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.
                                    ii

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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.
                                     iii

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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.
                                    13

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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.
                                     14

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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

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                            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

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                             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

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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.

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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

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                                            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

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     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

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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

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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

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  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

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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.

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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).

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                                                               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.

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 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

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                                                               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.

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                                                               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

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                                                               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*.

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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

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                                  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

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                                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-

-------
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.

-------
     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

-------
                                                              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.

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                                         £tatr
                                       Exmrttor Brpartment

                                          panning 
-------
                              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

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   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 permeability—presumably 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 ditches—such 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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     KDWINK C. OUY
        PARIS MILL
       MAINE O4871
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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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*v
                  t  -  .    •    --


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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

-------
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

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                                    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.

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     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

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                                       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.

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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

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                    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.

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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

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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

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     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

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                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

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                                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

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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-
                 COMMONWEALTH REPORTING COMPANY I7]7> 761-715O

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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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                           COMMONWEALTH REPORTING COMPANY (717) 761-7I5O

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                  PROCEEDINGS                       i
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          MR. STICKNEY:  Ladies and gentlemen, can I have     j


your attention, please?

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          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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                                                         10
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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                                                                      11
 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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                                                          13
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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                                                                      15
 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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                                                                      17
 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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                                                         18
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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                                                         19
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,    ,
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 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


              COMMONWEALTH REPORTING COMPANY  (717i 761-715O

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                                                                      21
 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





              COMMONWEALTH REPORTING COMPANY  17171 761-715O

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     SK21A
                                                                                           21A
                                         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
      Tubi fifty

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SK21B                                                                                 21B
                 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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                                                                        22
 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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                                                          23
          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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                                                           24
 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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                                                                       25
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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                                                                        26
 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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                                                                      27
 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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                                                                       28
 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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                                                                       29
 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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                                                                       30
           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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                                                          31
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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                                                                        32
           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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                                                                       34
          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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                                                          36
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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                                                                       37
 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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                                                                        38
           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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                                                                        39
           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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                                                                        40
          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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                                                                      41
             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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                                                                      42
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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                                                         43
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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                                                                      45
 "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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                                                                        46
 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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                                                                       47
 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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                                                                        49
          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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                                                                        50
           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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                                                         51
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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                                                                       52
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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                                                                      53
 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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                                                                        54
           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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                                                          55
          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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                                                          56
(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
                            COMMONWEALTH REPORTING COMPANY  (7171 761-71 SO

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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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