prevent leaching of pollutants into the ground-
water.
The Board of Environmental Protection held five days of public hear-
ings on the application during the summer and fall of 1975. Some 1200 pages
of testimony were taken. The principal controversial issues as cited by the
board in its findings were:
effectiveness and impact of lowering the groundwater,
table;
leaching of pollutants from the sludge and their entry
into groundwater or surface waters; and
traffic problems caused by sludge haul trucks and the
ability of the trucks to continue operations, year-round.
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Following the hearings, the board approved the application subject to several
requirements, including a detailed erosion control plan, proof that the pro-
posed drainage system would lower the groundwater table at the site, and a
detailed monitoring program to insure that water quality standards would be
met.
The Board of Environmental Protection is limited by Maine statutes to
evaluation of the single site submitted by the applicant. EPA's original
environmental assessment and negative declaration had not considered sludge
disposal at the Ryerson Hill site. Several local citizens requested an
Environmental Impact Statement fully investigating sludge disposal alterna-
tives. The Board of Environmental Protection concurred that an EIS would be
helpful, and urged that the study be conducted immediately in view of the long
delays already experienced in choosing a disposal site and method. An initial
public workshop was held on July 8, 1976, to discuss the objectives and scope
of the study. In August, EPA contracted with EIC Corporation of Newton, Mass.
to perform the necessary analyses.
B. Characterization of the Sludge Disposal Problem
Sludge generated by the South Paris wastewater treatment facility is
unusual because of the character of the influent to the facility. Currently,
some 90% of the raw wastewater originates at the A.C. Lawrence Company's top-
side leather tannery in South Paris, with the remaining 10 percent representing
ordinary sanitary sewage and cannery effluent. As a result, the waste stream
entering the treatment facility has a high solids content and high concentra-
tions of chromium and other constituents used in the tanning process.
The treatment facility combines primary sedimentation with a carbonation
step and secondary biological treatment. Separate sludges are generated from
each of the three treatment steps; primary and carbonation sludges are combined
and centrifuged and the resulting dewatered solids are carried by conveyor belt
to storage and transport containers where they are combined with centrifuged
waste activated sludge.
The facility was designed to treat a chemically complex influent with
essentially conventional processes. It has experienced intermittent opera-
tional problems since the tannery effluent was brought on-line in September of
1975. The origin of these problems is not fully understood. One result, how-
ever, has been bulking of the plant. As a consequence, secondary (waste-
activated) sludge was not being produced during study period. The primary and
carbonation sludge currently has a dry solids content of only about 14 percent;
design levels were 30 to 35 percent for primary sludge and 22 percent for com-
bined, final sludge.
The general elements of the sludge disposal problem, therefore, may
be summarized as follows:
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the sludge has a complex chemical composition,
the ultimate composition and volume of sludge to be
disposed are currently uncertain.
The complexities and uncertainties make choice and evaluation of disposal
alternatives unusually difficult, since criteria and conclusions applicable
to typical sludges are unsuitable In this case.
Disposal options for current and future sludges from the Paris waste-
water treatment facility are also closely tied to the impacts of many years
of waste disposal at the historical A.C. Lawrence site. Prior to construc-
tion of the treatment facility, this site was used for surface dumping of
sludges from the tannery's settling ponds. Since the treatment plant began
operation in 1975, it has been used for trenching of the resulting sludge.
Hence the site offers an opportunity for in situ analyses of environmental
Impacts and was therefore subjected to intensive field investigations. As
data on the characteristics and fate of sludge disposed at the Lawrence site
were generated, alternative options for disposal were concurrently evaluated.
C. The Draft Environmental Impact Statement
These investigations culminated in the issuance of a Draft Environ-
mental Impact Statement (DEIS) on sludge disposal options in October, 1977.
The principal findings of the Statement, however, had been summarized in a
Public Workshop held in South Paris the previous March.
In that Workshop, the following major conclusions were offered:
The Lawrence and Ryerson Hill sites are representative of
the geology and hydrology of the two types of disposal
sites available in the area: lowland or valley areas and
upland or hillside areas.
As a lowland area, the Lawrence site lies within the direct
recharge zone of a major aquifer within the Little Androscoggin
River Valley. Hence the principal environmental risk of sludge
disposal on such a site is contamination of this aquifer, which
serves as the principal source of potable water for the region.
Despite this risk, no evidence was found of any significant
groundwater contamination as a consequence of the 20 years
of tannery and treatment plant sludge disposal on this site.
As an upland area, the Ryerson Hill site lies in the watershed
of several brooks and streams that originate and traverse the
hills of South Paris. The principal environmental risk of
sludge disposal there is contamination of these streams, which
are pristine in quality and support many species of wildlife.
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Because it would require a special and unproven drainage
system to remove perched groundwater, the Ryerson Hill
site is more expensive as a sludge disposal option than
the Lawrence site, and poses significant threats to local
surface waters.
Other disposal methods chemical sludge conditioning and
incineration, in particular would be substantially more
expensive than land disposal by trenching, and would not
eliminate the need for land disposal of the eventual solid
wastes.
Detailed findings supporting these conclusions may be found in the Draft
Environmental Impact Statement, which is incorporated by reference herein.
At the Public Workshop, representatives of the Maine Department of
Environmental Protection (MDEP) expressed reservations about the Lawrence
site findings and requested additional data and analyses. Publication of
the DEIS was postponed through the spring and summer of 1977 while these
requests were addressed. Finally in September, an independent geological
expert, Dr. Harold W. Borns, Jr., Director of the Institute for Quaternary
Studies, University of Maine at Orono, was requested to evaluate the methods
of investigation and findings relating to the Lawrence site.
Dr. Born's review (see the Appendix) indicated that "... the geologi-
cal investigation in question was carried out by competent scientists, the
methodology was correct, and the geological definition of the site was
accurate." The DEIS was published in October.
Publication of the Draft Impact Statement and the related Public Hearing
on January 4, 1978, however, failed to resolve the controversy over sludge
disposal options. Most public and agency reviews agreed with the DEIS findings
and urged continued sludge disposal at the Lawrence site and environs. The
MDEP, on the other hand, remained in disagreement with the study's methods
and findings and urged further investigations.
In August, 1978, Maine State Geologist, W. Bradford Caswell reviewed
the DEIS upon the request of the Board of Environmental Protection. His
memorandum (see Appendix) noted that, "None of the geologic information pre-
sented indicates that a hydrologic barrier exists between the A.C. Lawrence
sludge disposal site and the major gravel aquifer..." and that the groundwater
sampling results "... leave room for doubt [about impacts to the aquifer] where
no doubt should exist."
While the controversy continued in 1978, several additional reasons
for further study grew more evident. The South Paris treatment facility
remained unable to achieve its design criteria for pollutant removal as well
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as sludge de-watering; an evaluation of the facility's inputs and operations,
rather than sludge composition and disposal alone, appeared necessary.
Information on new incineration technology in testing for chromium-laden
tannery wastes indicated that treatment plant modifications coupled with
a chromium recovery process might make incineration a more attractive
alternative than previously thought. Within the Environmental Protection
Agency itself, new regulations and guidelines for the disposal of sludges
were in preparation, and their impact on the South Paris problem was uncer-
tain. Lastly, the Lawrence site, which had continued as a trenching location
under temporary permits, was rapidly running short of usable land, leaving
the Paris Utility District without a clearly acceptable replacement.
D. The Need for Further Facilities Planning
This combination of events made it evident that a long term solution
to the South Paris sludge disposal problem was neither immediately obtainable
nor within the scope of the original Environmental Impact Statement. On the
contrary, a more fundamental study of potential modifications to the treat-
ment facility, their effects on sludge composition, and the implications
for final sludge disposal was required.
During the summer of 1978, the EPA determined that such a study should
proceed and authorized the Paris Utility District to seek an engineering
contractor. In September, the firms of Jones and Beach, Engineers and the
Environmental Assessment Council, Inc., with Dale E. Caruthers Company as
subcontractor, were selected for the investigation. These firms were
authorized to proceed with the work in December, 1978.
Given the above series of events, no purpose would be served in this
Final Environmental Impact Statement by reiterating earlier analyses or
recommending an action. The DEIS fulfilled critical needs in providing a
substantial empirical data base on the problem, in offering an adequate
forum for public inputs to the decision-making process, and in highlighting
the complexity of the situation. Now that additional studies are underway,
this Statement need only respond to substantive comments on the Draft and
briefly summarizes the objectives of on-going analyses.
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II. RESPONSE TO COMMENTS
The Draft Environmental Impact Statement stimulated a substantial
body of comments from agency reviewers and the general public. Rather
than responding to these comments individually, the following section
summarizes and addresses the principal areas of concern. Copies of all
substantive written comments are appended.
A. Site Preferences
Perhaps the most frequently expressed response to the Draft EIS was
opposition to the Ryerson Hill site for sludge disposal. In addition to
the risks of surface water contamination and higher than expected costs
specified in the Impact Statement, local residents evidenced concern about
esthetic effects of sludge trucks passing through the historic Paris Hill
District, the adequacy of roads leading to and from the site, and the
possibility that road improvements might be necessary, thus altering the
character of Paris Hill.
In conjunction with such criticisms of the Ryerson Hill site, many
respondents actively favored continued use of the Lawrence site for sludge
trenching. They cited the long history of disposal there without evidence
of significant environmental impacts and low operating costs as the main
points in support of continued activities at the site.
These comments follow directly from the findings presented in the
Draft EIS, which suggested that the Lawrence site is lower both in environ-
mental risks and in probable costs than the Ryerson Hill site. In view of
these findings, several respondents questioned the lack of a recommended
action in the Draft EIS.
This lack, and indeed the procedures followed in publishing the DEIS,
were strongly influenced by the position of the Maine Department of Environ-
mental Protection. Hence a summary of and response to this position is
required.
B. Maine PEP Comments
The Maine Department of Environmental Protection's comments, as
expressed in the February 5, 1978 letter of Arthur R. Day, indicate sub-
stantial disagreement with the DEIS on the suitability of the Lawrence site
for sludge disposal. These disagreements, as noted above, actually date
back to the spring and summer of 1977, during which major efforts were made
to resolve the situation.
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The major concern of the DEP is that the impacts of sludge disposal
at the Lawrence site have not been fully determined. This concern derives
from the following specific issues:
that the geologic and hydrologic analyses of the site
were in error;
that monitoring wells on site were consequently placed
upstream rather than downstream of sludge disposal
areas, thus preventing detection of leachate;
that vegetative uptake of chromium suggests more substantial
transport than stated in the DEIS;
that additional field work on site is necessary to clarify
these issues; and
that the aquifer in the Little Androscoggin River Valley
be protected from any potential source of pollution.
The response of EIC Corporation, EPA's contractor responsible for
the Lawrence site evaluation, is as follows:
Geologic analyses of the Lawrence site were conducted
jointly by four professional geologists and reviewed by
a leading expert in Maine glacial geology. The geologic
and hydrologic characterization of the site is fundamentally
correct.
Monitoring wells were placed not only in location judged to
be downstream of sludge disposal areas but also directly
beneath these areas. Since no evidence of significant ground-
water contamination was found in any of the wells, there is
little chance that a leachate plume was missed.
The vegetative uptake of chromium follows surface contours
of the site and is easily explained by surface runoff as the
transport mechanism.
Additional field work, unless conducted at a substantial level
of effort over an extended time, is unlikely to improve sig-
nificantly the current characterization of the Lawrence site.
Continued use of the Lawrence site for sludge disposal does
not appear to be an active threat to the regional aquifer.
However, the potential for groundwater contamination will
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always exist while sludge remains in place on the site*
This potential appears slight, but it cannot be elimi-
nated and must be judged against the risks and costs of
alternative disposal methods.
After reviewing the objections of the DEP and EIC Corporation's
response, as well as the comments of Mr. Caswell and others, EPA has
concluded that the acceptability of the Lawrence site is a matter of
legitimate technical dispute. Moreover, technical disagreement notwith-
standing, the essence of the decision rests on the potential threat to a
major regional aquifer. That such a potential threat exists is not at
issue, and the complexities of the sludge in question, as well as of the
geology and hydrology of the site, make meaningful quantification of this
risk very difficult. Under these circumstances, further study is clearly
necessary to define lower risk alternatives in greater detail. In particu-
lar, a short term means of discontinuing disposal at the Lawrence site is
desirable.
C. Analysis of Other Alternatives
Several respondents raised questions about alternatives other than
land disposal at the Lawrence or Ryerson Hill sites. The principal comments
were as follows:
The evaluation of incineration in the Draft EIS assumed
continued production of sludge with 15 percent dry solids.
If improved operation of the treatment facility could
achieve the design goal of 22 percent solids content,
incineration might be a more attractive disposal option.
The Draft EIS touched upon but did not analyze in detail
chromium recovery or recycling as an element of the sludge
disposal system.
Land disposal with leachate collection and treatment was
not evaluated in detail.
These comments are all well taken.
The two principal drawbacks of incineration expressed in the Draft EIS
were high costs relative to direct land disposal and the continued need to
dispose of chromium-laden ash. It is entirely correct that production of
dryer sludges would reduce the former problem by eliminating some $50,000 per
year in fuel costs, but because of the substantial capital investment required,
incineration would remain a relatively expensive option. And at the time the
Draft was issued, no evidence of improved sludge dewatering capability was
available, so the more conservative approach to cost estimation was appropriate.
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The problem of ash disposal is directly tied to the issue of
chromium recovery as an option. At the time of the Draft EIS, no proven
method of recovering useful chromium from incinerator ash was available.
However, several processes are currently being tested and, if successful,
could not only reduce the problem of chromium in the ash but also sub-
stantially improve the economics of incineration.
The specifics of such an approach, are also tied to the operations
of the treatment plant, as well as the quantity of chromium discharged
from the tannery. At the Public Hearing on January 4, 1978, A. C. Lawrence
Company representatives indicated that the South Paris tannery was recycling
some 50 percent of its chromium effluent and hoped to increase that percen-
tage. However, they also stated that complete recycling is not feasible.
Hence some chromium will continue to enter the treatment plant and influence
the sludge disposal problem.
These uncertainties could not be resolved within the scope of the
Draft EIS because they require further facilities planning to integrate
production of a drier sludge based on known chromium inputs, incineration
of that sludge, and recovery of the chromium to reduce costs. They were a
major consideration in the decision to undertake further facilities planning.
The option of leachate collection and treatment in conjunction with
land disposal of the sludge was viewed in the Draft EIS as an expensive
last resort. In view of the uncertainties since expressed, however, and
because such precautions may be required by regulation in the future, this
option has become relevant and is under study in the on-going facilities
planning effort.
D. Summary
Comments on the Draft Environmental Impact Statement may be briefly
summarized as follows. Despite considerable public opposition to the
Ryerson Hill site and support for the Lawrence site, technical uncertainties
prevent continued use of the latter site and its immediate surroundings for
conventional sludge trenching. Objections to the site are based on concerns
about potential hazard to a major regional aquifer, concerns that EPA shares.
Unfortunately, however, if the Lawrence and similar lowland sites are
ruled out, then direct land disposal as the simplest and least costly alter-
native depends on use of an upland site like Ryerson Hill, where environmental
hazards are also severe. Hence the more complex and costly alternatives that
were briefly evaluated in the Draft EIS require detailed analysis. This is
best accomplished through additional facilities planning, in which the com-
bination of tannery effluent, treatment plant operations, sludge composition,
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and sludge disposal can be examined systematically. Such planning can also
take into account the rapidly evolving new resource recovery technologies as
well as changing regulatory guidelines for disposal of sludges.
The following section briefly summarizes the'major elements of the
facilities planning now underway.
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III. FACILITIES PLANNING STUDY
Out of the findings of the Draft EIS and the comments to the Draft
emerged a clear need for further study of sludge disposal options in
South Paris. In particular, a return was necessary to the facilities
planning stage of the construction grants process, so that interrelated
problems of tannery effluent, treatment plant operations, sludge produc-
tion, and sludge disposal problems that were not fully characterized
at the time of the original facilities planning study could be addressed
systematically.
It was also evident from events to date that these problems are
best approached with two time frames in mind. The short term goal must
be simple, safe disposal of the sludge as it is now produced by the
treatment facility, so that the Paris Utility District can effect a smooth
transition as the current Lawrence site is closed. Longer term, however,
the goal must be to explore modifications to existing facilities and
operations that will support an optimum sludge management program.
Both time frames are being addressed in the Facilities Planning
Study initiated in December, 1978. Figure 1 shows the organization and
major elements of this study.
A. Short Term Sludge Disposal
In the short run, no major modifications to the treatment facility
and the sludge it is now producing are possible. Yet this sludge must be
disposed in an acceptable fashion while longer term options are evaluated.
The only feasible short term method is continued land disposal; hence
new sites must be analyzed to replace the Lawrence site when it has been fully
utilized and closed. However, it is also feasible to reduce the water con-
tent of the sludge by mixing it with additional dry wastes and to secure the
land disposal operation by providing for leachate collection and treatment.
These options are being considered together with alternative sites
for whatever land disposal method is selected. Up to six new sites will be
evaluated in a preliminary fashion based upon:
Land availability
General geologic and hydrologic conditions
Site life and life cycle costs
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Existing
Sludge
Modified
Sludge
Interim Solution
(Landfilling or Storage)
Final Solution
Sludge Management System Development
T
A.C. Lawrence
Site
Incineration
Composting
Ryerson Hill
Site
L
J
Marketing
1
Land Spreading
Landfill ing
Public Hearing
Other Sites
Public Meeting
(Input and Discussion
of Viable Sites)
Selected
Sludge Management
System
Public Meeting
(Input and Discus-
sion of Viable
Alternatives)
Public Hearing
Figure 1
Implementation
Enyifonmentafl Assessment Council, Inc.
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Probable environmental impacts
Planned new regulations
Following the preliminary analysis, one site will be chosen for in-depth
study. The investigation will include groundwater conditions and sub-
economic factors, and historical or archeological factors. If the selected
site offers safe and cost-effective sludge disposal, preliminary develop-
ment plans and an application for site approval will be prepared for
submission to the Board of Environmental Protection.
B. Long Term Sludge Management
To provide more options for sludge management, the long term portion
of the study must begin with an updated characterization of the sludge's
composition and an evaluation of how this composition might be favorably
altered. The first stage of this effort involves potential changes to the
tannery's effluent. Possibilities to be studied include:
Use of chromium fixatives
Further recycling of chromium liquors
Use of non-sulfide depilatory agents
Installation of a sulfide oxidation or recovery system
The impacts of such changes on both the tannery's operations and treat-
ment plant operations are under study, with the goals of improving effluent
quality while reducing chromium content and sulfide emissions from the sludge.
Effects on treatment plant costs will also be determined.
The feasible modifications to sludge composition will determine what
sludge management options may be viable in the long run. In principal,
these options include incineration, land spreading and composting, as well
as direct land disposal through trenching or area-filling.
Principal questions regarding incineration are the actual combustion
properties of the sludge and the effectiveness of chromium recovery methods
in treating the resulting ash. To answer these questions, the current study
includes incineration testing of the sludge, analysis of chromium recovery
from the resulting ash, and cost estimates for incineration for the current
as well as modified future sludge. The study is also investigating potential
combined incineration with the Saco, Maine, treatment facility sludge, as well
as co-incineration with other solid wastes at the proposed Lewiston-Auburn
Incinerator.
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Land spreading as a viable option will depend on prospects for
modifying the sludge to reduce chromium content. If such reduction proves
possible, the current study will assess area requirements and site availa-
bility, evaluate probable heavy metal build-up and migration mechanisms,
and investigate potential site uses to immobilize hazardous sludge con-
stituents. The potential for implementation will be evaluated through
comparison with land spreading practices in other areas to determine
probable environmental impacts and costs.
Composting also depends on the sludge's ultimate chromium content
as well as its moisture content. Special needs for pre-treatment will be
determined and their costs estimated. Ultimate disposal of the finished
compost will be examined through a market survey to determine quantities
that can be readily absorbed by local activities. Several alternative forms
of composting will be compared for efficiency and cost when applied to the
South Paris sludge.
When all potential long term sludge management options have been
characterized, they will be compared on the basis of probable environ-
mental impacts and costs. Public comments and suggestions will be sought
prior to recommending an alternative for implementation. Such as recom-
mendation, together with a proposed timetable will be submitted together
with the overall findings of this study.
The study is scheduled for completion in the summer of 1979. Its
work plan calls for a series of public workshops and hearings to provide
continuous access to technical findings and conclusions as well as ample
opportunities for public response. It is hoped that the final recommenda-
tions will provide both short and long term solutions to South Paris' sludge
disposal problems.
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IV. CONCLUSION
The issue of sludge disposal for the South Paris wastewater treat-
ment facility has continued now for some four years without final resolution.
The process of evaluating alternatives, reviewing them with the public and
government agencies, and seeking a concensus on the appropriate action has
been long, time consuming, and often frustrating.
It is important to recognize, however, that the problems involved
are both atypical and highly complex. The chromium and water content of
the sludge, the operating difficulties of the treatment plant, and the,
geology and hydrology of the area combine to create major uncertainties
about the environmental consequences of any disposal alternative.
The environmental review process of which this impact statement is a
part has been aimed at developing information to support a sound decision.
There is no simple way of judging when the available information is suffi-
cient. In this case, some uncertainty is likely to remain no matter how
much effort is devoted to studying the problem. The lack of concensus by
responsible participants of the process, however, has indicated that addi-
tional investigations can provide relevant new information.
At the Public Hearing on the Draft EIS, a local resident called the
water of the area a precious resource and urged, "Don't gamble with it!"
If this Statement has failed to offer a positive solution to the sludge
disposal problem in South Paris, it has also prevented any unwise gamble
with the water quality of the area. As intended by the National Environmental
Policy Act, the review process has provided both citizens and institutions
with a forum for exchange of information and opinion. As a consequence, the
search for an adequate sludge disposal plan continues. With perserverance by
all involved, the search will succeed.
15
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APPENDIX
Comments to Draft EIS
16
-------
Index of Comments
Author
Professor Harold W. Borns
Earle G. Shettleworth, Jr., State Historic Preser-
vation Officer
Stephen M. Diamond
Vernon S. McFarlin
i
Charles A. Berg (1)
Charles A. Berg (2)
Charles A. Berg (3)
L. K. Barber and W. E. Marshall, A. C. Lawrence
Leather Company, Inc.
Lajos and Claire C. Matolcsy (1)
Lajos and Claire C. Matolcsy (2)
Warwick M. Tinsley, Jr., State Conservationist,
Soil Conservation Service
~«
Suzanne Thorndike
Remi Jurenas, State Clearinghouse Coordinator
William L. Lucas, Resource Conservationist, Environmental
Protection Agency
Charles N. Smith, Whitman and Howard, Inc.
James B. Stewart
William Patterson, Department of the Interior
Donald K. Mason
Date
9/19/77
11/28/77
11/30/77
12/2/77
12/8/77
12/18/77
12/18/77
12/20/77
12/20/77
12/21/77
1/9/78
1/10/78
1/10/78
1/12/78
1/13/78
1/17/78
1/20/78
1/22/78
17
-------
Index of Comments
(continued)
Author
Miss Edwlne Guyer and Mrs. Edward R. Guyer
Paris Hill Historical Society
Barbara B. Rideout
Schuyler L. Mott
Dorothy ,Rossman
Bradford H. Jones, Jones & Beach Engineers, Inc.
Judith Berg
Arthur R. Day, Maine Department of Environmental
Protection
Joseph L. Ignazio, U.S.. Army Corps of Engineers
Paris Utility District
Bradford W. Caswell (Memorandum to Henry E. Warren)
Date
1/22/78
1/25/78
1/27/78
1/29/78
2/4/78
2/10/78
2/14/78
2/15/78
2/22/78
5/8/78
8/7/78
18
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UNIVERSITY OF MAINE at
INSTITUTE l-'OKQUATEKNAUY STUDIES ' " "X Ituanlmnn l!:i!I
Pnleoclimnlolopy-I'aleiHjcolojjy-Pri.'hiMorir Archncolu^y . .- './\ Orono, Maine 0 117.'*
September 19, 1977
Dr. Al Makredy, President
EIC Corporation
55 Chapel Street
Newton, MA 02158
Dear Dr. Makredy:
I was asked to examine Appendix C of your report dealing with the en-
vironmental analysis of the A.C. Lawrence Disposal Site, South Paris, Maine;
to visit and evaluate the geology of the site in the field; to comment on
several points concerning the validity of the geological analysis; and to
comment on the methodology used in determining the geology of the site.
The following are the specific areas of concern to be commented upon,
as indicated in Mr. John Attig's letter to me on August 31, 1977.
1. Presence of possible marine deposits in the site:
I find no reason whatsoever to indicate that significant deposits of
marine silt/clay exist at depth in this site. If they do exist, the type
of drilling used and the depth and distribution of the drill holes would
certainly have revealed their presence at depth. In addition, the U.S.D.A.
soil studies as well as geological observations of the surface of the site
would have revealed any surface silt/clay unit. Possibly the sedimentary
unit identified as sand and gravel "outwash" is, in part, of near-shore
marine origin. However, no positive evidence for this was found. In any
event, its origin would have no bearing upon the use of the site. The
grain-size distribution of the "outwash" unit is known and this is the para-
meter significant to the use of the site.
2. Distribution of ice-contact stratified deposits:
I find that the geological cross section of the site (Figure C-2 of
Appendix C) is basically correct.
There is a ridge on the site that, if very casually examined, might
possibly be identified as an esker segment, based upon its ridge topography,
its N-S orientation, and upon the fact that esker segments do exist in the
valley upstream and downstream of the site. However, proper examination
indicates that this ridge is composed of till and that a good deal of the
ridge form is due to a buried bedrock high. Clearly the ridge is not a
deposit of water-laid granular material characteristic of an esker, but
rather it is a veneer of ice-deposited till over bedrock. It is most
probably related to a "crag-and-tail" type of feature in origin.
THE LAND. GRANT UNIVERSITY OK THE STATE OF MAINE
-------
Dr. Al Makredy 2. , September 19, 1977
The deposit identified as Quaternary Ice Contact Deposit (Figure C-2,
Appendix C) is composed primarily of water-laid sand and gravel. The deposit
is clearly in the stratigraphic position indicated on the cross section.
The data indicate that the deposit is of ice-contact origin. Possibly it is
a kame terrace or it may be a segment of the esker system that is present in
the valley. In either case the name is not important compared to the composi-
ti on.
3. Methodology:
The methodology used in defining the geology of this site involves very
standard and well-proven techniques. Furthermore, these techniques are en-
tirely adequate to solve the problems as defined.
4. Ground water table:
Based upon the well-defined geology of the site, and upon the hydrologic
methods used, I feel that the geometry of the ground water table has been
accurately defined.
In conclusion, I feel that the geological investigation in question was
carried out by competent scientists, the methodology was correct, and the
geologic definition of the site is accurate.
If I can be of further help, please feel free to contact me.
Sincerely yours,
P
Harold W. Borns, Jr.,
Professor of Geological Sciences
Director, Institute for Quaternary Studies
HWB/pb
Enc. Vita: HWB
Bill
cc: Mr. John Attig
Androscoggin Valley Regional Planning Commission
70 Court Street
Auburn, ME 04210
-------
Name: Borns, Harold W., Jr.
Birthdate: November 28, 1927
Married: Phyllis C. Kuehl, Jackson 1952
Children: Harold W. Borns, III, Tufts, Class of 1977
Donna J. Borns, University of Maine, Class of 1979
Military Service: 2 yrs. active duty, U.S. Coast Guard, 1946-47
2/c Petty Officer
2 yrs. reserve duty, U.S. Naval Reserve, 1/c
Petty Officer
4 "yrs. reserve duty, U.S. Army, 1st LT.
Education: B.S., Geology, Tufts University, 1951
M.A., Geology, Boston University, 1955
Ph.D., Geology, Boston University, 1959
Post Doctoral Fellow in Glacial and Pleistocene
Geology, Yale University (1963-1964)
Present Position: Professor of Geological Sciences and Quaternary Studies;
Director, Institute for Quaternary Studies
Professional Experience: Instructor of Geology, University of Maine (1955-
1958); Assistant Professor of Geological Sciences, University
of Maine (1958-63); Associate Professor of Geological Sciences,
University of Maine (1963-1968); Professor of Geological Sciences,
(1968-present). Special assistant to the President (UMO) for
Environmental Affairs (1970-71). Chairman, Geological Sciences
(1971-1974); Director, Institute for Quaternary Studies (1974-
present). Visiting Professor, Geologisk Institutt, University
of Bergen, Bergen, Norway (1975).
Membership in Professional Societies: Geological Society of America (Fellow),
Glaciological Society (Member), National Association of Geology
Teachers (Member), Sigma Xi (Member), Phi Kappa Phi (Member),
The Explorers Club (Fellow), American Assoc. for the Advancement
of Science (Member).
Honors: Recipient of the Congressional Antarctic Service Medal (1963).
Borns Glacier, Antarctic - named by the U.S. Board of Geographic
Names (1964).
Research Interests and Activities: Framework of continental glaciation in
the northern Appalachians; Glacial history of Scandinavia; Glacial
history of Antarctica; Late-Pleistocene sea level changes in Maine
and Atlantic Provinces; Sea Level changes and crustal adjustments
following glaciation; Modern and ancient glacial processes; Environ-
ment of Paleo-Indians (early man) in North America; Climatic change
during the Quaternary.
-------
Research Support:
National Science Foundation
NSF-G-18910 (1960) Late glacial history of the northern
Kennebec River Valley, west-central Maine
NSF-G-1125 (1963) Late Wisconsin and Neoglacial history
of Kaskawulsh Glacier, Yukon Territory, Canada
NSF-G-2823 (1964) Significance of a late Wisconsin age
end moraine complex in coastal Maine
NSF (1965) Travel grant, International Quaternary Conference,
Boulder, Colorado
NSF-G-2823 (1966) An extension of 1964 grant
NSF-GA-764 (1967) Postglacial crustal rebound on Baffin
Island, Canada
NSF-GA-1148 (1967) (with B.A. Hall) Age and origin of the
Mawson Tillite, South Victoria Land, East Antarctica
NSF-GA-1563 (1968) Late Pleistocene history of northwestern
Maine
(1969) Travel grant, International Quaternary Conference,
Paris, France
NSF (1970) Travel grant, International Committee on Antarctic
Research-Geology and Geophysics, Oslo, Norway
NSF (1972) (with B.A. Hall) Travel grant, Field conference on
comparative Antarctic and South African geology, Republic of
South Africa
NSF-G-28273 (1973) Detailed C14 Chronology and stratigraphy of
Late Wisconsin fluctuations of the Laurentide Ice Sheet in Maine
and portions of New Brunswick and Quebec
NSF-GA-14388 (1974) (with G.H. Denton) Late Cenoaoic glacial
history of Antarctica; glacial stratigraphy and chronology of
the McMurdo Sound region
NSF-GA-38273 (1975) Extension of NSF-G-28273
NSF-DPP76-23460 (1977) Documentation of the Ross Sea Glaciations:
Events in Wright and Victoria Valleys, Antarctica
NSF (1977) Travel grant, Fourth International Gondwana Conference,
Calcutta, India
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-3-
University of Maine Research Fund
1960-70 Variety of research related to Maine
1972 Internal characteristics of the Ra moraines in the
vicinity of Bergen, Norway
1973 Comparative study of Antarctic and South African
Mesozoic geology
1975 Detailed radiocarbon chronology and stratigraphy of late
glacial fluctuations of the Scandinavian Ice Sheet in Norway
Rockefeller Foundation
Grant to develop an exchange program with the universities of
Bergen, Stockholm and East Anglia for the purpose of enhancing
Quaternary paleoclimatic research
i
Publications
Borns, H.W. , Jr. and Hagar, D.J., 1962 Evidence for a Wisconsin ice advance
into north central Maine (abs): Geol. Soc. America Annual Meeting, p. 20A.
, 1963, Preliminary report on the age and distribution of the late Pleis-
tocene ice in north central Maine: Am. Jour. Sci., v. 261, p. 738-740.
, and Allen, H.W., 1963, A preglacial residual soil in Thomaston, Maine:
Jour. Sed. Petrology, v. 33, p. 675-679.
, (with Stuiver, Minze and Denton, G.H.), 1964, Age of a wide-spread
layer of volcanic ash in the southwestern Yukon Territory: Arctic, v. 17.
p. 259-260.
_, 1965, Late glacial ice-wedge casts in northern Nova Scotia, Canada:
Science, v. 148, p. 1223-1226.
, and Hagar, D.J., 1965, Late-glacial stratigraphy of the Kennebec River
valley from Norridgewock to Solon, Maine: New England Intercoll. Geol.
Conf. Guidebook, p. 45-51.
_, 1965, the Paleo-Indian's geography of Nova Scotia (abs): VII Inter-
national Congress, International Assoc. for Quat. Res.
, and Hagar, D.J., 1965, Late-glacial stratigraphy of a northern part of
the Kennebec River valley, western Maine: Geol. Soc. Amer. Bull.,
v. 76, p. 1233-1250.
_, 1966, An end-moraine complex in southeastern Maine (abs): Geol. Soc.
America Northeastern Meeting, p. 13-14.
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-4-
_and Goldthwait, R.P., 1966, Late-Pleistocene fluctuations of Kaskawulsh
Glacier, southwestern Yukon Territory, Canada: Am. Jour. Sci., v. 264,
p. 600-619
_, 1966, The geography of Paleo-Indian occupation in Nova Scotia: Quaternaria,
v. 15, p. 49-57.
_and Swift, D.J.P., 1966, Surficial geology, north shore of Minas Basin,
Nova Scotia: Geol. Assoc. and Mineral Assoc. of Canada Guidebook,
p. 81-85.
_, 1967, Geology of an end-moraine complex in eastern coastal Maine:
Field Trip Guide, Friends of the Pleistocene, Eastern Section, 30th
Ann. Reunion, 20 p.
_(with Stuiver, Minze), 1967, Deglaciation and early post-glacial sub-
mergence in Maine (abs): Geol. Soc. America Northeastern Section,
p. 59-60.
_(wir.h Swift, D.J.P.), 1967, Raised fluviomarine outwash terrace, north
shore of the Minas Basin, Nova Scotia: Jour. Geology, v. 75, p. 693-710.
_and Hall, B.A., 1969, A reinvestigation of the Mawson Tillite, Victoria
Land, East Antarctica: Antarctic Journal of the U.S., v. 4, 1 p.
_and Hall, B.A., 1969, Mawson "Tillite": In Antarctica: Preliminary
report of a volcanic deposit of Jurassic age: Science, v. 16, p. 870-
872.
_ and Goldthwait, R.P., 1969, (reprint of 1964 article) in; Icefield
Ranges Research Project, Scientific Results, v. 1.
_(with Stuiver, Minze and Denton, G.H.), 1969, (reprint of 1964 article)
in; Icefield Ranges Research Project, Scientific Results, v. 1.
_(with Denton, G.H.), 1970, The form of the Late Wisconsin glacial cycle:
Am. Jour. Sci., v. 267, 30 p.
_and Calkin, P.E. 1970, Multiple glaciation and dissipation of the last
ice sheet in northwestern Maine (abs): Geol. Soc. America, Northeastern
Section, p. 12.
_(with Hall, B.A.), 1970, Jurassic geology of the Allan-Battlements-
Carapace Nuriataks area, Victoria Land, Antarctica (abs): SCAR/IUGS
Symposium on Antarctic geology and solid earth geophysics, p. 71.
_, 1970, Late Wisconsin fluctuations of the Laurentide Ice Sheet in New
England (abs): Geol. Soc. America, National Meeting, p. 499-500.
_and Calkin, P.E., 1970, Quaternary history of northwestern Maine: New
England Intercollegiate Geological Conference Guidebook, p. E2-1 to
E2-6.
_and Calkin, P.E., 1970, Introduction to the Quaternary history in the
highlands region of western Maine, southeastern Quebec, and northern
New Hampshire: New England Intercollegiate Geological Conference
Guidebook, p. 25-26.
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-5-
» 1971, Possible Paleo-Indian Migration Routes in Northern North Am.-rica -
a Geological Approach, Bulletin of the Maine Archaeological Society
v. 11, no. 1, p. 33-39.
and J' D- Ives, 1971, Thickness of the Wisconsin Ice Sheet in southeastern
Baffin Island, arctic Canada, Zeitschrift fur Gletscherkunds u. Glazial-
geologie, Band VII.
. 1971, Late Wisconsin fluctuations of the Laurentide Ice Sheet in
southern and eastern New England, Geol. Soc. America, symposium volume
The Wisconsinian Stage, ±n press.
, 1971, Unpublished
Geological reports to:
State Geologist
State Planner
Application of my research to State problems
(with J. B. McKeon), 1972, A late glacial wind direction for west-central
Maine: Abstracts with Programs, Geol. Soc. America, v. 4, no. 1, p. 31.
(with D. M. Mickelson), 1972, Chronology of a kettle-hole peat bog,
Cherryfield, Maine: Geol. Soc. America Bull., v. 83, p. 827-831.
»1972, Possible Paleo-Indian migration routes in the Northeast:
Massachusetts Archaeological Soc. Bull., v. 34, p. 15-15.
and Denton, G. H., 1972, Port Huron. Readvance in eastern North America
(?): (Abs.), Geol. Soc. Am. Nat'l. Mtg., p. 455.
_Hall, B.A., Ball, H.W. , and Brooks, H.K., 1972, Mawson Tillite,
Victoria Land East Antarctica: reinvestigation continued: Antarctic
Jour, of the U.S., v. 7, p. 106-107.
» 1972, Quaternary geology, geomorphology and hydrology of the Atlantic
provinces, i.n Glass, D.J. , Ed., Guidebook, Field Excursion A-61-061.
24th International Geological Congress, p. 33-36.
_(with Jones, L.M., Walker, R.L., Hall, B.A.), 1973, Origin of the
Jurassic dolerites and basalts of southern Victoria Land: The Antarctic
Journal of the U.S., V. VIII, No. 5, p. 268-270.
» 1973, Late Wisconsin fluctuations of the Laurentide Ice Sheet in
southern and eastern New England: in The Wisconsinian State, Geol. Soc.
America Mem. 136.
, 1974, The recession of the Late Wisconsin Laurentide Ice Sheet in
eastern Maine: in Geology of East-Central and North-Central Maine;
New England Intercoll. Geol. Conf. Guidebook, p. 23-31.
_, 1974, (with R. Davis and D. Sanger), The Late Wisconsin and Holocene
geological, biological and archaeological history of the Orono, Maine
region: In Geology of East-Central and North-Central Maine; New England
Intercoll. Geol. Conf. Guidebook, p. 136-139.
_(with Denton, G.H.), 1974, Former grounded ice sheets in the Ross Sea:
Antarctic Jour, of the U. S., IX(4), p. 167.
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-6-
(with Stuiver, M.), 1975, Late Quaternary marine invasion in Maine:
Its chronology and associated crustal movement: Geol. Soc. America
Bull., v. 86, p. 99-104.
(with Denton, G. H., Grosswald, M. G. , Stuiver, M. , and Nichols, R. L.),
1975, Glacial history of the Ross Sea: Antarctic Jour, of the U. S. ,
X(4), p. 160-164.
(with Davis, R.B., Bradstreet, T. E., and Stuckenrath, R.), 1975,
Vegetation and associated environments during the past 14,000 years
near Moulton Pond, Maine: Quaternary Research, v. 5, p. 435-465.
(with Sanger, D. , Davis, R.B. and MacKay, R. G.), The Hirundo
Archaeological Project - An Interdisciplinary Approach to Central
Maine Prehistory. In Amerinds and Their Paleoenvironments in North-
eastern North America, Newman, W. F., and Salwen, B. (eds.), pub-
lished by the N.Y. Academy of Sciences, v. 288, pp. 457-471.
(with Ball, H.W. , Brooks, H. K., Carpenter, F. M., Delevoryas, T., and
Hall, B. A.) Biota, age, and significance of lake deposits, Carapace
Nunatak, Victoria Land, Antarctic (in press).
and Calkin, P. E. , Quaternary history of West Central Maine, Bulletin
of the Geol. Soc. America, (in press).
,(with Hughes, T.J.) The Pineo Ridge readvance and its significance to
Quaternary events in southern Quebec, (in press).
(with Stuiver, M. , and Denton, G. H.) C dates of Adamussium colbecki
(mollusca) in marine deposits of New Harbor, Taylor Valley, Antarctica
(in press).
In Preparation
,A glacial advance during mid to late Allerod time, Hemne Fiord
area, western Norway.
In Final Stages of Preparation
,A Late Wisconsin end-moraine complex in eastern Maine.
,The Quaternary of New England: Handbook of North American Indians,
Smithsonian Institution.
,Preliminary Surficial geology map of Maine: Maine Geological Survey.
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MAINE HISTORIC PRESERVATION COMMISSION
242 State Street
Augusta, Maine 04333
Earlc C. Shettloworth, Jr.
Director
Telephone:
207-289-2133
November 28, 1977
Mr. William R. Adams, Jr.
Regional Administrator
U.S. Environmental Protection Agency
Environmental & Economic Impact Office
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Dear Mr. Adams:
I have reviewed the Draft EIS for South Paris, Maine,
Sludge Disposal Alternatives and find that the historic
and archaeological resources have been properly addressed.
As noted on page G-l, there are no endangered prehistoric
sites; and the importance of the Paris Hill Historic District,
entered in the National Register of Historic Places, has
been recognized on pages 13-15.
Sincerely,
Earle G. Shettleworth, Jr.
State Historic Preservation Officer
-------
721 Greendale Avenue
Needham, Massachusetts 02192
November 30, 1977
J.S.Environmental Protection
Agency
Environmental & Economic Impact
Office
John F. Kennedy Federal
Building, Room. 2203
Boston, Massachusetts 02203
Dear Sirs:
I have reviewed the Draft Environmental Impact Statement
for South' Paris, Maine sludge disposal alternatives, and offer
the following comments:
1. On page 12, bogs and wooded swamps are mentioned
as habitat types in the Paris area. Are these wetland areas
found on either of the actual proposed disposal sites?
2. If so, what total amount of wetlands will be
destroyed? What will be the ecological consequences of this
loss of wetland habitat?
3. On page 43, the EIS states "Each of the alternatives
discussed is, in a broad sense, environmentally acceptable". How
was this conclusion reached? Such a vague statement is meaningless
in an ETS.
I appreciate the opportunity to comment.
Sincerely yours,
'/
STEPHEN M. DIAMOND
-------
1 Frederick Av.
South Paris, Maine, 042-;1
^December 2, 1977
U.S. Environmental Protection Agency
Environmental and Economic Impact Office
John if. Kennedy Fedejral;- building, Room 2203
boston, MA.,'02203
Gentlemen:
The following comments apply to the draft Environmental Impact State-
ment on .Analysis of Sludge Disposal Alternatives for South Paris, Maine.
EIC Corporation is to be commended for writing the report in plain
English.
It is gratifying to note that the present and proposed disposal method,
burial in trenches, is the only practical method. Surface spreading and
area filling are not suitable for-our sludge and incineration is vastly
more expensive.
In conrparing present and proposed disposal sites the key points appear
to be the following. Parenthetical references are to page numbers in the
draft EIS.
Ryerson Hill , , . .
"Major~"pr"oblems may arise, if groundwater originating in bedrock fissures,
probably under pressure, is encountered on the site such occurrences
are not uncommon in upland portions of the region. They are difficult to
identify in advance. If such springs are present they could render por-(
tions, or conceivably all, of the site unsuitable for sludge trenching.
Concentrated leachate will probably collect in the trenches. The soils
are acidic there which is particularly unfortunate since chromium hydrox-
ide is increasingly soluble with decreasing pH. (P. D-19).
"Soil recharged by precipitation will not be drained by the proposed
ditches at the boundaries.(P. D-21).
Use of this site consumes more energy in transportation and produces
higher noise and visual impact than use of the Lawrence site. (P. 47).
The proposed design is innovative and unu'sunl. (P. D-21).
Utilization of the site would involve at least a financial risk (P. D-l)
a substantial financial risk. (P. D-22).
"~'ThisWsiteeis causing no environmental problems. The chromium from the
old sludge has.remained insoluble and did not degrade water quality, ^P.
The sludge now being buried at the site is less 1ikely to generate
contaminated leachate than what was dumped there before. (Pp. 34»C-^-
contamin^ ^^^ parcel and its immediate surroundings are an accept-
able location for trenching the sludge." (P. 34).
One does not need a college degree to see that the present disposal
site is far superior to the proposed one, both from engineering and eco
nomic st^points. One- only needs a little Practical common sense
Lawrence site.
Verno'n"'s7 McFarlin
(Registered Professional Engineer. Member, South Paris Action and
6 Research Committee)
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R.F.D. 1, Box 165
Buckfield, Maine 0^-220
December 8, 1977
U.S. Environmental Protection Agency
Environmental & Economic Impact Office
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Re: The Draft Environmental Impact
Statement for "Analysis of Sludge
Disposal Alternatives for South
Paris, Maine"
The draft EIS reveals that many uncertainties surround the
possible use of the Ryerson Hill site for sludge disposal. These
stem from incomplete knowledge of the geology, the soil chemistry
and the hydrology of the site and the surrounding lands. The
draft EIS points out (pp. 16-19) that the chromium (and other
heavy metals) in the sludge must be viewed as potentially
hazardous to humans (p. 18) and to fresh water fish (p. B8).
To safeguard against the possible hazards that could arise from
depositing sludge on Ryerson Hill one must prevent contact between
the sludge and local groundwater. It has been planed to install
a system of subdrains on the site for this purpose (p. D-10). The
information given in the draft EIS, upon which both the description
of this plan and the hydrological character of the site is based,
is taken from the "Design Report and Operational Manual for Sludge
Landfill, Paris Utility District, South Paris, Maine," by Whitman
and Howard, June 1975 (p. D5 and from the record of the hearings
held before the Maine Board of Environmental Protection on the
Ryerson Hill site (e.g. p. D21).
As the draft EIS points out, the supposed existence of a con-
tinuous sheet of impermeable fragipan over the entire Ryerson Hill
site is of crucial importance to the plan to prevent local ground-
water from contacting the sludge that might be deposited there
(p. D-10). The supposition (on the part of Whitman and Howard)
that the fragipan layer is continuous over the entire site is of
key importance to engineering aspects of the plan for sludge dis-
posal on the site. It is also, a key assumption concerning the
character of the local hydrology.
In the draft EIS it is npted (pp. D-15, D-l6) that the plan
for use of the Ryerson Hill site requires that fragipan first be
-------
disturbed and then restored to its impermeable conditon by
« backfilling and (possibly) vibratory compacting, in order to pro-
vide impermeable troughs to contain the sludge. But, as the
authors of the draft EIS point out (p. D-16) it is uncertain that
the fragipan, once disturbed, can be restored to its original
^ condition. (The condition of fragipan is a result of centuries
of slow compaction.) Thus, it is doubtful that the trenching
operation required in the plan can provide the hydraulic isolation
, of the sludge-, upon which success of the plan depends.
Further, the draft EIS notes (p. D-l?) that only 15 to 20
percent of the Ryerson Hill site has been tested (by boring, etc.)
» to determine whether the fragipan layer is in fact continuous (as
was assumed in the plan of Whitman and Howard, 1975i op.cit.) or
whether it might actually be penetrated bv outcroppings of bedrock
or by natural springs (p. D-3 and p. D-l?}. The draft EIS notes
(p. D-l?) that "the possibility will remain that during excavation
of 80-85$ of the site springs will be encountered." This would
require substantial departures from the plan for construction and
use of the site for sludge disposal. Moreover, the draft EIS notes
(p. D-3) that "springs, probably of this origin (sic. penetration
of the fragipan by bedrock) occur near and on the site." Thus,
* the evidence available to the writers of the draft EIS indicates
that the fragipan layer is not continuous, as was assumed in the
plan of Whitman and Howard.
V
The writers of the draft EIS summarize (p. D-l) by saying that
"overall analysis suggests that the site can probably be operated
in an environmentally acceptable manner. However, considerably
t uncertainty will remain until actual operating experience demon-
strates that such operation is indeed possible. Thus, utilization
of this site would entail at least a. financial risk." On p. D-22
the draft EIS makes clear that the "substantial" financial risks
entailed in use of the Ryerson Hill site derive from the probabil-
ity that once construction or use of the site were under way one
might well find that the original assumptions upon which the plan
. for construction and use were based are in fact wrong. This would
require modification of plans for construction and methods of use,
while use of the site were in progress. Such "corrections" are
extremely expensive.
In summary, the plan for use of the Ryerson Hill site, as
put forth by Whitman and Howard (1975) depend upon certain key
assumptions which cannot be verified in advance. Yet, there are
no contingency plans to deal with the significantly high
-------
probability that the assumption might be wrong. And of course,
there is no indication of a contingency budget for implementation
of the (non-existent) contingency plans. It is clear from the
draft EIS that to use the present plans for sludge disposal on
Ryerson Hill requires that one simply try the proposed method
and see if it works. The monitoring of the site that has been
required by the state will merely indicate whether the proposed
method is working or not. Neither monitoring of the site nor
any aspect of.the present plan provide any guidance as to how
to deal with failure of the present plan or how much it will cost
to do so.
In principle, of course, the same criticism could be leveled
at many construction projects; it is never possible fully to cover
the contingencies that might arise. However, the proposed Ryerson
Hill project is quite different . from typical construction pro-
jects. In typical construction projects the balance of probability
is on the side of successful completion. . .. ' . In the
case of the proposed Ryerson Hill project the plan for construction
is as yet untried (as is pointed out by the draft EIS (P. D-15).
Moreover, the authors of the draft EIS find that the balance of
probabilities is against successful completion and operation of
the project as presently planned. Departures from a plan for
construction that is partially implemented can be extremely costly.
If, for example, it were to be found that artesian springs do
emerge over the 80 to 85 percent of the site that is untested,
during operation, additional measures, at additional cost, would
have to be taken to provide adequate environmental safeguards
for Ryerson Hill and the surrounding area. The money to imple-
ment additional measures is as important as the identification of
the measures themselves, and, as the draft EIS emphasizes, the
costs of implementing corrective measures may become large. Thus,
the absence of contingency plans and of a budget for contingency
plans makes the present plans for use of Ryerson Hill useless.
If the EPA were to finance the use of the Ryerson Hill site,
then it would be incumbent upon that agency to determine, in ad-
vance of the start of construction, what measures might have to be
applied to deal with the probability of failure of the present
plan, and what contingency measures might cost. EPA should be
prepared to provide additional monies to correct specific probable
failures of the present plan; this is the only way that adequate
environmental safeguards can be provided for the Ryerson Hill area.
One notes that the original estimate of the cost of construction
for the Ryerson Hill site, given to the state of Maine BEP by
Whitman and Howard, was $70,000, of which $35,000 was the actual
cost of site preparation, and the remaining monies were to be
-------
spent on equipment, utility connections, etc. The draft EIS
now indicates that the total cost of the Ryerson Hill site will
be $155,900 (p. 41), of which nearly $100,000 is to be spent on
site preparation. In the face of the new cost data given in the
draft EIS, the question of budgeting to implement the contingency
measures required to deal with probable specific failures of the
present plan can be seen to be of essential importance to protec-
tion of the environment.
The present plan for use of Ryerson Hill is as bad as having
no plan at all.' To provide adequate environmental safeguards for
the Ryerson Hill area, if the Ryerson Hill site were to be used,
entirely new plans for use of the site should be drawn. These
must include methods for detecting failures of the basic plan,
contingency measures to overcome specific probable failures of
the basic plan of construction, and budgets for implementing these
measures., No monies should be committed to beginning a project
on Ryerson Hill unless a.dequa.te provisions have been made to see
the project through to a. successful environmentally acceptable
conclusion.
Given the weight of probability against successful implemen-
tation of the proposed plan (Whitman and Howard, 1975, op. cit. )
for sludge disposal there, which the writers of the draft EIS .
found, one can understand that they may not have made an exact-
ing ly critical review of the estimates of the influence that the
planned construction on Ryerson Hill might have on the hydrology
of surrounding lands. Nevertheless, the evidence on the hydrology
of Ryerson Hill, quoted in the draft EIS, is flawed in two sig-
nificant respects. Comment on this matter is required.
First, the estimate (P. D-19) of the distance over which the
ground water on lands adjacent to the Ryerson Hill site would
suffer significantly adverse effects by construction of the pro-
posed drainage system on the site, consists of an uncritical mis-
application of an equation extracted from a textbook on hydrology.
Moreover, the data introduced in this estimate are wrong. The
estimate, in fact, can tell nothing about the effect of the pro-
posed drainage system on adjacent lands. Thus, this important
environmental question has not received adequate attention. In
fact, it has been examined with grossly erroneous methods.
The second flaw is somewhat more subtle, and more important.
It is this: If one were to grant that the hydrology on and near
the Ryerson Hill site were actually to conform to the assumptions
on which the Design Report and Operation Manual for Sludge Landfill
is based, then straightforward application of well known laws for
groundwater flows would indicate that the presence of the proposed
-------
drainage system on the Ryerson Hill site could cause extremely
severe damage to surrounding lands. This conclusion might be
questioned on the grounds that similar phenomena have not been
observed in this area. But, this argument is equivalent to re-
jecting the assumed character of the hydrology on and near the
Ryerson Hill site, upon which the validity of the proposed
drainage system depends. I shall deal with these two flaws
separately.
The estimate repeated on P. 0-19.
This estimate is taken from evidence provided by Whitman
and Howard at the Maine BEP hearings on the Ryerson Hill site.
It purports to provide an estimate of the lateral distance (L)
over which water will be drawn from the soil having permeability
(k), next to a ditch of depth (H) and having sidewall area (A)
The relationship between these quantities and the rate (Q) at
which water flows from the soil into the ditch is (claimed) to be
Q = k § A,
as is given on p. D-19. The authors of this estimate insert the
following values into this equation:
k = 3 X 10'5 ft/sec.
(k represents the permeability of the soil. The value chosen
falls approximately in the mid-range of values measured on soils
of the type found on Ryerson Hill - "impervious soils modified
by effects of vegetation and weather" = as reported in (e.g.)
Jhe Handbook of Applied Hydraulics, edited by C. V. Davis, McGraw
Hill, 1952, p. 166. However, the range of permeabilities found
for these soils varies by a factor of 10,000 to 1. Use of the
"average" permeability, in the absence of measured values, provides
only a crude approximation to the actual behavior of drainage.
No measurements of soil permeability on Ryerson Hill were given
by Whitman and Howard, upon whom the authors of the draft EIS
rely, to substantiate their choice of the value of(k) given in
their estimates; this value could be wrong by a factor of about
70, in either direction. A copy of the page cited above is
enclosed.)
H = 11 ft (max).
(H represents the depth over which the water table is to be de-
pressed^by drainage of the soil into the ditch. The authors of
the estimate assume that this is the same as the depth of the
ditch, although this assumption clearly contradicts their basic
-------
assumptions concerning the local hydrology, as is further ex-
plained below.)
A = 11 X 2300 - 25,000 ft2.
(A represents the area through which water'flows into the ditch
from the soil. The authors of the estimate assume that this is
the same as the sidewall area of the ditch; this also contradicts
the authors' basic assumption concerning local hydrology.)
Q = 0.5? cfs.
(Here Q. represents the volumetric flow rate of water flowing into
the ditch from the adjacent soil in which the effects of "draw
down" are to "be estimated. At least, this is what (Q) must repre-
sent if the equation cited above is to be applied. The authors of
the draft EIS give no indication of why the value of 0.57 cfs was
chosen. This value corresponds to a flow of approximately 370,000
gallons of water per day, which in turn is about 85 percent more
than the maximum discharge rate of 200,000 gallons per day which
the ditch system is designed to carry (see P. D-l6)).*
In the record of the Maine BEP hearings on the Ryerson Hill
site one of the authors of the estimate in question testified that
the value of the flow rate, was chosen: "To determine the worst
condition using very high permeability rates for the materials
we were working with. In other words, we said 200,000 gallons per
day because that's the worst figure we would expect. In an effort
to make the (L) distance the worst possible condition you would
have, we have gone beyond even the logical numbers and come up
with this high (C) effect to determine the worst (L)." /See the
testimony of Mr. Hickman of Whitman and Howard, Volume 2, Part 2,
p. 2-324-, record of public hearings in Re Paris Utility District
Application for Construction and Operation of a Waste Treatment
Plant, August 21, 1975i at the Paris Firehouse, Pine Street, South
Paris, Maine^ In answer to the question as to whether, in his
estimation procedure, the use of a high value for the flow rate
(Q) would yield a conservative estimate for the extent (L) of the
lateral effect of the trench, Mr. Hickman testified: "Conservative
in that it would be a longer (L), yes." /See p. 2-325 of the
hearings cited above_J7 Thus, the record of testimony before the
Maine BEP, from which the authors of the draft EIS have taken
the estimate, establishes that the authors of this estimate chose
to use a very high value for (Q) in the belief that in doing so
their estimation procedure would yield a large value of the extent
(L) of the lateral effect of the trench. The testimony also es-
tablishes that the authors of .the estimate believe that the value
of 0.57 cfs chosen for (Q) represents a very large over-estimate
Using these data in the equation above, the authors of this pro-
cedure estimated (L) to be 15 feet. On this basis they claimed
that the ditch will not affect groundwater on adjacent lands.
-------
of the volumetric flow rate of water from the adjacent soil into
the ditch. In the same record of testimony (p. 2-326) Mr. Hickman
states that he and his colleagues considered volume flow rates in
the range 0.15 "to 0.57 cfs as "being reasonable upper bounds to
use in their estimating procedure. The record establishes that
the Whitman and Howard engineers claim that by using a flow rate
at the upper end of this range, in their estimating procedure,
they produce a "conservative" over-estimate of the distance (L).
The estimating procedure is used to predict the distance (L<)
to which the influence of the ditch will extend laterally; (L)
thus obtained is supposed to indicate whether the groundwater on
adjacent lands will be adversely affected. The assumption of the
value of (Q) in this estimate is of key importance. If one chose
for (Q) the value of 0.15 cfs, the estimate of (L), via the
equation cited above along with the other data, is
1 n 1 c (3 X 10=5) X 11 X 25.000
or L = 55 feet.
Thus, by choosing a smaller value of (Q) in the estimating pro-
cedure one arrives at a larger value for (L).
The reason for this is, of course, simple. The equation used
to estimate (L) can be rewritten as
_
-
If one may assume fixed values for k, H and A, as has been done,
and if one is then free to choose the value to be used for (Q),
one can use this equation to obtain any value of (L) one likes.
In particular, if having claimed that by choosing a. large value
for (Q) one will overestimate the distance (L), one may then
insert a large value of (Q) into the estimating equation, and
obtain as small a value of (L) as one wishes. Clearly this pro-
cedure is wrong, and one cannot rely upon it, or upon any of the
results given by it, to provide a basis for adequate environmental
examination of the effects of the drainage system proposed for the
Ryerson Hill site.
What Is Wrong with the Estimating Procedure
The procedure fails because it entails a naive mathematical
error: the authors apparently failed to observe or test the char-
acter of the equation they used for estimating the length (L).
-------
8
Rather, one value for (Q) was assumed, and one value of (L) was
calculated. The result was convenient; and it was accepted.
More fundamentally, the estimating procedure is based on
very poor physical modeling of the drainage of the adjacent soil
into the ditch. In the first place, the depth of the permeable
soil from which the ditch is to permit drainage of water on
adjacent lands, according to the evidence put forward by
Whitman and Howard and cited by the authors of the draft EIS,
is about 3 to 4 feet. It is, supposedly, only in this layer of
soil that lateral water flow can occur at all. The accompanying
copy of figure D-6 from the draft EIS illustrates the supposed
soil structure on Ryerson Hill. The cross-section of the peri-
phery drainage trench is shown. The permeable soil is shown a.s
a layer three feet thick. Now, if the structure of the soil is
as shown in this figure, it is meaningless to speak of a depression
(H) of the water table by eleven feet. The water table is sup-
posedly "perched" in the top 3 feet of soil. It cannot be more
than 3 feet deep. It, therefore, cannot be depressed by more than
3 feet.
In addition, the lateral area (A) through which the water on
adjacent lands will flow into the drainage ditches is not 11 feet
high by 2300 feet long; it is 3 feet high by 2300 feet long, or
approximately 7000 ft^. This error in the choice of data intro-
duces an error of a factor of (about) 13-5 in the results obtained
from the estimation procedure. That is, the length (L) estimated
by the (incorrect) method indicated on p. D-19 is too large by a
factor of 13-5 The estimate of (L), as given on p. D-19, should
be about 1.12 feet, rather than 15 feet.
This might lead one to believe that the estimate given in the
draft EIS does inadvertently overstate the lateral distance (L)
over which the periphery drains will depress the water table on
adjacent lands. But;, this is not the case. The corrections in
the value of (H) and (A) cited above are significant, but they do
not remedy the basically flawed physical model on which the es-
timating procedure is based.
The most serious flaw in the estimating procedure is the as-
sumption that one can assign some typical value of the rate of flow
of water (Q) from adjacent soil into the ditch, and from this
determine how far back the water table in the adjacent soil will
be depressed. The water flows through the soil in response to a
gradient of pressure (not in response to an assumption). In the
first instant that the ditch of figure D-6 were cut into the soil,
the gradient of water pressure in the adjacent soil would be im-
mense, and water would pour into the ditch at a very high rate.
-------
As the water were drained from the soil immediately adjacent
to the ditch, the gradient of water pressure would decrease, and
the flow of water would diminish. As time preceded more and
more of the water in the soil adjacent to the ditch would have
been drained, the gradient of water pressure would have been de-
creased, and the rate of water flow into the ditch would have
declined steadily; in this process, of course, the lateral extent
(L) over which the water would have been drained from the adjacent
soil would have increased steadily. In the absence of recharging
of the water table by direct precipitation on the land being
drained, the process described would continue indefinitely.
To see how far wrong the estimating procedure is consider
the following example. Suppose, as is proposed by the authors of
the estimating procedure, that water from adjacent soil does flow
into the ditch at a rate of 0.57 cf s . The water table in the
adjacent soil will decline as this flow proceeds. With the soil
being initially saturated it will contain about 7 to 8 pounds of
"free" water per cubic foot. (See, e.g. Hydrology for Engineers.
Linsley et. al, McGraw Hill, 1958, p. 126T. As the water table
declines and recedes from the trench about 50 percent of this
water will flow into the ditch. (The water table will become
sloped and the soil above the table will have been drained.) This
means that from each cubic foot of soil adjacent to the ditch,
from which drainage has flowed to the ditch, about 0.06 ft3 of
water will have flowed to the ditch. Suppose that the area, over
which this water is drained we>-e an ellipse with its major axis
(a) lying along the axis of the ditch (2300 feet long) and its
minor axis (b) extending progressively normal to the ditch. The
volume of soil (Vs) contained in this drainage field will be
Vs = |r
where (D) is the depth of the layer of soil being drained. The
factor (i) appears because we are considering the drainage from
only one side of the ditch, the side extending toward the adjacent
land. Now, the volume of water (Vw) removed from this drainage
field will be approximately
Vw = 0.06 Vs = -f (If a.b).D.
The rate at which this water is removed (dVw/dt) must be equal
to the rate (Q) at which water flows from the soil into the ditch.
Since the rate of extraction of water is proportional to the rate
of growth of the area of the drainage field, one has
-------
10
Q . * = (0.03 IK -a-D) f .
This eauation provides an approximate estimate of the rate at
which the boundary of the drained soil will extend into adjacent
lands. With the data given agove (D = 3 feet-, a = 2300 feet;
and with the assumption that Q - 0.57 cfs one finds that
% = 9 X 10'^ ft/sec
dt
or 3-155^ ft/hr.
Thus if it were possible for the flow rate of 0.57 cfs to prevail
for 'sav, one week, the boundary of lateral drainage would have
advanced 530 feet toward (and onto) adjacent lands. Of course,
this willpnot actually happen. The water table will have receded
so far from the ditch that it could not provide the pressure
IradKnt required to maintain a flow of.0.57 «3/sec The example
here points out that one could not consider a."typical flow^rate
of 0 57 ft3/sec being maintained for a full week. And, it is
hardly useful to regard a given flow rate of water from the ad-
jacent soil to the ditch as "typical," in any sense, if the flow
rate could not persist for, say, a few weeks at a time. The
"selection" of a typical flow rate would require one to be able
to guess, in advance, what the average flow rate would.be, over a
specified period of time, as the water table in the adjacent
lands recede. It is hardly worthwhile attempting such guesses.
It il easier and simpler to solve the field equations for transient
drainage in the adjacent soil, and this is the approach that .
should be taken if one is to arrive at any meaningful conclusions
concerning the possible effect of the proposed drainage system on
adjacent groundwater.
Incidentally, the estimate of Whitman and Howard, given
on t> D-19 of the draft EIS can be meaningfully interpreted as
follows. When the water table has receded an average distance
of 1.09 fe^Tfrom the edge of the ditch, then the average flow
rate into the ditch will be 0.57 cfs. (The corrected values of
(H) and (A) are used here; some appropriate sense of averaging
distances is implied.) This is the only meaning the estimating
procedure has.
The Second Flaw
If as is assumed in the information given on Ryerson Hill
the fragipan layer is not only impermeable but continuous over
the proposed site, then one must assume that it is probably con-
tinu^Ss over some substantial sector of the adjacent lands also.
-------
11
(It would "be miraculous if a continuous sheet of impervious_
soil were to have been deposited only on the Ryerson Hill site,
and not on adjacent lands.) If so, then the drainage field of
the proposed ditch system will extend onto adjacent lands and will
substantially drain the permeable soil layer above the fragipan.
This will occur even though ground water originating in higher
lands flows through the affected land. The ground water in^the
affected land may be partially recharged by periodic precipita-
tion directly on this land. But, there will be a zone of land
adjacent to the drainage system in which the effects of drainage
to the ditches will predominate even over the effects of direct
precipitation. The size of this zone will be determined by the
amount and frequency of precipitation. In dry summers it is not
uncommon for the Ryerson Hill region to experience several con-
secutive weeks without rain at all. Moreover, in these periods
rain, when it does come, occurs in sparse showers. Thus, in a
dry summer the effect of the drainage field about the proposed
ditch system could drain substantially all the groundwater from
the thin layer of permeable top soil over a large area of ad-
jacent lands. If this drainage were sufficiently severe to hamper
the growth of small vegetation now found on this land,_the ad-
jacent land affected by the trench would become more highly
susceptible to erosion. In particular, with the beginning of
the heavy fall rains the top soil in the zone adjacent to these
trenches could be washed away; there would be no vegetation to
restrain the soil. . Recall that the trench system proposed for
Ryerson Hill amounts for a furrow cut completely through the
permeable top soil and lying directly down the path of steepest
descending slop on the site. Thus, the effect that_these ditches
might have in promoting erosion of adjacent lands might be
(approximately) likened to the effects of deep plowing of a steep
field, directly down slope.
The only thing that might restrain the soil from eroding would
be the survival of fine vegetation. This vegetation might be sus-
tained in dry seasons by springs coming up through the "imper- _
meable" fragipan layer. But, if, as has been assumed, the fragipan
layer is continuous, then there will be no source of water to
support the vegetation.
When the .first episode of erosion occurs, the effect will be
to displace the boundary of the trench outward onto the adjacent
land. This will occur because the removal of the thin permeable
layer of soil adjacent to the trench will allow water from the
soil behind it to flow across the impermeable layer and into the
ditch. This mechanism will operate even if in the first episode
of erosion the lateral dimension of the eroded belt of soil were
very small, say only 6 inches or so. The effect still will have
been to displace the boundary of the drainage system toward the
adjacent lands. With each repetition of the pattern of rainfall
-------
12
suggested above, a new belt of erosion can be formed. In each
episode, the effective boundary of the drainage system will be
displaced laterally across the face of the hillside. Eventually
all the permeable soil can be eroded away, on that area of the
hill where the fragipan layer is continuous. This possibility
carries serious environmental consequences for the Ryerson Hill
area.
To determine precisely how serious this possibility is re-
quires exacting hydrological analysis along the lines acknowledged,
but not used, in the draft EIS. The draft EIS does not, therefore,
provide adequate fact finding for evaluation of the environmental
consequences of using the Ryerson Hill site.
The phenomenon of erosion described above represents a
potentially hazardous threat to the environment of the Ryerson
Hill area, one that has not been evaluated. This phenomenon is
most likely to occur if the fragipan layer is continuous as
assumed. Thus, the continuity of the fragipan layer, which might
make it feasible to prevent contact between the slude and the
groundwater on the Ryerson Hill site leads to an environmental
hazard of a different sort for the surrounding area.
Sincerely yours,
Charles A. Berg
Enclosures: as noted
-------
» »
1
Turbulent :
Turbu/ent <2i Figh .
(_0minor ffr >ow i
1 1 1
! .-! 'i./doy lO5 IO4 IO3 1
. . - r >,, cm^ec. I02 10' 1.0 IO'1
>u/sec. iO6 10s 10" IO5
iii
,'Vtff /?'/<;' C5
Soil
types
~**r-
cf f'
Indirect
determination
of k
Cfi OIQW down
Clean growl
Clean s<7
sora a-' '
Laminar-. 0 -kiAi
0J IO1 10 IO'1 IO"2 IO'3 IO"4 IO"5
<;- lO'3 lO'4 I0'b I0-6 I0-7 tO'8 I0-9
y io1 i.o io-' iO'2 ID-' io-* io-s
iii i i -
n"1 ce draining
now down
>'' *t7T
>r core core material
very tin? sands, organic and inor-
ganic silts, mittures Of sand silts
and clay, glacial till, stratified
clay deposits, etc
'Tioervious" soils modified by effects of
vegetation ana *£Ctr\ering
Drect 'cs'ingc! so!1 in i's . > . .'. position -pump -
~*j tests Re/,ct:/e if proper , ~ured
r v -tant - head permeame/fir '. >ft/e et
pe'ience required
Foiling -nyx wmea
meter re/iabie. Lit tie ex-
perience required
Computation Irom grain - size distribution.
Appticooie only >o dean cohesionless
materials
"imperv'ous " soils, e.g^homogc-
neou; cloys below zone of
r
Fol/inQ-heodpermeomei- _ . , . , . ^
er unreliable Much expert- ^nrg-neodpermeameter. f»ly reliable.
ence required . Constate experience required.
Horitonloi and vertical capillarity .
tests, (airly reliable. Little experi-
Computation based on
results of consolidation tests,
reliable. CcfisideraUitfperi"
ence required.
8
5
i
5
. ».1
/4fer4 Casagronde and R. E. ROurn,
ottoO*.
-------
PERMEABLE KDKIZON OF
SANDY, LOAMY WTEkl<\L
FI.s. I)-'-: Cro->s section i'sovin^ the relation-hip of the underdraln
ni h'ti to siutige cells anil the distribution of soil
-------
R.F.D. 1, Box 165
Buckfield,. Maine 04220
December 18, 1977
U.S. Environmental Protection Agency
Environmental & Economic Impact Office
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
To the EPA Staff:
The, draft Environmental Impact Statement, on Sludge Disposal
Alternatives for South Paris, Maine, draws extensively upon the
record of the hearings before the Maine Board of Environmental
Protection for physical data pertaining to the, Ryerspn Hill site.
The state hearings in turn draw upon documents submitted to the
Maine Board of Environmental Protection by the Paris Utility
District for these physical data. Since it is not possible for
anyone fully to evaluate the evidence given in the draft EIS,
or fully to comprehend the basis for any decision that might be
taken as a consequence of the EIS, without having acccess to
these physical data, I respectfully request that the record of
hearings on the Ryerson Hill site before the Maine State Board
of Environmental Protection be officially incorporated as a part
of the draft EIS. In addition, I request that any other documents
submitted to the Maine BEP by the Paris Utility District pertain-
ing to physical characteristics of the Ryerson Hill site also be
included officially in the draft EIS. I request that the documents
cited above be included in their entirety so that any discussion,
evaluation or commentary that pertained to the record of data
upon which the authors of the draft EIS relied may also be
available in the course of public examination iand public commen-
tary upon the EIS.
Very truly yours,
Charles A. Berg
-------
R.F.D. 1, Box 165
Buckfield, Maine 04-220
December 18, 197?
U.S. Environmental Protection Agency
Environmental & Economic Impact Office
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
To the EPA Staff:
I believe that the procedures followed in issuing the Draft
Environmental Impact Statement on Sludge Disposal Alternatives in
South Paris, Maine, may have been in conflict with the guidelines
for policies and procedures set forth for Environmental Impact
Statements by the Council on Environmental Quality (Federal
Register. Vol. 38, No. 1^-7, Wed., August 1, 1973, pp. 20551 + ff).
As you are aware, the CEQ Guidelines (1500.2) set forth
policy for writing and circulating draft environmental impact
statements. These guidelines state that "FederalAgencies shall
(l) Provide for circulation of draft environmental statements to
other Federal< State and local ggencies and for their availability
to the public in accordance with the provisions of these guidelines;
(2) consider the comments of the agencies and the public; and (3)
issue final environmental impact statements responsive to the
comments received."
The guidelines also state:
"The purpose of this assessment and consultation process
is to provide agencies and other decision makers as well
as members of the general public with an understanding of
the potential environmental effects of proposed actions,.
The guidelines further state, (1500.8, a, l), that an en-
vironmental impact statement must include:
"A description of the proposed action, a statement of
its purposes and a description of the environment af-
fected, including information, summary technical data
and maps and diagrams where relevant, adequate to permit
an assessment of potential environmental impact by com-
menting agencies and the public."
-------
Under the same article the guidelines require that an EIS
explicitly consider*
"The relationship of the proposed action to land use
plans, policies, and controls for the affected area.
This requires a discussion of how the proposed action
may conform or conflict with the objectives and specific
terms of approved or proposed Federal, State and local
land use plans, policies and controls, if any, for the
area affected, including those developed in response to
the Clean Air Act or the Federal Water Pollution Control
Act amendments of 1972. Where a conflict or inconsistency
exists the statement should describe the extent to which
the agency has reconciled its proposed plan, policy or
control and the reasons why the agency has decided to
proceed notwithstanding the absence of full reconciliation."
It' is clear from the language of these guidelines that, in
respect to commentary on a draft EIS, the public is to be treated
on the same basis as other federal, state or local government
agencies. It is also clear that one important purpose of an EIS,
as set forth in CEQ guidlines on policy, is to equip the public
with a full understanding of the environmental effects that a pro-
posed action may have.
It is acknowledged in the draft EIS that the Maine BEP has
previously rejected one site considered in the draft EIS (the
A.C. Lawrence site). It is also acknowledged that the same state
body has (conditionally) approved use of the other site (the
Ryerson Hill Site) which is considered in the draft EIS. The
evidence given in the draft EIS would, upon its face value, in-
dicate that the use of the A.C. Lawrence site is preferable to
use of the Ryerson Hill site. Thus, there is an apparent con-
flict between the technical evidence found by EPA's consultants
who authored the draft EIS and the previous determination of the
Maine BEP and its staff, the Maine Department of Environmental
Protection.
Despite the policy directive of the CEQ guidelines (the
last quoted above) the draft EIS gives no commentary on this
apparent conflict. In particular, the draft EIS offers nothing
that might aid members of the general public to understand the
substance of this apparent conflict, or to evaluate its merits.
In addition, the record of communication between the Maine
State Department of Environmental Protection and EPA regarding
the draft EIS indicates a strenuous effort on the part of the
former agency to persuade EPA to delete from the draft EIS the
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conclusions and recommendations of the technical consultants
who authored the document. .Moreover, EPA has apparently acceded
to these demands. This cannot be consistent with the intent of
the CEQ guidelines on policy and procedures. Members of the
general public, whom the agency issuing an EIS is required to
inform, cannot be expected to understand or'evaluate the merits
of conflicting technical opinion if one party to the conflict is
privileged to cause the conclusions and recommendations of the
other party to be deleted. In such a case the public's right to
be informed, under NEPA, has been thwarted.
In addition, I should like to note that the mere publication
of the technical evidence gathered by technical experts in writing
a draft EIS, in the absence of their conclusions and recommenda-
tions, cannot be held to meet the requirement to inform the public
set down in the CEQ guidelines, irrespective of the reason for
the absence of conclusions or recommendations. Technical data.
are meaningless as public information, without interpretation,
conclusions, and recommendations offered and explained by tech-
nically qualified experts.
In the case of the draft EIS in question the def 'iciency
represented by the absence of technical interpretation, conclu-
sions and recommendations is compounded by the fact that these
have been deleted at the insistence of one party to a technical
dispute, the Maine Department of Environmental Protection. While
the procedures for writing of a draft EIS may not be entirely
governed by rules of administrative law, the resulting EIS itself
may be of crucial evidentiary importance in later administrative
law proceedings. The procedures followed here not only appear to
have been in conflict with CEQ guidelines, they are in the nature
of ex parte communication, which would consitute a serious problem
in the event the EIS were to be tested in the courts.
I respectfully protest the way in which the Maine Department
of Environmental Protection has been privileged to comment upon,
to cause deletions from and in general to shape, the draft EIS.
When CEQ wrote its guidelines it stated that an EIS is to be
drawn "in consultation with other Federal, State and local
agencies and the public." CEQ did not say "in consultation with
State agencies and then the public."
In light of the above, I respectfully request that all in-
terpretations of technical data and all conclusions and recommenda-
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tions based theron, offered to EPA by the technical consultants
who authored the draft EIS be reincorproated into the document.
Sincerely yours,
Charles A. Berg
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C. LAWRENCE LEATHER CO.. PEABODY, MASS., 01960 U
December 20, 1977
U. S. Environmental Protection Agency
Environmental & Economic Impact Office
John F. Kennedy Federal Bldg., Room 2203
Boston, Massachusetts, 02203
Gentlemen,
We are in receipt of a draft copy of an environmental
'impact statement on sludge disposal at South Paris, Maine,
entitled "Analysis of Sludge Disposal Alternatives." The
draft is accompained by a letter from the U.S.E.P.A.
Regional Administrator in charge of Region One, which
invites comment by interested parties. Our company owns
and operates the tannery referred to in the statement.
We would be remiss if we did not respond to the request
and place our company's position alongside that of others
who also may be deeply involved.
As a company we try to be a responsible citizen at
each of our four locations, and we think this is rather
amply demonstrated through commitment of capital funds for
waste water systems which at this point has reached a total
of some three million dollars. In addition we are supporting
operation and maintenance expenses on treatment systems at
all four locations which this past year has amounted to
almost $400,000 in the aggregate. While these are not huge
figures, our company is not large or affluent.
We have studied the E.I.C. Corporation document. It
seems to be very professional and comprehensive. All conclusions,
such as the authors have elected to make, are well supported
by analytical data. They looked into four methods of sludge
disposal, incineration, surface spreading, area filling, and
trenching. Of the four, evidence is presented which indicates
trenching to be the most desirable, thus effectively removing
other methods from consideration.
They then moved toward making a choice for a suitable site
for trenching operation. As you know, the field was narrowed
some time ago to the A. C. Lawrence site and the so-called
Ryerson Hill site. Our over-all reaction, briefly stated, is
that very little, if any, adverse comment is directed toward the
A. C. Lawrence site, while very little is said in favor of
Ryerson Hill. In fact, misgivings of considerable substance are
documented in reference to the latter, both operational and
financial.
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On page 34, it is stated "The principal conclusion of
these analyses is that the Lawrence parcel and its immediate
surroundings are an acceptable location for trenching the
sludge." On the other hand, on page 40, it is stated "On the
whole, then, Ryerson Hill could be operated in an environmentally
acceptable fashion.
The only practical means of determining the extent of such
interactions (acceptability) is to attempt to drain the site
as planned. Clearly this is a costly way of establishing whether
the site is acceptable." This statement, in addition to others
in the same vein, seems to indicate lack of confidence on the
part of the investigators that Ryerson Hill would, in fact, be
found suitable, and then only after the expenditure of a considerable
sum of money which very well might turn out to have been made in
vain.
After carefully considering the material presented in this
report we find it difficult to envision how a well substantiated
decision could be made in favor of developing the Ryerson Hill
site. Many citizens have voiced their opposition from an aesthetic
point of view; we as a company oppose it as being questionably
suitable, as well as more cost and energy intensive both initially
and over the long run; and it is our understanding that our view
is shared by Paris Utility District Commissioners and others.
Obviously there is concern as to protection of drinking water
sources and supplies, but this apprehension should be well
answered through language presented on page 33, paragraph two,
where a summary statement clearly says "The over-all result
(of historical sludge dumping) has been little or no deterioration
of groundwater quality at the Lawrence site.
We are not at all professional in this area, and can only
respond to the findings as they have been presented and appear
to us in Impact Statement. We respectfully urge those who are
responsible for protection of the environment to accept what
seems to be evidence in favor of the Lawrence site, and its
environs, and use the site characteristics and advantages found
there for guidance in selection of property other than Ryerson
Hill for future sludge deposition.
jincerely yours,
Leather Company, Inc.
L.'
Director of Manufacturing
x V £i<>-t-*jrvvA^_x
P. D. Finnegzn
Director of Manufacturing, South Paris
W. E.
President
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- /
RFD 2
South Paris, Maine 0^281
20 December 197?
U.S. Environmental Protection Agency
Environmental and Economic Impact Office
John F. ivennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Dear Sirs»
The Draft EIS on Sludge Disposal Alternatives, South Paris IViaine,
is excellently written and researched, toe commend the Environ-
mental Impact Center for the thoroughness of their investigation
of alternatives developed in the EIS and cannot but agree with
their findings. Based on a reading of the entire document, the
present dump site, A.C. Lawrence along with adjacent land, is
clearly not only the most environmentally suitable alternative
but the most cost effective one.
Our major concern is, therefore, not with the text and compilation
of data, but rather with the fact that EPA has chosen not to publish
the Draft along with 1) conclusions on the environmental impacts of
the various alternatives and 2) recommendations as to a preferred
solution to the final resting place of sludge generated by the
South Paris treatment facility.
EPA has stated that the involvement of the public is vital to the
EIS process. Initially, it appeared that the public was involved
up until the conclusion of the last workshop in March 197?. How-
ever, from that time until the issuance of the Draft, it has been
apparent that the public together with interested agencies have
been overlooked in deference to one State body. There is, in fact,
some question as to whether EPA has pursued the proper course of
action in terms of the intention and wording of the National Environ-
mental Policy Act since it is clear that the Maine State DEP has
enjoyed what amounts to a privileged position with respect to input
into the form which the Draft EIS was to assume.
We believe that NEPA makes clear the role that EPA shall play in
the EIS process; namely« that EPA is obliged to create public
understanding of the issues involved. One of the most discouraging
results created by publishing the Draft in such form has been the
affect on the majority of the public in this area. Instead of
developing an info?6>ned public, the Draft has caused confusion and
uncertainty. Most people here are inexperienced in the fields oi
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2.
geology and chemistry. The length of the document alone, especially
without clear-cut conclusions and recommendations, is a formidable
obstacle to a real understanding by the general public who, in
the last analysis, will be required to pay for the EIS and for
whatever alternative is eventually chosen.
The effect of the Draft has been the impression, based primarily
on pronouncements by members of the Paris Utility District that
nothing new has been accomplished and the whole EIS was "just a
waste of time and the taxpayers' money." EPA elected to hire
their own consultants to a job which they did well. It would
seem not only logical but imperative that EPA support the findings
of their i own consultants and publish those findings in such a
manner as to*eeasily understood by everyone.
It would be a travesty of the whole EIS process if forces which
are pressuring for the use of the Ryerson Hill site are able to
prevail in their attempts because of an ill-informed public.
Sincerely yours,
La jos Matolcsy and Claire C. Matolcsy
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RFD 2
South Paris, Maine 0*1281
21 December 1977
U.S. Environmental Protection Agency
Environmental and Economic Impact Agency
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
As an addendum to our letter of 20 Oecember 1977, we would like
your office to consider an alternative which was not raised in
the Draft EIS on Sludge Disposal Alternatives for South Paris.
Maine.
toe feel one good reason to avoid use of the Ryerson Hill site is
that in the near future burial of chromium-laden waste will be
obsolete., It would be an irretrievable step to subject this semi--
wild, "open area" to the burial of toxic waste when the need for
recovery and recycling of chromium is becoming increasingly clear.
We realize that the amount of money allocated to the EIS was
limited. ^ In any event, we rather this alternative be approached
as a subject for EPA to study not on an individual case but rather
as a national problem.
Chromium is a non-renewable and strategic resource. Its acquisition
dependent on the whims of international politics. For economic
reasons and for national self-interest it is necessary to take a
closer look at this metal with the thought of recovery and reuse.
toe have recently learned that the treatment facility for the South
Essex Sewer District (MA) will be going on line in March 1978. If
South Paris has a problem, theirs is multiplied many times. Among
six town? in the District are two which between them will contribute
wastes_from approximately 30 tanneries. At present, it is intended
to incinerate sludge at fairly high temperatures. However, plans for
incinceration at lower temperatures making easier the reclamation of
Cr are already being made. Hopes are for the removal of Cr al-
together in the not too distant future.
In view of EPA's strict guidelines on the burial of hasardous wastes
and standards for effluents, we feel it only realistic that EPA
undertake an in-depth study for efficient and cost effective
methods of Cr recovery, preferrably in cooperation with the tanning
industry as well as with industry interested in Cr recapture as
a feasible economic venture.
We feel present practices of burial of Cr-laden sludge are waste-
ful unrealistic and,important in the case of South Paris, short-
term .
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2.
Not only is "burial wasteful of a non-renewable resource making
future recovery difficult, but it is wasteful in terms of land
needed to accommodate? hazardous sludges. Engineering of safe
sites, their maintenance and operation further add to already
high costs.
Removal of Cr, therefore, should be considered as an important
alternative not only in the case of iouth Paris, but in any area
where large amounts of Cr-laden sludge are generated. The results
of implementation of such an alternative would be a permanent,
cost effective and environmentally suitable solution.
Sincerely yours,
L .
(7
Lajos Matolcsy and Claire C. Matolcsy v
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
USDA Office Building, University of Maine, Orono, Maine 04473
January 9, 1978
U. S. Environmental Protection Agency
Environmental & Economic Impact Office
John F. Kennedy Federal Building, Room 2203
Boston, MA 02203
Dear Sir:
The following are our comments in regard to the draft Environmental Impact
Statement for the South Paris, Maine - Sludge Disposal Alternatives.
1. Page 1 - States that three locations were studied in detail. Only
two are discussed. Why was discussion of the third omitted?
2. Page 11, paragraph 3 - It is unclear as to what the three (mgd) figures
go with. Do they apply to the three outfalls, or do they apply to
the outfalls, the tannery, and the cannery?
3. Page 32, figure 3 - Since the Norway municipal dump is mentioned in
the narrative, it would be helpful to show its location on the map.
The map also lacks a north arrow.
4. Page 33, paragraph 2 - Suggest being consistent in referring to the
Lawrence "sludge disposal area" rather than to the "dump," to avert
further confusion with the Norway municipal dump. This usage occurs
at many other places in the report also.
5. Page 37, figure 4 - The map lacks both a scale and a north arrow.
Other maps further on in the report also lack one or the other.
6. Page C-14, Table C-4 - The table indicates presence of "plagioclase"
and "feldspar." Plagioclase is_ is feldspar. Perhaps the headings
could be changed to "sodic plagioclase feldspar" and "alkali feldspar,
the terms used in the narrative on page C-12.
7 Page C-15, paragraph 3 - The reference to "District Soil Conservation
Service" is incorrect. Either "the local Soil and Water Conservation
District" or "The Soil Conservation Service" would be correct.
8. Page C-17 & 18, Table C-5 - The reference to the "AASHO" soil classi-
fication is incorrect. It was changed to "AASHTO" some time ago.
This also pertains to Page D-ll, Table D-l.
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-2-
9. Although a detailed erosion control plan and a detailed water
quality monitoring program were listed on page 2 as conditions of
application approval, neither was discussed in the report. There-
fore, we can make no comment on their adequacy, but we suggest that
discussion of these plans be incorporated into the Final EIS.
10. There is little, if any, discussion of the current land use of
planned conservation practices at either site. This would be
helpful and allow us to comment on the effects of project action
upon such items as:
(a) Impact on existing conservation systems, if any.
(b) Changed land use, particularly if agricultural land is involved
(c) Wetlands.
(d) Conservation of topsoil.
If you have any questions, please let us know.
Sincerely,
wick M. Tinsley, Jrt
Stte Conservationist
cc: R. M. Davis, Administrator, SCS, Washington, D.C.
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January 10, 1978
Mr. William R. Adams
E.p.A. Region 1 fe toftft
John F. Kennedy Builaia* *
Boston, Mtia&acausetts
Re: Paris Utility District
Sludge Disposal Site
Dear Mr. Adams:
Although I am a member of the Paris Conservation Commission
and agree with its stand regarding the Paris Utility District sludge
disposal, I am writing to you as an individual to express my personal
feelings on the subject and to go on record as one more person
emphatically opposed to dumping any form of sludge or waste at the
Ryerson Hill location.
i
The reasons I offer have all been set forth by other persons
far more eloquently than I am able to present them, but here goes. As
an outdoor person who enjoys exploring the bits of wilderness which
can still be found in the Paris area, I strongly oppose turning such
an area into a sludge dump. As a person who has travelled through
32 of the United states and had to drink water that tasted almost as
bad as the paris treatment plant smells, I bitterly oppose polluting
tne crystal clear springs and brooks that originate and flow from the
vicinity of Ryerson Hill. As so dramatically expressed by Mr. Tony
Jt'ontanaro at the January 4th hearing, water is precious and it doesn't
take a college degree to comprehend tnat sludge dumped on Ryerson Hill
could cause extremely wide-spread/pollution and devastation. The
proposed disposal site is hign on tne nill, and to quote Mr. Verlin
Cooper, "How far does water run downhill?".
Next let's mention transportation. That "honey truck" seems
to run continually from the plant to the dumping site which is a
relatively short distance. That same truck could never make the
same number of trips per day to Ryerson Hill. This means one or more
additional units and further expense to the citizens of Paris. In
this day and age when we have been told every effort should be made
tc conserve energy , these intellectuals wno control our destiny would
run large trucks twenty miles per trip to haul sludge! Not only would
the heavy trucks cause excessive wear and tear on the still inadequate
Ryerson Hill Road, their fuel consumption would be costly.
It's an old trite saying that figures don't lie but liars do
figure. It is well known that statisticians all use figures to
express their side of any issue and carefully omit any figures which
do not support their cause. I believe the cost figures for the use
of the Ryerson Hill site have been grossly under-estimated.
Although many opinions have been expressed as to what might
happen if the Ryerson Hill site were used, no one can say with any
degree of certainty what actually will happen if the site is used.
There are far too many unanswered questions.
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Mr. William R. Adams -2- January 10, 1978
The A. C. Lawrence site seems to have worked well for the past
twenty years. With proper monltering It would seem any contamination
could be spotted immediately and steps taken .to rectify it. Although
not much has been mentioned about it, taere is additional land
available for expansion at tnis site.
Let's face it tne only reason anyone wants to dump sludge
at the Ryerson Hill site is because someone was stupid enough to
purchase it in the name of Paris Utility Districtl
Please don't let a few greedy, self-centered people spoil
this beautiful wilderness area, contaminate the springs and brooks,
and displace the deer, bear, bobcats, small wild animals, birds and
hippies who enjoy their respective forest homes.
Please don't let these same greedy, self-centered people
spend money that isn't theirs to further burden the citizens of Paris
with ever increasing sewer assessments, unnecessary road repairs
and transportation costs which the use of the Ryerson Hill site
would spawn. i
Please do convince the State D.E.P. that the A. C. Lawrence
site can be safely utilized.
Thank you for your consideration.
Sincerely yours,
Suzanne S. Thorndike
Mrs. Charles J. Thorndike
Paris Hill Ponies
R.F.D. 2 Paris Hill Road
South Paris, Maine 04281
P.S. Dr. Berg's closing comment addressed to both E.P.A. end D.E.P.
at the January 4tn hearing was a provocative one,
«*Yhat if you are both right?".
S.S.T.
-------
£tatr
Exmrttor Brpartment
panning
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STATE OF MAINE DEC 2 a 137?
Inter -Departmental Memorandum Date December 28, 1977
Remj. Jurenas^ State Clearing House Coordinator p^/ State Planning Office
rfl Y^Markj^ i^omM
pTOm Maynarfl YMarj^ i^omMssioner ,Dept. Inland Fisheries & Wildlife
Subject _ Comments on South Paris Sludge Disposal Sites
We received the EPA Environmental Impact Statement concerning the South
Paris Sludge disposal alternatives. The final decision here appears to
involve some highly technical predictions concerning ground water and
surface runoff containment. This Department does not feel qualified to
make a technical analysis which would allow us to favor one site over the
other, but we do have strong concerns regarding the Ryerson Hill site.
Enclosed is our August 19, 1975 recommendation to DEP concerning this
project.
After' reviewing the EPA Environmental Impact Statement our concerns
are not changed. The streams near the Ryerson Hill site are good brook
trout streams and the quantity and quality of the water supply is essential
to the maintenance of these trout populations. If we consider the very
real factors of mechanical failure, human error, and imprecise estimation,
we feel that in the final analysis the Ryerson Hill site has a lot of
unanswered questions, and from our point of view, our best judgment at
this time is to recommend the A.C. Lawrence site even though we recognize
the problem of less space available.
MFM/CFR:cs
cc: Lyn Bond, Chief Fishery Division
Scarborough Headquarters
David H. Spencer, District Warden
Hollis McGlauflin, Environmental Protection
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ATTACHMENT
Treatment Facility Sludge Landfill
Paris - Oxford Co.
049-0907-17230
6. Erosion of soil at ends of drainage pipes could effect the terrain and cover
below the project area and have an adverse effect on receiving streams (Moody
Brook, Basin Brook and Darnit Brook).
7. With soil types in the-Cobble Hill area resembling those in the A. C. Lawrence
sludge disposal s'jLte.,where -testing has indictated no groundwater or river
contamination, why" was.-the Cobble Hill area or some similar area passed by as
a choice for this project?
.8. Tree planting in the areas where sludge disposal has terminated will in time
h.elp to restore area and control erosion, but the time frame mentioned at the
hearing does not seem adequate for these trees to grow suitable to do much
good to control erosion and restore the area to its natural beauty.
9- What effect will the extreme high alkaline sludge water have on the groundwater
and -receiving streams?1.1
^Wildlife Considerations - P. Bozenhard & Perry
"The acreage of this project is ultimately to be planted to trees or some type
of cover as the project is completed. The plans call for the planting of pine, spruce
and other softwoods. This type of plantation planting results in the loss of early
successional stages which are beneficial to many species of wildlife. Since this
is an experiment in a sense to see what types of vegetation will live on this type
of material I feel the Utility District should plant a variety of species - not
only to determine what species will survive but also to provide suitable interspersion
of cover and food species for wildlife. Species such as autumn olive, crabapple,
multiflora rose as well as various seed mixtures are available commercially. Altering
tree spacing and planting a variety of species would provide better wildlife habitat
than would be provided through normal tree planting programs. Such conservation
practices may possibly be funded under ASCS conservation programs."
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To: Department of Environmental Protection From: Inland Fisheries and Came
Proposed Project Treatment Facility Sludge Landfill - Paris - Oxford Co.
Paris Utility District
DEP Project Number 049-0907-17230
After a thorough review of the above named project,.as presented to us by the applicant
or his agent, and consideration of the project's effects on the environment and our
programs and responsibilities, the following comments are submitted to the Department
of Environmental Protection.
_i
1. Aspects of the proposed project fall within the jurisdiction and/or interests of
this agency. CHECK ONE: YES £_ NO .
2. The proposed project is in accord with our programs and responsibilities.
CHECK ONE: YES NO . If NO, please submit details on a separate sheet.
3. It is our opinion that the proposed project does warrant a public hearing.
CHECK ONE: YES NO X .
Fisheries Considerations - S. DeRoche
"I have reviewed the design report and operation manual for this sludge disposal
.operation and have attended one day of public hearing relative to the project area
and the plans for the operation. Although there is still more testimony to be heard
regarding this project, I feel that I am well versed enough with the project to
"present the following areas which should be of major concern to the Department of
Inland Fisheries and Game:
1. The soils in the project areas are far from suitable for this type of project.
Peru and Ridgebury soils have very severe to severe limitations for sanitary
landfill projects involving sewage sludge.
2. The ground water table is relatively high (12") and the soils offer only very slight
permeability .
3. Draining off of the groundwater and "catching" and redirecting surface run-off
could very well adversely effect the summertime flows in Basin Brook, Darnit
Brook and possibly Moody Brook. There are two and possibly three intermittent
streams flowing through the project area which feed the above mentioned brooks.
Isolated, clear, cool water pools were present in these streams on July 25 when
the area was investigated. Periodic outcropping of groundwater seepages were present
within the project area and increased in intensity and frequency as one travels
down slope toward the receiving streams. Trout were present in the pools and surface
riffles in these streams just downstream of the project area several hundred
feet below the Old Sumner Road.
4. Intense freezing of groundwater drainage pipes could occur in winter within the
pipes as they angle upward from the 11 foot level to ground level. Such freezing
could greatly reduce groundwater draining and create water contamination from
deposited sludge within the 40 foot trenches.
5. Only 20% de-watering of sludge at the "plant" is possible; therefore, additional
water in significant amounts will enter the ground water table, thus creating
further draining problems .
SEE ATTACHMENT
1Qt TOTS
For 4ho
-------
DATE:
SUBJECT:
FROM:
TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
January 12, 1978
Comments on Draft EIS South Paris, Maine
Sludge Disposal Alternatives
William L. Lucas
Resource Conservationist
Kenneth H. Wood
Environmental and Economic Impact Office
Following comments are directed to the soils information and
trenching installations only.
A. C. Lawrence Site
The proposed site of disposal lies in an area mapped as Adams
series by the U.S.D.A - SCS and is a loomy, fine sand over fine
sands to a depth of 40 inches. It is rapidly permeable and
therefore has been rated as unfavorable for sanitary land fills
(per se). This means that a potential for underground water
contamination exists and that further investigations and study
is warranted.
The Draft EIS describes in detail the further study made and
their results. They are self-explanatory.
The disposal site (if selected) should have a surface water
disposal system designed to restrict runoff waters from the
area. The less water entering the sy-stem, the less chance of
dilution and percolation into the ground water.
Ryerson Hill Site
The proposed site of disposal lies in an area mapped as Ridge-
bory series by the U.S.D.A. - SCS and is a poorly drained soil
with a compact fragipan occurring at depths of 10-25 inches.
It also has a seasonal high perched water table. This soil is
difficult to drain, and requires a somewhat elaborate and costly
system of underground drainage to lower the water table. Sur-
face waters penetrate to the fragipan then move laterally,
usually down slope to where they may eventually break out to the
surface. Even with an elaborate drainage system installed, there
may be future need for additional pollution control measures to
remedy a malfunctioning system. The system and any additional
measures needed would require constant monitoring and a well-
managed maintenance program. This site appears to be very costly
for development and operation and maintenance.
The overall EIS is well written and addresses itself to the
concerns of Water Quality.
EPA Form 1320-6 (Rev. 3-74)
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EST. - 1869 INC. 1924
Robert T. Jonet, fmident
Paul C. Buckrum, Jr., Treasurer
Howard R. Perkins, Mwuger
Anthony Chiarawlotti
Ellas A. Cooney
Brewster W. Fuller
Robert E. Hicknun
Myles F. Howard
Frederick D. A. King, |r.
lames T. McDonough
Steven I Medlar
Arthur T. Lucchlni, Controller
lames A. S. Walker, Arch. Officer
WHITMAN & HOWARD, INC.
Engineers and Architects
45 WILLIAM STREET. WELLESLEY, MASS. O2181 TEL: 617-237-5000
January 13, 1978
Environmental & Economic Impact Office
U.S. Environmental Protection Agency
J.F. Kennedy Federal Building
Boston,' MA 02203
Attn: Mr. Wallace E. Stickney, P.E., Director
Re: Written Testimony
For Public Hearing
South Paris, ME.,
January 4, 1978
Gentlemen:
Pursuant to both our review of the "Draft Environ-
mental Impact Statement, South Paris, Maine, Sludge
Disposal Alternatives", and our attendance and oral
participation at the public hearing, Whitman & Howard,
Inc., on behalf of the Paris Utility District, would
like to state for the records several comments in regard
to the Environmental Impact Plan.
It is well known at this time, that the Environ-
mental Impact Statement lacks any definite conclusion,
other than the land disposal of sludge appears to be the
best and most cost-effective alternative.
Obviously this conclusion is weak, and the fact
that no solution for the Paris Utility District has
been formulated, is primarily due to the indecision by
the State Department of Environmental Protection (DEP),
Bureau of Land Quality's unwillingness to agree with
substantial and accurate data of soil characteristics,
and water quality generated both by Whitman & Howard,
Inc., and the EIC Corpration. The very fact that EPA
is going along with allowing the DEP to conduct further
on site evaluation of same is certainly an indication
that EPA does not wish to derive a solution from all the
supporting data to date. The State agency had ample
ASSOCIATES
Gerald T. Carey
T. T. Chiang Ph.D.
Edward R. demons
Robert E. Crawford
John L. Daniels
Donald F. Dargie
Charles C. Ellis
Ernest H. Fagerstrom
Curtis H. Flight
George D. Cusulson
Arthur Liatsos
lames A. Little
Edward R. Mayer
lames F. Murphy
loseph A. Murphy
Robert L. Wyman
LJur 108 tn Wear of L^ontinuou6
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-2-
opportunity to make comments during the workshop period
of the EIS so that if they believed "the sampling methods
used in the analysis were questionable" as they stated at
the hearing, they could have raised these doubts in
the process. Frankly it is very easy to make general-
ities that the "methods of the analysis are question-
able, and further investigations are needed."
You will find in reading the public record of the
sludge landfill (hearings), that the State has the
very same general comments concerning the Whitman &
Howard data presented in those hearings. We think it
is about time that the EPA should finally ask them-
selves if any additional water analysis or soil data
would really be any different than what has been shown?
If it were, what would the State really do with it
anyway.i Would it be in favor or against the A.C.
Lawrence site? or would it be neither? We ask the
EPA to really take a second look at where we are going,
to see now, if it really revolves around just some more
data. Such delays to the conclusion of the EIS, are
just more time consuming, more costly, and more burden-
some. You may recall early last fall, when after the
Paris Utility District met with both you and the DEP in
Augusta, when the EPA said a conclusion was about 3
weeks away pending "important and necessary data by the
DEP involving seismic analysis of the site." Such
important analysis never appears in the Draft Impact
Statement, and the still unanswered questions, as raised
in the public hearing, as to where it was is still un-
answered, if it were ever perfomed at all. It further
appears that the EPA, outside of the draft impact
statement, has no knowledge of it all. How long do
you expect the PUD to be able to continue financing
efforts like these?
It is very important to realize the very nature
of the DEP-EPA indecision in this particular case,
which, if a decision is ever made, will effect other
sludge landfill applications in the State of Maine.
Frankly, the indecision is reduced to the State being
in favor of an impermeable soil for sanitary landfill,
and the EPA being in favor of the permeable type. The EPA
should face this question NOW, in the final conclusion of
the EIS. Certainly the above two characteristics are the
only differences which divide the so called "hill sites"
such as the Ryerson Hill site, from the so called "valley
sites," such as the A.C. Lawrence Site, with perched water
being indicative of the former, and deep ground water
tables being indicative of the latter. It appears
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-3-
that if you have doubts in forming the conclusion of
the EIS, they are certainly focused on this subject,
and if and when any conclusion is formed if you don't
"pick the high road or the low road" then certainly the
EIS has brought us all nowhere.
The EIS in the final form should make a firm
cost effective decision on the best site. In terms
of the A.C. Lawrence site, such conclusions should
state not only the reasons for such a decision, but
also should state the landfill operating criteria,
restrictions and conditions so that they may in the
near future, become a part of any operation and main-
tenance report the PUD will have to prepare before using
the site, so that any further opposition can not be
honored if such opposition deals with the same premises.
Such criteria, restrictions and conditions should
also be in the final EIS and be related to costs to
determine if the A.C. Lawrence site is then indeed the
least costly alternative.
In terms of the Ryerson Hill site, such conditions have
been well addressed in previous hearings, and contrary
to the written correspondence of A.C. Lawrence Leather
Co., Inc. dated December 20, 1977, the Paris Utility
District does not "oppose it as being questionably suit-
able, as well as more cost and energy intensive both
initially and over the long run..." The Paris Utility District
simply wishes to own and operate the least costly landfill
site over the years to come, with Federal eligibility for
preparation of initial conditions, and such cost can only
be estimated after all conditions are raised, costed out
and agreed to by all in the final impact statement.
On behalf of the Paris Utility District,
Very truly yours,
WHITMAN ft HOWARD, INC.
Smith, P.E.
CMS/dfb
cc: Paris Utility District
Mr. Theodore Kurtz, Esquire
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1099 S. 7th Avenue
Yuma, Arizona 85364
January 17, 1978
U. S. Environmental Protection Agency
Region I Office
J. F. K. Building
Boston, MA 02203
Gentlemen:
Having spent most of ray life in the area, I am concerned about
the sludge disposal alternatives at South Paris, Maine. Through
several acquaintences, I have been asked to review your Environmental
Impact Statement, dated October 1977, on this subject.
Recognizing the fact that much of this may already be known, I
wish to make a few statements I feel are important.
Using your figure of 1.15 million gallons of industrial waste
water per day (page 10) and a conservative figure of 3% solids (page 17),
the result is a daily production of:
1.15 X 106 gal/day X 0.1336? ft3/gal X 3% solid = 4612 ft3/day
(of solid waste)
4612 ft3 at 22% solid content results in a total production of
20,964 ft3
This means that a 5-day, 50-week year will yeild:
20,964ft3 X 250 work days * 5,241,000ft3
2
Since the 52 acres at Ryerson Hill (page 35) equal 2,265,120 ft ,
a 100$ land use (not to include the buildings, spacing between trenches,
drainage ditches, and access roads) will result in a depth of waste
material of 2.31 feet per year.
I may not be a licensed engineer, but as a practicing mechanical
engineer, even I can forsee the consequenses of expecting this site to
last the minimum twenty years. It would require trenches approximately
46 feet deep over the entire property to do this. Any spacing between
trenches means they must be deeper, and I would not wish to be respon-
sible when digging a trench that deep next to one filled with a slurry
which, like wet clay, will produce tremendous pressures on the common
wall. I personally doubt if the trenches could be within twenty feet
of each other given that depth.
Doubting the ability to "bury" a slurry of this sort (clay of
that water content cannot be burried), there is also the added volume
of this overburden, as well as the disposition of the removed soil.
Recognizing that an Environmental Impact Statement does not
specifically offer recommendations, it does furnish information to
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those who do. For this reason, I feel that any information you have
available should not only be passed on, but should be carefully
evaluated as to its validity.
I believe I have given enough simple information to show that
there is no practical way to expect a twenty-year life at the Ryersbn
Hill site, regardless of the technical problems to be solved. Depending
on the final layout of the trench widths, lengths, and spacihgs, I would
guess that the site could not last ten years given no unforseen problems.
Incidentally, 20,964 cubic feet of waste per day at a density
greater or equal to water would result in a load limit per truck of 10 to
15 cubic yards. At that rate it will require 50 to 80 trips per day to
the Ryerson Hill disposal area. On a 2^-hour basis with 2 trucks, the
result is one trip every 35 minutes to an hour for each truck. It requires
a half-hour to make the round trip in a car. Loading/unloading will add
time. Snow and ice will add time. Vehicle maintenance will add consider-
able amounts of time. And don't forget that those roads were not designed
to handle those weights on a regular basis.
Granted, those last few statements may not affect the Environmental
Impact Statement; however, they may help you realize the quality of
forethought that has gone into this proposed project and why you may find
many people highly agitated about this subject.
I hope this letter is informative if not specifically influential.
Sincerely,
James B. Stewart
Project Engineer
Yuma Proving Ground
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United States Department of the Interior
OFFICE OF THE SECRETARY
NORTHEAST REGION
15 Sfcaite Street
Boston, Massachusetts 02109
ER-77/1080 "
January 20, 1978
U.S. Environmental Protection Agency
Environmental and Economic Impact Office
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Dear Sir:
The Department of the Interior has reviewed the draft environmental
statement, for sludge disposal alternatives at South Paris, Oxford County,
Maine.
We find that the statement is adequate except in regard to discussion
of ground-water resources, about which we have the following comments.
Metal recovery is mentioned as an alternative that would be more eco-
nomical earlier in the treatment process at the Paris plant or in the
tannery (p. 21, par. 1). Changes earlier in the process are, however,
not discussed nor mentioned again. It is also indicated that effluents
from the Paris plant to the Little Androscoggin River are periodically
very high in chromium as particulates, probably due to the substantial
fluctuations in pH and chromium of the tannery waste stream (p. F-9,
par. 2). Thus, changes in the treatment processes of the tannery and
the Paris plant would be of interest both with respect to reducing
current chromium impact to the river and reducing the chromium content
in the sludge. Potential improvements in these processes should there-
fore be further discussed.
Land-surface contours, all testhole locations, water-level observations,
and present, proposed, and past disposal sites should be indicated on
both figure 2 and figure 3. It is difficult to correlate with any
accuracy the data now shown on these two figures or given in the text.
A north arrow is needed on figure 3. The location of the Norway dump
and related topographic contours in the vicinity of the dump and between
the dump and the river should be shown because of the reported signif-
icance of contaminants from the dump in the vicinity of the proposed
A. C. Lawrence site.
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A water level of 32 feet is shown on figure 3 for test hole 17, which
was reportedly drilled through the historical sludge deposit. At least
an interpolated altitude should be given for this test hole because of
its importance in the evaluation of ground-water impact potential and
because of the considerable amount of data obtained from the hole.
Similarly the location and data for test hole 18 should be shown.
The text asserts that there is no permanent water table under the
current trenching area (p. 30). Presumably this refers to the sediments
overlying the highly fractured granite. Thus, the water table and
quality of ground water in the granite should be included in the assess-
ment of ultimate effects, and also monitoring or other mitigation, hit-
or-miss procedures.
The statement should explain more adequately the indications of contami-
nation found in observation well 7 at the A. C. Lawrence site; probable
paths of the contamination, which is attributed to the Norway dump that
is located about 400 feet directly across the Little Androscoggin River
(p. 33, Cr60), should be discussed. It is not clear from the text how
the contamination might have moved across the river or under it. Inclu-
sion of adequate analyses of the river water taken at strategic points
might help. The evaluation should also consider the apparent agreement
of the relatively high nitrate concentration in the water of test well
7 (P. C-59) with that of test well 18 (p. C-64), which was drilled
directly through a sludge deposit on the A. C. Lawrence site.
It is asserted on page 33 that ground-water-quality degradation at the
historical dump site has been avoided because of great dilution by a
large amount of ground-water flow and good permeability of soils that
allows rapid infiltration of precipitation. However, immobilization of
the wastes at the proposed A. C. Lawrence site is to depend upon the
reported relatively low permeability of till consisting of sand, gravel,
and boulders. At the historical dump site chromium is found throughout
the sand down to the water table (p. 33). Although currently produced
sludge is to be dewatered, the potential for subsequent mobilizing of
the chromium and positive mitigation measures should be more adequately
addressed. Determination of the typical vertical permeability of the
till would seem to be basic to the evaluation of the potential for
impacts on ground water over an indefinitely long period.
Current and planned design and operation of trench disposal at the pro-
posed A. C. Lawrence site should be discussed fully in the text; the
treatment should include details concerning any linings or covering
materials under consideration.
The draft statement manifests concern that a perched ground-water table
may be reestablished at the Ryerson Hill site, once the drainage ditches
are backfilled (p. D-18). It is stated that if the hydraulic conductivity
of the backfilled trenches is not substantially different from that of
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the undisturbed soil, the underdrains will be insufficient for removing
precipitation intercepted by the site (p. D-18). We note that according
to figure D-6 the peripheral underdrain trenches, which are to serve as
collectors for the parallel drainage ditches as well as to carry any
shallow perched underflow and infiltration, would be filled with crushed
stone. The analysis should also consider the use of well-rounded sized
gravel in these trenches to mitigate against the possibility of leachate
accumulation. Similarly, we agree that it is extremely doubtful that the
proposed drainage ditches (p. D-13) to be constructed parallel to the
disposal trenches would function effectively for drainage after they are
backfilled with material of low permeabilitypresumably the previously
excavated materials. The original continuity of any horizontal layers
would be destroyed; thus, lateral permeability would probably be drasti-
cally reduced at the backfill; furthermore, subsequent to backfill,
gradual compaction and subsidence would continue to reduce permeability.
We suggest that the statement should assess the use of adequate and
sustained drainage within the drainage ditchessuch as might be achieved
from the use of gravel-pack field drains tributary to the peripheral
drains. Because the interception of springs is probable (p. D-17), the
design of the drainage ditches (which are later to function as under-
drains and of the peripheral underdrains) should be adequate to transmit
all spring flow that might be intercepted as well as all infiltrating
precipitation. The statement stipulates that the drainage ditches will
be excavated sufficiently in advance of the ditches for sludge deposition
to permit effective dewatering of the area of the disposal trenches
before sludge is placed in them (p. D-13). The document should present
sufficient details of a hydrologic analysis of the extent of dewatering
within probable time constraints. Planned spacing of the system of
drains, which should be discussed in the statement, should be adequate
to accomplish and maintain drainage of all ground water to safe levels
below the disposal site.
Sufficient information on the distribution and construction of monitor-
ing wells should be included in the statement to permit assessment of /
the mitigation and of the potential that the wells themselves might
become avenues for contaminants. '
We note that the amount of relatively permeable materials seems to be by
far the greatest at the south and southeastern limits of the proposed
Ryerson Hill site (p. D-6, D-7: test holes 1, 6, 11, 17, 22, 23, 23A,
25). Accumulation of underflow and load on the proposed peripheral
drains would thus be increased in these portions of the site. The
impact evaluation should indicate plans to control and channel such
accumulation without disrupting the efficiency of the field of parallel
drainage ditches and underdrains.
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-2-
It is not clear whether lined disposal facilities and/or a systematic .
leachate collection system that could function indefinitely long have
been considered. The final statement should address these expedients,
Although it is commendable that the National Register of Historic
Places has been consulted (p. 14) and the sensitive Paris Hill site is
recognized (pp. 13, 14, and 15), we feel that a commentary from the
State Historic Preservation Officer (Mr. Earle G. Shettleworth, Jr.,
Director, Maine Historical Preservation Commission, 31 Western Avenue,
Maine 04330) should be secured, displayed and discussed in the final
environmental statement.
Further, we feel that a more detailed discussion of consideration for
archeological resources should be presented in the final environmental
statement. We do not wish to refute Dr. Sanger's report (Appendix G-l),
however, we must recommend following the guidelines for documenting
location and identification studies prescribed in 36 CFR 66, Appendix
B III, Federal Register, 28 January 1977. It is difficult to objectively
evaluate archeological considerations from the information provided in
this draft environmental statement.
Sincerely yours,
William Patterson
Regional Environmental Officer
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DONALD K. MASON
PARIS HILL. PARIS. MAINE Q4271
22 January 1978
E and E Impact Office
Room 2201
U.S. EPA Region 1
J.F. Kennedy Building (Federal)
Boston, MA.
Gentlemen:
There has been a tremendous amount of talk about the matter
of the sludge removal from the sewer treatment plant to a
point where the environment will not be adversely affected.
Most of us here on the Hill are opposed to bringing the sludge
to Ryerson Hill, the one next to ours, because of the follow-
ing reasons:
1. We do not want sludge trucks making 9 to 10 round trips
a day through our village main street. (Sewer Supt's est.)
2. The cost of the Ryerson Hill site will be far more costly
to maintain than the present site, now owned by A.C.Lawrence Co.
3. There is no guarantee that the leachate will not get into
the Cole and Darnit brooks, which now serve as water systems
for those on the lower side of Ryerson Hill.
4. Neither the Paris Hill nor Ryerson Hill roads are designed
to handle the traffic generated by sludge trucks.
S. Should the sludge trucks come over the Hill there is the
distinct possibility that they will leak sludge over our
roads, as it is doubtful that supervisors will be on hand
to see that these trucks are properly sealed.
6. Last but certainly not least of the reasons is the adverse
effect these trucks will have on the National Historic
aspect of this small but beautiful country vintage.
I hope the above reasons are enough to convince you that Ryerson
Hill is not the place to establish a site for dumping the
industrial waste generated by the various plants in South Paris.
Very truly yours,
Donald K. Mason
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PARIS HILL ' " 5 }g.
MAINE 04*71 ''
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PARIS HILL HISTORICAL SOCIETY
PARIS KILL.
PARIS. MAINE O427I
January 25, 1978
Environmental and iiconomic Impact Office
Room 2203
U.S. EPA Region I
John F. Kennedy Federal Building
Boston, MA 02203
Dear Sirs:
We have been directed by the members of the Paris hill
Historical Society to write you concerning the disposal of
sewerage on the Ryerson .Hill site, Paris Hill is a recognized
National Historic District, and our historical society works to
preserve the authenticity of the Paris Hill area.
We are concerned about the detrimental effects the dumping on
Ryerson Hill will have on adjacent Paris Hill. There will be trucks
carryiag sewerage, passing through the historic district's narrow
roads many times a day. Such trucks are a hazard to our children
and numerous tourists, and will certainl, detract from the lovely
views of the Paris Hill homes. Moreover we fear that a continuous
stream of trucks will shake the foundati. ns of the colorial homes
and church which are situated on the pro.osed truck rouie.
Many of the homes located on the ma n street are only five feet
from the road. It is feared that the ro-ds would have to be widened
to accomodate the trucks, thereby changiiig the very nature of the
Paris Hill Historical District.
We wish that your office would con. ider these problems, and
deny the Paris Utility District the righ; to develop iiyerson Hill
as a sewerage disposal area.
Sincerely,
Frances Alexander, President
..^> -.a. £ t"..!v .
Sue-Milieu Myers, Secretary
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.Mrs. 1 keodore R. Ridenul
Box 71
Paris Hill, Maine 04271 Qv ^
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SCHUYUER L. MOTT
PARIS HILL
PARIS. MAINE O4271
29 Ja.-u.-vry 1973
:". 1C Corporation
"[; Chapel Street
:.-.;:.on, Kass^chusettc 02158 APRS '1979
Ci=a-." Sir or I-Iada:a:
Z<..rly in January,! attended the hearing held at the Oxford Hills
:-iiih School Library concerning the "Draft Environmental Statement
or. Analysis of Sludge Disposal Alternatives for South Paris, I-'airie1'
prepared by your company for the U. S. Environmental Protection
Agency, Region I Office. At that time I raised the question of
whether the transportation of the sludge for lon-7; distances,
specifically The Hyerson Hill Site, had been made pa.-'t of the
environmental study. I was told to write this letter with that
~u-;._;estion. I regret that I have not been able to do so sooner,
but rathor pressing business obligations have prevented it. "However,
x now have had time to study the Draft Statement and sec that the
problem of transportation was never thoroughly addressed.
First, let mo state that I do not live on or near any of ths '-:-c>aclr*
proposed as routes for the sludge trucks, but I atr deaplv cc^.co^ie'"
for all those that do. in South Paris, Paris Hill, and the ro-e'ru^l
sections of the routes. I am fully aware that the sludge rnu.st be~:noved,
rra I thin'.: any environmental study vnust include thorough rese-rch
or- ths environmental impact the needed transportation will v-.vs.
Obviously, the shortest distance v-if-. the fewest 'cscple livins'or. th3 rou-
iv ths best i? it cf..n b- obtained. However, ths Evorson nil3 ":;i^ -- "" " -
v-.."l-.l 5-J-3S1 to force trrncportaticn of the slui^ so.no ei =;?!t or".-!::-e
-'- 1-".u;:h the h";o.rt of South Paris; and, at Is-st Wt of- tro
,i-\ tVi's :-:ain ntrsot. of Paris Hill. I thin> t^e -"olio- --
.-:-.::itt Ho: ='.^r\y trip:-; -=.'j.ily will be necessp.ry? I pc rso-rialy V/.-v:- henrd
-; -£' -- flv1?- o-v-.c. as .-.i-any --.s yighte-vn round trips. A^ this aros. -.row:,
:.^ ".'.'. it p.&c ;rov;n con si durably the lac-;t few v's^rsj v;il2 .-BO"'^ "^-l ~..->v^
t.rv.v)s be gra-di-t!.lly adJo-iT " " ""'"' ' ' " " '"" "
Second: I am most concerned for the people of South Paris w'-o will
h«--v= thes^ trucl:s passing with no alternative routes. At least," we
-.r- told, that ths trucks v^ill use tV.3 baclc of Paris Hill to"r^o.ch"'
.yrji-soi'i Hill c->:o3pt in b?.d. woathor. Hov/over, tv-.ir. routo is nu.oh"lorj ;er:
:--..;..^ h.2"v v;:;- h.^.ve the hu;"sn factor ont'DrJn^ the p-.\-ible;-.i. Aft-:r /. f-yj-
-I'-^t.h". -i;'.!1 udinr thr. lon^sr rout^. vril' tv» Jv>' vp1"- s^^r)"1-' ~t-"-''t ''"^
t.7 nl-r-t^t route strc-Ijht ^r--u.;h ?^-ii.' Hiii/"/::^o ' v;'iil"p,7iicJ"^i.-;-'
= :: c
. .
f-.cj..or-v/l ": :. tho trucks bo Vropv, in ex-col.-ont .-ey^.ir: no t- .:.
" ' ' '
i^ '
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-.- ' -2.
*
cheVi; to cvj.]~r5 liurs tho trualwo are properly -3 eel .5(1, o" v:lll Vr. 2 o. .:-,y
.m.j ~.;3 taken rxftu-r -i -.V.ils and the trucks filled -.nu sent ;-;i;t
v:it> --ithor V.:-: to ^ c~ hr.tnhs lov.'srcd but not zci2 ?ri? If tv orj i ;..
-jillv.^e want :\t^ tl'- ? e.v. /ii-onnental hazard c-ouor pdl'jttlor, to/.:-; pol" '..^ lor
in 'the air or to ner-r-by walls o-r v.T.ter in roe^gid^ dit.cl.oo o.' r. o :.: l:y
. . J. .^ -a .'O
- O . ;B...o .
*
Fiva: V/hat c.:.:.r.33rs ;ire tharc In c.-'.so of a serious 2. ^cicL'jnt tc on3 u ".
tr-.e trucks v/hsre all or most of the sludge is spill-ad?
Finally: I have been told that the ro;ic.3 proposed to Ryerson Hill
have bsen cleared. to carry the load by only one engineer? Is this true?
My concern hero is that heavy trucking ever ^^ the best of roais c?.n \~>3
& problem. I recently '.lived' for a brief ' £ine in a community v/hero
trucks from a nearby sravsl pit constantly went dov.m the main street
vhich vas a U.. 3. Kighv/ay. At the various stops along t'r.ia rcuto th i
constant applyins o? tha bralcoaof these trucVic created a ripple
effect v/hich was extremely dangerous to the lighter passengor care,
particularly for out-of-tov.mers not fAnili&r with the highv/ay. Th?
street via.s often torn up and a nov baoe ejid pavsnent laid, but ths
ripples alv;ay3 reappeared ir. a fev/ months. This is only an e".:anpl~ of
-./hir.t can happen on a v;i»ll raa'ntained highway. I hc.to to thir.': -,,rh''.t
the trucks would do to the proponed route to P.yerson Hill.
It cesrnr, to -'ne that no environmental study .3:>uli "bo complete v,rith~
cut a. thorough investigation of ths above probleas; and you, an
'c-nviroiaental engiheerG,-. can probaly t'lJnlc of a great :.iany r^ors
prc"bl:j3s relating to t;ie transportation of sludge. I hope t'.iat y"U
vill be able to incorporate such a study into the final atat
bs-foro its prrS3er.t?.ti.;-i to SFA.
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MRS. E. F. ROSSMAN
P.O.Box 47, Paris Hill
Paris, Maine 04271
February 4, 1978
E.I.3. Environmental & Economic Impact Office
Room 2203 - U.S. E.P.A. Region 1,
John Fitzgerald Kennedy Bldg.
Boston, Mass. 02203
Dear Sirs:
I am a resident of Paris Hill and I vigorously op-
pose the Ryerson Hill site as a depository for the
sludge from the industries in the area of South
Paris, especially the A.C. Lawrence Tannery with
its dangerous chemicals.
Several years ago our village was declared a His-
toric Site and my home, which Is on the Main road,
is one, of many in the community, on the National
Registry in Washington, D.C. of historical houses.
If the narrow road in front of my house had to be
widened to accomodate the heavy truck traffic it
would have a devastating effect on my property and
that of several of my neighbors. The pavement would
come right up to ouf front doors!' Furthermore, the
Town of P8ris does not service this road and any
leakage from the trucks would have to be cleaned up
by the residents. The roa.d has not been resurfaced
for years although it was promised four years ago
and it has been up to the property owners to clean
up the litter and debris cast off from the already
heavy traffic of trucks and cars.
In addition, how can the Ryerson Hill site be con-
sidered a favorable choice when there are so many
springsjand underground strums in that location?
There s no guarantee against, possible and probable
contamination of the water supply in the area. In
view of the severe winters how could the trucks ne-
gotiate the snow and ice covered hills and how could
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the trenches be dug *»<* covered daily in frequently
aub zero temperatures? It would cost a fortune.
Please give this matter your careful considerajlon,0
in reaching your decision and bear In mind that the
choice of Ryeraon hill would have a very damaging
effect on our purely residential community, inanx
you.
.Sincerely,
r&Uj
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JONES & BEACH ENGINEERS, INC.
N02AM^X<^-
IX'-
CONSULTING ENGINEERS 85 Portsmouth Avenue
Bradford H. Jones Post Office Box 159
David W Beach Stratham, New Hampshire 03885
Tel. 603/772-5017
February 10, 1978
U. S. Environmental Protection Agency
Environmental & Economic Impact Office
John F. Kennedy Federal Building Room 2203
Boston, Mass. 02203
Attention: William R. Adams, Jr.
Regional Administrator
Re: E.I.S for So. Par is, Me,
Gentlemen ;
In your draft Environmental Impact Statement for Sludge
Disposal in South Paris, Maine the alternative of sludge in-
cineration was considered but not in terms of chromium re-
covery from a standpoint of handling a well dewatered tannery
sludge. We have pioneered the use of belt dewatering equip-
ment for tannery sludges in both Hartland and Saco, Maine.
The second generation of this equipment is capable of prod-
ucing a 25% dry solid sludge and the third generation as
manufactured by Parkston, Fort Lauderdale, Florida and
Komline Sanderson of Peapack, New Jersey is capable of prod-
ucing over 30% dry solids in the sludges.
The centrifuged sludges at the South Paris Treatment
Facility have: 12.0 to 14.1 percent dry solids(l). This
is similar to the results obtained from the centrifuge at
the Berwick, Me. Tannery Waste Treatment Plant (15 percent).
The centrifuges at Saco, Me. have been able to consistently
produce ami 18% dry solids sludge. Therefore, we suggest
that belts rather than centrifuges should be considered for
dewatering prior to incineration. Each two meter wide de-
watering belt costs about $150,000 installed and has a de-
watering capacity of between 1200 to 1500 pounds of dry
solids per hour. Four, 2 meter wide machines are in oper-
ation in Hartland, Me. and an improved unit is being install-
ed in Saco, Maine to replace two existing centrifuges. This
1) Page A- 7 Table A-5 £ f p .-. ; y . .
rr--' ]( 1978
-------
U. S. Environmental Protection Agency
William R. Adams, Jr.
Page -2-
latter unit will handle primary sludges from the Saco Tanning
Co.'s waste and it will be in operation in March.
Tannery sludges will self combust in an efficient low
temperature incinerator with a dry solids content of about 22
to 25 percent. Therefore the fuel costs of $60,000 per year 2)
can be reduced to less than $5,000 of fuel used for start-up of
the incinerator. The addition of waste leather shavings and
leather scrap can produce energy. Batelle Columbus Laboratories
found that "burning the available leather waste from a blue split
tannery could save nearly all of the money now spent for coal or
fuel 'oil to furnish the required hot water". We therefore sug-
gest that the addition of the 20,000± pounds of wet lea- -
ther shavings and scrap being produced at South Paris each day
be considered an incinerator alternative.
Finally incineration of tannery sludges and leather shav-
ings has been demonstrated to be a cost effective means of pro-
ducing a totally recoverable hexavalent chromium ash. This ash
can be reduced to a one bath trivalent chromic sulfate tanning
solution in the normal manner. This unique patented process
allows for the recycle of all of the waste chromium which can
amount to between 50 to 65 percent of the chromium purchased.
Incineration is accomplished at low temperatures and in an al-
kaline state to avoid the escape of toxic chromium compounds
and oxides of nitrogen in the flue gases. An application is
being prepared by the Berwick Sewer District for an E.P.A. spon-
sored research and development grant to obtain further operating
data on this equipment. This type of incineration equipment
was tested full-scale in Saco, Maine two years ago and it met
E.P.A. "existing source standards" for air emmissions.With sub-
stantial improvements,the pilot plant unit that will be tested
in Berwick is expected to meet and exceed your "new source
standards" for air emmissions.
The economics of incinerating tannery and domestic sludges
along with the available solid tannery waste is outlined in
Tables 1 & 2. Assumptions have been made from information coll-
ected from similar tanneries and from data contained in the Draft
Environmental Impact Statement.
2) Page E-12 Table E-3
-------
U. S. Environmental Protection Agency
William R. Adams, Jr.
Page -3-
TABLE I
COST DATA
1) QUANTITIES
Sludge
Leather Waste
14,000 Ibs/day (dry)
20,000 Ibs/day (wet) 8,000 Ibs/day (dry)
22,000 Ibs/day
2) INSTALLED CAPITAL COST
1
Two Replacement
Dewatering Belts @ 1200#/hr.
each (12 hrs)
Incinerator unit 1200#/hr.=(18 hrs)
Building-Complete
Electrical & Instrumentation
Total Construction Cost
25% Engineering &
Contingency
3) OPERATION AND MAINTENANCE EXPENSE
$300,000
675,000
125,000
75,000
$1,175,000
295,000
$1,470,000
Dewatering
Incinerator
Same as cost of running centrifuges
Labor 15,000
Maintenance 7,000
Electrical 10,000
Replacement 3,500
Fuel 5,000
$40,500
4) RECOVERY
a> AVAILABLE IN HEAT 10 Tons of wet 3havings/day= 2,000,000
BTU/hr. @ 10,000 BTU/lb over a 24 hour day.
b) SAVINGS IN HEAT 320 gallons of oil/day = $160/day @ $.50/gal
-------
U.S. Environmental Protection Agency
William R. Adams, Jr.
Page -4-
TABLE I (CONT)
c) AVAILABLE CHROMIUM AS Cr
7 Tons of dry sludge/day @ 7%=
5 Tons of dry shavings/day @3%=
TOTAL
d) VALUE OF HEXAVALENT CHROMIUM
1280 Ibs x $.90 =
i
e) DAILY SAVINGS
HEAT
CHROMIUM
TOTAL
f) ANNUAL SAVINGS *
980#
300#/day
1280#/day
$1152/day
$ 160/day
1152/day
$1312/day
$393y600/year
* Assume 300 operating days/year
TABLE 2
COST SUMMARY
CAPITAL
O & M
$1,470,000 @ 20 years @ 10% =
SAVINGS (Chromium & Heat)
EFFECTIVE ANNUAL SAVINGS
($173,000/yr.)
( 40,500/yr.)
$393,600
$180,100
We trust that this information will helpfull and will
lead to the consideration /of an incineration alternative with
heat and chromium recovery. All of the information in this
-------
U.S. Environmental Protection Agency
William R. Adams, Jr.
Page -5-
response can be verified and will be demonstrated in our
upcoming project in Saco, Maine.
Please advise if we can meet with you to discuss this
environmentally safe and chromium free method of disposing
of potentially hazzardous chromium tannery wastes.
Very truly yours,
Bradford H. Jones, President
BHJ:vj
-------
R.F.D. 1, Box 165
Buckfield, Maine 0/4-220
February 14, 19?8
U.S. Environmental Protection Agency
Environmental & Economic Impact Office
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
To the EPA Staff:
Regarding the Environmental Impact Statement on "Sludge
Disposal Alternatives," South Paris, Maine, I should like/to
offer the following remarks.
The analysis of the present site, as done by the EIC Corp.,
appears to be thorough, and should have been undertaken whether
the present site (A. C. Lawrence) is to be used in the future or
not.
There are three drawbacks to the EIS. First, no recommenda-
tions are made. Therefore, the solution to the problem appears
to be as distant as before. Second, no investigations were under-
taken of the Ryerson Hill site. Conclusions were based on infor-
mation supplied by the engineers, Whitman & Howard. This is a
serious omission because it has become obvious over the course
of the EIS that the sludge for which the Ryerson Hill landfill
site was supposedly designed is not the sludge that is today going
into the current landfill site (A.C. Lawrence). The small amounts
of chromium to be deposited daily (^ Ifi of the dry-weight sludge)
were found in EIC's tests at the A. C. Lawrence site to be '1-1%
of the dry weight. (The tannery now claims that this amount has
been reduced.) The amount of solids for which the landfill was
designed by Whitman & Howard (22$) is actually about lk% solids,
which means a much wetter sludge would be going into the Ryerson
Hill site than the sludge for which Ryerson Hill was designed.
That the consistency (and proportion of constituents) is vastly
different from that predicted by Whitman & Howard can be seen
from the acreage per year currently being landfilled at A. C.
Lawrence site. It considerably exceeds the 1.7 acres allocated
by Whitman & Howard, and it is using up the A. C. Lawrence site
at such a rapid rate that the Paris Utility District expects to
be out of land by July 1.
-------
Third, alternatives were not seriously considered, resource
recovery being the outstanding alternative. Although incinera-
tion was considered as an alternative, it was a perfunctory con-
sideration. The premise remained that landfilling was an accept-
able way to dispose of hazardous solid wastes. I seriously
question the premise, especially for most areas of Maine, and I
believe EPA studies do so too. Lack of consideration of alterna-
tives is a major failing of the EIS , although not the fault of
EIC, which obviously had limited resources with which to carry
out its investigations.
The Maine DEP, of course, has raised many questions regarding
leaching from the A. C. Lawrence site into the adjacent acquifer.
Although the state has been less than thorough in its examinations
of both the A. C. Lawrence site and the Ryerson Hill site, I feel
DEP deserves to have every necessary test made before being asked
to reconsider the A. C. Lawrence site.
My belief is that the A. C. Lawrence site is the best tempor-
ary site for sludge disposal. It is the only site that has ac-
tually been tested after sludge deposits were made. It is, of
course, lost for other uses. To destroy another area, especially
one in a rural section, is very poor land use. If, at a later
time, it becomes necessary to retrieve the sludge, because of
federal regulations or for resource recovery, the A. C. Lawrence
site is certainly more accessible.
In the long run (say five years), if the tannery does not
go out of business, another solution must be found for the sludge.
EPA is responsible for the entire treatment plant-landfill program,
so it must bear the responsibility for indicating and financing
an environmentally suitable method of safe sludge disposal.
Sincerely yours,
vJ
q
(Mrs=) Judith Berg
-------
STATE OF MAINE
*»
Department of Environmental Protection
HAIR OfTICt RAY BUILDING. HOSPITAL STREET. AUGUST*
WUL ADOtEiS: STATE HOUSE. AUGUSTA 04333
Henrj E. Warren
COMMISSIONER
28928ii
AONIIIISTMTntSEMICCS:
289-2(91
February 15, 1978
BUIEAUV
AnguAimrcoiTiOL
2892437
LMDQUAUTTCOITiai
2892111
2892591
OIL POLLUTION CONTROL
2892591
«EG»«ALOFTW1
31 CENTRAL STREET
BANGOR 04401
9474746
415 CONGRESS STREET
PORTLAND 04101
775-6587
634 MAIN STREET
PRESQUEISLE 04769
764-3737
on poiumoN coma.
40 COMMERCIAL STREET
PORTLAND
7736491
OIL SPILL BEPCITS OiLT
(TOLL FREE) UOO-482-0777
ASSISTANCE SEITVICE
2892691
(TOLL FREE) 1-800-4 52 1942
Mr. Wallace Stickney
U.S. Environmental Protection Agency
Environmental & Economic Impact Office
J.F.K. Federal Building, Room 2203
Boston, Massachusetts 02203
Dear Mr. Stickney:
The DEP-Division of Solid Waste Management has completed its review of the
Draft Environmental Impact Statement for Sludge Disposal Alternatives for
South Paris, Maine. I hope that the comments offered in this letter can be
considered in the preparation of the Final EIS.
The writers of the report have synthesized a body of complex data into an
exceptionally well written document. However, I would like to express several
important concerns noted in the review of the report and earlier, draft sections
developed during the summer of 1977.
I am concerned that the impact of sludge at the so-called A. C. Lawrence
trenching site has not been fully determined. I believe that groundwater
quality monitoring wells were not placed at locations likely to be significantly
impacted by the disposal site. I also feel that the geometry of the groundwater
table is not properly described. As noted later, it appears that measure-
ments of groundwater levels in the schedule presented in Table C-6 (page C-21)
can be used to determine the groundwater table surface. A groundwater gradient
can only be determined from two points measured at the same time, and a plane
from three such points. The observations were made one well/one day at a time;
the data are not comparable.
The vegetative analysis of chromium uptake strongly suggests chromium transport
away from both the new and old disposal areas. This transport can not be
explained by the reported soil conditions.
The incomplete placement of monitoring wells, vegetative impact, and incomplete
description of the groundwater table clearly require collection of additional
raw data. Only by such additional field work can this office be confident that
the impact of the Lawrence site has been determined. The letter from Mr. Howes
of 15 February, 1978 discusses this in greater detail. A copy is included.
With regard to alternative methods of sludge disposal, I feel that incomplete
attention has been given to pre-treatment of wastewater from the A. C. Lawrence
Company for the purpose of chromium removal. Only a short, cursory paragraph
was devoted to this option. As you know, significant chromium removal from the
industrial waste stream could make other sludge disposal methods, such as land
spreading or composting, attractive.
-------
Mr. Wallace Stickney - 2 -
U.S. EPA, Boston
The analysis of the Ryerson Hill site has pointed out that the permeability of the
soil used to backfill the drainage trenches 1s an important determinant of the
efficacy of draining the perched water table. I suggest that a more permeable material
be considered for this backfilling than the native soil discussed. Use of a well
sorted sand or gravel would .aid in drainage control.
Specific page-by-page comments oh the Draft are presented on the attached pages.
Also attached are review comments prepared on draft sections of the report last
summer.
As you know, this office has expressed concerns over the investigation of the
Lawrence site over the past one-half year. It is our concern that the vital aquifer
located in the Little Androscoggin River Valley, be protected from any potential
source of pollution. I feel that the report should stress that contamination of
this aquifer would result in a serious, long-term health problem for thousands of
water users. The potential impacts of the Ryerson Hill site, while undesireable,
are never the less significantly less.
Yours truly,
Arthur R. Day, Geologist
Division of Solid Waste Management
ARD/ln
Attachments
cc: Ira Leighton, EPA, Boston
-------
Review Comments - Draft EIS
Sludge Disposal Alternative-South Paris
1) (page 3) first public workshop was July 8th, not 9th
2) (page 5) Report should identify why secondary sludge is not being produced,
and when it may be expected to be
3) (page 5) Why is the sludge solids content lower than estimated. What could be done
to increase it. This is an important concern for land disposal.
4) (page 8) The report identifies kame terraces. This is thought to be a dissected
outwash plane.
5) (page 10) The identification of the Little Androscoggin River aquifer as the only
significant source of potable water for the region is likely to result in an im-
permeable liner/leachate collection and treatment system if the site is used for
future sludge disposal, should draft RCRA guidelines be implemented
6) (page 17) Kjeldahl nitrogen includes ammonia-N; the report should state that the
"remainder is organic-N".
7) (page 19) "All chromium is Cr*3" is not supported.
8) (page 20) If Cr is removed from the waste stream, composting and anaerobic digestion
may be attractive.
9) (page 21) Metal recovery is thought to be possible. Why isn't this point followed-up?
10) (page 21) Incineration is discounted due to a high % water and Cr content in the
sludge. The cause of the low solids content and measures to correct it should be
determined. It should also be determined why Cr removal is not feasible. A com-
bination may make incineration possible.
11) (page 25) "Area filling not acceptable due to low % solids"-comment #10 also applies
to this.
12) (Figure 2) The new sludge disposal site width is about 290 feet on Figure 2.
On Figure 3, it is 420 feet. Other features of Figures 2 and 3 do not agree (such
as mill location, missing transmission line, no north arrow in Figure 3, well
#18 not shown)
13) Why isn't a complete topographic map available for the sludge disposal areas of the
Lawrence site. Additional information is needed for the area south of the site
interior road and area north and west of the new area.
14) (page 30) Why isn't a groundwater level measurement available for well #4. The
report implies that water was encountered, which is inconsistent with statements
that the area beneath the new area is dry.
15) (page 30) Disagree strongly that groundwater was monitored downgradient of the
sludge areas.
16) (page 33) The location of the Norway dump should be shown. Why is degraded water
quality attributed to it?
17) (page 34) The mechanism of chromium accumulation in the soil profile beneath disposed
sludge is considered to be inaccurate. Additional comments on this aspect are
presented in the attached memo.
18) (page 34) The suitability of the Lawrence site has not yet been demonstrated.
1~9) (page 39) Are springs, in fact, present at the Ryerson Hill site.
20) (page 39) It is important to realize that the amount of water coming in contact
with sludge at the Ryerson Hill site is small, particularly compared to the
Lawrence site.
21) (page A-3) Cr is reported to be present as Cr203 after ignition. It should be
stressed that this is stable only at these high temperatures.
22) (page A-5) Presentation of the diffractograms would be useful.
23) (page C-4) The methods used in drilling test wells should be more clearly defined.
State how well pipes were installed.
24) (page C-4 and following) Having two sets of wells numbered 1-5 is confusing.
25) (page C-4, 12) Were augered holes done with a hollow stem auger? details necessary.
-------
Mr. Wallace Stickney - 2 -
U.S. EPA, Boston
The analysis of the Ryerson Hill site has pointed out that the permeability of the
soil used to backfill the drainage trenches is an important determinant of the
efficacy of draining the perched water table. I suggest that a more permeable material
be considered for this backfilling than the native soil discussed. Use of a well
sorted sand or gravel would aid in drainage control.
Specific page-by-page comments on the Draft are presented on the attached pages.
Also attached are review comments prepared on draft sections of the report last
summer.
As you know, this office has expressed concerns over the investigation of the
Lawrence site over the past one-half year. It is our concern that the vital aquifer
located in the Little Androscoggin River Valley be protected from any potential
source of pollution. I feel that the report should stress that contamination of
this aquifer would result in a serious, long-term health problem for thousands of
water users. The potential impacts of the Ryerson Hill site, while undesireable,
are never the less significantly less.
Yours truly,
Arthur R. Day, Geologist
Division of Solid Waste Management
ARD/ln
Attachments
cc: Ira Leighton, EPA, Boston
-------
26) (page C-12) Phlogopite MICA is unlikely-it may be muscovite, biotite, or
some hydrated or weathered phase.
27) (Appendix C) The circumstances surrounding the drilling program are confused
and sketchy.
28) (Table C-6, page C-20, following). The measurement of groundwater levels in
test holes is very confused. Well levels were not determined on the same day,
but as much as one month apart. There is, therefore, no basis for stating
that groundwater levels dropped one foot over a month's time (p. C-20),
because the data used for comparison was one month old. The conslusions on
groundwater table geometry are meaningless; it is entirely likely that the
groundwater table fell or rose over this time. Three or more coeval points are
needed to define the groundwater table (a planar surface).
29) (page C-42) Groundwater table gradients are not reliable due to comment #28.
30) (page C-45) Improper sample collection technique in test hole #17
31) (page C-45) Was I.ON HNOa used in extracting Cr in test hole #17?
32) (page -48) Disagree with mechanism proposed for Cr transport through soil
profile (see other comments and memo)
33) (page C-52) The arguement that present Cr attachment to particles "proves"
mechanical transportation of Cr-bearing particles is unreasonable. Cr may
have adsorbed on these particles from solution.
34) (page C-52) Where is the location of the sample reported in Table C-18)
35) (page C-55) How can a COD of a soil be determined?
36) (page C-57) A precise reference for groundwater analytical techniques/methods
is needed. Were samples for metal analysis preserved with acid prior to
analysis?
37) Discrepencies in data-in Table C-20, well #14 water depth reported as 14.5 feet,
and #15 as 14.5. In earlier draft, levels were 14.5 and 22.1 respectively. Also,
in Table C-6, both wells have a reported water depth of 13.64 feet. In addition,
an early draft identified the water depth in well #17 as 25-30 feet. The present
report identifies it as between 30 and 35. Why is the water depth known to only
within 5 feet; what reliability place on other reported levels? In Table C-9,
water depth at time zero given as 15.80 feet, but in Table C-6, it is 13.64.
In Table C-10, same situation for #13 and #16 is 23.2 feet, but in Table C-6,
it is 22.1 feet.
38) (page C-57) Don't feel that groundwater quality monitoring wells were properly
located, and consequently, the results are not significant.
39) (page C-65) Chromium-plant uptake-see comments expressed in attached memo.
40) (page C-67)"Settling lagoons mentioned, but not discussed elsewhere. Were
the oak and pine data averaged? The contour maps agree with no single set of
data.
41) (page C-69) The groundwater gradients reported are not really "steep", as
stated.
42) (page C-69) The assessment of the Lawrence site is not supported by facts.
43) (Figure C-2) Data from well 2 and 5 used in drawing geologic cross-section.
In fact, the cross-section line passes through well #3. Well data from #3
should be used; the results are significantly different.
44) (page D-3) The suggestion that springs are likely beneath the fragipan at the
Ryerson Hill site should be supported by field observations.
45) (page D-3) The "large volumes of groundwater above the fragipan at Ryerson
Hill" is significantly less than the volume encountered at the Lawrence site.
46) (page D-15) Why should the fragipan be backfilled with soil to its original
density?
47) (page D-16) It should be determined how much groundwater can be transmitted in
the upper soil layer in contact with sludge.
48) (page D-18,19) Backfilling of the drainage trenches with native soil (till)
with noted hydraulic conductivity may be unnecessary- I suggest using a well
sorted coarse sand or gravel instead. This material has a greater hydraulic
-------
conductivity; better site dewatering could be achieved.
49) (page D-19) The soils of the Lawrence site are also acidic.
50) (page D-19) The analysis of the sludge's buffering capacity 1n section A stated
that 1t had significant buffering capacity 1n the mildly add range. This
contradicts the statement of "Little buffering capacity".
51) Incineration-see comment #10
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DEPARTMENT OF THE ARMY
NEW ENGLAND DIVISION, CORPS OF ENGINEERS
424 TRAPELO ROAD
WALTHAM, MASSACHUSETTS O21S4
REPLY TO
ATTENTION OF:
NEDPL-R
22 February 1978
Mr. William R. Adams, Jr.
Regional Administrator
U.S. Environmental Protection Agency
Environmental and Economic Impact Office
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Dear Mr. Adams:
The Draft Environmental Impact Statement for the South Paris Sludge
Disposal Alternatives has been reviewed and it appears that the
proposed project does not involve or relate to any Corps of Engineers
activities or jurisdiction. Therefore, no Corps of Engineers' permit
action need be taken. Subsequently, we have no further comments on
the Draft Environmental Impact Statement.
Thank you for the opportunity to review this impact statement.
Sincerely yours
Planning viyis
-------
PARIS UTILITY DISTRICT
TELEPHONE 743-6251 SOUTH PARIS. MAINE 04281
May 8, 1978
Environmental & Economic Impact Office
U.S. Environmental Protection Agency J-1
John F. Kennedy Federal Building
Boston, Mass. 02203
Attention: Mr. Wallace E. Stickney, P.E., Director
Dear Mr. Stickney;
As you are already aware, The Paris Utility District has had
a problem over the past three years in obtaining a permanent sani-
tary land fill site for the disposal of sludge from our Pollution
Control Facility. The State Department of Environmental Protection,
based on exhaustive testimony and other data, favors the Ryerson
Hill site. The U.S. Environmental Protection Agency, it would
appear, favors the A.C. Lawrence site, based on tests conducted
by their consulting engineers. The Paris Utility District has
been left in the middle due to the indecision and inability to
reach an agreement between the state and federal agencies.
At the present time, however, the Paris Utility District is
not in the middle, but backed into a corner. To put if bluntly,
even if all parties concerned reached an agreement tomorrow on
using the A.C. Lawrence site, we would not have any available
land left shortly after July first. The land adjacent to the A.C.
Lawrence property, owned by the Gladding Corp., we have been told,
is no longer available due to a corporate expansion program. This
land, as you know, was in the original plan for the land fill site,
however, when the DEP told us that the area was not according to
their specifications for the disposal of sludge, the PUD looked to
Ryerson Hill and won state approval based on meeting certain condi-
tions .
Our engineers tell us that it will take about six months to
get the Ryerson Hill site ready. So you see, we may possibly have
three or four months with no place to dump the sludge.
We do not wish to sound like a group of alarmists, but we
ask you, what do we do now?
Time is of the essence. We are rapidly running out of land
and it still appears that the DEP and EPA are miles apart in reach-
ing an agreement.
The recommendation of this Board is that Ryerson Hill be de-
veloped as quickly as possible. We have state authorization to
-------
May 8, 1978
Environmental & Economic Impact Office
Page 2
use that site once the conditions are met. However, we cannot
receive EPA funding without your approval also.
We ask you please to re-evaluate all your data and come to
an agreement with the DEP or at least tell us where to dump the
sludge while the two agencies continue to "fight it out".
Thank you.
Very truly yours,
Trustees of Paris Utility District
"iv'.viC- C/. ""
JP
cc: Henry E. Warren, Department of Environmental Irotection
Arthur Day, Department of Environmental Protection
Ron Howes, Department of Environmental Protection
Senator Edmund S. Muskie, Augusta, Maine
Senator William D. Hathaway, Augusta, Maine
Congressman William S. Cohen, Augusta, Maine
Jerry Hopcroft, Environmental Protection Agency
Robert E. Mendoza, Environmental Protection Agency
Bill Adams, Environmental Protection Agency
-------
STATE OF MAINE
Inter-Departmental Memorandum Da« August 7. 1978
-. Henry E. Warren, Commissioner _ Depi.
W. Bradford Caswell »^J/ Deftr DOC, Maine Geological Survey
***^^*» »»»»/>. --
Paris Utility District Sludge Disposal Sites
' ... -
Following your request of last week, I have reviewed the materials from the
DEP Solid Waste Division files relative to sludge disposal at the A. C. Lawrence
site near the village of South Paris, and the Ryerson Hill site in Paris. I did
not conduct on-site investigations at either site.
A. C. Lawrence Site
The A. C. Lawrence site is situated on the eastern flank of a major gravel
aquifer currently used as a municipal water source by the towns of Norway and
Oxford. This aquifer extends from Paris to Poland along the valley of the Little
Androscoggin River, a distance of about 20 miles. The sludge disposal site is
located at the approximate mid point in the length dimension of the aquifer.
Recharge to the gravel aquifer is derived from precipitation falling
on the vallev flanks, and on the exposed parts of the aquifer itself. Regional
ground water movement within the overburden is from the valley flanks inward
towards the river, into which ground water discharges, and southeastward through
the main body of the gravel deposit that occupies the river valley. The Norway
municipal well produces 1,500 gallons per minute with a drawdown of 16 feet.
The saturated part of the aquifer in the vicinity of the Norway well is about 70
feet thick. The quality of water from the Norway well is excellent. The areal
extent and saturated thickness of this aquifer, combined with the high quality
of the water, make it one of the most significant sources of ground water in Maine.
I estimate that aquifers of this magnitude and quality occur over less than
5% of the state.
None of the geologic information presented indicates that a hydraulic
barrier exists between the A. C. Lawrence sludge disposal site and the major
gravel aquifer; therefore, waste materials introduced into the ground water
beneath the site will, unless physically or chemically tied up by the soil or
fractured rock, ultimately migrate into the aquifer.
The key concern regarding continued use of the A. C. Lawrence site appears
to be the possible introduction of contaminants into the ground water beneath
the site, and the concentration of any of these substances that leave the site
and migrate into the major gravel aquifer.
Testing for harmful concentrations of substances moving away from the sludge
disposal site and into the gravel aquifer requires that ground water samples be
obtained from wells that intersect flow paths leading away from likely points
of contaminant introduction. Selection of ground water sampling points is a
I RMf 1CTV
-------
three-dimensional problem in that both geographic location and depth below
ground surface must be considered. The draft environmental impact statement
(EIS) includes neither a water table map, nor any cross sections that indicate
ground water flow paths. It is not apparent that even a rough 3-diraensional
analysis of ground water flow was made prior to selection of the ground water
sampling points. This apparent lack does not necessarily invalidate the con-
clusions of the EIS authors (that disposal of tannery sludge on the site is
not contaminating ground water), but does leave room for doubt in an environ-
mental situation where no doubt should exist.
Ryerson Hill Site
The Ryerson site in northeast Paris is typical of Maine's upland areas
where bedrock hills are plastered with less than 20 feet of campact glacial
till. There are no major aquifers near this site. This area is, however,
likely to contribute recharge to the underlying rock fractures; that is, the
regional movement of ground water in the area of the site is downward, away
from the ground surface. Wastes deposited at this site may migrate downward
into the underlying rock fractures.
The key technical question concerning this site appears to be the ability
of the soils to adequately filter and otherwise tie up harmful constituents
that may in time be released from the sludge. The techinque for lowering the
water table in order to expand the thickness of the unsaturated soil appears
reasonable. Migration of chromium out of the sludge docs not appear to be a
problem. From the information presented, the Ryerson Hill site seems acceptable,
as long as the "conditions" imposed by the Board order of 12 November 1975 are
followed. From my point of veiw, however, this hill-top site is less appropriate
for the tannery sludge than is a valley bottom site that is not adjacent to a
major auqifer. In the valleys, the regional movement of ground water is upwards,
toward the land surface. The land is not necessarily wet in these discharge areas.
Escaped leachate in such areas cannot contaminate ground water over an extensive
area, as it can in hill top areas, because the ground water discharges within
a short distance into a stream. The concentration of surface and ground water
flow in valley-bottom sites diludes the leachate that enevitably escapes from
a land disposal site.
Recommendat ion
My recommendation is that no further investigations be conducted at the
A. C. Lawrence site, and that sludge disposal be discontinued there as soon
as is practical. The applicant should be permitted a period of possibly 2 years
in which to develop the Ryerson Hill site or, preferably,.to locate and develop
some other site in a regional ground water discharge area. Any plans to expand
or move.the existing disposal site up or down the river valley should be discouraged
because of the close proximity of a major ground water source, and the likely
health hazard if this source should ever become contaminated by any harmful
substances. The applicant should be responsible for designing a plan to close
the A. C. Lawrence site that allows for decomposition of the sludge, but maintains
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Henry E. Warren 3 August 7, 197.9
the Immobility of the chromium. The Norway municipal water well does not appear
to be in immediate, if any, danger because it is on the opposite side of the river
(an assumed ground water divide), and it apparently is a water-table well now pumped
at an average rate of 700 gallon per minute, thus its radius of influence is
relatively small. Furthermore, the quality of water from the Norway well remains
excellent in spite of the poor quality of water in the Little Androscoggln
River, which would be induced into the well if the radius of influence extended
significantly beneath the river for'extended periods of pumping.
WBC/aJl
cc Ron Howes, DEP, Solid Waste Division
R. G. Doyle,, DOC, Maine Geological Survey
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Advisory Council on
Historic Preservation
1522 K Street N.W
Washington. D.C. 20005
September 1, 1978
Mr. Robert E. Mendoza
Environmental Planner
Environmental and Economic
Impact Office
U.S. Environmental Protection Agency
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Mendoza:
This is in response to your letter of August 15, 1978, asking that the
Council revise its previous comments on EPA's draft environmental impact
statement for a sludge disposal project in South Paris, Maine. This
request was apparently prompted by a change in the project since
publication of the EIS; i.e., of the two sites originally considered
for sludge disposal, the preferred site has since been found unacceptable
because of "technical problems". This makes the Ryerson Hill site the
potential disposal site and utilization of this site would require daily
routing of 10 to 15 sludge trucks through the Paris Hill Historic District,
a property that is listed in the National Register of Historic Places.
As you know, Section 800.9 (c) of the Council's "Procedures for the
Protection of Historic and Cultural Properties" (36 CFR Part 800) (attached)
states that
"Introduction of visual, audible, or atmospheric elements that are
out of character with the property or alter its setting"
constitutes an adverse effect. EPA should review the proposed site
location and its impact on the Paris Hill Historic District and determine
whether the nature of the effect requires that you obtain the comments
of the Council in accordance with Section 106 of the National Historic
Preservation Act of 1966 (16 U.S.C. 470f, as amended, 90 Stat. 1320).
The Council requests that you report the results of your investigation
to this office at the earliest opportunity. If you have further
questions or require assistance, please call Ms. Sharon S. Conway at
202-254-3967.
Thank you for your cooperation.
Sincerely you
SEP 5
1978
Harrison
Assistant Director
Office of Review and Compliance
Enclosure
The Council in an independent-unit vf the Executive Branch of the Federal Government charged by the Act of
October 1 5, 1966 to advise the President and Congress in the field of Historic Preservation.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
_____ ____________ x
Public Hearing:
Sludge Disposal Alternatives;
Draft Environmental Impact Statement
Library
Oxford Hills Regional High
School
South Paris, Maine
Wednesday/ January 4, 1978
Met, pursuant to notice, at 7:40. p.m.
APPEARANCES:
WALLACE STICKNEY
:EPA, Boston, Massachusetts
DR. A. G. MAKRIDES
E.I.C. Corporation
ROBERT MENDOZA
EPA, Boston, Massachusetts
RONALD HOWES
Department of Environmental Protection, Maine
KENNETH H. WOOD
EPA, Boston, Massachusetts
-0-
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WITNESSES
CONTENTS
Wallace Stickney
Tye Rabbe
Mr. Day
Sturart DeRoche
Vernon McFarlin
Mr. Smith
Charles Burg
Mr. Hopcroft
Paul Finnegan
Mr. Cooper
Tony Montanaro
Emory Ackley
Mr. Barber
Schuyler Mott
Danny L. Komulainen
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PROCEEDINGS i
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MR. STICKNEY: Ladies and gentlemen, can I have j
your attention, please?
i
It is somewhat past the appointed hour and I would j
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like to open the hearing on the Draft Environmental Impact i
Statement that we have before us.
My name is Wallace Stickney. I am Director of the
Environmental and Economic Impact Office at EPA, Region I,
Boston, Massachusetts, and it is my pleasure to be Hearing
Officer for the hearing tonight.
The hearing is held as required by EPA Regulations
which appear at 40 CFR 6, dated April 14, 1975.
A notice was included with each EIS that was sent oui:
indicating that the public hearing was tentatively scheduled
for tonight and since then additional notices have been
posted and have appeared in the local papers.
At the outset I would like to thank the folks in
the South Paris area, the officials in the Paris Utility
District, and the A. C. Lawrence people for their cooperation
in the study and their participation in the Public Workshops.
We are also grateful for the facilities that have
been provided for the conduct of the Workshops and the
hearing tonight.
With me here this evening on the hearing panel are,
from EPA, Mr. Robert Mendoza who is the Project Officer for al
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EPA municipal facilities and Environmental Impact Statements;
Mr. Ken Wood, on the far left, who is the Project Manager
for this particular impact statement; and sitting in the
audience down to my left is Jerry Hopcroft who is our
Construction Grants Engineer for the State of Maine projects;
representing the consulting firm, the EIC Corporation, is
Dr. Al Makrides, to my right; and front left is Mr. Tye Rabbe
From the Maine Department of Environmental Protection,
we have Ronald Howes; and there are other distinguished citizens
here such as Mr. Charles Smith who is consultant for the PUD,
and Mr. Tom Clifford, and other officials as well that are here
The Draft EIS was published on November 25, 1977.
It has an official date of recording with EPA, Washington,
of December 30, 1977. The 45 day comment period closes on
February 13, 1978; this hearing record will remain open
until that date.
As you will notice we have with us here tonight
a stenographer. He is here for the purpose of making a
stenographic record of the proceedings, a summary of which
must appear in the final Environmental Impact Statement, and
full copies of which will be made available for study here
in the South Paris area.
As you know, our regualtions require that all
responsible comments made during the EIS process be addressed,
and this record serves the purpose that all comments made
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verbally here at the hearing tonight will be properly addressed
Of course, all written comments that come in tonight;
or before February 13 will be addressed as well.
I would appreciate your cooperation in presenting
your comments. If you have them written, and would like to
submit the written comments and present a verbal summary
that may allow more time to give everyone a chance to speak
during a reasonable hour. The full text of your written
comments will be treated as if they were given here verbally.
There are some procedural issues that need to be
discussed at this time as well. At the present time, there
are draft Council on Environmental Quality Regulations now
in the works which will affect the conduct of the Environmenta:.
Impact Statement process.
We don't know what affect these regulations will have
on this particular Impact Statement, except that we do not
expect that they will be effective until the fall of 1978 and j
hopefully by that time we will have published the final
Impact Statement.
As soon as we know the effect we will let everyone
know via the newsletters that we send out on an occasional
basis.
There are also EPA Regulations regarding hazardous
wastes which are being promulgated in response to the water
quality legislation passed by the last Congress.
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If this sludge is determined to be hazardous as
defined by the Legislation and by the Regulations, this
would have further implications for the project, but we
can only surmise what these might be at this time.
Finally, as you know, and this is public information
there is concern on the part of the Department of Environmenta
Protection that there should be more work done at the
A. C. Lawrence site in order for them to have enough
information to evaluate any engineering solutions should
they feel that the site is capable of supporting an engineered
solution.
EPA has agreed to do this work, and it will be done
soon, hopefully within the next few months, and the results
of that information will be incorporated into the final
EIS and will enable us to make a final recommendation.
I anticipate that Mr. Howes from the DEP will be
making comments on that issue as soon as I am through here.
Our procedure for this evening will be to first
turn to Mr. Howes to present the comments and statement
of the State DEP; then we will turn to Mr. Tye Rabbe who will
present a short summary of the project as it appears in the
final EIS.
We will then ask for comments from elected or
appointed state officials, elected or appointed local
officials, and then from citizens at large.
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If there are no questions- concerning the procedures
I would like to turn to Mr. Howes who will present a statement
on behalf of the Maine DEP.
MR. HOWES: Thank you, Mr. Stickney.
The staff of the Department of Environmental
Protection has reviewed the Draft Environmental Impact
Statement on the sludge disposal alternatives in South Paris,
Maine.
It was noted that the statement for the most
part did focus on the A. C. Lawrence site alternative as oppos
to the Ryerson Hill Site.
At present the Department has not taken a position
favoring either of these two sites. However, we feel that
the following points should be stated:
First, there does remain, in our minds, substantial
unanswered questions concerning the A. C. Lawrence site.
A meeting was held on December 22 with the Department and
representatives from EPA; and we did reach a mutual agreement
that EPA would pay for additional work to be done at the site
primarily in the area of installation of additional wells
and sampling of additional borings into the geologic profile.
Secondly, it was noted that no other sites other
than the A. C. Lawrence and Ryerson Hill sites were really
considered in the Statement.
Thirdly, because of the potential of a high yield
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aquifer associated with the A. C. Lawrence site as opposed
to a perched water table at the Ryerson Hill site, it is felt
that the impact of any contamination at either site would
probably be more extensive and of longer duration at the
Lawrence site.
For this reason it is felt that all questions must
be resolved concerning the A. C. Lawrence site before the
Department considers giving the approval to long term
sludge disposal at the site.
We are optimistic that the completion of the
investigation outlined in the work plan,which staff will be
presenting shortly, will answer these questions and place the
Department in the posture whereby a concrete recommendation ca
be made on the A. C. Lawrence site.
Thank you.
MR. STICKNEY: Are there any questions from the
panel?
Next I would like to turn to Tye Rabbe who will
present a summary of the Impact Statement just to insure that
everyone is dealing with the same information.
MR. RABBE: I am going to try and summarize the
major findings and conclusions of the Environmental Impact
Statement the details are in the Statement itself, and
afterwards if there are any questions I would be happy to
entertain them.
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The purpose of the study, as you all know, was to
identify and evaluate alternative methods for disposing of
the sludge generated by the South Paris Pollution Control
Facility.
There are numerous alternative routes available
for disposing of the South Paris sludge; they involve
different sequences of conditioning and final disposal steps.
However, the environmental acceptability and
economic attractiveness of most potential routes are severely
limited by the unusual characteristics of the sludge in
question.
The sludge has low solids content (14% vs. 22% design
and thus has insufficient load bearing capacity for area filli
It also has a high chromium content which is about
7 percent of its dry weight; that is about 7 percent of its
dry weight is chromium metal.
While all of the contained chromium is in the
relatively stable and benign trivalent state, its presence
precludes surface spreading since the existing concentrations
are far in excess of those allowable for other heavy metals.
This also eliminates from consideration several
conditioning steps such as disinfection, composting or
digestion which might be used to stablize the sludge in
conjunction with surface spreading.
With these exclusions in mind, the remaining option
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with potentially acceptable environmental consequences are:
Incineration of the sludge followed by land disposal
of the resulting ash.
Chemical treatment of the sludge to immobilize
constituents and improve load-bearing capacity followed by
land disposal.
. And direct land disposal of the current sludge with
no further conditioning.
I would like to go through these major alternatives
one at a time and briefly discuss their benefits and their
disadvantages.
There are proven technologies for incinerating
conventional sludges, but the unusual features of the
South Paris sludge make it impossible to confidently assess
their applicability in the absence of actual combustion tests.
Even assuming technological effectiveness, however,
the high water and inorganic solids contents of the sludge
make incineration an expensive option.
Because of these energy consuming constituents,
incineration would require substantial supplemental fuel at an
annual cost of about $50,000.
Incineration would also oxidize the chromium to its
toxic hexavalent state necessitating chemical treatment of the
resulting ash. This not only increases costs, but the
efficiency of the ash treatment system would have to be proven
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before plans could proceed.
The costs of incineration are estimated to be
$600,000
in initial expenses, and about $120,000
in annual operating costs.
While the supplemental fuel requirements could be
satisfied by other solid waste materials about 15,000
to 20,000 pounds of municipal refuse, for example this
approach would require more expensive equipment and a
consistent volume and mix of waste materials.
Incineration of other solid wastes, moreover,
would merely subsidize incineration of the sludge since the
latter would remain a net economic loss.
Chemical treatment of the sludge prior to land
disposal would serve two purposes: to immobilize potentially
hazardous constituents and to improve the load-bearing capacit
of the sludge.
Several chemical conditioning systems are in
commercial application one of which is applied to chrome
plating both sludges similar in some respects to the South
Paris sludge.
However, our analytical results suggest, as noted
later, that the sludge constitents are already relatively
immobile. Thus, the major gain of such treatment would appear
to be more intensive use of the landfill site through
area-filling.
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Chemical treatment is estimated to require some
$200,000 in capital investment and an annual operating
cost of about $160/000; most of this would be for
chemicals.
Trenching of the unconditioned sludge is the simples
disposal alternative, but its impacts are situation-specific.
They, therefore, must be evaluated in the context of specific
disposal sites.
Our review of topographic, geologic, and soils data
for South Paris indicated that the area contains two distinct
types of potential disposal sites.
Upland areas are composed of fissured bedrock
overlain by a stratum of glacial till with very low permeability
The upper weathered surface of this till, however, frequently
contains perched groundwater confined within a few feet of
the surface. The true groundwater table is found within the
bedrock underlying the till; it is often in artesian
conditions.
Lowland areas near the valley floor, on the other
hand, are characterized by deep, highly permeable deposits of
sand and gravel. The water table in such areas is typically
at substantial depth and the groundwater flows from them
recharge the major regional acquifer underlying the Little
Androscoggin River.
To investigate the potential environmental impacts
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in these two types of areas, the A. C. Lawrence parcel, a low-
land site, and the Ryerson Hill parcel, an upland site,
were studied in some detail.
This approach was taken not because the two parcels
represent the only available landfill sites in the area, but
rather because their geologic and hydrologic characteristics
are representative of other available sites. The same
potential environmental impacts can be expected of other
alternaives of the same types.
The A. C. Lawrence site comprises some 50 acres
situated between Oxford Street and the Little Androscoggin
River.
It was studied in detail to determine if its use
for sludge dumping over the last 20 years has led to ground-
water contamination, and, if so, what corrective measures
should be taken.
The investigation included extensive geologic,
hydrologic, and water quality testing on site to characterize
ground water flow patterns and identify leachate from sludge
deposits. Groundwater was sampled not only downstream of,
but also directly beneath, historical deposits to assess
contamination.
Without going into technical details, it is accurate
to summarize that we found no appreciable groundwater
degradation anywhere on or downsteam of the site.
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Even groundwater directly beneath old surface deposits
of non-dewatered sludge did not show significant contamination,
It appears that the sludge itself is sufficiently
impermeable, and the surrounding soils sufficiently
permeable, that infiltrating rainwater does not leach
contaminants in significant contrations from the deposits.
While there is evidence of some verticle migration
of contaminants from the old deposits to the groundwater
table, the compounds in question have remained in insoluble
particulate form with no significant effect on water quality.
This migration should be mitigated for the current
dewatered sludge which contains no free liquids that might
carry particles downward.
From this we conclude that the continued use of the
Lawrence site is a environmentally acceptable alternative.
While the risk of degradation to local groundwater or the
regional acquifer cannot be ruled out with absolute certainty
the data on historical impacts suggest that this risk is quite
small.
However, we recommend continued monitoring both on
and downstream of the site to ensure detection of any future
problems.
There are no other major adverse impacts to be
anticipated from continued operation of the site. While the
land will be permanently removed from some wildlife habitation
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or alternative uses, and localized noise and esthetic impacts
will occur, they can be minimized through appropriate
operating procedures and buffer zones.
The current site, however, contains only some 15
acres of useable land and would have to be expanded to
offer a 20 year design life.
Land available to the south with similar geologic
and hydrologic characteristics could provide sufficient area
but it should be studied further to ensure suitability
before expansion occurs.
Costs for continued use of the Lawrence site
including expansion are estimated to be $36,000 initially
and some $25,000 in annual operating expenses.
The Ryerson Hill site, comprising some 52 acres in
the northeastern corner of Paris, was analyzed intensively
prior to this study. Our emphasis, therefore, was on a review
and independent evaluation of previously collected data,
analyses, and conclusions.
The principal facts concerning the Ryerson Hill site
are well known. The site contains lenses of perched ground-
water underlaid by impermeable glacial till.
A lateral drainage system was proposed to remove
this groundwater permanently. Sludge would then be trenched
in a fashion analogous to that now used on the Lawrence site,
except that the trenches would extend through the permeable
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cover material into the till. An eight foot buffer zone
would be left between the edges of the nearest trenches
and the lateral drains.
Omitting once again the technical details, our
conclusions concerning the Ryerson Hill site can be summarized
as follows:
The proposed lateral drainage system, coupled with
ditches extended directly to the sludge trenching area
should effectively drain the site of ordinary perched groundwa
at least initially.
However, the system will not permanently eliminate
groundwater flows arising from the true water table in the
underlying bedrock.
Such flows, if encountered, would require more
elaborate diversion systems to ensure that they would not
contact the trenched sludge. Unfortunately, the extent, if
any, of such flows is impossible to determine through ordinary
investigative procedures.
In addition, our calculations show that once the
direct drainage ditches are filled, the lateral system alone
is insufficient to eliminate the recurrence of perched
groundwater arising from precipitation; depending on the
degree of infiltration some groundwater will continue to flow
through the site.
The cover material on the trenches should be permeab
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to some degree because of the extreme difficulty in
re-compacting disturbed till to its original state.
The groundwater, therefore, is likely to move
horizontally across the top of the sludge deposits,
through the buffer zone, and into the lateral drains
to be discharged below the site.
Because of the extended contact time between these
flows and the buried sludge, the possibility of leachate
formations and contaminated drainage effluent cannot be
disregarded.
Unfortunately, there is no reliable method of simulat
these conditions to forecast the degree of leaching that
might occur. We can only say that the potential for
contamination exists.
Concerning impacts of the system outside the site,
it is likely that the drainage effects would be roughly
symmetrical.
Thus the land from one to several hundred feet
outside the drainage system would no longer contain perched
groundwater lenses. There is no reason to anticipate, however
that this would have devastating ecological impacts.
Rather, it would probably be accompanied by a gradual
and modest transition in vegatative cover, with little or no
change in wildlife habitats.
Additional impacts of the Ryerson Hill site shoud be
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no more severe than those at the Lawrence site. The land,
of course, would be permanently committed to this use.
Noise and esthetic impacts can be minimized. Perhaps the
major distinction is that the Ryerson Hill area is a better
deer habitat than the Lawrence site area.
In its approval of the Ryerson Hill site, the Board
of Environmental Protection attached certain conditions to
the proposed plan, most notably that the effectiveness of
the drainage system be demonstrated and that discharge from
the system be monitored.
There is little question that if these conditions arc
met the site would prove to be environmentally acceptable.
The key risk is that the currently planned drainage
system will not prove effective because of groundwater
interactions on the site.
Such an event would not necessarily require
abandonment of the site, but it would entail engineering
modifications with concomitant expenses.
A subsidiary risk exists that monitoring of the
drainage system effluent would reveal sufficient contamination
to require further action.
Estimated costs for the Ryerson Hill site are
$156,000 in initial capital, and $42,000 per year in
operating costs.
They are substantially higher than those of the
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Lawrence site because of the drainage system required and the
greater distance to the treatment plant. These estimates
assume that the drainage system will be effective with no
modifications.
In comparing these alternatives, several conclusions
are evident. Incineration and chemical treatment of the
sludge are substantially more costly than direct land
disposal. They could reduce land requirements for final
disposal and might also lower the risk of water contamination
although this would have to be proven in pilot testing.
The two trenching alternatives have, in most respect
similar potential environmental impacts.
The key difference is in possible water degradation.
At the Lawrence site the risk of significant water quality
impacts appears small, but the threatened resource is an
aquifer of major regional significance as a potable water supp
At Ryerson Hill the risk of contamination must be
viewed as greater and the threatened resources are the streams
and brooks orginating in the area.
The other key difference, of course, is cost. The
costs of operating the Lawrence site are well established and
relatively low. The costs of developing the Ryerson Hill site
because of its more complex design and potential problems, wil
be substantially higher under optimal conditions and could
expand further if problems are encountered.
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MR. STICKNEY: Thank you, Tye. Are there questions
from the panel?
If there are no questions I would like to turn
next to Mr. Day of the Maine DEP who will present the
specifics of the additional work that the DEP would like to
have done at A. C. Lawrence.
MR. DAY: The DEP staff has reviewed the analysis
of the so-called A. C. Lawrence sludge disposal site prepared
by the E.I.C. Corporation.
The substantive finds of this review have been
previously discussed by the EPA office in Region I.
Summarizing these review findings, criticism was
expressed over the methods used in the site investigation, ,
i
the geologic analysis, and the proposed mechanism of chromium
transport through the soil profile.
i
It was felt that the full impact of this disposal
site could not be adequately described unless additional
site investigation and water sampling is performed particularly
if the DEP is to be expected to react to another request for
long-term approval of the Lawrence site. I
i
Consequently, the staff has developed a work plan
for additional site investigation. A detailed plan is submitted
with this report, but can be summarized as follows:
It is suggested that additional test borings and
groundwater monitoring wells are required in four general zones
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of the Lawrence site. As many as 12 wells may be needed.
These wells should be installed in locations coordinated with
the DEP staff using a specific type of drilling and sampling
equipment. Water sampling and analysis should be performed
using EPA recommended methods.
A detailed review of the entire Draft EIS will also
be submitted to the EPA Region I shortly.
Rather than reading over the detailed work plan,
I would like to submit that to the Board as a written comment.
MR. STICKNEY: Thank you, Mr. Day.
Are there any questions?
We will next turn to other elected or appointed
State officials -- are there any here who would like to
speak?
MR. DE ROCHE: I am Stuart De Roche, Regional
District Biologist.
I would like to briefly comment that the Maine
Fish and Wildlife did review the original site selection
application that was submitted to the Maine Department of
Environmental Protection,, and we did make our comments known
to them with a report of August 19, 1975; and that is on
file.
We have reviewed the EPA's Environmental Impact
Statement and the alternatives, and I would like to briefly
read Maynard Marsh's who is the Commissioner of Inland
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STATE OF MAINE
Department of Environmental Protection
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Proposal for further work: A. C. Lawrence Site
After studying data prepared by Whitman & Howard (1975)
the following work plan is submitted that, is hoped will
not addressed in the Draft EIS submitted 1977.
and DEP staff
answer questions
(1) Ten to twelve monitoring wells are necessary.
(2) All wells be installed using Hollow Stem Auger.
(3) Soil sampling will be done using a spiff spoon sampler driven ahead of the
bottom of the auger. Samples will be taken at 5 foot intervals to refusal
(4) Four inch diameter PVC pipe be used as wells.
(5) Well slots to be about 0.25mm.
(6) Slotted intervals will be determined at the time of drilling.
(7) Security devices should be installed at the tops of the various wells
with keys available to DEP, EPA and consultant.
(8) Soil samples are to be analysed for grain size distribution (using ASIM
procedures for washed samples, coarse sieve, fine sieve and hydrometer
analysis), cation exchange, and extraction and leaching analysis.
(9) Wells are to be located at sites specified by DEP staff. Well locations
will be checked before drilling using seismic methods to determine depths
to bedrock.
(10) A member of DEP staff to be present at the time of drilling.
(11) Maine Testing Borings of Brewer, Maine is recommended to do the desired
drilling, soil samplim and well installation.
(12) Water sampling should be done at several intervals throughout the zone
of saturation in eacli well.
(13) Water samples should be collected at least twice per month for the dura-
tion of the contract but in no case should less than 6 samples be
collected from each well.
(14) Parameters that should be noted or tested for at each well at the time
of sampling are:
A. d^pth to groundw-Tter surface
I1'. Temperature
C. pi I
El
C.
Te
G.
Cl - (spccilic ion electrode)
NII3 (specific ion electrode)
filtrate (specific ion electrode)
II. Conductivity
J Salinity
15. Parameters to be tested for at a lab using recommended EPA methods
(samples should also be preserved using recommended methods)
BOD5
COD
TOC
TSS
IDS
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Hardness
Alkalinity
Nitrogen-K.N
Total Cr. J
Ca#
NA+
Mg#
K+
Total Pb
Total Fe
Mn#
16. Results reported to D.E.P,
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Fisheries and Game -- statement to Remi Jurenas who is the
State Clearing House.Coordinator in the State Planning
Office.
I do think that the DEP does have a copy of this:
"We received the EPA Environmental Impact Statement
conerning the South Paris Sludge disposal alternatives.
The final decision here appears to involve some highly
technical predictions concerning groundwater and surface
runoff containment. This Department does not feel qualified
to make a technical analysis which would allow us to favor one
site over the other, but we do have strong concerns regarding
the Ryerson Hill site. Enclosed is our August 19, 1975
recommendation to DEP concerning this project.
"After reviewing the EPA Environmental Impact
Statement our concerns are not changed. The streams near the
Ryerson Hill site are good brook trout streams and the
quality arid quantity of the water supply is essential to the
maintenance of these trout popluations, Jf we consider the
very real factors of mechanical failure, human error, and
imprecise estimation, we feel that in the final analysis the
Ryerson Hill site has a lot of unanswered questions, and from
our point of view, our best judgment at this time is to recommend
the A. C. Lawrence site even though we recognize the problem
of less space available."
MR. STICKNEY: Thank you very much.
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We do appreciate your coining here and making the
statement. Are there other State officials here who wish
to be heard?
Are there local elected officials who would like
to be heard?
Our next category is local appointed officials.
MR. MC FARLIN: My name is Vernon McFarlin, and
I am the Secretary of the Paris Conservation Commission.
The Commission reviewed the Environmental Impact
Statement at its regular December 7th meeting.
The following points were noted:
Regarding the Ryerson Hill site A possibility
which cannot be predicted with certainty is that groundwater
originating in bedrock fissures could render part, or all, of
the site unusable.
Two, concentrateed leachate will probably collect
in the drainage trenches. Being acidic it will tend to dissol
chromium hydroxide an unfortunate circumstance according to
the EIS.
- Three, drainage ditches at the boundaries will not
effectively drain precipitation on the site.
Four, using the Ryerson Hill site will produce more
noise and visual impact and consume more energy in transportat
than use of the Lawrence site.
Five, development of the site involves using a
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previously untried design.
Six, utilization of the site involves a considerable
financial risk.
Regarding the Lawrence site:
One, no environmental problems are being experienced
the chromium in the sludge originally dumped there has not
' migrated.
Two, the sludge now being dumped there is still less
likely to cause contamination.
Three, the Lawrence parcel and its immediate
surroundings are an acceptable disposal area.
In view of the above findings, the Paris
Conservation Commission requests that the sludge from the
Paris Pollution Control Facility be buried at the A. C.
Lawrence site and not at the Ryerson Hill site.
MR. STICKNEY: Thank you, Mr. McFarlin.
Are there other appointed local officials who
would like to speak?
Our next category is citizens-at-large perhaps
the most important.
Because we have not set up a speaker's list,
we will simply ask who would like to speak first?
Mr. Smith.
MR. SMITH: I have questions about what the speakers
were talking about will this be handled later in the prograiji
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or at this time?
MR. STICKNEY: Are your questions devoted to
how we will procedurally handle the questions?
MR. SMITH: They have to do with the summaries that
were explained by the previous speakers here this evening.
MR. STICKNEY: The way that we normally conduct
the hearing is for the speakers to make their presentatio^i
and if others have differing viewpoints, we request that they
get up and make a presentation developing that viewpoint
rather than getting into a direct cross-examination of the
speakers.
If that can accommodate your desires,we would
appreciate it. If not, you can raise your questions for the
record, and the record will be available before the close of
the comment period so that additional comments can be made
at that time.
Do you have questions that you would like to raise
for the record at this time?
MR. SMITH: Yes, I do.
My name is Charley Smith. From the Draft
Environmental Impact Statement that has been distributed prior
to this meeting and especially some of the summaries that
were given here earlier this evening -- I think raise some
substantial questions of underlying facts in comparing, if
in fact we are comparing, the A. C. Lawrence with the
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Ryerson Hill site.
Obviously there seems to be some differences
between the Federal Agency and the consultants the E.I.C.
people and the State Agency through the Bureau of Land
Quality Control of the DEP.
Basically, I think that the unanswered question
here is the premise of whether or not the valuableness of a
site is first founded for this sludge based on whether we
are looking for a permeable type of soil on the trenching
method for this type of sludge or are we looking for an
inpermeable type of soil for this type of sludge.
I don't think, truthfully, the Impact Statement has
addressed itself to this underlying fact.
I think that the question of permeableness between
the two sites are very different; and it has not been really
analyzed as to what viewpoint the Impact Statement is taking
as far as looking at a permeable soil for suitability to
this type of sludge or the impermeable type soil that is
common to the Ryerson Hill site.
I think that the other questions that are unanswered
at least in my mind is that I recall a meeting late last
summer which involved the applicant, the Paris Utility
District.
At that time, the State Agency, the Bureau of Land
Quality, was about to embark on a soils investigation program
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involving some seismic studies amongst other things: I
don'Vt see any of this data in the Environmental Impact
Statement, and I question at this time why that data was
not performed, and if it was,why it was not presented.
Secondly, the amount of groundwater analyses and
soil data that has been done by Whitman and Howard in previous
reports the extensive amount that was done by the E.I.C.
seems very hard for me to realize that one of the conclusions
by the State Agency here tonight, is that additional
investigations in^ water sampling are needed; namely some
more borings and some more wells.
Certainly, I think that the Draft Environmental
Impact Statement has shown both the data of Whitman and
Howard and the E.I.C. people, and has substantially investigat
both the soils and the water quality on that site, both during
a treated sludge condition and during an untreated sludge
condition which took place over several years.
I doubt very much that any additional soil
information or water quality analysis would show anything
different than what has already been presented.
The other question that came out of tonight's
summaries given by previous speakers, seems to be the
basic difference again it hasn't been addressed is that
the EPA seems to feel that the water quality impacts on the
A. C. Lawrence site are smaller than what they would be on
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the Ryerson Hill site.
I believe that one of the State's speakers from
the Bureau of Land Quality one of his summary statements
was to the effect that there would be more extensive and
of longer duration of problems of contaminants at the
A. C. Lawrence site.
Again, I think it leads the public here tonight,
those hearing the opposing arguments of which site really
does have the least possible water quality impairment due to
the sludge burial.
I think that at this point in time -- and the time
and money that has been spent both by the District, and the
A. C. Lawrence, and other users of the treatment 'facility
and the emergency landfill site I think that enough
good data has been presented by both sides and from all
parties that additional borings or wells or seismic surveys
are not going to shed anymore light on the subject than that
when it was previously investigated.
I would be interested if such data does have an
impact. As I recall that meeting we had with the DEP -- there
was some question of the involvement of formations on the
A. C. Lawrence site, and the possiblity of kettle-hole formati
that would cause leachate sinks to the groundwater table.
Again, I don't see this data on the impact statement
and I have to question why it is not in there; and if it does
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have an impact, whether or not it will appear on the final
Impact Statement.
MR. STICKNEY: Thank you, Mr. Smith.
One general comment is that one of the burdens
as well as one of the blessings of this process is that
the disagreements between the various agencies are not aired
behind closed doors but in public.
And that is precisely what we are doing here in
this process; everyone is learning where the interested
parties stand, and, of course, it goes without saying that
there is no simple single right solution.
With each solution there is a considerable amount
of judgment involved.
MR. BURG: My name is Charles Burg, and I wanted
to make an unusually brief statement.
I know that we are highly likely to go into a sessior
in which given sections or points of the EIS will be
intensely examined and perhaps even critically.
I just wanted to say that having read one or two
of the EIS's with the exception of the fact that the entire
body of physical data on the Ryerson Hill site was taken
primarily from the state record I think it would be
worthwhile to say that the remaining structure of the EIS
is technically a very fine job.
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MR. STICKNEY: Thank you very much for that
unusual comment; it is very much appreciated.
Are there other comments or statements that need
to be made this evening?
I see a hand at the very back.
MS. BURG: My name is Judith Burg.
I have been looking at the tables in the EIS and
I see that the sludge was last analyzed in October of 1976,
and I was wondering if the sludge we were talking about then
is the same sludge we are talking about today; have the
physical characteristics changed in any way?
The characteristics that were found in 1976 were
not the ones that were supposed to be there.
MR. STICKNEY: I might turn that question over to
Mr. Hopcroft, and ask whether or not he believes there have
been significant changes in the operation of the plant over
that time.
MR. HOPCROFT: There have been changes in the
operations of the plant since 1976 I don't know
MR. STICKNEY: By the way, you might note in
Appendix A, page A-/8, table A-6 of the EIS that there was
a composite sludge sample analyzed on 6/22/77.
MS. BURG: It does not give chromium.
MR. STICKNEY: We have solids and chromium content
data which does not appear which I am told indicates essentia
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the same values as were there before.
Yes, sir.
MR. FINNEGAN: My name is Paul Finnegan, and I am
with the A. C. Lawrence Leather Company.
I am surprised that the chromium content of the
sludge hasn't gone down because we began recycling at least
50 percent of our chromium at the plant so that there should
be a lesser amount -- in the original statement made by
Mr. Rabbe that 7 percent of the solid was chromium.
I would hope that that has gone down a little bit;
I would hate to be throwing that money away.
DR. MAKRIDES: I am Dr. Makrides of the E.I.C.
Corporation and I would like to respond to that.
I am not sure about the compound. The solids
content of the sludge was still about 14 percent; I don't
know what happened to the chrome.
MR. STICKNEY: Mr. Finnegan, when did you begin
the recycling process?
MR. FINNEGAN: I think it was around October of 1976
somwhere in that period of time. What is the date of the
analysis you are looking at?
MR. STICKNEY: October 1976 end of October 1976.
MR. FINNEGAN: The end of October, yes; probably
there would not have been any impact at that time.
Subsequent tests should show that it is down.
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MR. STICKNEY: You feel that it should be reduced about
half?
MR. FINNEGAN: I would think about half; we are
recycling about half and we are making efforts to recycle
the other 50 percent of it.
We will never get 100 percent; there is a point of i
no return in this recycling business. I
We are effectively recycling about 50 percent of
it right now and have been since October of 1976.
MR. STICKNEY: Thank you very much.
Is there someone who has not spoken who wishes
to speak?
This is a very quiet group; I must say that I am
impressed.
Yes, sir.
MR. DE ROCHE: I have spoken but I would like to
ask a question; are there any sites now being considered
if either of these two sites are not chosen?
MR. STICKNEY: I can answer that from the Impact
Statement side and say that we are not considering other sites;
we consider these as typical sites. Would Mr. Howes like
to respond to that as well?
MR. HOWES: As far as the State is concerned, we
have not looked at alternative sites, but we willing to
consider any alternative sites the District comes up with and
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offer any technical assistance in evaluating the sites.
The State has not considered any other sites, but
would be willing to offer the District any assistance
in evaluating any other potential sites that they might
want to look at.
MR. STICKNEY: I might ask the District whether or
not they have been evaluating any other sites just for the
record?
MR. BARLOW: I am John Barlow, Treasurer of the
Paris Utility District.
We have not been evaluating any other sites; but as
a question to this man's previous answer, will the State totally
fund any other site evaluations?
MR HOWES: The State has no money available for
funding; I can only offer technical assistance in terms
of evaluating the geology. It is unfortunate but it is a
fact.
MR. STICKNEY: Mrs. Burg, did you have your hand up?
MS. BURG: If the tannery is recycling 50 percent,
what is that in pounds? That is 50 percent of what?
How much does it loose a day?
MR. FINNEGAN: I think it is something like 600
pounds of chromic oxide.
MS. BURG: That is leaving the plant a day?
MR. FINNEGAN: Yes.
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MR. STICKNEY: Are there other statements regarding
the Draft Environmental Impact Statement that should be
made for the record?
Yes, sir.
MR. COOPER: In the hearings that we have had
previously, and there is nothing in the Environmental Impact
Statement other than if you go to page 40
On page 41 of the Environmental Impact Statement
on the estimated cost of operating there has been
by the State's how to judge the effectiveness or uses
of the Ryerson Hill site; my question is this: how far does
water flow down hill?
This 350 feet is okay if you are on a perfectly leve
plane, but these streams are more than five degrees how
far does water flow down hill if it is running out of the
drains that they have on the Ryerson Hill site?
I'll bet that has never been figured in.
Another aspect that I think was taken the State's
decision to use the Ryerson Hill site which had been brought
up at the first public meeting that we had or the second
on the feasiblity of the road being able to hold the load that
was to be transported over there daily or five days a week or
whatever it is estimated at.
Of all the testimony that we have in the Environment
Impact Statement and all the testimony that has been submitted
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to you people it has all been by geologists, chemists,
and other people of high educated levels, but when it came
to deciding if the road was feasible they took two people --
one was a woodsman, and the other was an eighth grade
graduate who is a road maintenance man.
Their testimony was used to say whether or not
the road is capable of carrying this amount of sludge over
it everday.
Last spring or last fall they tore part of this
road up and put on a new surface and it is in worse condition
now than when they started in the fall, and it has only had
one bus.
I think that this is an additional cost that has
to be figured in in the maintenace of the Ryerson Hill site.
I don't know if the PUD will pay for it or if the town will pay,
but in the long run somebody is going to pay for it.
If this is the case, go out and take a look at the
bridge; no disrespect to the town, but I would hate to see
a bus and a car pass on that particular bridge, today, with
the way that it was plowed.
I also would hate to see a sludge truck and an
automobile pass the way that it is today.
I would also like to see the condition of the road
if the Paris Utility uses the Ryerson Hill site if there
is going to be a different maintenance, and who is going to
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pay for that?
Thank you.
MR. STICKNEY: Thank you, Mr. Cooper. When you
mentioned water flowing down hill is the spring your
spring, and is it in use?
MR. COOPER: Yes.
MR. STICKNEY: Mr. Burg.
MR. BURG: I am concerned with what happens to the
Environmental Impact Statement from here on and what uses
will be made of it; I assume that that is the purpose of
this review of the Draft Statement, or rather one of the
purposes of this meeting.
There are several points that I want to raise in
that connection -- some of which I have already given as
written comments.
One is that on the Ryerson Hill site almost the
entire body of technical information appearing in the
Draft EIS is taken from the records of State hearings; and
there are certain technical errors ift those records of
acknowledged
technical data.
It is not so much my concern that these be
and corrected as it is that these be treated in such a way tha
they might not establish a precedent for accepting fallacious
methods.
I believe that there may be other comments on
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on technical errors that appear in the EIS through the EIS
having adopted certain sections of the state record.
I think that it might be a good idea, and I believe
that I did suggest this in writing, that since the EIS
will have drawn extensively on the State's records, that the
State record should be adopted as a whole since to extract
parts of it may be to leave arguments of substantiation
missing.
The second thing that concerns me, as has already
been pointed out this evening, is that there is evidently a
fundamental and vigorously pursued technical dispute in this
matter -- in that one State agency has opted for one site
while the evidence offered in the Draft EIS would seem to
lead to contradictory information.
There does happen to be a fairly thick body of
correspondence pertaining to this technical dispute; the
correspondence contains citation of certain technical question
and specific technical answers given to those questions, and
it would seem to me that since the major purpose of an
Environmental Impact Statement is to permit the public to
gain an understanding of the technical and other aspects of
ones environmental choice as compared to another, it would
be worthwhile to incorporate a summary of those or just to
incorporate the correspondence as a whole so that it could
be examined and understood by the public.
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The final thing that I wanted to say is that the
applicants who proposed the Ryerson Hill site, and the
State officials who accepted its use, have as the correspondence
in the EIS will show, pointed out that the Environmental
Impact Statement does not address the prospective use of the
Ryerson Hill site with as an intensive investigation as it
did the A. C. Lawrence site.
My own interpretation of that was that the consultanis
apparently decided that once they found enough to give a
negative indication they might as well not beat the horse
to death -- but whatever it was that does seem to be the case.
I just wanted to point out if we accept those
criticisms, which I am prepared to accept, as a basis of
fact finding for the federal government's decision, the
Environmental Impact Statement would not be in a position to
support a positive decision on Ryerson Hill.
MR. STICKNEY: Thank you, Mr. Burg.
One aspect of EPA, Environmental Impact Statements,
which is always interesting but hardly ever fun, is that the
decisions are not EPA's alone, but are a combination decision
of EPA and the responsible state agency; and it is very
important that any agency which has a permit responsibility
or funding responsibility, be comfortable with the basic
data. We are going to do everything we can to see that that
is done.
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We would like to do the additional boring work
as soon as the proper contract documents can be arranged
and would like to have this data for the record within the
next few months; and would like to be able to develop
the final Environmental Impact Statement during the spring.
We will at that time take note of your comments
here tonight, and the extensive written comments that you
have presented.
MS. MATOLSCY: My name is Claire Matolscy.
Will the data that you obtain from the new borings
be immediately available to the public?
In the past after the March 1977 meeting the
conclusions of the consultants were fairly clear, and I think
a great many of us left that meeting with the idea that there
the decision was quite clear.
However, from April until now, the public has been
very much in the dark in terms of what has been going on:
why the State has protested, in what areas they have protested
and what correspondence has gone on as Dr. Burg has pointed ou
If it weren't for a number of citizens calling up
EPA and poor Dr. Makrides and the State the public has been
totally unaware of what is going on.
Therefore, I am asking you, will this be available
to the public before any report is published in a further
Draft EIS or a final EIS?
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MR. STICKNEY: We recognize our responsiblity
and sympathize with the need for providing the public with
the information prior to the time that it appears in a
final Impact Statement because at that time the limitations
on comments are stringent, and time is very short.
There is only a 30 day period and recognize that
something ought to be done. It could take the form of a
newsletter if the data essentially supports what is now in
the Environmental Impact Statement, or perhaps could take the
form of another public workshop at which the data is presented
We recognize our responsibility to present the
public with information and will try to work out a way so that
it will be done in the most efficient way possible.
MR. MONTANARO: May I make a simple emotional
statement; I just can't hold back any longer?
MR. STICKNEY: Yes, sir.
MR. MONTANARO: My name is Tony Montanaro.
If the public were told very simply I mean
very clearly and not in the terms that I have been reading
in the paper and what I have been hearing at these meetings
DUP, EPD, IPS, PUQ.
I am so confused. If the public were told clearly
that public water which is getting more and more difficult to
to find a rare treasure that is literally our life-blood
except that it is not yet red, but it will be blood -- if they
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were told clearly that their water was being gambled with,
they would say no to any plan of dumping things into their
water.
They would say no clearly; but they are not being
told clearly. They are not involved emotionally. It seems
to me that they are being appealed to at intellectual levels;
but if they were told emotionally,that look we are gambling
with your water,they would take your head right off.
Tell the public what is really going on.
I am not public; I feel a little bit different
than public because I make it a point to find out what is
going on once in a while I am talking about the average
guy who has no time to be at this meeting.
I would say that about 10 percent of you are being
paid to be here indirectly; it is your job to be here.
It is pretty nice to have a job in this kind of thing.
But there are public people who are not being
told this.
I quit gambling with my money years ago because I
discovered that I could not afford to loose; that is why
I quit. If I won I would be okay, but I can't afford to loose
so I don't gamble. :
We can't afford to loose good water. Don't gamble
with it. Period.
And they keep saying the economic features of this
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thing. If you are going to kill somebody, it will cost
them a million to keep them alive, then spend the million.
And also, I don't know who to get mad at anymore.
I wish I could be mad at somebody. i don't think it is you.
I keep looking at your face and wondering if you are an enemy
of mine. I don't even know who the enemy is anymore.
We shouldn't even be here talking about this thing;
this should have been settled a long time ago -.
Is there a gamble with water? There is. No.
And you go on talking about it trying to find a
loophole. A loophole with water?
It is precious stuff. I have been impressed by
the Environmental Impacts that have been going on in the
last 20 years in this country about water and how it is
getting difficult to find good water.
It is freightening how we tamper with it in the name
of intellect, and intelligence and college degrees.
I am so surprised at how the responsible people
have dropped the ball on the public; if they don't protect
the public -- who have intelligence, education, and opportunity
who in the world is going to do it?
MR. STICKNEY: Thank you. Any other comments?
MR. ACKLEY: My name is Emory Ackley, and I have
a very brief comment. This whole Environmental Impact
Statement addresses itself to a waste product, and it seems to
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me that there should be a statement in it somewhere which
makes a point of the fact that what we have here is a
valuable resource that we are hauling off each day which is
contaminated with one heavy metal which turns it into a
dangerous product; and the Impact Statement really does not
in depth address the question of whether there is a technology
which will more effectively remove that chromium even within
a five or ten year period from now.
Maybe the dumping site does not have to be good for
20 years; maybe it only has to be good for 10 years if
the technology can then be found that will turn that sludge
into something useful.
MR. STICKNEY: Thank you, Mr. Ackley. Are there
other comments?
Go ahead.
MR. HASPRECH: My name is Jim Hasprech and I
wonder if somebody here could respond to that remark?
Somebody here has got to have some information in
relation to what he said.
MR. STICKNEY: In a general sense, we can say that
the importance of recycling and the attention to recycling is
even more heightened by the toxic and the hazardous regulation^
which will be developed by EPA in the near future; and that
is a significant issue, and it is one that defintely ought
to be addressed and we will try to address it in the final
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Impact Statement as we will all of the comments that are
being made here tonight.
Yes, sir. Mr. Burg.
MR. BURG: Is the drafting of the final Impact
Statement going to be -- oh, curse the bureaucratic word --
coordinated in some way with whoever it is that administers
this National Resource Recovery and Recycling Act?
MR. STICKNEY: As a matter of fact, as you know,
EPA administers it but that does not necessarily mean that we
are in communication with it.
We are going to have to as much as we can be
involved with the initial drafters of those regulations
with those that are devising the experimental tests that
will have to be performed to make sure that the material that
we present here is essentially in consentience with what will
be coming out over the next few years. It is not a problem
for South Paris alone; it is a problem that we in the
bureaucracy as well as many applicants and consultants are
facing; we are going to try to do our best with it, but as
you know it is a difficult problem.
MR. BURG: I would like to start a response,that
this gentleman asked for, in the following way:
Everyone in this country is now finally aware that
high quality fuels are damm hard to find and you have to pay
a lot to get them; the awareness is embodied in the term
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"energy crisis."
The fact is as I believe the fact and. I am
supported in this belief by both data and other expert opinion
that the "energy crisis" is just the tip of an iceberg.
There is a crisis in geochemically scarce minerals
including fossil fuels; chromium happens to be one of the
most critically scarce technical elements in the world.
It is my guess that where oil and natural gas
were a problem of the seventies, chromium and then nickel
and a few more are going to be a problem in the eighties.
In the case of chromium itself when this sludge
was coming out at 7 percent chromium concentration let's
put it this way: the Rhodesians would have put a mine in it.
One other thing that you might bear in mind when
considering the potential in chromium extraction here in
connection with the long term significance 95 percent or
more of the known chromium deposits in the world lie in
Rhodesia and the Soviet Union.
You cannot build a single electric heater, a
single boiler plant or a single machine tool without chromium.
It is as important to the industrial economies of the world
as natural gas and oil.
We have been through one experience in having the
price of oil elevated from $1.73 to $12.00 in a period of
months with an embargo; we might possibly smarten up about
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what could happen to us in the future with other critically
scarce elements.
I just don't think that economic justification
based on present prices has a thing to do with the problem;
it has to be treated in a much further looking manner than
that.
MR. STICKNEY: Thank you.
Yes, sir.
MR. BARBER: My name is Mr. Barber and I am with
the A. C.Lawrence Leather Company.
I would like to respond to Mr. Burg very briefly
I think I mentioned this at a previous meeting where all of
us were present and that is that our industry's outlook
is to the fact that there are limits to the supply of
chromium.
There are a number of investigations going on
right now in the country among the tanning people. Some
papers have already been presented and more are coming up
from time to time; and we,ourselves,are attempting to
conserve and use as little chromium as we can and what little
that does escape from us we are also trying to capture.
We know the problem, and we would like you to
know that we are not just using it willy-nilly. We are
making efforts to conserve it our industry is and I
think that as time goes on less and less chromium will be
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wasted through sludge dumping as we presently know it.
At the same time, the technology of tanning is
such that I would very seriously doubt that there will ever
come a time when all of the chromium will be reduced from
our effluent discharge.
We don't make leather in a fashion that lends itself
to complete removal of chromium; but I can assure you that
there will be less and less discharge not only from our
tannery but from others also as time goes on. We are
making efforts in that direction.
MR. STICKNEY: Thank you, Mr. Barber.
MR. MONTANARO: Can I ask a quick question of
that gentleman?
MR. STICKNEY: You can ask a question of the panel
and we will try to get an answer.
MR. MONTANARO: I am sure you will try: you better
I wanted to ask you what you used before you used
chromium in the tanning of leather?
MR. BARBER: Let me start by telling you that
there are two methods of making leather; two primary large
scale methods of tanning.
The first tanning was done by Indians and perhaps
people thousands of years ago; and at that time they used
extracts of nuts and bark and a number of things -- they
were all natural tanners.
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We still use natural tanners today. We have
two tanneries in the south that don't use a pound of
chromium; all of the leather in those tanneries is made
with natural materials.
About the turn of the century I guess, something
like that -- the technology of tanning with compounds of
chromium came into prominence.
Prior to that it had been known that metallic
compounds could accomplish tanning; you can tan with iron,
for that matter,or with a number of other elements, but
chromium seems to be the one which does the best job in
making leather.
At that time, a second technology emerged and came
into great prominence; and now we have the two methods of
tanning one with chromium and the other using natural
tanners.
The chromium makes a different type of leather;
it is less stretchy and it has a nicer feel and handles
better for certain purposes. All of the upper leather of
shoes is made with chromium tanning or a combination of the
two.
Chromium tanning gives a different type of leather
than the natural tanning; that is the reason why we don't
use all natural tanners it is a different type of leather
that is produced.
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The public demands it and it is impossible to
make the same type of leather with natural tanners than
that which is made with chromium compounds.
MR. STICKNEY: Are there other comments or questions
If not I would like to --
MR. MONTANARO: That seemed to be very important
and I am going to continue a little bit longer here because
this whole thing hinges on what the public demands; am I
correct?
MR. BARBER: I think that is a fair assessment, yes.
MR. MONTANARO: You, who are the maker of a product
have a right to dictate to the public, somewhat.
MR. BARBER: I don't think so.
MR. MONTANARO: This is what it comes to because
we cannot literally let our life go down the drain --
MR. BARBER: You seem to be a very dedicated and awar
person, but I think that there are large segments of the
popluation who would not agree with you.
I don't want to get into --
MR. MONTANARO: This is an important thing -- this
is more important than all the technical talk that has been
going on here; we are getting down to the nitty-gritty.
I am a performer in the theater; I can make much
more money doing pornography I am a very clever mime, and
I can do pornographic mime.
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MR. BARBER: I would like to make a quick comment:
I happen to know of one company in Maryland that about five
years ago embarked upon a program of making upper leather
with natural tanners.
They thought they were going to make their mark;
they are not in business today.
MR. MONTANARO: My last comment: If the national
government made it a law that all of you tanneries do it that
way, there would be no problem if they all had the same
restriction.
MR. BARBER: I think we are getting a little afield
here.
MR. MONTANARO: You see people always say that
we are getting afield when we are getting down to the real
stuff.
MR. STICKNEY: Tony, I think that the role of the
federal government is to insure as completely as they can
that the environment is protected based on the laws which
Congress as our elected representatives will pass in
which they try to achieve a balance between economic viability
and environmental protection.
We may disagree with that balance but that is simply
the way that the process is working.
MR. MONTANARO: I am part of the process. My
emotional output right now is part of that process, and it wil
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get word up there eventually.
I respect this gentleman; he is the first
gentleman from the tannery that I respect he has come
out with a straight statement.
He said that if you make it fair for all the
tanneries I will do the same thing. Let's help him make all
the tanneries do it then.
MR. STICKNEY: The federal rules and regulations
are designed to provide uniform standards against which all
must be judged, and that is the process that is going on
right now.
MR. MONTANARO: That is why we are suffering here
in South Paris we are not making it unilateral; it seems
to me that we are fighting upstream.
MR. STICKNEY: I would like to stay a little closer
to the specifics of the EIS if I could, andmake sure that
everyone has a chance to speak on that.
I note someone who has not spoken in the back.
MR. MOTT: My name is Schuyler Mott.
I have had only a very cursory look at the statement
so perhaps I am wrong. What concerned me particularly in
here seemed to be totally missed or just mentioned very
briefly; has a real study been done of trucking this material
the distance to the Ryerson Hill site not just on the
highway, but on the people who live on the highway in case of
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accidents, and in case trucks don't get sealed, and so on and
so forth? Has this ever been done? That seems to be part
of the environment which is immediate -- which will begin
immediately upon the site being opened long before we start
to have leachates and things such as this; was that ever part
of the study?
MR. STICKNEY: I think that that was generally
specified in one of the impacts of the two sites in which
we said that we concluded that the A. C. Lawrence site would
have a smaller impact in that regard than would Ryerson
Hill.
We can review that section very carefully and
would appreciate your comments,in writing,on that section
as to precisely what other issues ought to be raised and
considered there.
Yes, sir.
MR. BARBER: I would like to say one more thing:
I don't look upon this investigation as having the nature
of gambling with our water supply one bit -- I look at it
as exactly the opposite because the DEP and the EPA are
making every effort to see that the water supply is protected.
MR. MONTANARO: But the reasonable doubt they have
found is enough to stop right now.
MR. BARBER: I don't think so.
MR. STICKNEY: I think that it goes without saying
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that if either agency felt that there was a significant
danger to an aquifer such that it ought not to be exposed to
that danger then neither would suggest that the work be
done you can count on that.
I would agree that this is the most rigorous
investigation of this sort of thing that has been done in
some time certainly in this area.
Mr. Burg.
MR. BURG: To come back to the EIS and its future
uses you know that the EIS is presented in such a way
that it tends to produce a false dichotomy either
A. C. Lawrence or Ryerson Hill.
Now I know that within the budget provided for
this project it simply would not have been possible to do a
really comprehensive examination of the alternative means of
treating this waste material.
Nevertheless, you are left with an Impact Statement
that is suppose to provide some basis for decision that
reflects that dichotomy, and I don't even think that it is
a valid dichotomy.
I think, in other words, you are lacking in
alternatives.
MR. STICKNEY: To make sure that we are talking
about the same thing, we did investigate incineration,
fixation, and one or two other things.
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Do you feel that those alternatives should be
investigated in greater depth? How about the alternative
of recycling? Which do you think should be investigated?
MR. BURG: Let me put it this way, suppose you
find out as the evidence in the EIS suggests, that you
definitely should not use Ryerson Hill for a number of
reasons.
And suppose you also find out that you definitely
shoud not use Lawrence.
I don't think that anybody would propose waiting --
for whatever it would be the Tannery Standardization
Act of 1985.
In the meantime we need some alternative courses
of action,and although the subjects that you cited are mention*
there, in all fairness I think you will have to acknowledge
that they are little more than mentioned.
I mean that the budget for this thing would have
barely covered about two and one half man-years of work.
You can criticize the consultants for not going
further than that because that is all that they had available
to go with; but if both parties to the technical dispute
turn out to be right, you are in a fix and you don't have any
alternatives to go with.
MR. STICKNEY: Thank you. I must say that that
would be unusual.
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If there are no further questions or comments I
would like to close the formal hearing at this time.
We will be available for informal discussions as
long as you wo.uld like to talk about the Statement and what
we have done.
We appreciate your good humor, and I can assure you
that the comments that you have made will be responded to
in the final Environmental Impact Statement.
As far as developing the data in such a way that
the public can get it and understand it before the final
Impact Statement that is the data that we will be generating
over the next couple of months I don't know what form that
exposure will take, but you can be assured that we will
develop a way in which you will know what additional data
will be going .into the final Impact Statement before the
Impact Statement appears in your mailbox.
Thank you very much.
(Whereupon, at 9:15 p.m. the hearing was closed.)
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(Material provided for inclusion in the record.)
1-4-78
Boston Office of the U.S. Environmental Protection Agency,
C favor the Lawrence site because I'm concerned about
groundwater and runoffs which supply my water table. I don't
feel the eight-foot buffer zone around the site would contain
the sludge due to the lay of the land.
Danny L. Komulainen
Ryerson Hill Road
South Paris, Maine
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3 !!
I hereby certify, as the stenographic reporter,
jl that the foregoing proceedings were taken stenographically
by me, and thereafter reduced to typewriting by me or under
my direction; and that this transcript is a true and accurate
record to the best of my ability.
COMMONWEALTH REPORTING COMPANY, INC.
By;
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Steven Kalman
COMMONWEALTH REPORTING COMPANY (7171 76 1-7 1 5O
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