EPA
904/9
82-015
United States
Environmental Protection
Agency
Region 4
345 Courtland Street, NE
Atlanta GA 30365
EPA 904/9-82-0 95
APRIL 1982
xvEPA
Environmental Final
Impact Statement
Sewanee, Tennessee
Waste water Facilities
Environmental
Protection
2 1982
EJBD
ARCHIVE
EPA
904-
9-
82-
095
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 30365
2 3
TO: ALL INTERESTED AGENCIES, PUBLIC GROUPS AND CITIZENS
Enclosed for your review and comment is the Final Environmental
Impact Statement (EIS) for proposed wastewater facilities for
the Town of Sewanee, the University of the South and the
surrounding areas of Franklin County, Tennessee.
OS This EIS was prepared in compliance with the National
Environmental Policy Act and implementing Agency regulations
(40 CFR Part 6, November 6, 1979). In accordance with these
regulations, the Final EIS will be filed with EPA's Office of
Federal Activities. Availability of the EIS will then be
announced in the Federal Register, beginning a 30-day comment
period. This Agency will take no administrative action on this
project until the close of the comment period.
We will appreciate your review of this document and any
comments you may have. Please send all comments to John E.
Hagan III, P.E., Chief, Environmental Assessment Branch at the
above address.
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Final
Environmental Impact Statement
for
Sewanee, Tennessee
Prepared by
United States Environmental Protection Agency
Region IV, Atlanta, Georgia 30365
) This Final EIS addresses proposed wastewater facilities for the
Town of Sewanee, the University of the South, and the
surrounding areas of Franklin County, Tennessee. Seven
wastewater management alternatives have been evaluated with
particular attention to the protection of area surface water
and groundwater resources. The proposed action of the Final
EIS includes replacing the existing surface water discharge of
wastewater with a land application systenuj
Comments or inquiries should be forwarded to:
John E. Hagan III, P.E., Acting Chief
Environmental Assessment Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Approved by:
larles" R.
Regional Administrator
Date
S
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-
Repository ft
Permanent Collection
Executive Summary
US EPA
Headquarters and Chemical Libraries
EPA West Bidg Room 3340
Mailcode 3404T
1301 Constitution Ave NW
Washington DC 20004
202-566-0556
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EXECUTIVE SUflflABY FOB EMVIBOIHEMTAI, IMPACT STATBHEMT
SEBAMEE 1ASTEIATEB FACILITIES
SEWANEE, TEIBBSSEE
DRAFT { ) FINAL (X)
Environmental Protection Aqency
Reqion IV
345 Courtland Street
Atlanta, Georgia 30365
Type of Action: Administrative Action (X)
Leqislative Action ( )
EXECUTIVE SOHHABT
PABT A. BXISTIBG PBOBLEB
1, STODT ABBA SETTIMG
The Sewanee Environmental Impact Statement study area is located
in Franklin County in Southcentral Tennessee, The study area is set
in the northeastern corner of Franklin County along the western face
of the Cumberland Plateau. The study area is approximately 81 railes
southeast of Nashville and 44 miles northwest of Chattanooga. The
county seat of Winchester lies 11 miles to the west of Sevanee. The
cooDunity of Sewanee is bisected by U.S. highways 64 and 56 and lies
just west of Interstate Highway 24, a major transportation artery con-
necting Nashville to Chattanooga,
The study area is unique in that much of the area under consider-
ation in the EIS is located within the 10,000 acre Domain of the Uni-
versity of the South. The community of Sewanee is located completely
within the Domain of the University of the South. As the owner of all
the land on which tho community is located, the University is respon-
sible for much of the administration, operation, and maintenance of
the community. Land vithin the Domain may not be purchased tut is
leased on a long-term hasis. The careful control of the community by
the University has provided for the development of a community which
is picturesque and blends easily with the surrounding woodlands of the
area.
The EIS study area centers around the community of Sewanee, but
its boundaries are not as clearly defined as those in the Sewanee 201
S-l
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Nastewater Facilities Plan. The elasticity of the EIS study area
boundaries results from the need to assess the far reaching impacts of
the Sevanee sevaqe treatment plant and its alternatives many miles
downstream of the study area.
2. DESCilPTIOM OF THE E1ISTIBG PBOBLEB
The Sevanee EIS was initiated in October, 1977 to address the
provision of wastewater facilities for the town of Sewanee, the
University of the South, and the surroundinq^areas of Franklin County.
The wastewater treatment plant operated by the Sewanee Utility Dis-
trict has been in operation since 1952 and is in serious need of
upgrading to meet existing water quality criteria. The Sewanee STP
currently discharges to Depot Branch of lost Creek and ultimately to
Big Sink and the Peters-Buggy Top Cave System.
In 1976, the Sewanee Utility District prepared a 201 Facilities
Plan. Sometime prior to or concurrent with this study EPA, through
the State of Tennessee, issued an NPDES (National Pollutant Discharge
Elimination System) permit to the Sewanee Utility District outlining
certain effluent limitation and monitoring requirements. All of the
requirements set forth in this permit are standard to the area receiv-
ing streams with the exception of the nitrate-nitrogen standard. This
standard was set at a monthly and weekly average of 10.0 og/1.
The alternative recommended in the 201 Facilities Plan proposed
construction of a new treatment plant and monitoring of the plant's
discharge to determine if additional treatment would be required.
However, this treatment and discharge alternative did not meet the
nitrogen requirements set by EPA. Consequently, the 201 Facilities
Plan was not approved.
EPA's primary concern in issuing the rigid nitrogen standard vas
the protection of drinking waters in the downstream Crow Creek Easic.
the high degree of protection offered by the 10.0 mg/1 standard was
proposed by EPA as a result of concern for residents in the Sherwood
area located approximately 10 miles south of Sewanee on Route 56 who
receive their potable water from wells and springs. Consequently, the
quality of the discharge into Depot Branch was raised as a ma-jor issue
and served as a focal point for the conduct of the EIS.
Additionally, the stringent discharge standards had been required
because of attempts to coordinate water quality levels in Lost Creek
which would be consistent with the pending designation of the tost
Cave - Buggy Top Cave area as a wilderness area by the State of Ten-
nessee and an interest in examining the influence of improved stream
quality on aquatic species which have been intolerant to sewage flows
in the past and to determine the likelihood that these species would
return to Lost Creek.
The nitrogen standard issue was complicated by two conflicting
matters. First, the Sewanee Utility District maintained that to meet
the nitrogen standard, exorbitant user fees would be inflicted upon
S-2
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the users of the Sevanee wastewater system. Consequently, in the 201
Plan, the District recommended a treatment system that would meet Ten-
nessee water quality criteria except for the nitrogen standard imposed
by EPA, Additionally, the Utility District was concerned about the
complexity and costs of operatinq and maintainiaq a treatment plant
capable of raeetinq the riqid uitroqen removal requirements.
Further complicating the matter was the existinq and proposed
expanded use of the Carter Natural Area also located downstream of the
STP. Odors and turbid, polluted waters have reportedly distracted
from the recreational enjoyment of this site.
Durinq the course of the EIS, two water quality samplinq proqrams
were conducted to establish existinq conditions in the study area.
These were conducted in December 1977 and April 1978, The results
point to a lack of evidence that qround and surface waters in the
inhabited areas near Sherwood are adversely impacted by the upstream
discharqe of the Sewanee Utility District wastewater treatment plant
effluent. Aa additional samplinq proqram was conducted in October
1978 to improve the data base and to aid in makinq a decision on the
effluent limitations, particularly for nitrate-nitroqen.
Based upon the water quality samplinq results, it was decided by
EPA in February 1979 that a nitrate-nitroqen limitation was not appro-
priate. The alternatives developed and presented in this EIS are
based upon these newly issued effluent limitations shown in Table S-1.
In summary, the EIS is the mechanism throuqh which: (1) the
strict effluent limits have been re-examined, (2) the impact of waste-
water discharqes on downstream water quality and water uses have been
documented and (3) wastewater manaqement alternatives, including the
201 Plan alternative and land application have been evaluated.
PART B. DESCBIPTIOM OF ALTERIATI?BS
1. U.TMMATITES IDEBTIPICATIOH
Seven wastewater manaqement alternatives have been evaluated in
the EIS. At this point, the raaior difference in the alternatives is
in the effluent disposal method. The three remaininq disposal options
include: (1) advanced secondary treatment (AST) discharqe at the
existinq discharqe point in Depot Branch, (2) secondary treatment dis-
charqe to the Elk Biver or (3) land application,
A schematic illustration of each of the seven alternatives is
presented in Fiqure S-1. The alternatives are described below:
S-3
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TABLE S-l
EFFLUENT LIMITATIONS FOR
SZWANEE PLANKING AREA
Boiling Fork
Crow, and West
Paraceter Receiving Stream
Treatment Level
Flow CMGD)
BOO5 (rng/D
HH3-H Cmg/1)
D.O. (rng/l)
Suspended Solids (mg/1)(2)
Settleable Solids (mB/D(2)
Chlorine Residual (mg/1)*2*
Fecal Coliform (per 100ml)
Fork of Battle Elk
Depot Branch Creek River
I
0.43
10
2.0/5.0
(sunmer /winter)
5.0
15.0
0.1
0.1
200
I
0.43
10
5.0
5.0
15.0
0.1
0.1
200
II
0.43
30
—
1.0
30.0
1.0
2.0
200
(1)
Effluent limitations set by the Tennessee State Department of Public
Health Division of Water Quality Control and approved by EPA, except
as noted*
(2)
Set by the Tennessee State Department of Public Health, Division of Water
Quality Control, but not by EPA.
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FIGURE s-i
SEWANEE, TENNESSEE EIS ALTERNATIVES
ALTERNATIVE I
ALTERNATIVE 2
C JSEWANEE
EXISTING AST.
STP O> DISCHARGE
TO DEPOT
BRANCH
O
ABANDON
EXISTING STP
NEW STP
SEWANEE
AST.
DISCHARGE
TO DEPOT
BRANCH
ALTERNATIVE 3
SECONDARY
DISCHARGE
TO ELK
RIVER
SEWANEE
EXISTING
ALTERNATIVE 4
ALTERNATIVE 5
ALTERNATIVE 6
RUTLEDGE
POINT
LAND
APPLICATION
SITE
LAND APPLICATION
SEWANEE
EXISTING
STP
ALTERNATIVE 7
SEWANEE
ABANDON
EXISTING
STP
S~~\ SEWANEE
ST. MARYS LAND APPLICATION
SITE
EXISTING STP
M GARNERSTOWN LAND APPLICATION
SITE
SEWANEE
ST. MARYS LAND APPLICATION
NEW f) SITE
FACULTATIVE -fiLtt
LAGOON V^** ABANDON EXISTING
STP
UGARN
GARNERSTOWN LAND APPLICATION
SITE
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Alternative 1
• Upgrade existing STP
• AST discharge to Depot Branch
Alternative 2
• Construct new STP at existing site
» AST discharge to Depot Branch
Alternative 3
• Upgrade existing STP
• Secondary discharge to Elk River
Alternative 4
• Upgrade existing STP
• Spray irrigation at Rutledge point site
Alternative 5
• Construct new STP (Facultative Lagoon) at spray site
* Spray irrigation at Butledqe Point Site
Alternative 6
* Upgrade existing STP
* Spray irrigation at St. Marys and Garnerstovn sites
S-5
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Alternative 7
• Construct itew STP (Facultative Lagoon) at spray site
* Spray irrigation at St. Harys and Garnerstovn sites
Figure S-2 presents configurations of each alternative, outlining
proposed collection, conveyance, treatment and disposal facilities.
This Figure also locates the site of the present sewage treatient
plant.
Through the evaluation and review process, three of the seven
options have been effectively eliminated. Alternative 3 was elimi-
nated because of the cost associated with conveying treated wastewater
almost ten Biles to the Elk River, Alternatives 4 and 5 were elimi-
nated because of the University's reluctance to locate a sprayfield at
Butledge Point.
and Pros and Corns of B<
This section presents a description of the remaining four alter-
natives (Numbers 1, 2, 6 and 7) and a discussion of the pros and cons
of each reaaining alternative. A cost summary follows.
Alternative 1
• Description
>
1. Upgrade existing STP
2. AST discharge to Depot Branch
• Pros
1, STP upgrading is at existing STP site
2. Upgraded STP and improved reliability would result in
improved water guality in Depot Branch and correct odors at
existing STP
S-6
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ALTERNATIVES CONFIGURATION
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J. IB proved water quality in Depot Branch would benefit aquatic
bioloqy, cave biology, downstream water supplies and recre-
ation areas
4. Total present worth cost of $2.7 million, $0.3 million more
than the alternative with the lowest present worth value
5. Public opposition is not expected
• Cons
1. Since the hydroloqy of Depot Branch is not completely known,
the potential exists for the continued discharge to impact
downstream water quality and uses (including water supply,
recreation and habitat)
2, Annual 0€M costs are next to hiqhest ($68,300)
3. Total annual costs bt the proposed project are the highest of
the four remaining alternatives ($131,300)
Alternative 2
* Description
1. Construct new SIP at existinq site
2. AST discharge to Depot Branch
1. STP construction is on existinq STP site
2. Upqraded STP and improved reliability would result in
improved water quality in Depot Branch and correct odors at
existing STP
3. Improved water quality in Depot Branch would benefit aquatic
bioloqy, cave bioloqy, downstream water supplies and recre-
ation areas
'4. Lowest total present worth cost ($2.4 million)
5, Public opposition is not expected
* Cons
1. Since the hydroloqy of Depot Branch is not completely known,
the potential exists for the continued discharge to impact
downstream water quality and uses (including water supply,
recreation and habitat)
2. Annual 06M costs are the hiqhest ($69,800)
3. Total annual cost of the proposed project is the second high-
est of the four remaining alternatives ($127,400)
S-7
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Alternative 6
* Description
1, Upgrade existing STP
2, Spray irrigation at St. Marys and Garnerstown sites
1. STP upgrading is at existing site
2. Uastewater discharge would be removed from Depot Branch
3. A no discharge option would benefit downstream water quality,
aquatic biology, cave biology, water supplies and recreation
areas
U. Has the second lowest annual 06M cost ($59,100)
5. Has the second lowest total annual cost of the four remaining
alternatives ($120,400)
6. The University of the South is supportive of land application
and has shown an interest in developing a power generation
system making use of forest biomass as a fuel source and the
harvested biomass from the spray field holds potential for
direct revenue generation
7. Since the University of the South owns most of the lands in
and around the proposed spray sites, future development near
the sites can be controlled thereby minimizing conflicts
between community development and the Utility District
8, All treatment and land application components of the alterna-
tive may receive 85 percent EPA funding
9. The proposed spray sites have been evaluated and have been
determined to be suitable for spray irrigation
* Coas
1. Currently four residences are located at and four homes are
located across Boute 56 from the proposed spray sites, howev-
er these homes are leased from the University and may not
require re-location.
2. Effluent will have to be conveyed approximately 3000 feet
from the STP to the sprayfield
3. The St. Marys site (approx, 90 acres) and the Garnerstown
site (approx, 75 acres) will be removed from other develop-
ment purposes
U. Although most people on the BIS Community Review Group have
expressed interest in implementing land application, the
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degree of public acceptance on a community-wide basis is not
known
5. Has the highest total present worth cost ($3.0 million)
Alternative 7
* Description
1. Construct new SIP (Facultative Laqoon) at spray site
2. Spray irrigation at St. Harys and Garnerstown
££2.3
1. STP upqradinq is at existing site/spray site
2~ Wastewater discharge would be removed from Depot Branch
3. A no discharge option would benefit downstream water quality,
aquatic biology, cave biology, water supplies and recreation
areas
U. Has the next to the lowest total present worth cost at $2.5
million (after utilizing the 115 percent ad-justment factor to
compare alternative-technology schemes to conventional
schemes),
5. Has the lowest annual 0 & H cost ($51,900)
6, Has the lowest total annual cost of the four remaining alter-
natives ($104,600)
7. The University of the South is supportive of land application
and has shown an interest in developing a power generation
system making use of forest biomass as a fuel source and the
harvested bioraass from the spray field holds potential for
direct revenue generation.
8, Since the University of the South owns most of the lands in
and around the proposed spray sites, future development near
the sites can be controlled thereby minimizing conflicts
between community development and the Utility District
9. Ail treatment and land application components of the alterna-
tive may receive 85 percent EPA funding
10. The proposed spray sites have been evaluated and have been
determined to be suitable for spray irrigation
11, Lower power and 0 & ?! requirements associated with the facul-
tative lagoon
• Cons
S-9
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1, Currently four residences are located at and four homes are
located across Boute 56 from the proposed spray sites, howev-
er these hones are leased from the University and may not
require re-location,
2. Wasteuater will have to be conveyed approximately 3000 feet
from the existinq STP site to the sprayfield
3, The St. Marys site (approx. 90 acres) and the Garnerstown
site (approx, 75 acres) will be removed from other develop-
ment purposes
4, Altbouqh most people on the EIS Community Heview Group have
expressed interest in implementing land application, the
deqree of public acceptance on a community-wide basis is not
known
The costs associated with the remaininq alternatives (1, 2, 6,
) are summarized in Table S-2.
and 7) are
PART C. fHAL BIS PROPOSED ICTIOI
Alternative 7 has been selected as the proposed action for the
Final BIS, Alternative 7 proposes that the existing STP be replaced
by a combined storaqe pond/facultative laqoon at the proposed spray
site and pretreated effluent be spray irriqated at the St. Marys and
Garnerstovn sites approximately 3000 feet west of the existinq STP,
This option represents the least cost option in terms of total present
worth cost. Another important cost consideration to the community is
total annual cost, especially annual 0 6 M cost, Alternative 7 has
been determined to be the least cost option iu these cost cateqories.
Land application of effluent will remove the wastewater discharqe
to Depot Branch of Lost Creek and will benefit water quality, cave
resources, aquatic bioloqy, recreation areas and downstream water sup-
plies. A major drawback to 7 is the need to possibly relocate four
existiaq residences. However, any relocation activities will be
directed by the University of the South who now owns and lease the
land on which these homes have been built.
PABT D. OBAFT EIS COBBEBTS
Comments on the Draft Statement were received from the followinq:
S-10
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TABLE S-2
COSTS ASSOCIATED WITH REMAINING ALTERNATIVES
PROJECT
COST
ALTERNATIVE [MILLIONS)
1 $2.3
2 $2.0
6 $2.9
7 $2.4
ANNUAL
0§M
$68,300
$69,800
$59,100
$51,900
TOTAL
PRESENT
WORTH
(MILLIONS)
$2.7
$2.4
$3.0
$2.5
AFTER 115%
ADJUSTMENT
(MILLIONS)
$3.1
$2.8
$3.0
$2.5
LOCAL
ANNUAL
COST
$134,300
$127,400
$120,400
$104,600
ESTIMATED
ANNUAL
USER COST
$170
$163
$156
$141
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Federal Aaeacies
U.S. Environmental Protection Aqency
Water Quality Management Branch
0.S. Department of Agriculture
Soil Conservation Service
U.S. Department of Health and Human Services
Environmental Health Services Division
U.S. Army Corps of Engineers
Nashville District
U.S. Department of the Interior
Office of the Secretary
J. Roy tfauford, J. R. Hauford and Company, Consulting Engineers
Dr. Charles Baird, University of the South
Jack i. Robinson, Attorney, representing the Sisterhood of
St. Mary
Brad Heff, Associate Director, Tennessee Karst Research
Dr. Arthur Schaefer, Provost, University of the South
Edmund Kirby-Saith, Sevanee Utility District
HiIliam Kershner, Citizen
Henry Ariail, Citizen
S-12
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TABLE OF CONTENTS
Executive Summary
A. Existing Problem
B. Description of Alternatives
C. Preferred Alternative
D. Draft EIS Comments
I. Introduction
II. EPA Decision
A. Purpose of and Need for Action
B. Description of the Proposed Action
C. Cost Evaluation Summary
D. Operability Evaluation Summary
E. Iraplementability Summary
F. Environmental Evaluation Summary
G. EIS Requirements
III. Draft EIS Summary
A. Background of the Study
B. Alternatives Development and Evaluation
C. Description of the Preferred Alternative
D. Description of the Study Area
1. Existing Natural Environment
2. Existing Man-made Environment
E. Environmental Impacts of the Preferred Alternative
F. Mitigative Measures, Recommendations and/or Requirements
G. EIS Coordination
IV. Comments on the Draft EIS and E?\ Responses
A. Index of Written and Oral Comments
B. Index of Oral Comments Received at the Public Hearing
C. Responses to Written and Oral Comments
D. Responses to Oral Comments Received at the Public Hearing
V. Revisions to the Draft EIS and Additional Information
VI. Transcript of Public Hearing Held on October 20, 1981
VII. Written Comments Received on the Draft EIS
VIII. List of Preparers
S-l
S-3
S-10
S-12
1-1
II-l
II-l
II-2
II-6
11-10
11-11
11-12
11-13
III-l
III-l
III-2
III-4
III-6
III-6
111-10
111-12
111-14
111-15
IV-1
IV-2
IV-3
IV-4
IV-25
V-l
VI-1
VII-1
VIII-1
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LIST OF TABLES
Page
S-l Effluent Limitations S-4
S-2 Costs Associated with Remaining Alternatives S-11
II-1 Proposed Monitoring Program II-7
II-2 Preferred Alternative Cost Summary 11-9
III-l Wastewater Management Alternatives - Present III-5
Worth Analysis
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LIST OF FIGURES
Following
Page
S-l Schematic Illustration of the 7 Alternatives S-4
S-2 Alternatives Configurations ^~6
II-l Preferred Alternative Process Schematic II-3
II-2 Preliminary Monitoring System Sites II-6
III-l Preferred Alternative Process Schematic III-5
111
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Chapter I
-INTRODUCTION-
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I. IITBOOOCTIOI
This Final Environmental Impact Statement (FEIS) for the 3ewanee,
Tennessee Wastewater Facilities supplements the Draft RIS issued in
August 1981. The EIS has been prepared in accordance with the Council
on Environmental Quality (CEQ) Guidelines and EPA Guidelines for the
preparation of Environmental Impact Statements. This EIS is also in
response to the requirements of Public Law 91-190, the National Envi-
ronmental Policy Act of 1969, which requires the preparation of an EIS
for any major Federal action that will significantly affect the quali-
ty of the environment. While this summary document is intended to be
comprehensive, the supporting information furnished with the Draft EIS
should be reviewed and is incorporated here by reference. It is to be
noted that this Final EIS supercedes the Draft EIS wherever conflicts
between the two exist.
This Final EIS for Sewanee, TN contains eight major sections.
Section II, EPA Decision, describes the preferred approach to waste-
water management in the study area and the evaluation process that led
to the selection of this alternative. Section III presents a summary
of the Draft EIS, including a review of each Chapter in the Draft EIS
and major findings and recommendations. Section IV presents any
revisions to the Draft EIS (in the form of an errata sheet), and addi-
tional information gathered following issuance of the Draft statement
in August 1981* EPA's responses to comments received on the Draft EIS
are tabulated in Section V. The written comments and the oral com-
ments received at the Public Hearing are indexed in this section.
Section VI contains the transcript of the Public Hearing held on Octo-
ber 20, 1981, Letters received commenting on the Draft EIS are
presented in Section VII. A list of EIS preparers is presented in
Section VIII.
1-1
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Chapter II
-EPA DECISION-
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II. EPA DECISIOI
PURPOSE OF AMD MEED FOB ACTI01
The Sewanee, Tennessee Environmental Impact Statement (EIS) is
being prepared to address the provision of wastewater management
facilities for the Sewanee area of Tennessee. The study area is situ-
ated in the northeastern corner of Franklin County, and is mainly
within the 10,000 acre Domain of the University of the South. The
existing Sewanee sewage treatment plant and pumping station is located
just south of the town of Sewanee. The treatment plant discharges
into Depot Branch of Lost Creek. In 1966, the first documented
instance of water use conflict occurred when visitors to Ruggytop Cave
became ill after drinking water found in the cave. The source of the
micro-organisms causing the illness was attributed to discharges from
the Sewanee sewage treatment plant. The Big Sink, which ultimately
receives water from Lost Creek, is believed to provide water to the
Peters-Buggytop cave system.
In 1976, the Sewanee Utility District conducted a 201 Wastewater
Facilities Plan, Sometiae prior to or concurrent with the preparation
of the 201 Plan EPA issued, through the State of Tennessee, an MPDES
permit to the Sewanee Utility District putlining certain effluent lim-
itations and monitoring requirements. All of the requirements sot
forth in the permit are standard to the area streams except for the
total nitrogen standard. EPA's primary reason for setting the strict
standard was to protect the water supplies of residents of the Sher-
wood area who receive their potable water from wells and springs.
This strict nitrogen standard became the focus of conflict prior
to initiation of the EIS. On one hand was the exorbitant Sewanee
wastewater system user fees and complexity and costs of operating and
maintaining a treatment plant capable of meeting the rigid nitrogen
standard. While on the other hand was the real and potential threat
odors and turbid, polluted waters have on the recreation value of the
downstream Carter Natural Area and the impact of wastewater discharges
on downstream water supplies.
Consequently, the EIS became the mechanism through which EP.\, by
way of three water quality sampling programs conducted in 1977 and
1978, re-evaluated the strict nitrogen effluent limitations. The
result of the sampling programs pointed to a lack of evidence that
ground and surface waters near Sherwood were adversely impacted by the
upstream discharge of the Sewanee plant. Conseguently, it was decided
by EPA in February 1970 that the strict total nitrogen standard was
not appropriate. Therefore, the only nitrogon standard deemed appro-
priate was the aamonia-nitrogen limitation set by both EPA and the
Tennessee Department of Public Health. These effluent limitations are
presented in Table S-1f under Description of the Existing Problem in
the Executive Summary.
II-l
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Throughout the decision-making process concerning the nitrogen
standard, several key issues of the Sevanee EIS were defined by EPA,
including;
* preservatin of surface water and groundwater resources
in the Lost Creek and Crow Creek Basins as drinking
water.
• coordination of water quality levels in Lost Creek which
are consistent with the pending designation of the Lost
Cove-Buqgytop Cave area as a wilderness area by the
State of Tennessee,
• examination of the influence of improved stream quality
on aquatic species in the Lost Cove-Buggytop Cave areas
in hopes that species which have been intolerant to sew-
age flows in the past will return to Lost Creek:.
• mitigation of potential impacts to the recreational
resources of the Carter Natural Area from upstream dis-
charges of the treatment plant.
B. DESCBIPTIOI OF THE P1OPOSBD ACTIOH
This section describes in detail the preferred action for waste-
water treatment in the Sewanee area. The action selected by EPA as
the preferred alternative for wastewater management for the study area
is Alternative 7. This alternative involves the abandonment of the
existing sewage treatment plant, the construction of a combined stor-
age pond/facultative lagoon at the spray site with land application of
effluent via spray irrigation at the St. Marys and Garnerstown spray
sites. The St. Marys and Garnerstown spray sites are located on Fig-
ure S-2 in the Executive Summary.
This option is not only environmentally preferred, but also com-
patible with local economic constraints. Land application of effluent
will remove the wastewater discharge to Depot Branch of Lost Creek,
thereby benefiting water quality, cave resources, aquatic biology,
recreation areas, and downstream water supplies. In addition, this
alternative represents the least cost option in terms of total present
worth, annual 06J! costs and total annual cost. These cost consider-
ations are very important to the community.
Alternative 7 is recommended by EPA following careful consider-
ation of several factors, including the size of the community, the
strength of the wastewater, an! the lover 05M costs associated with
the lagoon. One major drawback to Alternative 7 is the need to possi-
bly relocate four existing residences presently situated at the pro-
posed spray sites. However, any necessary relocation activities will
be directed by the University of the South who now owns and leases the
land on which these homes have been built.
II-2
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Treatment Facilities
The proposed treatment facilities will be constructor at the
spray irrigation site. This move offers the advantage of consol-
idation of maintenance at one site for both the spray equipment and
the treatment facility. The proposed facility will consist of the
following components:
« headworks (at existing STP site)
— preliainary treatment facility
• facultative lagoon
• sludge drying beds {at lagoon site)
• chlorine contact tank
• control building and laboratory
» pumping facilities to the spray site
The headworks of the facility will consist of preliminary treat-
ment facilities and flow measurement devices. Raw wastewater will
flow to the existing plant site for preliminary treatment. In order
to reduce extreme flows through the downstream units (in this case,
the facultative lagoon), portions of the incoming flow will be stored
in the egualization basin to be constructed at the headworks. Stored
wastewater will be gradually released, controlling flow to the lagoon,
The wastewater will be given Level B pre-application biological
treatment in the lagoon which will consist of 3 cells with total sur-
face area of 12.24 acres. The Level B effluent limitations also
include the control of fecal coliforms to less than 1000 MPN/100 ml,
therefore, lagoon effluent will be disinfected by chlorination. The
chlorinated effluent is then applied, via solid set spray irrigation
facilities, to the land application sites,
The sludge that accumulates in the lagoon will be digested in the
bottom, anaerobic layer of the lagoon. The digested sludge will then
be dredged from the lagoon and dried on open beds followed by land
disposal. Due to the small amount of sludge generated in a faculta-
tive lagoon, dredging will probably occur only once every 5 to 10
years.
Figure II-1 is a schematic diagram of the preferred alternative's
proposed processes, presenting each of the components described above,
Spray Irrigation Facility Components
Components included in the costing of spray irrigation facilities
are as follows:
II-3
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FIGURE II- 1
ALTERNATIVE 7 PROCESS SCHEMATIC
LAND TREATMENT
NEW PLANT SITE
TREATMENT LEVEL B
INFLUENT
FACULTATIVE
LAGOON
SPRAY
•4H IRRIGATION
^FACILITIES;
DISCHARGE
BY LAND APPLICATION
AT ST. MARYS AND GARNERSTOWN SITES
SCHEMATIC DOES NOT INDICATE DUPLICATE UNITS
..EFFLUENT LIMITATIONS.
FECAL COL! FORMS-
1000 MPN/ 100ml
-------
• fencing
• buffer zones (200 feet vide)
• service roads
* distribution puaping
• distribution, solid set spray
* field preparation services
• land costs
• relocation costs
The proposed St. Marys land application site is within approxi-
aately 1/2 Bile of the town of Sevanee. The St. Harys site, the Gar-
nerstovn site (just south of St. Harys), and the facultative lagoon
vill have a natural buffer zone of forest surrounding then, in addi-
tion to total enclosure by fencing. The purpose of both vill be to
limit public access to, and viev of, the proposed sites. The natural
buffer zone also preserves the aesthetic quality of the area, partic-
ularly around the treataent facility and guards against possible
health risks due to aerosol-borne pathogens.
iaad Applicitioa Sites
Studies vere conducted by both Dr. Williaa E. Sopper of the Penn-
sylvania State University and Soil Systems, Inc. (SSI) to deteraine
the feasibility for disposal of treated wastevater at Sewanee. SSI
performed a series of auger borings at the proposed sites to deteraine
the thickness and nature of the soil and prevailing groundvater condi-
tions at each site. These borings indicated that at the St. Harys
site, the depth of refusal varied froa 2.2 feet to 21.2 feet. Gener-
ally, the upper two to eight feet of the boring was easily penetrated
by the auger at which point drilling resistance increased steadily
until refusal was reached. The soils encountered were generally silty
sands to sandy silts. All borings reached refusal in the sandstone
unit. At the Garnerstovn site, the range of depths was froa 3.4 to
33.3 feet. The drilling conditions and soil types were siailar to the
St. Harys site. In one boring, the sandstone unit was penetrated at a
depth of approxiaately 18 feet. The gray silty clay at the depth
encountered is presumed to be the Pennington shale, a unit of flissis-
sippian age vhich occurs stratigraphically beneath the Pottsville
Foraation. All other borings reached refusal in the sandstone unit.
The SSI report concluded that soil thicknesses at the sites vere equal
to or greater than expected, and that the soils are of "sufficiently
granular nature to varrant further investigation of perneability and
other physical properties pertaining to percolation rates." In addi-
tion, the SSI report concluded that groundvater would not be a
restricting factor in the application of wastevater, as none vas
encountered in any of the borings.
II-4
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Dr. Sopper's study consisted of evaluation ot topography and an
evaluation of the physical, chemical, and hydroloqical properties of
each soil type. He determined that the tbpoqraphy of the St. Marys
and Garnerstown areas (less than 15 percent slope) is generally suit-
able for a spraj irrigation system. His results also indicate that
application rates of up to 1 inches per week would be feasible. Addi-
tionally, as a result of the analyses. Dr. Sopper concluded that
nutrient levels of the soils are extremely low and all sites would
benefit from the application of vastewater, with the probability that
tree growth would be greatly increased. He concluded that, as concen-
trations of trace metals in the soils are presently extremely low,
application of wastewator, with low concentrations of trace metals
would not pose problems in terms of phytotoxicity to vegetation or
degradation of soil percolate or groundwater quality. Therefore, over-
all results indicate that the proposed St, Marys and Garnerstown sites
are quite acceptable in terms of physical and hydroloqical properties
of the soils and topography.
The St. Marys land application site consists of approximately 90
acres and is located -just west of the existing Sewanee wastewater
treatment plant. The facultative laqoon is proposed to be developed
at this site. The St. Marys site would be the principal land applica-
tion site. The Garnerstown site (approximately 75 acres), situated
approximately 1/2 mile south of the St. Harys site, would be a backup
site. Figures S-2 and II-2 locate both sites.
Monitoring Program
A comprehensive monitoring program is required for the proposed
selected treatment/disposal system to ensure that proper renovation of
wastewater is occurring and that environmental degradation is not
occurring. Monitoring of flows in the proposed treatment facilities
(facultative lagoon system) is minimal compared to the monitoring
requirements of a sophisticated conventional treatment system, there-
fore, the addition of this proposed monitoring prog rain will not
reguire more laboratory related costs. The components of the environ-
ment that are usually observed at land application sites include;
applied effluent, surface waters, soils, groundwater, and vegetation.
For sites used in the production of crops for harvesting, monitoring
of vegetation for plant tissue analysis may be required for the pur-
pose of optimizing qrowth and yield. Since the selected site areas in
this study will be only maintaining forest land, there is no need to
include this component in the proposed monitoring program.
A preliminary monitoring program was developed for the proposed
alternative which incorporates observations of each component of the
environment. A manor portion of the proposed program involved the
design and installation of a network of wells to monitor groundvater
level and quality. The network included three types of wells; back-
ground, perimeter, and on-site. This is so that the groundwater
samples will represent the contribution from all points of the surface
area with each contributor arriving at the wells at different times.
Before locating wells, it is suggested that a groundwater flow model
11-5
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illustrating the water flow lines be developed to assist in the
location of the veils. Also proposed is a hydrogeologic investigation
to enable the determination of the number, depth, and location of the
wells so as to obtain the aost representative sample of groundwater
quality and level. Six wells and one surface water sampling site are
tentatively proposed for the study area. The wells include two back-
ground, three perimeter and one on-site. Figure II-2 locates the
preliminary site for surface water sampling, and for the six wells.
Also on Figure IJ-2 is the site of the existing sewage treatment plant
and the proposed facultative lagoon site. The costs of a comprehen-
sive monitoring program have been included in the costing of the
preferred alternative.
A suggested monitoring program is illustrated in Table II-1.
This table shows the constituents generally monitored and the frequen-
cy of sampling. It should be noted that applied effluent and ground-
water should be tested initially and periodically thereafter, as
appropriate, for heavy metals and trace organics. Also, if filtered
samples of raw wastewater demonstrate the concentration of a partic-
ular health-significant parameter, not listed in the table, to be in
excess of the permissible limit for drinking water sources, that
parameter should be included in the schedule.
C. COST BYAX.OATIOI SUHBA1Y
There are two general types of analyses that are considered in
the cost evaluation; the present worth cost analysis and the local
annual cost analysis. The present worth analysis establishes compar-
ative total costs (capital and annual operations costs) for each of
the alternatives over the planning period, including the federal share
associated with construction grants. This analysis is an EPA require-
ment in performing the cost-effectiveness evaluation and is used as
the primary cost evaluation criteria. The local annual cost analysis
compares the local share of the cost of constructing, operating, and
maintaining the waste water system on an annual basis. It is a meas-
ure of annual revenue requirements and, therefore, of cost to the
users. This cost analysis is conducted as a secondary cost
evaluation, not to be used as the alternative cost ranking mechanism.
The implementation of the proposed alternatives is better gauged with
such information leading to the estimated annual cost to the users.
This is further addressed in the Implementability Evaluation in this
section.
Cost Devclopmemt
To calculate both the present worth and local annual costs for
the cost evaluation, it is necessary to first develop the cost compo-
nents. They are construction, project, and operation and maintenance
(OSH) costs. All costs are adjusted to reflect local area, last quar-
ter 1978 price and labor rate levels. For the purposes of the cost
n-6
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EXISTING
SEWAGE
/7 TREATMENT/
PLANT /
AND PROPOSED
PRETRjf/TMENT
FACL&TY SITE
WERSTOWN
SPRAY
IRRIGATION
N
LEGEND
—— FORCE MAIN
PRELIMINARY FACULTATIVE
LAGOON SITE
9 PRELIMINARY SURFACE WATER
SAMPLING SITE
A PRELIMINARY BACKGROUND
WELL SITE
• PRELIMINARY ON-SITE
WELL SITE
• PRELIMINARY PERIMETER
WELL SITE
FIGURE n-2
PRELIMINARY MONITORING
SYSTEM SITES
noo
axo
4000
SCALE IN FEET
-------
TABLE II-l
PROPOSED MONITORING PROGRAM
FOR SPRAY IRRIGATION SITE
Parameter
Flow
BOD or TOC
COD
Suspended Solids
Nitrogen, total
Nitrogen, nitrate
Phosphorus, total
Co li forms, total
Coliforms, fecal
Chlorine, residual
pH (2)
Total dissolved solids
Alkalinity
Sodium Adsorption
Static Water Level
Applied
Effluent
Soil
D
w CD
M CD
D
M
2D
2D
M
M
M
_
2A
2A
-
-
-
Q
-
-
Q
Groundwater
On-Site
Wells
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
M
Perimeter
Wells
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
M
Background
Wells
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
M
Receiving
Surface
Waters
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
NOTE: C = Continuously
D = Daily
2D = Two samples per day
W = Weekly
M = Monthly
Q = Quarterly
A = Annually
2A = Two samples per year
(1) = Denotes samples to be 24-hour composites,
(2) = Field measurement.
All others are grab samples,
-------
analysis, construction of the wastewater facilities is assumed to
begin in 1983, resulting in a 17-fear planning period which extends to
the year 2000. In accordance with EPA guidelines, allowances are made
for salvage value at the end of the planning period.
Compoaent construction and O&H costs have been gathered primarily
from two sources. Cost curves contained in the 1978 EPA Saall_Coaau-
nity iastewater Treatment Facilities-Biological Treataent Systeas pub-
lication are utilized to estiaate the costs for the majority of the
new treatment process units. Costs associated with the land applica-
tion components are based on cost curves presented in the 1979 EPA
Cost of Land Treatment Systems publication. Other costs were esti-
mated and obtained from the contract consultant's wastewater
facilities design specialist and from the 201 Facilities Plan.
Table II-2 presents the present worth analysis, local annual
costs and annual user costs for the preferred alternative.
it iortm Amalvaia
The present worth cost analysis establishes a total cost value of
the capital expenditures and operating costs of each alternative over
the duration of the planning period. All construction is assuaed to
be performed during 1982-1983, with no planned phasing of construction
due to the relatively small size of the project and limited growth
over the planning period. The total 1983 present worth costs for the
preferred alternative are shown in Table II-2. This cost is the esti-
mated project cost associated with a wastewater management alternative
plus the present worth of annual O&fl costs during the planning period,
minus the present worth salvage value of the particular
treatment/disposal system at the end of the planning period (year
2000). The variation of the total present worth costs with the eff-
luent application rate for Alternative 7 {preferred alternative) is
presented below:
Application Bate Alternative 7
4 in/vk $2,488,1100
3 in/wk 2,521,000
2 in/wk 2,563,100
1 in/wk 2,721,800
As noted before, an application rate of 3 inches per week is used for
the cost evaluation.
Local annual costs reflect more closely the relative impacts of
the alternatives on the system owner, the Sewanee Utility District,
II-8
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TABLE T.I-2
PREFERRED ALTERNATIVE COST SUMMARY*
Present Worth Analysis
1983 Year 2000
Preferred Pro j ect Salvage
Alternative Cost Value
Alternative 7
Facultative
Lagoon with $2,435,600 $1,253,700
Spray Irrigation
Preferred Construction Project
Alternative Costs Costs
Alternative 7
Facultative $1,873,500 $2,435,600
Lagoon with
Spray
Irrigation
1983
Preferred Total Annual
Alternative Local Cost
Present
Worth Net
Salvage Present
Value Worth
$407,600 ^$2,028,000
Estimated Local Annual Costs
Annual
0 § M
Costs
$51,900
Assumed Local
Grant Share
Eligible Anticipated Project
Project Costs Grants Costs
$2,192,000 $1,863,200
Estimated Annual User Costs**
Average
Cost per
1000 Gallons
of Bi liable Water
Consumption
$572,400
Monthly
User
Costs
Present
Worth
Annual
0 & M Costs
$493,000
Annual 1983
Debt 0 § M
Service Service
$46,700 $50,300
Annual
User
Costs
Total
Present
Worth
$2,521,000*
Total
Local
Annual
Costs
$104,600
Alternative 7
Facultative
Lagoon with
Spray
Irrigation
$146,200
$2.34
$11.80
$141.00
* Assumes 3 inches per week effluent application rate.
**Includes existing annual costspresently being incurred.
-------
and its users. these costs are computed accounting for the federal
construction grant for the nev wastevater facilities. The remaining
costs of construction and other related project costs not covered fay
the federal grant are amortized as an assumed 30-year debt at the fed-
eral 7.125 percent interest rate. This debt service together with
past debt service obligations and estimated operation and maintenance
costs of the facilities for one year are used in determining the local
annual cost for each alternative. As stated previously, this cost
analysis is intended to help evaluate the potential for implementation
of the alternatives in light of the projected "user cost".
Table II-2 displays the new project total annual costs and
reflects local annual costs for the new project proposed in Alterna-
tive 7. It was determined by the cost evaluation that Alternative 7
(the preferred alternative) is the most desirable by having the lowest
total local annual costs and the lowest average residential estimated
annual user cost.
D. OPU1BILITT BfAL01TXOI SOBUIT
System operability provides a measure of the ability of a waste-
water management system to continuously provide the service for which
it is designed. The evaluation of operability of the systems should
include the assessment of the following three factors:
• reliability of treatment
* flexibility of operations
• maintainability of facilities
Evaluation of reliability considers the ability of the treatment
process and spray irrigation facilities to maintain the intended
treatment levels. Operational flexibility is a measure of the ability
of treatment components to adapt to changes in vastevater character-
istics and to comply with changes in water guality goals, Haintaina-
bility considerations include the complexity of eguipment, freguency
of maintenance down time, and efficiency of providing reguired mainte-
nance.
In order to provide a comparative operability ranking of the sev-
en wastevater management alternatives, a numerical rating system has
been developed which combines ratings for each of the above factors
into a total operability score. The rating system provides for a max-
imum possible operability score of 100 points. Flexibility, reliabil-
ity and maintainability are weighted at thirty (30), forty (40), and
thirty (30) points, respectively, thus indicating reliability to be
the most significant factor. For any given alternative each operabi-
lity factor is rated on a scale of 1 to 10, ten (10) being excellent
and one (1) being poor. This rating is multiplied by the weighting
proportion to determine the score. For example, a reliability rating
of 6t translates to a score of 24.
11-10
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(6 2U)
as
(10 40)
The most desirable alternative as a result of the operability
evaluation is Alternative 2- Construction of new STP with activated
sludge treatment units and surface discharge to Depot Branch. A close
second is Alternative 7- Construction of nev STP with a facultative
lagooa and land application via spray irrigation at the St. Harys and
Garnerstown sites.
It should be noted that the overall operability ranking is a rel-
ative desirability based upon operational ease and that there are no
serious operational problems projected for any of the proposed alter-
natives.
B. IflPLBaBffTABILITT SOU!AIT
System implementability considers the practicalities of imple-
menting a specific wastewater management alternative within the study
area. The implementability evaluation rating provides a method for
assessing the factors that affect the"successful implementation of the
alternatives based on public and institutional realities. The three
factors to be considered and assessed are public acceptability, man-
agement concerns, and planning flexibility.
Unlike the other evaluations in the cost-effectiveness analysis
{costs, operability, and environmental impacts), the implementability
rating is not independent, but rather is somewhat dependent on the
results of the other evaluations. This is especially the case with
public acceptance which is very much influenced by the estimated users
costs and the environmental impacts of the various alternatives.
Public acceptability of a wastevater facilities plan is crucial
to its total implementability. An important concern to the public is
the effect a particular alternative will have on the local financial
capabilities, particularly the local annual cost associated with a
particular alternative. The local annual cost includes annual opera-
tion and maintenance costs plus the annualized local share of the cost
of constructing the wastewater facilities. This is a measure of
annual revenue reguirements and, therefore, the estimated user costs.
Table 11-2 presents local annual costs, including estimated annual
user costs, for the preferred alternative. Generally, much emphasis
is put on the local annual costs for the final implementability evalu-
ation. This favors the land application alternatives with the
preferred alternative (47) having the lowest cost.
Both the type of treatment facilities and the type of disposal
facilities affect the environment and are of concern to the public.
The proposed facultative lagoon has created concern among the citizens
mainly due to the lack of available information on successful lagoon
11-11
-------
performance in the State of Tennessee. The proposed disposal method
is spray irrigation, however, spray irrigation alternatives do often
arouse adverse public reaction. Based upon prior EIS Community Heview
Group meetings and communications from the University of the South,
land application in the Sevanee area does not seem to be a potential
problem in terms of public acceptability. Most people sitting on the
EIS Community Review Group have expressed interest in implementing
land application of vastewater effluent.
Another factor to be considered in the implementation of an
alternative is management concerns. It is assumed that the Sewanee
Utility District will continue to own and operate the wastewater
facilities. This will help in providing continuity of management
throughout the selected project.
The proposed land application system may present some problems
due to the necessity of proper operation of spray irrigation facili-
ties to avoid odor, aerosol, and runoff problems. Experience in these
types of management/operation problems is not generally available
among conventionally-trained wastewater treatment plant operators,
although instruction, education and technical assistance is available.
The final factor in implementability is that of planning flexi-
bility. Planning flexibility is a measure of which alternative will
provide the greatest latitude for future planning decisions. This
mainly concerns the commitment of large tracts of land for a specified
land use under the proposed land application alternatives. The abili-
ty of all alternatives to ad-just to changes, created by future
planning decisions, in wastewater flows (both volume and pollutant
load) and changes in water gnality goals was addressed in the operabi-
lity evaluation.
Overall, the implementability evaluation ranking indicates that
Alternative 2 is the most desirable with Alternative 1 and the pre-
ferred alternative providing very close seconds.
P. BIf IBOMHEITAL ETAJ.OATIOI SUM AIT
In order to incorporate environmental impacts evaluation into a
cost-effectiveness analysis or to compare relative impacts of one
wastewater management alternative with another, it is necessary to
quantify or assign a numerical value to this subjective evaluation.
This Section deals with the development of numerical environmental
impacts ratings for both the natural and man-made environment and
includes a description of the evaluation methodology, a numerical
ranking of the eight wastewater management alternatives with respect
to natural and man-made environmental impacts, and a discussion of the
impacts for each of the alternatives.
A parameter-checklist evaluation methodology was used for the
evaluation of impacts to the natural and man-made environment for the
eight wastewater management alternatives. This methodology presented
a specific list of environmental parameters to be investigated for
11-12
-------
possible impacts but did not require the establishment of direct
cause-effect links to project activities. The list of parameters to
be investigated vas based on the Environmental Inventory prepared for
the project* with special emphasis on those resources that had been
identified as sensitive.
A sealing-neighting checklist vas used in this project for the
evaluation of potential impacts to the environment. Scaling factors
were used to estimate the relative magnitude of impacts while weight-
ing factors were used to estimate the relative importance of impacts.
Weighting (importance) factors were assigned to each environmental
parameter and were constant for all alternatives. Scaling factors
varied according to the magnitude of the impact for each alternative.
Factors were assigned to the parameters by an interdisciplinary
team of biologists, planners and engineers. Heights and scales ranged
from no impact or importance to a highly significant level of impor-
tance or impact. Impact scaling factors could be beneficial (+) or
adverse (-). The score for an environmental parameter vastewater man-
agement alternative combination is the product of the weight and the
scale. The summation of the parameter alternative scores for an indi-
vidual alternative yields a cumulative comparative score for that
alternative.
The natural environment evaluation for the preferred strategy
indicates that Alternative 7 tied for the third highest rating, coming
in very closely behind the highest and sedond highest scoring alterna-
tives. Alternative 7 vas shown to have a positive influence on odor,
soils, surface water quality, groundvater, aguatic and cave biology
and protected species; while negatively impacting climate, air
quality, surface water quantity, and terrestrial ecology.
The man-made environment evaluation for the preferred strategy
indicates that Alternative 7 has the highest rating, positively
impacting population, land use, cultural resources, recreational
resources, wastevater and water supply programs, and community ser-
vices and facilities. The only negative impact was shown to be on
transportation. The overall environmental evaluation results indicate
that the preferred alternative (#7) tied for the second highest rank-
ing.
G. BIS HBQOIEEHEITS
The following EIS Reguirements are included to mitigate adverse
or potential adverse affects of the proposed action. These require-
ments will be incorporated into the project as special grant condi-
tions.
11-13
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To ensure that proper renovation of wastewater is occurring and
that environmental degradation is not occurring, a comprehensive moni-
toring program similar to that which is suggested in Section II.B. of
this report (pages II-5, 6) is required to be developed and submitted
to EPA and the State for review and approval. The monitoring program
shall be approved prior to the issuance of funds for project con-
struction.
Since the exact placement of facilities is not known at this
time, detailed surveys have not been performed. Archaeological sur-
veys will be performed during facilities design prior to the issuance
of funds for project construction. Surveys that are performed will be
completed to the satisfaction of the State Archaeologist and the State
Historic Preservation Officer. Should resources be discovered, the
appropriate state office should be contacted for appropriate preserva-
tion, avoidance or other mitigative measures. Ho construction will
take place until the appropriate state offices have been satisfied
with the selected mitigative measures.
11-14
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Chapter III
-DRAFT EIS SUMMARY-
-------
III. DB1FT BIS SOBH1IT
A. B1CK6100ID OF THE STODT
The Sevanee, Tennessee Environmental Impact Statement (EIS) is
being prepared to address the provision oC wastewater management
facilities for the Sewanee area of Tennessee. The study area is situ-
ated in the northeastern corner of Franklin County, and is mainly
vithin the 10,000 acre Domain of the University of the South. The
existing Sewanee sevage treatment plant and pumping station is located
just south of the town of Sewanee. The treatment plant discharges
into Depot Branch of lost Creek. In 1966, the first documented
instance of vater use conflict occurred when visitors to Buggytop Cave
became ill after drinking water found in the cave. The source of the
micro-organisms causing the illness was attributed to discharges from
the Sewanee sewage treatment plant. The Big Sink, which ultimately
receives water from Lost Creek, is believed to provide water to the
Peters-Buggytop cave system.
In 1976, the Sewanee Utility District conducted a 201 Hastewater
Facilities Plan. J. B. Vauford and Company, Consulting Engineers of
Nashville, Tennessee was hired as the consultant for preparation of
the 201 Plan.
Sometime prior to or concurrent with the preparation of the 201
Plan, EPA issued, through the State of Tennessee, an HPDES permit to
the Sewanee Utility District outlining certain effluent limitations
and monitoring reguirements. All of the requirements set forth in
this permit are standard to the area receiving streams except for the
total nitrogen standard. This standard was set at a highly rigid
average of 10 mg/1. EPA»s primary reason for setting the strict stan-
dard was to protect the water supplies of residents of the Sherwood
area who receive their potable water from wells and springs.
Once completed, the 201 Plan's recommended alternative proposed
the construction of a new treatment plant and monitoring of the
plant's discharge to determine if additional treatment would be
required. This treatment and discharge standard, however, did not
meet the EPA nitrogen requirement. Therefore, the 201 Plan was not
approved.
In October 1977, EPA initiated the preparation of the Sewanee
EIS. The primary focus of the EIS was the elimination of potential
threats to the natural and cultural environment as the result of dis-
charge from the existing sewage treatment plant.
The nitrogen standard became the focus of conflict prior to ini-
tiation of the EIS. On one hand was the exorbitant Sewanee waste-
water system user fees and complexity and costs of operating and
maintaining a treatment plant capable of meeting the rigid nitrogen
standard. While, on the other hand, was the real and potential threat
odors and turbid, polluted waters have on the recreational value of
III-l
-------
the downstream Carter Natural Area and the impact of wastevater dis-
charges on downstream water supplies.
Consequently, the £15 became the mechanism through which EPA, by
way of three water quality sampling programs conducted in 1977 and
1978, re-evaluated the strict nitrogen effluent limitations. The
result of the sampling programs pointed to a lack of evidence that
ground and surface waters near Sherwood were adversely impacted by the
upstream discharge of* the Sewanee plant. Consequently, it was decided
by EPA in February 1979 that the strict total nitrogen standard was
not appropriate. Therefore, the only nitrogen standard deemed appro-
priate was the ammonia-nitrogen limitation set by both EPA and the
Tennessee Department of Public Health.
B. ALTXBIAlIfES DEVEIOPBEIT MO ETALOATIOI
The process of developing alternative wastewater management
schemes for the Sewanee area involved a presentation of a range of
structural engineering alternatives and non-structural considerations
for the solution of wastewater management problems. However, the
selection of final alternatives was not limited solely to either of
these two categories, but integrated both structural and
non-structural schemes into the proposed wastewater management system.
The first step in the process of developing wastewater management
alternatives was the development of structural solutions to the Sewan-
ee area's water quality problems. Four major structural alternative
categories were investigated. They are: a collection network and its
associated service area; treated wastewater disposal locations; waste-
water treatment facilities; and other structural considerations which
do not fit into the first three categories.
For the Sewanee study area, two general discharge alternatives
were considered for disposal of wastewater effluent: discharge to
local receiving waters and discharge by means of land application.
Specifically, five receiving streams and three land application sites
were considered.
Based upon effluent limitations, three wastewater treatment
alternatives were developed for the Sewanee area. They are: 1)
Advanced and Nitrification Treatment, 2)Secondary Treatment, and
3)Biological Treatment by Lagoons. It was determined that these three
treatment alternatives could be applied to either the continued utili-
zation of the existing treatment plant site or an alternative
treatment site.
In order to achieve the desired level of treatment associated
with each treatment alternative for the Sewanee area, various unit
process configurations were considered. These unit process configura-
tions formulate treatment process trains based not only on the eff-
luent limitations for the various discharge alternatives but also on
the existing wastewater treatment plant process units and their pres-
ent condition; existing treatment plant site constraints; and the
III-2
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reliability classifications affecting duplication of upgraded or new
units, or both.
Other structural alternatives considered for the Sevanee study
area included the continued use of on-lot vastevater systens in the
Senanee area, and also vastevater treatment and disposal for St.
Andrews.
Several non-structural alternative vastevater management consid-
erations vere investigated for application to the Sevanee area. They
are: improved operation and maintenance, flov and vaste reduction
measures, and management district concepts.
The second phase of alternatives development involved screening
various vastevater treatment/disposal techniques for applicability in
the Sevanee study area. This preliminary screening eliminated the
less desirable alternatives (due to cost and environmental disadvan-
tages) from further analysis, simplifying the later detailed evalu-
ation.
Based upon the vastevater treatment and disposal alternatives
developed thus far and other vastevater management considerations,
seven ( treatment/disposal schemes vere developed. These schemes com-
prise ' the vastevater management alternatives evaluated for the
selection of a vater quality plan of action. A brief description of
the components of each of the seven alternatives follows.
Alternative 1 - Advanced, nitrification (Class II)
Upgrade existing units
a.) At present only one primary clarifier exists; an additional
unit vill have to be added.
b.) The combination of the existing trickling filter and the
proposed activated sludge units vill, as a system, meet
reliability criteria.
c.) Two secondary clarifiers vill need to be constructed.
Alternative 2 - Advanced, Nitrification (Class II)
Abandon existing units
a.) Dual extended aeration basins vill be required.
b.) Duplication of the secondary clarifiers is required.
Alternative 3 - Secondary (Class II)
Upgrade existing units
a.) Only one primary clarifier exists; an additional unit vill
have to be added.
b.) A second trickling filter vill have to be added to supplement
the existing trickling filter.
c.) Tvo secondary clarifiers vill have to be constructed.
III-3
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Alternatives 4 and 6 - Land Treatlent (Class III)
Upgrade Existing Units
a.) An additional primary clarifier vill be regaired bat since t
clarifier is tbe only major component in the system it was
sized according to tlie reliability requirements for
biological treatment components of Class I. This should
compensate for the lack of other treatment units in this
unconventional system.
Alternatives 5 and 7 - Land Treatment (Class III)
Abandon existing units
a) Ho duplication necessary for a facultative lagoon.
la addition, a no-action alternative was developed and compared
with the most cost-effective structural alternative vitfa respect to
cost, operability, and implementability.
Figure S-2 in the Executive Summary presents configurations of
all seven alternatives. The present worth analysis of all seven
alternatives is presented in Table III-1.
C. DISC1IPTIOI 07 TIB PREFB1IBD ALTHBATIfl
This section briefly describes the preferred action for waste-
water treatment in the Sewaaee area. The action selected by EPA as
the preferred alternative for wastewater management for the study area
is Alternative 7. This alternative involves the abandonment of the
existing sevage treatment plant* the construction of a combined stor-
age pond/facultative lagoon at the spray site with land application of
effluent via spray irrigation at the St. flarys and Garnerstown spray
sites. Figure III-1 presents the process schematic for the preferred
alternative.
The proposed treatment facilities will be constructed at the
spray irrigation site. This move offers the advantage of consol-
idation of maintenance at one site for both the spray equipment and
the treatment facility.
The headwords of the facility (to be located at the existing STP
site) will consist of an egualization basin, preliminary treatment
facilities, and flow measurement devices. Baw wastewater will flow to
the existing plant site for preliminary treatment. In order to reduce
extreme flows through the downstream units (in this case, the faculta-
tive lagoon), portions of the incoming flow will be stored in the
equalization basin to be constructed at the headwords. Stored waste-
water will be gradually released* controlling flow to the lagoon.
The wastewater will be given Level B pre-application biological
treatment in the lagoon which will consist of 3 cells with total sur-
III-4
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TABLE IH-1
WASTEWATER MANAGEMENT ALTERNATIVES
PRESENT WORTH ANALYSIS (1)
Capital Cost
Treatment Plant
1S¥S" Proj ect Cost
2000 Salvage Value(2)
P.W, Salvage Value
Net Present Worth
Convcr
ayeyance
1983 Project Cost
2000 Salvage Value(2)
P.W. Salvage Value
Net Present Worth
Land Application
Appll
85 Pro;
1985 ProJectCost
2000 Salvage Value[2)
P.W. Salvage Value
Net Present Worth
TOTAL NET P.W. CAPITAL COST
Operating Cost
2000 Operating Cost
1983 Operating Cost (3}
Operating Cost P.W.
Discharge to Depot Branch
Exist. UnitsNew Process
Alt. 1 Alt. 2
$2,277,700 $ 1,965,300
842,700 , 727,200
261,600 225,700
2,016,100 1,739,600
$2,016,100 $1,739,600
68,300
66,300
649,500
69,800
67,700
663,400
Discharge to
Elk River
Exist. Units
Alt. 3
$2,084.000
771,100
239,300
1,844,700
1,058,000
695,000
215,700
837,300
Spray Irrigation
$2,682,000
54.400
52,800
517,200
Discharge to Rut ledge Farm Site
Exist. Units
Alt. 4
$1.542,600
570,800
177,200
1,365,400
363,500
239,900
74,500
289,000
1,394,000
1,254,600
349,400
l,004,bUO
$2,659,000
62,300
60,400
592,000
Facul. Lag.
Alt. 5
$ 832,400
308,000
114,000
718,400
363,500
239,900
74,500
289,000
1,643,600
1,329,400
412,700
1,230,900
$2,238.300
54,500
52,900
518,200
Discharge to Gernerstown
$ St. Marys Sites
Exist. Units
Alt. 6
$1.542,600
570,800
177.200
1,365,400
190,200
125,500
39,000
151,200
1,163,400
745,300
231,300
932,100
$2,448,700
59,100
57.300
561,600
Facul. Lag.
Alt. 7
$ 832,400
308,000
114,000
718,400
190.200
125,500
39,000
151.200
1,413,000
820.200
254,600
1,158,400
$2.026,000
51,900
50,300
493,000
TOTAL PRESENT WORTH 2,665,600 2,403,000 3,199.200 3,251,000 2.756,500 3.010.300 2.521.000
TOTAL PRESENT WORTH
ADJUSTED FOR 115 PERCENT
SPRAY IRRIGATION
ALLOWANCE (4) 3,065,400 2.763.500 3.679,100 3.2S1.000 2.7S6.SOO 3.010,300 2.521,000
(1) Present worth analysis is based on 1981 price levels. 17-year planning period and a 7.125% discount rate
(2) Year 2000 salvage values as percentages of initial construction costs are: conveyance - 66%; treatment plant - 37%: land application * 30%+ land s
(3) Ratio of 1983/2000 08M Costs is 0.97 assuming that one fourth of 0 S M costs are flow related
W In accordance with EPA Program Requirements Memoranda (PRM) 79-3, 15% adjustment of least cost alternative for ce*marison with
innovative/alternative technology alternatives. w»j»r«wi mn
Source: GFCC, Inc.
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FIGURE HZ- I
ALTERNATIVE 7 PROCESS SCHEMATIC
LAND TREATMENT
NEW PLANT SITE
TREATMENT LEVEL B
INFLUENT
FACULTATIVE
LAOOON
CHLORINE
CONTACT
TANK
DISCHARGE
BY LAND APPLICATION
AT ST. MARYS AND GARNERSTOWN
SITES
SCHEMATIC DOES NOT INDICATE DUPLICATE UNITS
EFFLUENT LIMITATIONS
FECAL COLI FORMS-
1000 MPN/ 100 ml
-------
face area of 12.21 acres. The level B effluent limitations also
include the control of fecal coliforms to less than 1000 SPH/100 ml,
therefore, lagoon effluent will be disinfected by chlorination {chlor-
ine contact tank). The chlorinated effluent is then applied* via sol-
id set spray irrigation facilities, to the land application sites.
The sludge that accuaulates in the lagoon vill be digested in the
bottom, anaerobic layer of the lagoon. The digested sludge will then
be dredged froa the lagoon and dried on open beds followed by land
disposal. Due to the small amount of sludge generated in a faculta-
tive lagoon, dredging vill probably occur only once every 5 to 10
years. The schematic diagram of the preferred alternative in Figure
III-1 presents each of the components described above.
A comprehensive monitoring program is required for the proposed
selected treatment/disposal system to ensure that proper renovation of
vastevater is occurring. The components of the environment that are
usually observed at land application sites include: applied effluent*
surface waters, soil, groundwater, and vegetation.
This study developed a proposed monitoring program for the Sewan-
ee land application sites. A monitoring program, which included con-
stituents to be sampled and freguency of sampling was suggested.
Additionally, this suggested program indicated the components to be
sampled for each constituent (See Table II-1).
A major portion of the proposed program involves the groundwater
component. Groundwater level and quality monitoring involves the
design and installation of a network of wells. This network is to
include three types of wells; background wells, perimeter wells, and
on-site wells. Although, a hydrogeologic investigation is proposed to
enable the determination of the number* depth, and location of the
wells, six wells and one surface* water sampling site have been tenta-
tively suggested {See Figure II-2).
D. DBSCRIPTIOI OF THE STUDY AH*
1. KIISTII6 lATOtAL B1YI1OIBBR
The Sewanee EIS study area is typical of middle latitude areas*
having marked seasonal variations in weather characterized by the fre-
quent occurrence of migratory high and low pressure systems. linds in
the study area rarely exceed 15 miles per hour. Temperatures in the
vicinity of the study area are moderate, with an average annual tem-
perature of about 57 F. Precipitation is plentiful, averaging over 62
inches per year.
The air guality of the study area is good. According to the
Division of Air Pollution Control all national ambient air guality
standards are being met in the Sewanee area, with the possible excep-
tion of the standard for photochemical oxidaats which may be violated
III-6
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due to natural formation and long canqe horizontal and vertical trans-
port of ozone.
There are several odor problem areas located and confirmed in the
study area. The aost chronic of which is associated with the waste-
water treatment facility located at Sewanee. Odors can emanate fro*
all processes at the plant with the exception of the digester which is
located underground, odors are also prevalent at the outfall and for
several hundred yards downstream. Additionally, objectionable odors
have been identified at the mouth of Buggytop Cave downstream from the
treatment plant discharge. Lake Cheston, a public swimming and recre-
ation area, vas also identified as an odor problem area. Odor
problems have also been associated vith septic tank failures bat the
Sewanee Utility District is attempting to rectify this problem.
The Sewanee study area has no serious noise problems, although
there are several potential sources of noise in and near the study
area including automobile traffic, the Sevanee Airport and a spur and
mainline of the Louisville-Nashville Railroad.
Two distinct topographic features, the Cumberland Plateau and the
Highland Rim, are contained within the Sewanee study area. The high
tableland of the Cumberland Plateau averages 2000 feet above sea level
and occupies much of the study area. The town of Sewanee sits oa the
Cumberland Plateau. The Highland Rim borders the western edge of the
Cumberland Plateau. The average altitude of the Highland Rim in the
study area is 900-1000 feet above sea level.
The study area is underlain by sediment rocks of lover Penasylva-
nian and upper Hississippian age. The Pennsylvanian rocks are mainly
limestones which crop out on the flanks of the ridges and underlie the
floor of the caves. A sandstone unit, the Sewanee conglomerate, and
another remnant sandstone. Warren Point Sandstone, are also present ia
the study area.
Lost Cove is an incised valley in the Cumberland Plateau extend-
ing southward approximately 65 miles from Sewanee to its north in the
Crow Creek Valley just north of Sherwood. The valley slope of the
cove is interrupted by a barrier wall within which Buggytop Cave is
located. The top of the saddle is at 1050 feet elevation which also
marks the highest closed depression contour of the depression behind
the barrier. The lowest place in the depression is the bottom of Big
Sink at 950 feet.
Caves are an important scenic, wilderness, and recreational
resource in the study area. There are at least 16 caves known ia the
study area, in addition to Buggytop Cave. Walker Spring Cave and Vet
Cave are particularly noteworthy caves in the area, as they both are
large, stream-carrying caves and discharge into tributaries of Hud
Creek.
The Buggytop Cave, also known as lost Cove Cave, is a central
feature of the new Carter Natural Area established by the State of
Tennessee. The cave is the downstream master trunk conduit for the
underground drainage system of Lost Cove. On occasion, the cave
stream runs 5 to 8 feet deep at velocities in excess of 10 cubic feet
III-7
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per second. Flood flows in the cave, from indirect geological evi-
dence, are in the order of hundreds of cubic feet per second. The
route by which water moves vertically fro« its swallow point in Biq
Sink to the stream in Buggytop Cave remains unknown.
The five soil associations of the study area were exalined to
determine the suitability of the soils for on-lot disposal and spray
irrigation. It was determined that most of the soil types found in
the study area have moderate to severe limitations for on-lot
disposal. A site-specific survey is necessary, however, to establish
if reported septic tank malfunctions are due to soil limitations or
poor maintenance practices.
Soils are categorized as suitable for spray irrigation based on
slope* soil texture, depth to bedrock and water table, pH,
erodability, and potential for flooding. In the Sewanee area, three
sites were chosen as potential spray irrigation sites. They were St.
Harys, Garnerstown and Hutledge Point. Following a detailed soil sur-
vey conducted by Dr. William E. Sopper, a land application specialist
from The Pennsylvania State University at the three sites, it was
determined that all three sites were suitable for the proposed spray
irrigation of wastewater.
•
There are eight drainage basins considered in this study. The
present wastewater treatment plant is located in the Lost Creek Drain-
age Basin and discharges into Depot Branch. Depot Branch flows into
the Lower Depot Branch Sub-basin and into the groundwater aquifer.
Various other tributaries of the Lost Creek Drainage Basin flow into
Lost Creek which also flows into the limestone aquifer and resurfaces
only after rainstorms. The creek waters appear to emerge from the
mouth of Buggytop Cave to form Crow Creek. Based on this assumption,
the existing treatment plant outfall is about 7.8 miles from the near-
est human habitation.
During low flow, wastewater discharged into Depot Branch consti-
tutes approximately 30-50 percent of the stream flow. Assuming that
all of the Depot Branch waters resurface at the entrance to Euqgytop
Cave, the Lost Creek watershed and Crow Creek watershed provide an
effluent dilution factor of 54 during low flow conditions upstream of
Sherwood. During more normal conditions, the dilution factor is
approximately 25.
Twenty impounded bodies of water, all man-made, have been identi-
fied in the study area. Lakes Jackson and O'Donnell are owned fay the
University of the South, and are sources of potable water for the
Sewanee Utility District. Several other lakes in the area have
reported odor and/or pollution problems, some of which may be the
result of septic tank seepage.
There are two aquifers in the study area. The first is the
perched groundwater body that exists in the sandstone on top of the
plateau. The second aquifer is the flonteaqle and St. Louis limestones
in which a substantial body of groundwater exists, mainly in solution
cavities. The Warren Point sandstone is an important aquifer in the
Sewanee conglomerate. The flonteagle and St. Louis limestones and two
III-8
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underlying formations which crop up outside the study area are the
principal aquifers for the Highland film.
The EJS water quality sampling program served two purposes: to
assure that HPDES permit limitations vere being net; and to evaluate
established and recommended water quality criteria for detrimental
impacts on downstream aguatic life and water supplies. Three sets of
samples were collected in the study. The first set of samples was
collected in December 1977 from eighteen selected sites. The second
set of samples was collected in April 1978. Sampling was restricted
to Lost Cove, Hawkins Cove, two wells, and the water sapply of Sher-
wood. The third set of samples was collected in October 1978 during
an extremely low flow period. The sampling results indicate generally
good to excellent water guality in the Sewanee area with the exception
of Depot Branch. Pollution problems in Depot Branch, particularly
elevated phosphate, nitrogen and fecal coliform levels, are associated
with the Sewanee wastewater treatment plant. In addition to the
Sewanee facility, the St. Andrews wastewater treatment plant is a
point source of pollution.. Ron-point sources are primarily agricul-
ture, septic system seepage aad urban runoff.
Sampling indicates healthy aquatic communities and high water
guality over most of the study area during low flow conditions. Those
sites of poor guality are associated with the Sewanee Wastewater
Treatment Plant. The impact of the treatment plant is diminished at
the month of Lost Cove Cave. Sampling at Lost Cove Cave indicates a
population with a low diversity, but a high Biotic Index, reflecting
relatively clean water with a low food availability typical of cave
systems in general. Periodic high flow conditions may wash the heavy
collection of settleable solids in Depot Branch below the treatment
plant into the limestone aquifer. During such flows, contamination of
groundwater may also occur from silvicultural and agricultural activ-
ities in Lost Cove Creek. This has the potential to affect water
guality and in turn impact the threatened Tennessee Cave Salamander,
Gyrinophjlus palleucus, which may inhabit not only Bnggytop Cove but
the entire complex karst system found under Lost Cove.
The sampling programs conducted under varying flow conditions
have produced sufficient water guality data to draw several conclu-
sions concerning the impact of a treated wastewater discharge upon
Depot Branch and downstream waters. Certain of these conclusions are
based on a preliminary review of the data without benefit of detailed
water guality modeling, which would be very difficult in the ground-
water regime. The conclusions are as follows:
1. The Sherwood water supply source is essentially geo-
logically isolated from the Sewanee Utility District's
wastewater treatment plant effluent discharge point,
2. There is little influence of the wastewater treatment
plant effluent discharge as far downstream in the Crow
Creek drainage basin as Sherwood.
3. Analysis of the two individual well water supplies near
Sherwood indicates little or no impact from the waste-
water treatment plant on them.
III-9
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4. The evidence provided by the sampling results supports
the Tennessee State Departaent of Health's proposed 1im-
itations which are primarily directed toward the dis-
solved oxygen levels in the streaa and which eliminate
the total nitrogen criterion.
The term terrestrial ecology refers to both terrestrial vege-
tation patterns and wildlife populations. Although the terrestrial
ecosystems of the Sewanee area are relatively undisturbed and remain
largely forested, the existing forest communities are primarily
second-growth. The composition and extent of present vegetation is
largely associated with two landforms which dominate the study area:
the level uplands of the Cumberland Plateau, and the steep slopes and
cover surrounding the Plateau. Cove forests are generally more highly
developed because of more constant moisture availability and greater
successional maturity.
There is a variety of wildlife species associated with the plant
communities of the study area. Six of these species, which are either
known or possibly occurring in the area, are listed as threatened or
endangered by the U.S. Fish and Wildlife Service (USFBS) and/or the
State of Tennessee. These six are the Tennessee Cave Salamander,
fGvrinophilus palleucusl , the Sharp-shinned Hawk (Accjpiter striatus).
the Gray Bat (Hvotis qrisescens) , the Indiana Bat filyotis sodalis) ,
and the Cougar (Felis concolor cougar).
There are currently ao plant species known from the Sewanee study
area which are listed as threatened or endangered by the OSFVS or the
State of Tennessee. However, there are four plant species known or
possibly occurring in the study area which are considered high priori-
ty by the USFHS, but are not presently listed due to the lengthy legal
and scientific procedures involved in placing species on the official
list. These four plants are: the Saxifrage fSaxifraqa carevana), the
Bosinweed (Silphium brachiatuai, the Prairie Clover fDalia foliosal.
and the Yellow Fringeless Orchid fPlatanthera integral .
2. mSYTIG MAX-BIDE KBVIROVMSMT
During the period 1960 to 1975, Sewanee*s population increases
were considerably above those for Franklin County, and also above the
overall Tennessee growth rates. However, 1980 preliminary Census fig-
ures reveal only an 8.1 percent increase in population from 1970 for
the Sewanee Census County District (CCD), while Franklin County and
the State of Tennessee exhibited much higher growth rates for that
same period of tiae. Host of the growth in the Sewanee area can prob-
ably be attributed to increases in enrollment at the University of the
South, which experienced a 62.5 percent increase between 1960 and
1975. The major assumption aade concerning population growth in the
Sewanee area is that enrollments at the University will continue to
gradually increase and along with these increases there will be coin-
ciding growth in faculty and other supporting staff and services. A
population projection of 4,232 is estimated for the year 2000 for the
111-10
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Sevanee area. This is an increase of 32 percent from the 1975 popu-
lation estimate of 3,211.
Bach of the study area is located within the Donain of the Uni-
versity of the South. This ownership has resulted in the development
of a picturesque community focused around the University canpus.
There is no industrial land use in the study area and very little com-
mercial development. Beyond the urbanized area of Sevanee, land is
primarily forested, with land at the bottoa of the escarpment utilized
primarily for agricultural activities. The only substantial commer-
cial development beyond the urbanized area occurs at the intersection
of 1-24 and U.S. 64/41A. flajor land use changes are not expected in
the Sewanee area in the future.
The major change in Franklin County employment since 1950 has
been the decrease in reliance of the county on agricultural employment
while manufacturing employment in the county has continued to
increase. This probably reflects the trend of the apparel and textile
industries migration from the northeast to the southeastern part of
the country. On a comparative basis, the County still has a larger
percentage of persons employed in agriculture than either Tennessee or
the United States, but lags behind slightly in the manufacturing area
despite significant increases since 1950.
The Sewanee area contains a variety of State and University-owned
recreational areas. Aoong established recreation areas in the study
area, the Carter Natural Area is the one with the greatest likelihood
of being affected by existing wastewater management practices. The
Carter Natural Area consists of 140 acres and contains Lost Cove Cave
(Buggytop - Peters System), Crow Creek, and the associated gorge.
The wastewater treatment plant serving Sewanee is a biological
process facility designed to treat a flow of 0.6 mgd. Major units in
the plant, which was tuilt in 1952, include a primary clarifier, a
trickling filter, a chlorine contact tank, and an aerobic sludge
digester. Replacement parts for many of the units are no longer
available. Conseguently, the operating condition of the plant is not
very good and the potential for incorporating existing facilities into
an upgraded plant is limited. The plant is located along Depot Branch
approximately 0.7 mile south of the David Crockett Highway. Effluent
is discharged into Depot Branch. The Sewanee treatment plant does not
appear to be meeting specified standards under its HPDES permit,
including fecal coliform levels. Visual observances of the stream, as
recorded during water guality sampling at Depot Branch, indicate set-
tleable solid effluent standards are not being met, although plant
data indicate otherwise. The plant is not capable of meeting the new
treatment reguirements.
The Saint Andrews School Wastewater Treatment Plant serves a
school with an approximate enrollment of 200 students, half of whom
are boarding students. The school is located approximately 1.5 miles
northeast of the University of the South, and discharges to Shakerag
Hollow Creek which empties into Mud Creek, a tributary of Elk Biver.
Nominally sized at 20,000 gallons per day, this extended aeration
plant was upgraded in 1976 to comply with EPA effluent standards.
III-ll
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Additional aeration basin capacity was provided, and post aeration was
supplied.
There is still a significant population being served by individ-
ual septic tanks in the Sewanee study area. Major areas utilizing
on-lot systems include the »ore recently developing areas on the west-
ern and northern periphery of the community of Sewanee. Sone parties
within the severed portion of Sewanee nay also rely on on-lot disposal
systems because the Sewanee Utility District has not actively required
connection to sewers when available. Shallow soil depths to sandstone
bedrock typically found on the Cumberland Plateau create leachate
problems In many areas in and around Sewanee. Septic tank failures
have been documented by the Franklin County Health Department. Host
of the areas cited for failing septic tanks have been proposed for
sewering as described in the Sewanee 201 Facilities Plan.
Two man-made reservoirs. Lake O*Donnell {capacity, 39,000,000
gallons) and Jackson Lake (capacity, 131,000,000 gallons) serve as
water supply sources for the Sewanee area. Lake O'Donnell is used as
the primary source of water with Jackson Lake as a back-up supply.
The water supply filtration plant is located to the vest of the lake
0*Donnell. Chemical coagulation followed by settling and filtration
are provided for the finished potable supply. Based upon a yearly
average, the treatment plant is providing a daily supply of 201,000
gallons to the Utility District.
The community of Sewanee is unigue in that nearly all community
services are provided by the University. Those services provided by
the University include health care, education and libraries, fire pro-
tection, police protection, and the administrative arrangement to man-
age these services. Other services are provided by Franklin County
and the Sewanee Utility District.
K. MfXBDUBmi IHP1CTS OF THE PIBPURED ALTEBIATIfE
I. IMPACTS 01 TH1 MATMAL EBTIBOlHBiT
Pew significant negative impacts to the existing natural environ-
ment are expected with implementation of the preferred alternative.
Although, they are not expected to be significant, localized climate
changes, air quality and odor problems may be present as a result of
land application of effluent and, in the case of odor, with operation
of the lagoon.
In several instances negative impacts are proportional to the
distance of pipeline. This is true when considering impacts to air
quality, topography, geology, terrestrial ecology, and noise. The
preferred alternative requires the third least amount of pipeline con-
struction and, therefore, negative impacts are not expected to be sig-
nificant.
111-12
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Soil drainage characteristics and levels of chemical constituents
•ay be beneficially affected by the land application system proposed
in Alternative 7. Results of chemical analyses of soils in the Sevan-
ee area indicate that nutrient levels of the soils are extremely low
and land application sites would benefit from the application of
wastevater. Trace metal concentrations in the soils are extremely
low, therefore, application of wastewater with low concentrations of
trace metals would not pose any problems in terms of phytotoxcity to
vegetation or the degradation of soil percolate and groundwater quali-
ty-
Potential impacts on the terrestrial ecology of the study area
are primarily associated with the construction of wastevater treatment
facilities and pipelines. Since the preferred alternative calls for
the third least amount of pipeline, the area affected is not of sig-
nificant size. However, pipeline construction to the St. Marys and
Garnerstown spray irrigation sites under the preferred alternative
could result in adverse impacts on the nesting of the threatened
Sharp-shinned hawk, Accjpiter strjatus. Ecological impacts to the
spray irrigation sites will primarily result from the alteration rath-
er than destruction of existing natural communities. Terrestrial
communities may be modified in favor of more moist adapted types, with
corresponding reductions in dry adapted types. Such alterations are
hard to classify as beneficial or adverse, unless the resulting chang-
es incur losses of unigue or valuable terrestrial community types or
the loss of protected plant or animal species through habitat modifi-
cations. Field investigations of the two proposed spray irrigation
sites observed no endangered or threatened species nor the presence of
likely habitats for such species.
The proposed action is expected to beneficially impact several
aspects of the natural environment. Odor sources at the present
treatment facility should be eliminated with implementation of the
preferred alternative. The water guality of the Lost Creek Cove area
would benefit, since the proposed action would eliminate discharge to
Depot Branch. Aquatic systems would also benefit from the removal of
wastewater from surface streams and the subsequent improvement in
water guality. Because the proposed action eliminates the discharge
to Depot Branch, the Tennessee Cave Salamander, a protected species
known from the Lost Creek Cave, should benefit from habitat improve-
ment. The land application system proposed in the preferred
alternative may contribute to groundwater recharge, thereby providing
beneficial impacts. There may be minimal adverse impacts to ground-
water or surface water resources as a result of surface runoff or
seepage.
2. MPACTS 01 THB HMMUPB BMTHOiBBW
Tery few impacts, either adverse or beneficial, to the man-made
environment are associated with implementation of the preferred alter-
native. Some population and residential growth is anticipated with
the availability of new facilities, however these changes are not
expected to be significant.
111-13
-------
Each of the alternatives evaluated foe the Sevanee area will
place financial burdens of varying degrees on the community. Because
the preferred alternative has the lowest local annual costs of all the
alternatives evaluated it would place the least burden on the communi-
ty.
Cultural resources of the study area will not be impacted by the
construction of pipeline. However, the proposed St. Harys spray site
will be developed adjacent to an existing Civil Bar overlook. Other
than visual impacts there should be no negative affect on this histor-
ical site.
Although it requires very little pipeline construction, force
•ain construction reguired in the preferred alternative lay disrupt
local traffic on Route 56 for a short period of tiae.
Recreational resources and wastewater and water supply programs
•ay be beneficially impacted by the preferred alternative. Downstream
recreation areas would be benefitted because of removal of wastewater
discharge. Hew facilities and removal of discharge should have a pos-
itive influence on wastewater and water supply programs in the area.
F. BXTXCATIfB OB AS DIBS, 1KCOUIIDATIOIS ABB/OB BBQOT1UBITS
For the most part, mitigation of adverse impacts to the natural
environment would entail implementation of controls during con-
struction activities. Hethods used to avoid adverse impacts to air
quality, odor, noise, geology, soils, water resources, surface water
quality, aquatic ecology, and terrestrial ecology involve:
* Utilization'of best management practices (sludge manage-
ment techniques to reduce odor, erosion and sedimenta-
tion control plans, bank stabilization and immediate
revegetation plans, controls to reduce non-point source
run-off from construction sites, dust containment prac-
tices)
» effective construction equipment (including sound
devices) and maintenance of equipment (meeting current
emission standards)
• limit amount of land under construction at one time,
time construction takes place, and size of pipeline cor-
ridors and treatment plant (lagoon) site
• effective land use control to prevent residential devel-
opment adjacent to treatment sites
• treatment plant inspection to insure proper operation.
In addition to the above methods, impacts to local geologic for-
mations can be mitigated by the use of site-specific studies to deter-
mine the proper blasting procedures. In order to monitor potential
111-14
-------
IBpacts on groundvater and surface water, a monitoring progran has
been included as part of the preferred alternative. This program is
discussed in Section II, Part B. It is recOBBended that all con-
struction activities be preceded by field investigations to confirm
the potential presence of any protected terrestrial species. If,
through investigations, it is determined that protected species are
present, they should be either transplanted, relocated or buffered
froo construction activity.
Effective management of land use through the use of planning and
regulatory tools can lessen any undesirable aspects of population
growth and increased residential, commercial and industrial develop-
ment. These tools include comprehensive plans, zoning ordinances,
easements, fee simple aguisition of land, conservation zoning
district, and floodplain ordinances.
Although there are no known historical or archaeological sites at
the proposed spray irrigation sites or within the tentative force main
route, there is the potential that undetected resources could be pres-
ent within these areas. No construction will take place until surveys
are completed to the satisfaction of the State Archaeologist and the
State Historic Preservation Officer. Should resources be discovered,
the appropriate state office should be contacted for appropriate pres-
ervation, avoidance or other mitigative measures. No construction
will take place until the appropriate state offices have been satis-
fied with the selected mitigative measures.
Any adverse impacts to recreational resources, transportation
facilities, resource use, and community services and facilities, also
may be mitigated through the implementation of planning tools.
G. BIS COOBDI1ATIOI
An important part of the Sevanee, Tennessee EIS process is the
public participation program. The program provides for active public
involvement in all phases of the EIS process, particularly the devel-
opment and evaluation of wastewater management systems. The focal
point of the public participation program has been the development of
a Community Review Group (CRG). This group has served in an advisory
capacity to EPA and their consultant GFC6C, Inc., giving interested
groups, individuals and government agencies the opportunity to partic-
ipate in the development of the EIS. The Group met at regular
intervals throughout the development of the EIS, responding to reports
prepared by EPA, providing local opinion on wastewater issues, and
indicating needs and sensitivities of the study area. The membership
of the group represented a cross-section of local, regional and state
interests who contributed information and comments on the development
of the EIS.
The following is a list of the members of the CKG and the organ-
izations they represent:
III-15
-------
Name
Representing
Edmund Kirby-Smith
Douglas Paschall
Or. Arthur Schaefer
Carl Reid
Hs. Barbara Ellis
Delegate Assembly
c/o Doaglas Paschall
Honorable James Boy Tipps
Bobert lyres
President
Order of Govnsmen
c/o Doaglas Paschall
Charles Baird
Dr. Charles HeGee
Project leader
David Tate
Professor Charles Forenan
D. B. Potter
Richard G. Threadgill
Lynn Hoore
John L. Stephens
Dr. Harry feataan
President
Sevanee Utility District
Associate Dean of College
University of the South
Provost
University of the South
University of the South
Sevanee Conmunity Council
University of the Sooth
County Judges Office
Franklin County Courthouse
Interin Vice Chancellor
University of the South
Sevanee Civic Association
University of the South
Chairman
Department of Forestry and Geology
University of the South
Principal Silvicnltnralist
U.S. Forest Service Research Station
Grounds and Buildings
St. Andrews School
Biology Department
University of the South
Department of Forestry and Geology
University of the South
Tennessee Departaent of Public Health
621 Cordell Hull Building
County Health Department
Franklin County Regional Planning
Commission
Biology Departaent
University of the South
111-16
-------
He. Bobert file hards
Hr. James Needha•
He. James White
He. Allen ft. Coggins
He. Thomas Camp
Re. David Geant
He. Art Brown
Tennessee Department of Conservation
U.S. Soil Conservation Service
Regional Planning Staff - TVA
Division of Planning and Development
Citizen
Baildimg Commissioner
Franklin County Courthouse
Local Planning Div., Planning Office
Tennessee State
ni-17
-------
Chapter IV
-COMMENTS ON THE DRAFT EIS AND EPA RESPONSES-
-------
If. COBHBBTS BADE OI TBS DH1FT SIS MO SPA HBSPOISBS
Ibis section of the Final EIS contains the responses that hare
been made to coaaents in writing to EPA and oral comaents aade at the
Public Hearing held in Sevanee on October 20, 1981.
The first part of this section indexes written and oral coaaents
received on the Draft report. The second part refers to the oral COB-
•ents received at the Public Hearing. A detailed listing of all COB-
•ents and responses is then included.
IV-1
-------
A. IIDBI OF 11IITBI AID ORAL COHRBITS
Name/Association
1) J.B. Sauford
J.B. laaford 6
Company, Consult-
ing Engineers
Date Received
Letter of
9/16/81
Concerning
In agreement with conclu-
sions reached; would like
to design a sewage paaping
station at the existing site;
would like to review detailed
design criteria used for all
components of the proposed
system.
2) Dr. Charles Baird
University of the
South
Telephone
Conversation
9/2V81
Comment on error concerning
University of the South
financial analysis.
3) Leonard V. lowak
Hater Quality
Hanagement
Branch, U.S. EPA
Letter of
10/2/81
Comments on various aspects
of the EIS
4) Donald C. Bivens Letter of
Soil Conservation 10/15/81
Service, U.S. Dept.
of Agriculture
Concerned that some of the
data contained in the
Sopper and SSI soil reports
are insufficient; need to
analyze impacts of sprayed
effluent on vegetation and/or
soils
5) Frank S. Lisella,
Ph.D., U.S. Dept.
of Health and
Bumaa Services
Letter of
10/26/81
Expressed concerns primarily
with management aspect of the
lagoon and spray fields
6) Jack l. Robinson
Attorney, repre-
senting the
Sisterhood of St.
Hary
Letter of
10/29/81
Opposed to the preferred
alternative
7) E.C. Hoore Letter of
U.S. Army Corps 10/29/81
of Engineers,
Nashville District
Comments on various aspects
of the EIS
8) James H. lee
U.S. Dept. of the
Interior
Letter of
10/30/81
Comments on various aspects
of the EIS
9) Brad leff
Tennessee Karst
Research
Letter of
11/17/81
Supports the preferred
alternative
IV-2
-------
B. IID1I OP 0111 COHBITS 1BCBITBD IT THE POBIIC HBA1IIG
Name/Association
1) J.fi. tauford, J.R.
Wattford 6 Associates,
Consulting Engineers
2) Unidentified Speaker
3) Dr. Arthur H. Schaefer,
Provost* Oniversity
of the South
4) Edmund Kirby-SBith,
President* Sevanee
Otility District
5) Unidentified Speaker
6) Villiaa K. Kershner,
Citizen* Sevanee
7) Henry Ariail
Citizen, Sevanee
Concerning
Concerned with potential pollution
of surface and/or groundvater; inno-
vative and alternative eligibility
aspect; next step in process to get
to the design stage; 201 Plan revision.
Concerned with insuring workability
of system before it is implemented.
Oniversity is no longer opposed to the
use of a facultative lagoon in the
area; appraisal procedure for the
land.
Otility District is in favor of
facultative lagoon and spray irriga-
tion.
Impact on sevage rates in the county.
Geological characteristics of lagoon
site; compensation to owners if wells
are contaminated; existing treatment
plant indebtedness.
Components of proposed system to be
present at existing treatment plant
site; odors at the pretreatnent site.
IV-3
-------
c. HESPOISES TO imiTTEi AID OIIL COBBBITS
1. J. Roy Mauford Jr., P.B.: 3.B. waufordS Company Consulting Engi-
neers- letter of September 16* 1981.
Comment; If the selected plan is used, we would probably want to
design a sewage puipinq station at the existing treatment plant
which would provide for sewage pumps to handle normal flow and
stormwater pumps to handle peak I/I conditions; this would require
a separate force main and would utilize the freeboard on the
facultative lagoon for 500,000 gallons of inflow storage.
Hesponse; This is a design consideration which would need to be
approved~~by EPA and the State of Tennessee. It would also need to
be acceptable to the Sewanee Utility District.
Comment; Be would appreciate an opportunity to review the
detailed design criteria used for the sewage pumping station,
force aain, facultative lagoon and any lines, land application
area and application system and laboratory and control building.
Hesponse; Detailed design criteria has been supplied to Hr. Yau-
ford. A copy of that data is included at the back of this
section.
2. Dr. Charles Baird; University of the South. Telephone Conversa-
tion of September 24. 1981.
Comment; Page If-28. The last two sentences under the "Oniyersi-
ty of the South Financial Analysis* beginning with "It is the
fourth..." should be omitted.
Response; This will be done.
3. Leonard V. Mowak: Water Quality Management Branch, fl.S. EPA. Let-
$
ter of October 2. 1981.
Comment: The EIS should include some discussion on the ability of
the users of the system to pay for it. This should include more
detail on existing debts, how and for how long they are paid,
alternative sources of funds and mechanisms available for financ-
ing the local share.
Hesponse; A minimal increase in sewer rates in the Sewanee area
is anticipated with implementation of the preferred alternative.
The current average monthly user cost is $8.85 and is expected to
increase by $2.95/month to $11.80. The existing annual costs to
the community presently being incurred which will continue as an
expense are: collection system operation and maintenance costs;
other administrative, billing, and legal costs; the outstanding
debt on the 1974 sewer and water revenue bond issue; and the oat-
standing indebtedness on the sewer rehabilitation bond issue. The
remaining outstanding indebtedness on the sewer and water revenue
bond issue is $562,575, with annual payments of approximately
$42*500. The remaining outstanding indebtedness on the sewer
IV-4
-------
rehabilitation bond issue is $113,208.48 with annual payments of
approximately $9,893. There is no debt limit on the utility dis-
trict. Alternative sources of funds and mechanisms available for
financing the local share of the project include floating a bond
issue and borrowing funds from a commercial lending institution.
Comment; Tables 11-10 and III-2 (in the DEIS) should include data
on the percentage of median household income used to pay for the
various alternatives.
Response; Hedian household income data is not available below the
county level. Therefore, the percentage of median household
income used to pay for the various alternatives can not be deter-
mined.
Comment; Proposed user charges should be thoroughly discussed at
the Public Hearing on the Draft EIS.
Response; Proposed user charges were discussed at the Public
Hearing held on October 20, 1981 to the satisfaction of EPA and
the citizens present. There was no adverse reaction to the
increases in sewer rental rates.
Comment; The population and per capita flows appear reasonable,
however, there must be some justification for assuming all flow is
received within 18 hours.
Response; As stated on Page II-3, the Tennessee Department of
Public Health Standards require vastewater treatment facilities
for plants less that 1 mgd to be sized for the daily flow volume
occurring over an 18-hour runoff period.
Comment; Hill 100 percent of the population in the sab-basins
iisted in Table II-1 be served?
Response; It is recommended in the EIS that all homeowners within
the service areas be required to connect, therefore alternatives
were developed on the assumption that 100 percent of the popu-
lation in the sub-basins listed would be served.
Comment; The need for and cost-effectiveness of a 197,000 gallon
equalization basin must be shown. Generally, for small land sys-
tems a storage and preliminary treatment function is accomplished
with one pond. The storage requirement should be based on the
period of time that the site is unsuitable for spraying or on
mechanical reliability.
Response; The need for an equalization basin as part of the pre-
ferred alternative was questioned at the Public Hearing on the
OBIS (see the transcript of that hearing in Section VI of this
report). It was determined that the equalization basin proposed
for Sewanee was unnecessary and that any excess storage can be
taken care of ia the freeboard of the facultative lagoon. The
following information, however, refers to the cost-effectiveness
of an equalization basin and discusses the storage requirements of
the lagoon.
IV-5
-------
Cost-effectiveness of a 497,000 qallon equalization basin - Refer
to page III-12 of the Alternatives Development and Evaluation
Technical Reference Docuaent (Voluae II).
• Basin proposed for handling excessive inflow doe to the
2-year, 7-day stora event which will produce 6 inches of
rain precipitation in the Sewanee area.
• Methodology utilized in the 201 Facilities Plan for esti-
mating inflow voluaes based on rainfall guantities is
presented in the SSES Final Report.
• Storage requirements for nonoperation time of land appli-
cation tiae is already accounted for in the voluae of the
facultative lagoon. This storage volume is separate froa
the flow voluae of inflow that was to be handled by an
equalization basin. Bonoperation tiae is taken to be 4
weeks; storage is required for 25 days (EPA
-600/2-76-250, "Use of Cliaatic Data in Estimating Stor-
age Days for Soil Treataent Systems"). This additional
volume was estimated as 10,875,000 gallons (1,453,700
ft3) . Therefore, the total volume of the laqoon was as
follows:
13,050,000 gal (30 days detention)
10,875,000 gal (25 days storage)
23,925,000 gal
= 23.9 ag which leads to a 6 ft.
lagoon on 12.24 acres
Comaeat; The cost-effectiveness analysis has not been completed
strictly in accordance with the construction grant regulations
(i.e. land can be appreciated at 3 percent per year) ; however,
our calculations based on the EIS*s raw capital and OSH costs
support the selection of Alternative 7.
Response: Comment does not require a response.
4. Donald C. Bivens: Soil Conservation Service, U.S. Department of
Agriculture. Letter dated October 15, 1981.
Comment; (This coaaent pertains to the Si.te Evaluation for Pro-
posed Forest Spray Irrigation Systea document prepared by William
E. Sopper of the Pennsylvania State University. A copy of this
report appears in the Alternatives Development and Evaluation
Technical fieference Document. However, the results of the evalu-
ation were very important in the eventual selection of a spray
irrigation site and ultimately in the selection of Alternative 7.
Therefore, this coaaent appears here, as a comment on the DEIS.)
The report referenced above states that much deeper profiles were
found on the evaluated sites, than the typical profiles described
in the 1958 Soil Conservation Service Soil Survey. The report
contains no description of these deeper profiles. If indeed, the
deeper soil profiles do exist, then these profiles should be
IV-6
-------
described in the report. The report concludes that the depth of
the soil profile is equal to the depth of material that can be
penetrated by a power auger. This is not consistent with Soil
Conservation Service procedures for determining soil depth.
Response; Soils in the proposed vastevater application areas have
been »apped as Hartsell fine sandy loans and Muskingam stoney fine
sandy loams. These soils are characterized by having depths to
bedrock ranging from 2 to 4 feet.
The soil boring logs indicate relatively deep soils primarily
associated with downslope topographic settings. Soils located on
this landscape position, for the nost part* do not fall within the
range of characteristics for the Ruskingum series (as previously
•apped) . The area of concern is those soils which formed on deep
colluvium and now lore closely resemble the description for the
Jefferson series. This series often times has a moderately deep
mineral or "C" horizon. The Garnerstovn site evaluation resulted
in even deeper or thicker *Cn horizons, a result of widely vari-
able colluvium deposits. Soils of this type more closely resemble
the Jefferson series due to the deeper nCH horizons consisting of
clay loam and silt loam textures. Soil boring depths are quite
variable due to the different thickness of colluvium.
The natural soil profile does not extend to depths as indicated
previously in the report. Soil auger borings, for the most part,
penetrated some weathered rock land and at first glance closely
resembled "C" horizon diagnostic properties.
The soil profile should only represent the organic and chemically
altered mineral or "C" horizon which probably developed from the
underlying weathered residuum. Since the boring techniques pro-
duced a much disturbed soil sample, precise differentiation
between the "CM horizon and residuum could not be made.
Therefore, soil boring logs are, to an extent, misleading in
describing soil depths and ma-|or horizons.
The most recent taxonomic descriptions for the three soil series
in the proposed land application areas - the Huskingum, the Hart-
sell and the Jefferson series - are provided as a supplement to
this response and can be found at the back of this section. These
taxonomic descriptions describe a typical soil profile and other
soil characteristics for the three soil series.
Comment: The report prepared by Gannett Fleming Corddry and Car-
penter, Inc. (refer to Sopper's Site Evaluation report) also con-
tains an analysis of the storage capacity and percolation of the
soils to a depth of 2U to 27 inches. The report, however, does
not address the percolation rate of the substratum, nor the stor-
age capacity that can be anticipated under field conditions during
different seasons of the year. This needs to be done in order
that actual storage volumes available on the site can be deter-
mined.
Besponse: Soil permeability tests were conducted at various
depths to determine which horizons or zones would limit the down-
IV-7
-------
ward movement of sevaqe effluent. Soils at both the Garnerstovn
and St. Marys sites are basically well drained, permeable fine
sandy loams. The Hartsell and the Muskingum soil series are char-
acterized by having blocky to subangular blocky structure. Soils
having sandy loam textures with this type of structure will not
have very slowly permeable subsoil horizons.
The proposed application rate is quite conservative in that it
approxiaates normal cropland irrigation. Dr. Sopper's report
indicates a somewhat slowly permeable B Horizon with a percolation
rate of 0.24 in./hr. Percolation rates this slow will still
greatly exceed the required permeability criteria associated with
the proposed application scheme. Three inches of applied waste-
water over a seven (7) day period translates to an average
permeability of 0.018 in./hr., considerably less than the slowest
measured permeability of 0.24 in./hr.
Effluent will not be applied so* as to create a saturated
condition, therefore the wastewater effluent should receive ample
renovation prior to reaching any limiting horizon such as bedrock
or seasonally high groundwater. Storage volumes should not be a
major concern in this proposed application scheme. Hastewater
application is a function of the hydraulic head gradient and the
soil hydraulic conductivity. Regulating the application rate with
sprinklers can prevent saturated conditions and allow the perco-
late to move through the profile and flow in the direction of the
natural groundvater gradient. Unlike cropland irrigation, the
rate of application will not be a function of storage volumes and
moisture losses due to plant uptake and evaporation. The remain-
ing volume of effluent not accumulated by the trees and shrubs or
lost to evaporation will be relatively small but nearly renovated
and available for percolation through the subsoils to a limiting
horizon. The remaining wastewater effluent will be for the most
part, renovated when it mixes with seasonally high groundwater or
moves in saturated zones above bedrock.
Comment: Page Iv-65, DEIS. (Impacts of the preferred alternative
on soils.) .The report does not contain an analysis of the antic-
ipated impacts of the sprayed wastewater on either the existing
vegetation or the soils. These evaluations need to be included in
the report.
Response; Wastewater application rates are anticipated to be
quite small in mixed hardwood forests. 80 adverse impacts are
anticipated to the vegetative forest floor mat nor to trees and
shrubs. Hastewater effluents have been applied to forest environ-
ments with little to no adverse impacts. Hutrient-rich effluent
will result in possible rapid growth of weeds and could conceiva-
bly choke off new tree saplings if weed growth is not periodically
checked by mowing. Increased concentrations of salts can conceiv-
ably lead to an alteration of soil structure with a resultant
reduction in soil permeability and a possible reduction in the
application rate. This situation would probably be quite remote
due to the sandy loam texture of the soils. Periodic diagnostic
soil tests are proposed to monitor adverse concentrations of
nitrates, phosphates, trace elements and heavy metals.
IV-8
-------
5. Frank S. LLsella: u.s. Dgpajrtmgnt of Health and Human Services.
Letter of October 26, 1981.
Comment; The effect that lacqe and/or long-term storm events will
have upon the managevent and operation of the spray fields should
be discussed.
fiesponse; The proposed application scheae has aaple storage at
the lagoon to retain vastevater for at least 3 weeks in the event
of prolonged rainfall and resultant saturated field conditions.
Therefore, effluent trill be stored and only applied during unsatn-
rated conditions. Excess rainfall will only saturate the field
and result in anaerobic conditions without leaching cheaically
bound nutrients.
Coaaent: Bhat aeasnres will be incorporated into the design and
operation of the lagoon to prevent field spraying during frozen
and/or saturated soil conditions?
Response: the high infiltration rates associated with porous and
loosely structured debris laden forest soils will probably aean
that the highly peraeable surface horizon will be able to receive
vastewater effluent for long periods of tiae. This will help to
further extend the wastewater application period and reduce the
requirement for off-site storage. Aapie storage will exist at the
lagoon to totally store wastewater for at least three weeks during
frozen or saturated conditions.
Comment; It has been our experience that poor aanageaent of a
spray irrigation field nay lead to potential runoff and water
guality problems. For this reason, the EIS should discuss the
aanagement aspects of maintaining necessary percolation and infil-
tration rates, suitable soil conditions and vegetative cover, and
preventing surface compaction, clogging and Batting.
Sesponse; A wastewater application plan will specifically address
the safe operation of the sites. This plan will state that irri-
gation in the woods will only be Bade during periods when the soil
aoisture is not at the saturation level. iastewater application
will not exceed the permeability of the aost restrictive soil
horizon except during dry periods when infiltration capacities
will substantially exceed saturated hydraulic conductivities. The
vegetative cover consisting of woody plants will experience rapid
development and weeds will also react to the nutrient rich waste-
water. Heeds will be cut and taken off site as well as selected
trees. Trails should be cut in the woods in such a manner so as
to liait disruption of the natural forest floor. Timbering and
maintenance operations should be performed utilizing only track
type eguipaent so as to minimize compaction and destruction of the
forest floor debris. Diagnostic soil testing is also proposed to
monitor adverse impacts to the soil environment such as the build
up of heavy metals and trace elements. The concentration of salts
will also be determined since salt effects soil structure and can
result in changes to soil permeability.
IV-9
-------
Collect; For general protection of public health and safety. Hill
the lagoon and spray irrigation areas be posted and fenced?
Response; Yes, for the protection of public health and safety,
both the St. Marys and Garners town spray sites and the lagoon will
be totally enclosed by fencing. In addition, a 200 foot natural
(forested) buffer zone vill be left intact surrounding the areas
(see page III-3- of the DEIS). Also, signs indicating the
locations of the spray sites and lagoon vill be posted.
&-
Comment; The potential vector problems that may be associated
with the operation and maintenance of the lagoon and spray fields
should be addressed. The vastevater treatment systems should be
operated in such a manner as to prevent the increase of any vector
populations that have the potential to cause vector-borne disease
or nuisance problems. We suggest that you contact the local
and/or State public health authorities for information on vector
problems and control technigues in the project area.
Response; Because of the strength of the wastesater and the level
of treatment afforded at the lagoon, vectors are not expected to
be a major problem at either spray site. The probability that
vectors (basically flies and losguitos) vill be attracted to the
lagoon is high, hovever, relative to the spray sites. Should
flies become a problem at either the lagoon or spray sites, peri-
odic spraying can control propagation. Hosguito breeding at the
lagoon site can be discouraged by periodically varying the level
of the lagoon. The asphalt lining proposed for the facultative
lagoon should discourage the attraction of rodents and other man-
mals. It has been found that if a lagoon is operated and
maintained properly and if measures are taken regularly to dis-
courage vectors, they vill generally not be a problem. This has
been the case in most of the lagoon sites visited in the State of
Tennessee.
6. Jack H- Robinson. Attorney representing the Sisterhood of St.
Harv* Letter of October 29. 1981. ~~
Comment; The Sisterhood of St. Mary is strongly opposed to Alter-
native Ho. 7 for the following reasons:
a. "The information concerning land ownership in the doc-
umentation is deceptive as it fails to reflect that land
immediately adjacent is already developed vith privately
owned residences in the drainage area of the lagoon and
spray installations."
b. "A pasture ovned by our client, vhere cattle {vhich are
raised for food) graze, has a pond vhich vould receive
water from the proposed spray areas."
Since there are obviously other alternatives to Proposal No. 7, ve
respectfully reguest that Proposal No. 7 be rejected and that
attention then be given to more appropriate vays to eliminating
the vastevater problem, particularly those vhich vould have less
impact on the Sisterhood of St. Nary.
IV-10
-------
Response: The only homes adjacent to the spray sites are four
homes located on University of the South property. These homes
may or may not be affected by the proposed project. The potential
that they will not be impacted is heightened by the fact that a
200 foot buffer zone of natural uncut vegetation ¥ill surround the
potential spray and lagoon sites. This buffer zone will serve
several purposes. First of all, it will act to eliminate any
potential visual, impacts to the surrounding area including these
four homes and the property of the Sisterhood of St. Mary. Sec-
ondly, it will act to protect the health risks due to
aerosol-borne pathogens. Finally, 200 feet of natural woodland,
in addition to the vooded nature of the spray sites, will only
serve to further renovate any excess runoff (should there be any
excess) from application of the effluent.
In responding to the comment concerning the potential influence of
the spray site on the down gradient farm pond on the Sisterhood of
St. Hary property, if wastewater application should ever exceed
the soil permeability resulting in runoff and overland flow of
partially treated effluent, additional treatment will take place
as the effluent travels across the above-mentioned grassland or
wooded environment. Potential bacteria and virus problems will
have already been minimized through disinfection. Hitrates and
phosphates will probably be trapped in the vegetative cover and
physically or chemically bound or transformed. Therefore, any
effluent flowing over the several hundred feet upgradient of sur-
face water sources will essentially be nearly renovated prior to
entering any such sources. Additionally, it appears that the
natural drainage pattern in the area of the sprayfield is not
toward the above mentioned farm pond, but toward another tributary
of Talleys Pork. Therefore, in the event that applied wastewater
would leave the spray site, the farm pond of the Sisterhood would
likely not receive wastewater runoff. It should also be noted
that a comprehensive monitoring program in which ground and sur-
face water guality will be monitored is a requirement of this EIS.
Therefore any runoff from the spray site into adjacent waterways
will be monitored and corrected, as appropriate.
7. E. C. Moore: g.S. Army Corps of Engineers. Nashville District^
letter of October 29. 1981.
Comment; The preferred alternative waste treatment system Alter-
native 7, involves replacing the existing STP with a combination
storage pond/facultative lagoon with pretreated effluent spray
irrigated at sites approximately 3000 feet west of the existing
STP. Reference should be made to the holding capacity of the sys-
tem during winter freeze conditions and in the event that
maintenance is required.
Response; Mhen determining the volume of the facultative lagoon,
several assumptions were made:
a. Storage required for periods of non-operation of the land
application was determined as 25 days according to
EPA-600/2-76-250, "Use of Climatic Data in Estimating
Storage Days for Soil Treatment Systems". This "25 days
IV-11
-------
worth" of storage could also account foe the storage
required due to sinter freeze conditions of the faculta-
tive lagoon. This storage is required for periods in
shich ice cover, ice breakup, or thermal (spring) over-
tarn cause the lagoon to beeone anaerobic therefore need-
ing time to become stratified again as a facultative
lagoon.
b. Lagoon detention time = 30 days
Therefore, lagoon total volume is determined as:
30 days detention time ?1 = 1,744,680 ft3 = 13,050,000 gal.
25 days storage ?2 = 1,453,700 ft3 = 10,875,000 gal.
3,198,380 ft3 23,925,000 gal,
= 23.9 mg
For 6 ft. depth
Surface area => 12.24 acres
Maximum solids per day
3160 pop. X 0. 17 fBOD/person/day = 44 fBOD/acre/day
12.24 acres
Proposed lagoon System - 3 cells
2 Primary cells is parallel
Chlorination
1 secondary cell
in series to
primary cells
Assuming BOD loading for primary cells must be less than
than 35 f/acre/day
¥1 total = 2 (1,085,500 ft3) = 2,171,000 ft3
* 2 (8,120,626 gal) = 16.24 mg
IV-12
-------
V2 = 7.68 ag
Comment; Page II-7. Overland flow is considered unmanageable
because of the sloping terrain, however, some of the terrain is
within the 9X slope liaitation according to Table A-2a.
Response; As noted in the preceding sentence on page II-7, spray
irrigation appears to be the only viable land application option
in the Sevanee area. Spray irrigation, not overland flow, is the
proposed form of land application in the EIS.
Comment; Page 11-19, 11-20. Table II-4 and II-5 footnotes refer
to Table 17-4 for information on spray sites. Table IV-4 lists
cultural sites in the area.
Besponse; Footnotes to Tables II-4 and II-5 should refer to Table
II-6 for information on spray sites.
Coaaent: Page III-3. Land Application Sites, paragraph 2, lines
3, 4, 5. Same as coament on overland flow above.
Besponse; Dr. Sopper's report indicated that the sites were level
to gently sloping (less than 15X slope) and generally suitable for
spray irrigation. As indicated above, the EIS proposed action
involves spray irrigation as the land application aethod and in
accordance with EPA Publication 625/1-77-008, "Process Design Han-
ual of Land Treatment of Municipal Jfastewater", wastewater can be
applied by spray irrigation on non-cultivated lands with slopes of
less than 4OX.
Coaaent: Page I?. Reference to the detailed soil survey should
be supplemented by data indicating the suitability of the soils
for spray irrigation.
Response; Dr. Sop per*s report discusses in detail the physical
and chemical characteristics of the soils at the proposed sites
with respect.to their ability to accept and treat wastewater eff-
luent. Specific reference is made to infiltration percolation and
cheaical bonding potential. Dr. Sopper>s report can be found as
an appendix to Volume II, Alternatives Development and Evaluation
Technical Reference Document.
Comment; Page IV. Odor, paragraph 3 was anaerobic lagoon consid-
ered? Aerators could be added to reduce odor.
Besponse; An aerobic lagoon was not considered because it is
"best suited for treating soluble wastes in wastewaters relatively
free of suspended solids" (EPA Technology Transfer, "Process
Design Manual - Hastewater Treatment Facilities for Sewered Small
Communities").
Aerators could be added and therefore make the system one with
aerated facultative ponds (partially mixed aerated ponds) where
only the upper zone is aerated by diffusers or mechanical
aerators. This, however, would result in higher capital and 06H
IV-13
-------
costs which would reduce the cost-savings inherent in the
low-energy requirements of a non-aerated facultative lagoon.
As far as odors are concerned, a properly operated facultative
lagoon vill generate no odors except possibly spring overturn odor
that occurs due to anaerobic conditions resulting from the pond
freezing over in the winter. This occurrence is for a short time
(until the lagoon "recovers" and becomes a stratified facultative
lagoon again) , if at all* considering the cliaatic conditions in
Sevanee, Tennessee. If this is a major concern, then the option
of aerating the upper zone can be considered. It should be noted,
though, that the facultative lagoon vas also proposed over an
aerobic or completely sized aerated pond because of its capabili-
ties to reduce sludge production resulting froa its anaerobic
bottoa layer.
Coaaent; Page 17-1. Under ME PA Guidelines Section 1502.17, the
experience of the preparers should be included.
Response; The qualifications and professional disciplines of
those persons in the List of Preparers, pg. VI-1, Chapter 71 in
the Draft EIS vill be included in the Final EIS List of Preparers.
Coaaeat; Page A-10. The table heading is Overland Flow Spray
Irrigation, is this correct?
Response; Ho. The table heading should read Soil Suitabilities
for Land Treataent.
8. James H« Lee; U.S. Departaent.of the Interior. Letter of October
30. 1981.
Coaaent; We suggest that the analysis of potential iapacts of
land application by spray-irrigation methods should include aore
adequate consideration of the fate of nitrates and any other con-
stituents little affected by traveling a short distance through
soils. The type (s) of crops under consideration for the irri-
gated areas should be assessed for their nitrate uptake capacity,
if tnis is fundamental to the plan.
Response; Undisturbed forest soils have been shown to have a ten-
dency to accumulate, store and redistribute nutrients. Many of
these soils have a strong capacity to retain nitrogen due to wide
carbon/nitrogen ratios associated with the organic forest aat as
veil as high cation-exchange-capacities (C.E.C.). Treataent in
the lagoon is expected to result in sizeable nitrogen concen-
tration reductions, less than 10 mg/1. ihen the effluent is
applied to the forest environaent, additional losses in nitrogen
will take place. The proposed land treatment fields are to peri-
odically rest in order to proaote aerobic conditions in the soil
environnent. This action will help to develop the conditions nec-
essary for denitrification, the chemical or biocheaical reduction
of nitrate or nitrite to gaseous nitrogen.
The total nitrogen for the p re treated effluent is anticipated to
be less than 10 ag/1, a concentration acceptable for drinking
IV-14
-------
water. Additional nitrogen will be removed by the land treatment
process, in that there will be a significant uptake of nitrates by
woody plants. Denitrification will farther reduce the nitrates to
nitrogen gas in the aerobic, organic-rich soil environment. Dur-
ing the winter months when biological activity is reduced, consid-
erable amounts of nitrate-nitrites will be absorbed by organic
complexes. Hany of these nutrients will then be made available to
plants for the next growing season.
Comment: The fate of effluent that reaches the resistent sand-
stone should be discussed; presumably it would move downgradient
along the top of the sandstone. A map showing sufficient geologic
detail to permit assessment of the possibility of effluent seepage
to drainage courses should be included.
Response; The proposed wastewater application techniques consid-
ers maximizing both infiltration of effluent by surface soils and
accumulation of wastewater nutrients by young trees. Renovation
of the effluent by the soil will be aided by physical uptake of
nutrients and wastewater by mixed hardwood trees. This process
will result in a sizeable reduction in volumes of wastewater that
will percolate through the soil profile. Both the Harsell and
Huskingum soils have relatively high cation-exchange-capacities,
an indicator of the soils ability to absorb ions. Additional
treatment of wastewater should take place as the effluent perco-
lates through the profile until it reaches a less chemically
active residuum (saprolite), This renovated effluent will then
combine with a nearby unconfined or perched aquifer and move out
of the region in the direction of the natural groundwater
gradient. At this point in the EIS process, no additional naps
will be drafted.
Comment; A specific omission regarding endangered species has
been noted. The DEIS does not address how Section 7(C) of the
Endangered Species Act of 1973, as amended, are being fulfilled
pertaining to the completion of a biological assessment. Once the
biological assessment is completed, the Federal agency oust deter-
mine if the proposed activities (alternatives in the DEIS) may
affect listed or proposed species and initiate consultation with
the Area Manager, U.S. Fish and Wildlife Service, Asheville, N.C.,
if a determination of "may affect1* is made. It should be pointed
out that positive as well as adverse affects require consultation.
In reviewing the DEIS, a conclusion of beneficial "may affect"
seems to have been made regarding at least one mussel species,
thus indicating the need for initiating consultation.
Response: Extensive discussions have been held between the U.S.
Pish and wildlife Service (FHS), EPA, and EPA's consultants con-
cerning the approach to be taken in evaluating protected species
and coordinating Section 7{C) activities. A three-step process
was agreed upon for the EIS. First, all protected species known
or suspected to be present in the study area should be reviewed in
detail to confirm or deny possible presence and impact fron the
project. If this review indicates no presence or impact, then no
farther action would be necessary. However, if the review does
not eliminate all species, then one of the two remaining steps
IV-15
-------
could be required. Either biological assessment surveys could be
required to demonstrate the presence or absence of the species in
question or the project could assune that the species in question
vere present, and proceed with the required analyses. These ana-
lyses include estimates of secondary impacts, cumulative effects
and efforts to be taken to eliminate, reduce, or mitigate any
adverse impacts.
This process was initiated with a letter to FWS on December 31,
1980 requesting a list of endangered and threatened species within
the study area. The PiS responded with a letter on January 12,
1981 listing 7 endangered species, 1 threatened species, 3 species
formerly proposed for endangered status, 2 species formerly pro-
posed for threatened status, and 2 species on the Smithsonian
Institution's list of threatened plants. These species vere
reviewed along with species listed by the Tennessee Heritage Pro-
gram (THP) during the EIS process. Particularly helpful in this
review process were the location maps and habitat descriptions
provided by the THP. None of these species are known to occur in
the areas of impact for' the proposed alternative (Mo. 7) , and
habitat conditions make their presence in these areas extremely
unlikely. These species are discussed on pages IV-16, I?-20,
IY-21, I?-50, and I?-51 of the Draft EIS. The FWS comment indi-
cates that an assessment was made that the preferred alternative
(Mo. 7) "may affect*1 at least one mussel species. The point is
made that . even a beneficial "may affect" requires the initiation
of a formal consultation. Ho "may affect" conclusion was reached
for any federally protected species under the preferred alterna-
tive. On page IV-50 possible adverse impacts to mussel species
are discussed for Alternative 3.. The possible beneficial "may
affect** discussed on that page is for the Tennessee Cave Salaman-
der (G;rinpphilus palleucusi. This species is listed only as
threatened on the state list, and the beneficial impact is very
remote under the preferred alternative.
Comment; Although the document (DEIS) includes an extensive list-
ing of area historic and cultural resources, there is no dis-
cussion of the significance of the resources or the effect on the
resources of the various alternatives.
Response; Alternatives 1, 2, 5, 6 and 7 would not be expected to
have any negative impact on area historic and cultural resources
due to pipeline construction. Extensive construction planned for
Alternatives 3 and 4, however, have the potential to impact nearby
historic resources. Impacts from construction include destruction
resulting from digging, soil erosion, and decrease in site visi-
tors due to noise. Spray sites in Alternatives 5, 6, and 7 all
are adjacent to cultural or historic overlooks. Generally, the
only impacts will be aesthetic, and even these are highly poten-
tial. The spray sites will not be seen because of the 200-foot
buffer zone surrounding the sites. Hoise may be a nuisance during
the construction phase, but is not expected to be a problem during
the operation of the sites. Odors at the lagoon site may be a
problem, but these odors would be localized and may not impact the
overlook. Additionally, if the plant is operating properly odors
will be minimal.
IV-16
-------
Comment: Me request that the State Historic Preservation Officer
(SHPO) be consulted concerning the survey for, and evaluation of,
cultural resources in the pro-ject area. A letter documenting that
consultation should be included in the final statement.
Response: Ho construction on the preferred alternative will take
place until historic and archaeoloqic surveys of the area are com-
pleted to the satisfaction of the SHPO. The SHPO for Tennessee is
the Executive Director of the Tennessee Historical Commission. A
copy of the Draft EIS was sent to the Executive Director, as well
as the State Division of Archaeology (State Archaeologist) and the
state clearing house for review and comment.
Comment; On page IV-54, the statement mentions that tentative
main routes for Alternatives 3 and <4 could result in negative
impacts to historic sites. Should either of these alternatives be
selected, we suggest close consultation vith the SHPO to mitigate
any negative impacts.
Response; Since neither Alternative 3 nor 4 was selected as the
preferred alternative, it is not necessary to consult with the
SHPO to mitigate any potential negative impacts.
Comment; The St. Marys spray site, utilized for the preferred
alternative (7) , is adjacent to an existing Civil War overlook.
le suggest close consultation with the SHPO to minimize effect.
Besponse; Close consultation with the SHPO will take place during
design and construction of the pro-ject to minimize any effect on
the overlook. Although any possible visual impacts to the scenic
overlook at the Bar Memorial will be eliminated by the 200-foot
buffer zone of uncut vegetation which will surround the sprayfield
site, oo construction will take place until the appropriate state
offices (including the SHPO) have been satisfied with the measures
selected to mitigate adverse impacts on the overlook.
Comment; The St. Marys spray site is also within one mile of the
Barnes Branch of Lost Cove, an area listed on page IV-33 as con-
taining popular swimming holes. The statement suggests that the
wooded nature of the St. Marys site will prevent the occurrence of
airborne pathogens. We suggest that the area be monitored to
assure that airborne or water-carried pathogens do not reach this
adjacent recreation area.
Besponse; The purpose of the monitoring system at the spray sites
is to detect any contamination of ground and surface waters early,
before that contamination reaches any outlying or adjacent areas.
However, Barnes Branch of Lost Cave is located in the Barnes
Branch drainage area which does not serve as a drainage area for
the proposed spray sites. Therefore, impacts to surface water
quality or uses in Barnes Branch as a result of the EIS proposed
action are not expected. With regard to aerosols, the recreation
area is approximately one mile from the proposed spray sites. The
sites will be surrounded by a 200 foot buffer zone of uncut vege-
tation. Coupled with the selection of appropriate spray systems,
IV-17
-------
the effect of aerosols on the Barnes Branch area is expected to he
sufficiently mitigated.
IV-18
-------
Response to comment by J. R. Wauford
in letter of September 16, 1981
SEWANEE, TENNESSEE WASTEWATER FACILITIES EIS
PROPOSED ALTERNATIVE - DESIGN CRITERIA
I. Land Area Requirement Determination
A. Total design wastewater flow = 436,900 gpd
B. Application rate for spray irrigation = 3 in./wk.
C. Used nomograph from "Process Design Manual for Land Treatment
of Municipal Wastewater" EPA 625/1-77-008 (Pg. 3-11) with the
assumptions of a 200 ft. buffer zone and 25 weeks nonoperating
time. Therefore land area requirements approximately 130 acres
which includes land for application, roads, storage, and
buildings.
II. Treatment Facilities
A. Equalization Basin
• Volume of 497,000 gal. based on a 2-yr. return frequency
for the 7-day rainfall event
• Asphalt lined earthen basin (SWD = 11 ft., width = 40 ft.,
and length = 120 ft.)
• Mixing to be provided by 3 aerators (15 HP with Mooring)
B. Preliminary Treatment
• Sized to handle flows = 0.435 X 2.5 = 1.1 MGD where Q avg. =
0.435 MGD
C. Sludge Drying Beds
- Surface area = 9,000 ft2
D. Chlorination Facilities
2 contact tanks with a volume of 1520 cf each and detention
time = 30 min.
• Chlorine feed equipment to provide a dosage of 8 ppm or 29
Ibs./day for Q avg. and 72 Ibs./day for Q = 1.1 MGD
E. Control Building and Laboratory (same as 201 Study)
F. Pump Station at existing treatment plant site
• Pump size = 2.5 X .435 =.1.1 MGD
Efficiency of pump =80%
Power Factor = 0.90
• Total head loss = 80 feet
G. Conveyance to spray site
8" diameter force main with length of 6,500 ft.
IV-19
-------
Proposed Alternative - Design Criteria
Sewanee, TN EIS (Cont'd.)
-2-
H. Facultative Lagoon (includes storage)
Biological lagoon to be designed with adequate freeboard to
provide storage during inclement periods of operations
• Storage volume for 25 days (Refer to EPA 600/2-76-250, "Use
of Climatic Data in Estimating Storage Days for Soil Treat-
ment Systems")
Nonoperation time for the year = 4 weeks
Lagoon detention time =30 days
Basin to be asphalt lined with a 6 ft. depth and a total
volume of 2.4 MG (12.25 acres)
• Suggest a 3 cell lagoon system (includes 2 primary cells)
III. Spray Irrigation Facilities (Q = .436 MGD, Land Area = 165 acres, and appli
cation rate = 3 in./wk.)
A. Distribution Pumping
• Structure built into dike of storage reservoir (facultative
lagoon)
• Continuously cleaned water screens
Normal standby facilities for pumping equipment
• Piping and valves within structure
• Design flow = 436,900 gpd
B. Distribution, solid set spray (Buried)
• Lateral spacing, 100 ft.
• Sprinkler spacing, 80 ft. along laterals
5.4 sprinklers per acre
• Application rate = 0.20 in./hr. (maximum)
16.5 gpm flow to sprinklers at 70 psi
Flow to laterals controlled by hydraulically operated auto-
matic valves
• Laterals buried 18 in., mainlines buried 36 in.
• All pipes 4 in. in diameter and smaller are PCV and larger
pipe is asbestos cement
C. Service Roads
12 ft. roads with gravel surface, around perimeter and within
D. Fencing
• 4 ft. stock fence around perimeter of area
E. Monitoring Wells
• 6 wells (2 background, 3 perimeter, 1 on-sitc)
1 Surface water sampling site
IV-20
-------
Response to comment concerning deeper profile descriptions by
Donald C. Bivens of the SCS in letter of October 15, 1981
Established Series
Rev. BJF
11/1/69
MUSKINCUH SERIES
The Muskingura series is a member of the fine-loamy, mixed, malic family of Typtc
Dystrochrepts. These soils have brownish silt loam A horizons and yellowish brown allt
loam B horizons. They contain coarse fragments throughout and bedrock it «t 20 (o .40,
inches.
Typifying Pedon; Musklngun silt loam - forested
(Colors are for moist soil.)
Al -- 0-3" — Very dark grayish brown (10YR 3/2) silt loemi au>darate fipe jraaula*
structure; very friable; many roots | 10 percent cparsa
medium acid; clear wavy boundary. (2 to 5 Inch* I thick)
A2 — 3-11" -- Brown ( 10YR 5/3) silt loam; weak fine granular sqd «•«> fi»«
angular blocky structure; very friable) cesston coots; 10- percent
fragments; strongly acid; clear wavy boundary* (2 to • inchat thick)
B2 -• 11-24" -- Yellowish brown (10YR 5/6) chancery tile loaaj; Moderate fine ami
medium subangular blocky structure; friable; few roots; 20 percent
coarse fragments; strongly acid; gradual wavy boundary* (4 to. 11
Inches thick)
B3 — 24-32" -- Yellowish brown (IOYR 5/6) channery silt loasi; weak fine and medium
subangular blocky structure; friable; 30 percent coarse Craaotantai
strongly acid; gradual wavy boundary. (0 CO 12 Inches thick)
C -- 32-35" -'- Fractured brown and gray horizontally bedded toft siltstone and fine
grained sandstone and 10 to 15 percent Cine* like that in the 13 hori*
con. (0 to 10 Inches thick)
R -- 35" — Fractured slltstone and fine grained sandstone.
Type Location; Raleigh County, West Virginia; 3.5 miles east of Arnett on W. Va. Route 3,
then north 3/4 mile on U. Va. Route (3/10); 50 yds. east of road*
Range in Characteristics: Thickness of the solum ranges fros 16 to 36 inches, Pepth to
hard bedrock Is 20 to 40 Inches. The B and C horizons are strongly or. very Strongly acid
except where the soil has been limed. Coarse fragments of shale, Slltstone or sandstone
range from 10 to 30 percent by volume In all parts of the B horlson and are more than 35
percent in the C horizon. The control section averages lesa than 35 percent coarse frag-
ments. The Ap horizon ranges from dark brown (IOYR 3/3) through strong brown (7.5YR 5/6).
The Al horizon Is leas than 6 Inches thick and coraraonly is very dark grayish brown or
dark brown. The A horizon is silt loam, loan or fine sandy loan and nay be channery. It
is friable to very friable. The B2 horizon ranges from dark yellowish brown (IOYR 4/4) to
strong brown (7. SYR 5/6). It Is silt loam or channery silt loan. It has weak or moderate,
fine or medium, subangular blocky atructura. A few discontinuous clay fllas era In some
pedons. The C horizon is yellowish brown (IOYR 5/4) or brown (IOYR 5/3 or 7.5YR 5/4). It
is channery or very channery loam or silt loan.
Competing Series and Their Differentiae: The Citico, Kltsap and Sadie Series are members
of the sane family. The Citico soils have thicker sola, bedrock la at depths of more than
4u Inches and they formed In residuum weathered from phylllte. Kltsap and Sadie soils lack
bedrock within depths of 40 inches. Other related soils are in the. Berkl, Brand/wine, Dakalb,
Cannon, Cllpln, Lords town, Parker, Steinsburg and Westmoreland series. Berks, Brandyviae,
Dekalb, Parker and Steinsburg soils average more than 35 percant coarse fragments within the
control section. Gannon soils have higher base saturation, Gilpin and Vestnorelaod foils
have argllllc horizons. Lords town soils average less than II perpent clay within tha COD*
trol section.
Setting; Muskingum aolls are mainly on rugged topography of dissected plateaus* Hope
gradients range from 5 to 70 percent and are nottly part tlw 10
IV-21
-------
Muskinguot Series
In resldutaa weathered from Interbedded slltstone, sandstone and shftle. Mean annual pr«cipl~
Cation range* fron 35 to S3 Inches and mean annual air temperature* Item 50° to 57* F.
Principal Associated Soils; These are the competing Dekalb, Gllpln and Westmoreland soils
and the Ernest, Ramsey, Rayne. Shelocta and Upshur soils. All of these except the Kaascy
soils have argillic horizons. The Ransey soils have bedrock «t !«*• than 20 Inches.
Drainage and Permeability; Runoff is medium to high. PexBeabllity if moderate.
Use and Vegetation; Gentle slopes are used for growing corn, wheat sod hay* Most «rsaj •*•
in mixed forest of oaks, yellow poplar, hickory and maple.
Olstributton and Extent; Wesc Virginia, Virginia, Pennsylvania, Ohio, Kentucky, Indiana,
Illinois and Tennessee. The series is of large extent.
Series Established; Monroe County, Indiana, 1922.
Remarks ; This description generally confoms with the concept established for til* MuekinguB
series in the "Report on Classification into Series of Certain Soils Derlvad frasi acM Gray
Sandstonea and Shales in Eastern United States", by I. U. Slaonson, 8/24/62. Host »f the
soils Mapped in the Musklngiai series in U. Va. contain less Chan 33 percent coars* fragvents
In the control section and it is believed that nost of the soil* mapped in the Mu
series In the other states listed under distribution are within, the concept of this descrip-
tion. However, some of the soils included in the Muskingum series in other states contain
.more than 35 percent coarse fragments and would be within the current concept of the terks
series.
National Cooperative Soil Survey
U.S.A.
IV-22
-------
Kstablishea Series
htv. CLb:Gtati
hAhlSELLS StkllS
The hartsells series consists of moderately deep, well drained, moderately permeable soils that formed in
loamy materials from acid sandstone containing thin strati of shale or siltstone. Ihese soils are on nearly
level to moderately steep ridges and upper slopes ot hills and mountains.
laxonomie Class: r'ine-loamy, siliceous, thermic lypic hapluaults.
Typical r'eaon: hartsells tine sandy loam--pasture.
~ (Colors are for moist conditions unless otherwise stated.)
Ap—0 to 5 inches; dark grayisn brown (101k
-------
Established series
lev. JOT:tf»
am
JEFFEHSM SERIES
The .iefferson series consists of deep, well-drained soils on Mountain sides and footalopes. reraxablllty Is
•ederately rapid. Slopes range from 5 to 60 percent.
Class; Finc-lcray. siliceous, sicale Typlc Rapludults.
Typical fedon: Jefferson gravelly loan—on • convet 30-percent slope on the loner psrt of • steep nountsln
Side la woods.
(Colors are for nolst soils.)
»l — 0 to 3 inches; very dark graylsii brown (toil J/2) grrvelly loam; Moderate fine granular structure;
very friable; sway roots; 20 percent sandstone fragments; re4iue> acid; abrupt SMOOth boundary. (2 to 5 Inches
thick)
«?— 3 to 10 Inches; brown <10IR 5/1) gravelly loam; weak fine granular structure; »ery friable; aany
rocts; 15 percent sandstone fragments; Medium acid; ctear smooth boundary. IH to 9 laches thick)
31—10 to IT inches; yellowish brown (10TR 5/6) gravelly loam; week fine sabangular blocky structure;
frlaMe; «*ny roots; 15 percent sandstone fragments; strongly acid; cK-»r socoth, boundary. (0 to 10 Inches
thick)
Wit— -17 to 30 inches; strong brown (7. SYR 5/6) gravelly heavy loan; Moderate Medium subsngular blocky
structure; friable; roeana roots; aany thin clay ft lea; 15 percent sandstone fragments; very strongly acid;
gradual saocth boundary. (10 to 30 inches thick)
B22t— • 30 to 43 inches; strong brown (7.5TR 5/8) gravelly heavy loaa; few flae distinct yellowish brown
(tOTR 5/4) and. yellowish red fSYR 5/6) Bottles; weak medi-jM subangular bloeky atructure; friable; few roots;
COMBO* thin clay filns; 25 percent sandstone fragments; very strongly acid; gradual smooth boundary. (10 to
21 inches thick!
83 — «3 to 5O inch-s. strong brown (7.5TR 5/6) very gravelly sandy loam; ooeawn fine distinct yellowish
troun COYS 5'4) and yellowish red C5YI 5/6) Mottles; weak medium subangular blocky atructure; friable; few
roots; 40 percent sandstor.e fragments; strongly acid; gradual smooth boundary. (0 to 15 inches thick)
C--50 to 65 inches; mettled r«.uish brown (5TR 5/») and light yelloMlah brown (10Tt 6/4) »ery gravelly
saady loan; aasstve; friable; 60 percent sandstone fraaaxnts; very strongly acid.
Rarlan County, Kentucky; 1SO ftet north of 0. S. Highway 119, near borrow pit, 5 1/2 Miles
arineaat 31 darlan, about 1 Mile east of flosspoir.t.
****** in CharaetairtstiesT Thickness of the solun ranges fron «0 to 60 inches. Content of rock fragMents of
jaedstone range froai 5 to 35 percent to a depth of about 3 feet, and below 3 feet froaj 20 to 80 percent. So
— •-- -~ •-- — -•- - - r
areas are stony to e*tn
itremely stony. The soil ranges fro« strongly to »ery strongly acid, eicept the .
noriaons range from very strongly acid to neutral.
The «1 horizon has hue of 10TR. value of 3 to 5. and chroma of 1 to 3. The »2 nor 1 torn has hue of 10TR, value
of » to 6. and chroma of 3 or 4. The Ap horizon has hoe of 10TH, value of 4 or 5, and chroma of Z to 4. The
are laam. fin* sandy loam, or sandy loaai. and gravelly or eobbly analogues.
Tho B horlxom ha* hue of 10Y1 or 7.5TR, value, of 4 to 4, aed chroma of 4 to '8. Sosw pcdoas have mottles la
shade, of brow, yellow, and- red, aad-the lower part shades of gray. It is lo«rTaadTelay loas>rclay loa.
c'hSilool* e°W> ' ""•1°«u*s- Soil« p*doaa »*" B1 *»••*»•«* Soa* •«*>»» haie B3 nori2ns^liila?yto S;
ThoChoriioai is in shades of brown, red, or gray, aad are usually mottled. It is gravelly or channery
••low a depth of about 50 laches, that are froei shaly Material with a higher ooatent of clay. ° *° '
r. «iney, Saasafraa, and Suaayside series. Uly soils
tho eeaoetteg Clyaer and Shaloota serftea aad the Dekalb, Gllpln,
;s W»ll drained irlth rapid ar sjadluM ru«off. dem*»dlB« am aM»e. Permeability is
"8. o^r5%s: ..U.r.a's.ra^ ss zzii. »•
Soatharn Kentucky, Teaaesaee), aad Virginia. The series is eiteaslve.
t»T**?«**«f I -mt«a.l«i»saaoo Survey or Soeitaimmora Pennslyvaaia; 1»0».
i>
are
Rational Cooperative) loll
v. S. a.
IV-24
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D. BESPOISBS TO O81L COM BITS R EC El TED IT THE PUBLIC BEA1IIG
Oral consents received at the Public Hearing are indexed in Part
B of this Section. All of these coaments were responded to satisfac-
torily at the Hearing and those responses can be found in the tran-
script of the Public Hearing in Section VI of this document.
Therefore, it is not considered necessary to respond in any way to
those consents in this Section.
IV-25
-------
Chapter V
-REVISIONS TO THE DRAFT EIS-
-------
V. •XYISIOIS 10 THE DOFT BIS AID 1DDITXOBAI, I1FOHHATIOI
Errata
Coaaents received concerninq the Draft BIS revealed soae cor-
rect ions which were needed to rectify errors ia the report. Below,
the correction, location in the text, and person or agency making the
consent are given.
Page IT-28, Third Last two sentences Or. Charles Baird,
fall paragraph, under "University of University of the
line 4 the South Financial South
Analysis1*, beginning
with "It is the
fourth..." will be
oaitted.
Page 11-19, 11-20 Footnotes for Tables E. C. Moore,
Il-ft and II-5 should O.S, Army Corps
refer to Table II-6 of Engineers,
for information on . Hashville District
spray sites.
Page A-10 Table heading should E. C. Moore,
read "Soil Suitabili- O.S. Aray Corps
ties for Land Treat- of Engineers,
•ent", Nashville District
V-l
-------
Chapter VI
-DRAFT EIS PUBLIC HEARING-
-------
fl. TH1MSCBIPT Of PDBLIC HB1BIHG BBLD Ol OCTOBEB 20, 1961
The following is the transcript of the Public Hearing for the
Sewanee DEIS held in Sewanee on October 20, 1981.
VI-1
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T81ISCBIPT SOHHA1I OF THE
PUBLIC HEAMIG OI THE SB1AIBE, TEIIBSSEB
DIAFT BlflBOIHEITAL IHPACT STATBHBIT
The Public Hearing oa the Draft Environmental lopact Statement
(DEIS) for proposed wastewater treatment and disposal facilities for
the town of Sewanee, the University of the South, and surrouadinq
areas of Franklin County, Tennessee was held on October 20, 1981 at
Cravens Hall, University of the South. The meeting began at approxi-
mately 7:30 p.m. (Central Daylight Time) with approximately 50 persons
in attendance. Presiding at the meeting were Hr. John E. Hag an. III,
Chief, BIS Branch with O.S. EPA in Atlanta; Hr. Robert Howard, Chief,
BIS Preparation Section, U.S. EPA, Atlanta; and fir. Honald Hikulak,
Sevanee, TH BIS Project Officer, U.S. BPA, Atlanta.
Introductions and opening remarks were heard by Hr. Hagan. He
began by recognizing the presence of several state, local and Univer-
sity officials. They were dr. Richard 6. Threadgill and Hr. Donald
Gregory of the Tennessee Division of Construction Grants and Loans;
Hr. Arthur H. Schaefer, Provost, University of the South; Hr. Edmund
Kirby-Smith, President, Sewanee Utility District; and Jlrs. Ina H.
flyers and Hr. Douglas Paschall, members of the Utility District.
Jtn continuing his opening remarks, Hr. Hagan stated that the
purpose of the meeting was to receive public and other agency comments
on tne wastewater management proposals in the DEIS for Sewanee, TH.
He proceeded to give a brief history of the project beginning with
VI-2
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preparation in 1976 of the 201 Hastewater Facilities Plan for the
Sewanee Utility District by J. H, wauford 6 Company, Consulting Enqi-
neers of Nashville, TH. Preparation of the BIS was authorised by the
Clean Hater Act and the National Environmental Policy Act. The Clean
Mater Act enables EPA to fund up to 75 percent of eligible costs for
planning, design and construction of wastewater facilities. The plan-
ning phase of this process results in the preparation of a document
known as a facilities plan. In this instance, the Sevanee Utility
District has been designated as the local agency responsible for
facilities planning in this area. HEPA requires federal agencies to
prepare EIS's on major federal actions which significantly affect the
quality of the human environment. Because of the environmental com-
plexities of the water quality issues involved in this project, EPA
determined that this was a major federal action significantly affect-
ing the quality of the huaan environment and decided to prepare an
EIS. In October, 1977, a Notice of Intent to prepare an EIS was
issued. This public hearing is beinq held to receive public ccements
on the Draft EIS, pursuant to the guidelines of the President's Coun-
cil on Environmental Quality and the Rules and Regulations of the
Environmental Protection Agency with regard to preparing EIS's. The
DEIS and Facilities Plan are discussed in a public forum to encourage
public participation in the federal decision-making process and to
develop improved public understanding of federally-funded projects.
The DEIS was made available to the public and to the EPA Office of
Federal Activities and to other federal and state agencies on Septem-
ber 2, 1981 and was listed as being available for public review in the
Federal Register on September 11, 1981. The DEIS comment period will
extend to October 30, 1981. The comments received during the Public
VI-3
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Hearing and during the comment period will be incorporated into the
Final EIS.
Hr. Hagan«s remarks were followed by a description of the project
itself by Hr. Hikulak. As a basis for describing the project, Mr.
Hikulak utilized a handout distributed at the Hearing. This handout
summarized the Draft BIS into approximately 10 pages. Hr. Hikulak
began his presentation by briefly discussing the purpose and back-
ground of the EIS. In addition he reviewed the problems and issues
which resulted in preparation of the EIS (particularly the water gual-
ity issues and the nitrogen standard)* the 201 facilities Plan pre-
ferred alternative, and the seven wastewater management alternatives
developed by the EPA consultants, Gannett Fleming Corddry and Carpen-
ter, Inc. of Harrisburg, Pennsylvania and Claude Terry and Associates,
Inc. of Atlanta* Georgia. Hr. Hikulak reviewed the present method of
wastewater treatment and disposal in the study area, and described in
detail the Draft EIS preferred alternative and its pros and cons.
This alternative consists of replacing the existing sewage treatment
plant (STP) with a combined storage pond/facultative lagoon at the
proposed spray site and pretreated effluent be spray irrigated at the
St. Marys and Garnerstown sites approximately 3000 feet west of the
existing STP. Hr. Hiknlak discussed the reasoning for implementation
of a monitoring program for the proposed system, and referred to the
suggested monitoring program developed in the Draft EIS. Hr. Hiknlak
ended his comments by expressing his thanks and appreciation for the
time and effort expended by the EIS Community Review Group which was
instrumental in reviewing information, and provided EPA with comments,
and local opinions and attitudes throughout the various stages of the
VI-4
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EIS,
The remainder of tine vas spent hearing and, in most casesr
responding to questions and/or comments received from persons attend-
ing the hearing. Mr. Bagan called upon ffr. Robert G. Threadgill of
the Tennessee Division of Construction Grants and Loans to offer a
presentation on behalf of the State. Mr. Threadgill declined,
however, saying he had no comments at that time bat that the state
would submit comments pcicr to the end of the comment period.
Comments and/or guestions vere then taken from the floor starting
with those persons who had indicated they wished to speak prior to the
start of the proceedings. The following is an account of the comment
and response portion of the Public Hearing.
Dr. J. 8, Hauford, President, J. B. wauford and Associates: If land
application plans and specifications are prepared, are submitted to
the State and/or EPA and are approved, the proiect is built, if later
on the wells for surface water monitoring indicate that pollution of
either the surface water or the wells is occurring, what will the
State and EPA*s positions be?
Mr. Hobert G. Threadgill, Jr., State of Tennessee: If an alternative
system is built, they (EPA) have a policy »hich is 100 percent payback
if the alternative does not work. If, in this case, it does not work
and there needs to be some other type of treatment provided, then EPA
has a policy in which 100 percent of what is necessary to bring this
treatment plant up to meet those effluent standards can be given. It
VI-5
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would be 100 percent payback to the Utility District and it would cost
the city no more or the Utility District no more aoney. However,
that's only if there's any money available, and the way things have
been qoinq in the past few months and in the past year, I'm not sure
if there vill be any grant monies in the next three or four years. So
it's up to the Congress and the new administration on whether there
will be any future grant money. So there cannot be 100 percent cer-
tainty that there will be that back up money there.
dr. John E. Ragan: I will last reinterate that the Clean Hater Act
reguires that the EPA essentially put up a word bond that says that if
an innovative and alternative system which gualifies for an 85 percent
grant, which we believe this facility would, if that facility fails to
operate, that EPA is responsible for 100 percent of the cost of
replacing it or bringing it up to operational capabilities.
Unidentified Speaker: Is this to say that this is so imprecise a sci-
ence that you can't go out there and spray something on the ground
before the fact, before you spent all that money and dug all those
holes?
Mr, Hagan: No sir, I think that this particular technology is not all
that imprecise a science. I think that our consultants and Rr. Bau-
ford, all the consultants that have been involved with this project,
have agreed that these facilities are designable, operable, and func-
tionable and they will do what they are designed to do. The incentive
for this payback was really an incentive to try to get, to try to sti-
mulate, the engineering community. This was passed back in 1977 when
VI-6
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the Clean Hater Act was amended, and the ob-fect of the alternative and
innovative incentive mone? - the 85 percent money, plus the guaranteed
payback - was an incentive for the consulting engineering community to
try to do things innovative and alternative. I think that this system
really has very, very low risk associated with it - very low risk.
Hr. Sobert Howard: One thing I night add to that, that there were, I
believe, 56 cores taken of the spray irrigation sites and that these
cores basically showed that the soils there were very suitable for
this kind of land application, which, I think, greatly reduces the
potential risk that might be associated with this as an alternative
treatnent.
Hr. Hagan; Our next speaker was Hr. J. H. Avent.
Hr. J. H. Avent: I don't care to talk at this time.
Hr. Hagan: Dr. Schaefer?
Dr. Arthur M. Schaefer, Provost, University of the South: As far as
the University is concerned, we looked at several of these types of
sites two years ago, I believe, particularly one pilot project in
northern Georgia which was not functioning effectively. On the basis
of that visit, we disliked the idea of a facultative lagoon and we
urged the EPA to pretreat before spray irrigation which would essen-
tially be, I believe. Alternative 6. Since that tine, some represen-
tatives of the University have visited other sites and are convinced
that the facultative lagoon, if constructed properly and properly
VI-7
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operated, is an effective way of doinq this and on the basis of that,
the University is no longer opposed to that particular suggestion.
Mr. Hagan: Thank you, sir. At this tiae 1*11 take comments or ques-
tions from the floor. I would ask that you identify yourselves and,
if you would, cove to the microphone.
Hr. Ednund Kirby-Saith, President, Sevanee Utility District: Hhat I
wanted to do was address the save point that Dr. Shaefer did concern-
ing the question of dislike of the facultative lagoon which had been
aade earlier. As he mentioned there have been visits Made to several
facultative lagoons in this part of the state which officials of the
University and of the Utility District found, I thought, in very good
operating condition and as far as the Utility District is concerned,
for the record,we would like to say we are in favor of a facultative
lagoon* Re have found that, in addition to these facilities existing
in Tennessee, there are at least several in the Carolinas, one near
Cleason College, a naaber in Mississippi and lust recently I received
a listing of land treatnent facilities which are being constructed by
the Corps of Engineers for U.S. Ar»y and Air Force installations in
the continental United States. That listed soae thirty odd locations
at which land application had been installed froa the very late 60's
through the 70"s. Cf those locations, I think 6 or 7, spray irri-
gation was applied to golf courses and had apparently been successful.
So the Utility District is in favor of this fora of treataent.
Unidentified Speaker: What will the iapact of this be upon sewage
rates in the county?
VI-8
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Me. Hagan: If you would refer to the cost table on page 9 of the
handout.
He. Howard: You should recognize that these costs we'll be qivinq you
are just estimated costs and they could vary up or down depending upon
what are the final costs of the system.
Mr. Hagan: The present rate as *e understand it, if 07 information is
right, is about $120 a year. Or somewhere in the neighborhood of
about $10 a month. The estimate here is that it would go up to
approximately $141 a year or approximately $20 a year per service con-
nection more. Now, perhaps you have some more precise information.
Mr. Kirby-Smithi Referring to Table 11-10 (Draft EIS) the monthly
estimated user cost would be $11.80 at the completion of the proposed
project. John Hall, Manager of the Utility District, made some compu-
tations based on computer printouts. At current rates, the average
bill statistically is about $8.85. That's based on an average con-
sumption of about 5000 gallons per month (refer to table). The figure
which he (Mr. Hall) obtained by using the actual billings and the sew-
age produced was guite close to that figure of 4900, around 4600 to
4700. So, I think at least the statistical average of the customer
bill to date is about $8,85 or roughly $3.00 under what the proposal
would indicate here.
Mr. Hagan: So an average of about $3.00 a month.
Hr. Kirby-Smith: Mow the accuracy and the validity of that would
VI-9
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depend upon the accuracy of that $11.80.
Mr- Nikulak: I would use caution on these figures. These were pre-
liminary estiaates that were done lost the past few months. By the
tine the facility is" constructed and operational the figures that
we1 re talking about to date nay be fiction.
Mr. Hagan: I would like to point out though that we're fairly confi-
dent of the coaparison of the numbers. All of the comparison numbers
are subject to the same types of inaccuracies due to inflation. So
while they may not be accurate absolute numbers, they are accurate in
relative terns. So this is still the least expensive alternative both
in project, not guite in project costs, but very close in project
costs, but tie least cost to the local citizens.
Mr. William Kershner: I have three gnestions. One, the facultative
lagoon sites that have been visited; do they have the sane geological
type situation that we have here — sandstone, etc.? Two, if the wells
are contaminated, what about owners of the property rather than nearby
wells? Is there anything in the way of insurance for them? And
three, abandoning the STP site, current, will that make any difference
as far as money is concerned? How much will we lose on that, or is
that taken into consideration in the prices?
Hr. Kirby—Smith: (response to first guestion) The primary factor is
the size of the lagoon. That will be a more appropriate factor to
compare with what's proposed here. Lagoons that we visited were in a
clay soil that had no need for a lining or a membrane to keep any
vi -io
-------
leakage from occurring. I believe the proposal here is, because of
the sandy silty nature of the soil and to avoid any percolation or
leaking into the soil strata, that it would be lined. By what aeans
would have to be determined during the design phase. The size of the
lagoons that ve visited, one was about 10 acres and one was about 15
acres, so they were quite comparable in size to what would be proposed
here.
fir. Kershner: Where were the sites of the ones that you visited?
Hr. Kirby-Smith: In Huntingdon, Tennessee and in Bruceton, Tennessee.
Mr. Hagan: He have some experience in constructing impervious liners
in lagoon systems in Florida where you have much laore permeable soils
than you have up here and they also, in the particular instance that
I'm thinking of, build these holding ponds, perhaps, as high as 35
feet above the natural ground level and through compaction of clay
material found on the site (the same type of construction techniques
they use for building a road; they use the same kind of road building
equipment to compact that clay to construct an impervious liner) we've
been able to get the permeability of the soil down to extremely small
numbers so that for all intents and purposes that is not a permeable
soil - I mean its probably less permeable than the concrete floor of
this building. So they are very, very tight. The second part of the
guestion that Mr. Kershner had was, will the owners be compensated if
their water wells are polluted? I wish I could answer that but I
really can't. I don't know what the legalities of that are. I would
hesitate to make a legal -judgement on that. It would seem to me that
VI-11
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the purpose of the monitoring program would be to detect, very early
before any wells were contaminated, whether there was any leakage froa
these ponds. And the location of the monitoring wells is such that
they are designed to do exactly that and we would hope that any
increase in nitrate levels in the ground water would be detected long
before it got to any drinking water wells. How far is the nearest
drinking water well, Bon?
Mr. Hikulak: well, I* • not sore. Host of the people in Sevanee are
served by the Sewanee Utility District water supply and because of,
what I understand, the high iron content of groundwater, it*s not used
very ouch as a drinking water source. Another reason its not used
very much is because of the accessability of the water mains for the
Utility Districts
Mr. Howard: I wanted to ask Hr. Kershner whether or aot he actually
is on a groundwater well for your water supply?
Mr. Kershner: Ho, I'm on city water. I was thinking about the people
over in Garnerstown and that area. There are a number of wells
there...
Hr. Kirby-Smiths I think the Garnerstown site is that area which is
between the Garnerstown loop road and the entrance to St. Harys. That
area is included in one large drainage basin. I would think that
because of the natural topography and the natural flow of water that
it would be most unlikely that there would be any flow other than
towards the escarpment towards the bluff line.
VI-12
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Hr. Howard; If you look at the figure on page 11 (of the handout) you
can see by the drainage basin and vhere the streams are that the par-
ticular area located between the St. Mary's spray irrigation site and
the Garnerstown spray site would, lust by looking at the topography
and the layout, that one would be led to believe that it is an iso-
lated area. Because there is a ravine immediately north of it and if
you look at the drainage basin from the Garnerstown site, it would be
draining south, away front that particular area.
Hr. Hagan: And the other question was, would there be any loss froa
abandoning the existing treatment plant? Is there any outstanding
indebtedness on the existing treatment facility?
Hr. John E. Hall: No.
fir. Hagan: Hr. flail says there is no outstanding indebtedness.
Hr. Henry Ariail: I'd like Hr. Hikulak to clear up a point that I'm
confused about. The diagram shows that the existing treatment plant
is to be abandoned and yet in the verbal description there is to be
some pretreatment to go on that site.
Hr. Hikulakc The existing treatment plant site would still serve as
the focus point for the wastewater. Pumps are there; its a good col-
lection point.
Hr. Ariail: Mould odors eninate from the pretreataent system or would
it be all in pipes last passing from there on to the new lagoon site?
VI-13
-------
Hr. Howard: That would be based somewhat on the design. There has
been some discussion already vith the 201 consultant or a consultant
who might very well be involved in this. There has been some dis-
cussion as to whether or not there might be an equalization basin and
whether or not there Bight be any need for any aeration of the waste-
water at that site. Some of the preliminary discussions we've had so
far indicate that there likely would not be; that it would be unneces-
sary. X think that based on the design, there are a number of ways
that even if there was an eguilization basin and there vas aeration at
that site that aesthetic problems associated with that particular
operation would be taken care of.
Hr. Hagan: In otaer words, it would lust be a pumping station.
Mr. Hikulak: Hhat's your experience now with odors at the facility.
J. know where you live.
Hr. Ariail: The treatlent plant and I are close friends, geograph-
ically, but we're not such close friends odoriphically. Sometiaes
it's guite noticeable.
Hr. Nanford: We're in basic agreement with the engineering concept.
le don't have any problems with that. From our own observations, we
doubt that the odor problems...as a matter of fact, we don't see any
great, real risk involved. There's always some risk or the government
wouldn't underwrite the cost of fixing things up if they go wrong and
that's the reason I asked my first question to get it in the record.
Veil, I'll ask another question. I was hopeful that I knew the answer
VI-14
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to the first question and I really wanted the EPA to qet their answer
in the records, which Mr. Hagan did. This question concerns the I/A
eligibility aspect. Jn other innovative and alternative projects in
which we've been involved, each component has been analyzed by your
I/A section and considered as to whether or not that particular compo-
nent is innovative or not, such as the pumping station to convey the
sewage from the existing site, and the force main, and the grit cham-
ber, in other instances have been considered to be not innovative, but
conventional treatment. Facultative lagoons, of course, are not, per
se, innovative. Are there any components in this system, which would
not quality for 85 percent funding? I didn't notice their being iden-
tified in the cost-effective analysis if there were.
Hr. Hagan:: The answer that I give you is going to have to be a
bureaucratic answer because, frankly, we don't know. At this point,
the alternative and innovative determination is made by our Con-
struction Grants Office in Atlanta and, I assume, perhaps in conjunc-
tion with the Construction Grants Office in the State of Tennessee.
And it's my understanding that the evaluation is made on a
coBpoaent-by-component basis. I can not frankly, in my own engineer-
ing judqement see that a grit chamber or a pumping station is very
innovative or alternative, however, I think probably the treatment
processes, and the sprayfields are either innovative or alternative.
Certainly in other ar^as spray irrigation sites have qualified as
innovative and alternative technology. On the facultative lagoons, I
have no personal knowledge of that so I won't try to answer it. I
think the actual answer to your question is that it will have to be
determined on a component-by-component basis.
VI-15
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Me. Howard: He will attempt to give an answer to your question in the
Final EIS.
Hr. Threadqill: The only thing I can add to that is the likelihood
that the lagoon itself - the facnltative lagoon - will be considered
part of the spray irrigation system and will receive the 85 percent
funding. That has happened in the past on other projects, so the only
problem we might have is the pumping station itself and maybe the pre-
liminary treatment given prior to going to the lagoon. These may be
considered non-eligible for the 85 percent grant and would lust
receive the 75 percent grant.
Mr. Hagan: Are there any more comments or questions from the floor?
Dr. Schaefer: Would you describe for us how the appraisal procedure
would take place for the land?
flr. Hikulak: It's an area I an not very familiar with; it's not part
of the activity I am involved with, fiat, I did a little of my own
work and I can give you a general idea of how the whole situation is
approached when we're talking about land appraisal and acquisition of
land. It's something that is basically a matter between the grantee,
in this case the Utility District* and the land owner or the land lea-
sor. There are procedures that are in place; they are guided by regu-
lations that EPA has come up with in response to federal law. The
procedures are very straightforward. I don"t think !•!! go through
each procedure step-by-step here. I made a copy of the policy proce-
dures available to the Utility District. Anyone who's interested, I
VI-16
-------
have a copy here, if someone wants to review it. If you wish to get a
copy of these procedures, I'll certainly be happy to nail you a copy.
The matter of land appraisal, aqain, is between the grantee and the
land owner, with EPA looking over everybody's shoulder because we're
paying for 85 or 75 percent of the activity. It's a matter in which
one, two or three appraisers are contracted with; the fair market val-
ue of the home or the land is thrown out for entertainment; there is
negotiation involved. When a number has been decided upon between the
grantee and the landowner, EPA approval is sought, hopefully obtained,
and we're all home free, so to speak. Again, there is a natter of
public notice involved, public notice of land acguisition and then
land appraisal. The home owners or the affected residences or
affected parties have to be made knowledgeable of what the project is,
what the impact might be on themselves and they have every opportunity
to obtain a fair market value for their properties. That"s -just a
very general overview; it's a fairly common-sense approach and believe
it or not there are some federal procedures and regulations that do
come from a common-sense approach, and hopefully everyone is treated
fairly; that's the intent of the regulations and procedures. If peo-
ple are not treated fairly, I'm certain that there are measures avail-
able - EPA probably wouldn't approve the whole thing if everybody
wasn't happy and, like I said, I'll leave a copy of these procedures
available here and if anyone is interested for more detail, please get
in touch with me and I'll provide you with what I can.
Mr. Hagan: He had the opportunity this afternoon to walk through some
of your beautiful woods. We went down to Peters Cave and Buggytop and
also walked over a portion of the Garnerstown spray site. The pro-
VI-17
-------
posal as 1 understand it is for a 200 foot aide buffer to be left
essentially intact. All the trees and all the underbrush and every-
thinq are to be left lust like they are, except for the necessary
access roads and piping corridors and that sort of thinq. My response
to this land issue is,'and in response to Mr. ffauford's question about
what is the risk of a spray irriqation site, I think really the only
risk you're qoinq to have is that you're qoing to forqet that its
there. With a 200 foot buffer strip around it, the people that live
in those houses adjacent to that site are not even going to knov the
thinq*s there and nobody else is ever qoinq to know the thing's there,
*
and the risk of that is that you'll forqet to maintain it. Tou'll
just never know the thinq is there.
'Br. Howard: I'd like to add one thinq regarding those procedures and
I thiak it's a key part of the process. The process is designed to
infora tke people who are likely to be affected by the regulations of
•hat the procedures are, and that there is a dialogue which is Ban-
dated by the regulations so that everyone is kept informed. It's
designed to be a fair process to both parties, that is to the appli-
cant and to the person who aiqht be affected.
Mr. Howard: Are there any other COBments or questions froa the floor?
Mr. Wauford: What are the procedures for the applicant to follow, to
aost ezpeditiously get to the money, so to speak?
Mr. Haqan: I think I can qive you that procedure in a series of fair-
ly large groupings of steps. I wouldn't want to try to lay out a
VI-18
-------
detailed procedure, particularly not lust off the top of my head, but
the nert step in this process is to complete the Final EIS which
should be done before the end of the calendar year. Upon completion
of the Final EIS, EPA would procede to authorize additional Step 1
grant funding (that ' would have to be applied for) to update the 201
Facilities Plan to bring the Facilities Plan in confornance with the
EIS, if that step is necessary. I would suspect then that you would
apply immediately for a Step 2 design grant which depending on your
placement on the State's priority list, would be funded vhen that
floated to the top of the list. Then immediately following completion
of the design, you would either apply for a Step 3 grant or, as Mr.
Threadgill has suggested, perhaps apply for a combination Step 2-3
design and construction grant in one operation. For a project of this
size, I think that would probably be an advisable way to go.
Or. Howard: Certainly the key factor here is where, after the EIS is
completed, does this particular project lie on the State's priority
list, and that is a matter that the State sets with all of the various
projects that they have to fund within the State of Tennessee; they
establish priorities with the available monies, and go down the list
and wherever the money runs out, that's where the projects run out. I
think that the guestion probably is more appropriately addressed to
discuss that further with the State at another date.
Hr. tfauford: The thing I was driving at is whether any extensive
revisions to the 201 Plan would be necessary or whether a one or two
page resolution saying the EIS is accepted, adopted, and approved
would be sufficient?
VI-19
-------
He. Hagan: Hell, again, I think you'd need to talk to the State of
Tennessee and to EPA's construction grants people as to what they will
be willing to accept along that line. I really can't ansver that Hr*
Wauford, 1 vish I could. In some other relatively complex projects.
He have had to go back and update the 201 Plan. It may not be neces-
sary.
Hr- Hagan: If there are no other comments I lust vant to thank you
all for coming tonight and participating in this. This has been a
very good, lively discussion. I vould reinterate that our comment
period will be open until October the 30th. If anyone wishes to sub-
mit written comments for the record they will be considered as if they
had been presented tonight, ft summary transcript of this Hearing will
appear in the Final EIS. He will try to answer all the guestions that
we were not able to get specific answers for tonight and those answers
will appear in the Final EIS. The Final EIS will be out before the
end of this calendar year and it will be made available to those who
are on the mailing list or who indicated on the registration card
tonight that they wished to receive a copy. So, if there are no other
comments, 1*11 declare this meeting adlonrned. Thank you.
VI-20
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Chapter VII
-WRITTEN COMMENTS RECEIVED ON THE DRAFT EIS-
-------
TIJ. BRITTEI COBBK1TS EECEIfED OI TIE DBAPT BIS
This section includes all those letters received from persons
coamenting on the Draft EIS. These persons or agencies are listed in
Section IV. Part A. of this document.
VII-1
-------
J. R. WAUFORD & COMPANY
P. O. BOX I4O38O — 2»3B LEBANON ROAD • CO1B) BB3-3243
September 16, 1981
NASHVILLE. TENNESSEE 37214
Mr. John E. Hag an. III, P.E.
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30365
Re: Draft and Environmental
Impact Statement
Sewanee, Tennessee
Dear Mr. Hagan:
We are the Consulting Engineers for the Sewanee Utility District and have reviewed
the copy of the Draft and Environmental Impact Statement received together with
your "Notice of Public Hearing", dated August 31, 1981.
First, allow us to compliment you and your consultants on the quality of work
performed and generally upon the conclusions reached. Secondly, we offer one
comment and that is if the selected plan is used, we would probably want to
design a sewage pumping station at the existing treatment plant which would provide
for sewage pumps to handle normal flow and stormwater pumps to handle peak I/I
conditions; this would require a separate force main and would utilize the freeboard
on the facultative lagoon for 500,000 gallons of inflow storage.
Thirdly, we would appreciate an opportunity to review the detailed design criteria
used for the sewage pumping station, force main, facultative lagoon and any lines,
land application area and application system and laboratory and control building.
If we might review these prior to the October 20 public hearing, we would appreciate
such consideration.
Yours very truly,
J. R. WAUFORD S COMPANY
CONSULT]
JEW: lid
cc: Gannett, Fleming, Cordday, Carpenter
Consulting Engineers
John Hall, Manager, Smith Utility District
^Wauftfrd, Jr.>
[dent
ENVIRONMENTAL IMPACT STATEMENT
BRANCH
SEP 1 8 1981
Ulh
REGION IV - EPA
iii
"•* i
356 SANDERSON ST.. SUITE C. ALCOA. TENNESSEE 377O1 • (615) 984-9638
1O8 KRESS BUILDING ON THE MALL. LAUREL. MISSISSIPPI 3944O • (6O1) 649-3252
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE:
QCT 2 1981
SUBJECT:
FROM:
TO:
Sewanee, Tennessee EIS
Acting Chief, SC/TN Facilities Planning Section
Water Quality Management Branch
Ron Mikulak, Project Officer
EIS Branch
The EIS should include some discussion on the ability of the users of the
system to pay for it. This should include more detail on existing debts,
how and for how long they are paid, alternative sources of funds and
mechanisms available for financing the local share. Tables 11-10 and
III-2 should include data on the percentage of median household income
used to pay for the various alternatives. Proposed user charges should
be thoroughly discussed at the public hearings on the draft EIS.
The population and per capita flows appear reasonable, however, there
must be some justification for assuming all flow is received within 18
hours. Will 100% of the population in the subbasins listed in Table II-l
be served?
The need for and cost-effectiveness of a 497,000 gallon equalization
basin must be shown. Generally, for small land systems a storage and
preliminary treatment function is accomplished with one pond. The
storage requirement should be based on the period of time that the site
is unsuitable for spraying or on mechanical reliability.
The cost-effectiveness analysis has not been completed strictly in
accordance with the construction grant regulations (i.e. land can be
appreciated at 3% per year); however, our calculations based on the EIS's
raw capital and O&M costs support the selection of Alternative 7.
Leonard W. Nowak
EPA Form 1320-6 (R«v. 3-76)
-------
United States
Department of
Agriculture
Soil
Conservation
Service
675 U. S. Courthouse
Nashville. Tennessee 37203
October 15, 1981
John E. Hagan III, P.E., Chief
EIS Branch
EPA, Region IV
345 Court! and Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
We have reviewed with considerable Interest the Draft Environmental Impact
Statement for the Sewanee, Tennessee Wastewater Facilities as well as the
technical reference documents, Volumes I and II. We have several concerns
with some of the Information contained In the documents, and the conclu-
sions that have resulted from this data.
The draft Alternative Development and Evaluation Technical Reference docu-
ment (Volume II) contains a report prepared by Soil Systems, Inc.The
report follows Page IV-39 in the draft document. Page two of the report
describes the subsurface conditions of one of the sites as follows: "At
the St. Mary's site, the depth to refusal varied from 2.2 feet to 21.2
feet. Generally the upper 2 to 8 feet of the boring was easily penetrated
by the augar at which point drilling resistance increased steadily until
refusal was reached. The soils encountered were generally silty sands to
sandy silts. All borings reached refusal in the sandstone unit."
The document also includes a Site Evaluation for Proposed Forest Spray
Irrigation System report prepared by, Gannett, Fleming, Corddry and Car-
penter, Inc. The report can be found immediately following the report of
Soil Systems, Inc. Page four of the report states: "Typical profiles as
described in the 1958 Soil Conservation Service Soil Survey are given in
Table I. The actual soil profiles were much deeper (in some cases, over
20 feet) on the three sites evaluated as indicated in the SSI report."
While the report states that the soil profiles were much deeper than the
profiles described by SCS, the report containes no description of these
deeper profiles... If indeed, the deeper soil profiles do exist, then these
profiles should be described in the report. The report concludes that the
depth of the soil profile is equal to the depth of material than can be
penetrated by a power augar. This is not consistent with Soil Conservation
Service procedures for determining soil depth. The report prepared by
Gannett, Fleming, Corddry and Carpenter, Inc., also contains an analysis
of the storage capacity and percolation of the soils to a depth of 24 to
27 inches. The report, however, does not address the percolation rate
of the substratum, nor the storage capacity that can be anticipated under
field conditions during different seasons of the year. This needs to be
done in order that actual storage volumns available on the site can be
determined.
The Sol Conservation Service
is an agency of the
Department ol Agriculture
SCS-A!
10-79
-------
John E. Hagan III
Page 2
October 15, 1981
Page IV-65, the Draft Environmental Impact Statement reads as follows:
"The major soil impact will be through soil erosion during construction,
this impact can be reduced by:
1. Limiting the size of the pipeline corridor to the minimum possible
area of disturbance.
2. Prepare and strictly enforce construction plans which require the
rapid stabilization and revegetation of construction areas.
3. Institute best management controls in order to reduce the amount
of non point source runoff from the construction sites."
The report does not contain an analysis of the anticipated impacts of the
sprayed wastewater on either the existing vegetation or the soils. These
evaluations need to be included in the report.
We appreciate the opportunity to comment on the Draft Environmental State-
ment. I trust these comments will be helpful in preparing the Final
Environmental Impact Statement and designs for the Sewanee, Tennessee
Wastewater Facilities. If we can be of further assistance, please let us
know.
Donald C. Bivens
State Conservationist
cc: Norman A. Berg, Chief, SCS, Washington, D.C.
ENVIRONMENTAL IMPACT
BRANCH
l'V °CT211981
REGION IV -
-------
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service
_iir
**. ~"<^ ——
Centers for Disease Control
Atlanta. Georgia 30333
(404) 262-6649
October 26, 1981
Mr. John E. Hagan, III, P.E.
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
We have reviewed the Draft Environmental Impact Statement (EIS) for the proposed
Sewanee Wastewater Facilities for the Town of Sewanee, the University of the South,
and the surrounding areas of Franklin County, Tennessee. We are responding on
behalf of the Public Health Service and are offering the following comments for
your consideration in preparing the Final EIS.
In general, implementation of the preferred alternative should have a positive
effect on current wastewater treatment facilities and programs and should result
in enhanced environmental quality and public health. Nevertheless, it is
important that the proposed monitoring program be performed, in the future to
assure protection of groundwater and surface water resources. The effect that
large and/or long-term storm events will have upon the management and operation
of the spray fields should be discussed. What measures will be incorporated
into the design and operation of the lagoon to prevent field spraying during
frozen and/or saturated soil conditions?
It has been our experience that poor management of a spray irrigation field may
lead to potential runoff and water quality problems. For this reason, the EIS
should discuss the management aspects of maintaining necessary percolation and
infiltration rates, suitable soil conditions and vegetative cover, and prevent-
ing surface compaction, clogging and matting.
For general protection of public health and safety, will the lagoon and spray
irrigation areas be posted and fenced?
The potential vector problems that may be associated with the operation and
maintenance of the lagoon and spray fields should be addressed. The wastewater
treatment systems should be operated in such a manner to prevent the increase
of any vector populations that have the potential to cause vector-borne disease
or nuisance problems. We suggest that you contact the local and/or State public
health authorities for information on vector problems and control techniques
in the project area.
-------
Page 2 - Mr. John E. Hagan, III, P.E.
We appreciate the opportunity to review this Draft EIS. Please send us one
copy of the final document when it becomes available. Should you have any
questions about our comments, please call Robert Kay of my staff at FTS 236-6649.
Sincerely yours,
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
ENVIRONMENTAL iMf ACT STATEMENT
'A OCT281981
li
REGION IV - EPA
-------
LAW OFFICES
GUXLETT, SANFORD & ROBINSON
B. B. OULLETT
VALERIUS SANFORD
JACK W. ROBINSON
W. HAROLD BIGHAM
J.MURRAY MILLIKEN
ALLEN D. LENTZ
JOEL M. LEEMAN
JEAN NELSON
WESLEY D.TURNER
BARBARA J. MOSS
JEFFERSON H. OCKERMAN
THIRD FLOOR, HOME FEDERAL BUILDIN<
23O FOURTH AVENUE, NORT>
POST OFFICE Box 275:
NASHVILLE, TENNESSEE 372 it
TELEPHONE (615) 344-499*
October 29, 1981
John E. Hagan, III, P.E.
Chief, EIS Branch
U. S. Environmental Protection
Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Re: Sewanee, Tennessee Environmental Impact
Statement
Dear Mr. Hagan:.
This letter is on behalf of the Sisterhood of St. Mary,
Sewanee, Tennessee, whom we represent in connection with the
above matter.
For the reasons indicated below, our client is strongly
opposed to Proposal No. 7 contained in the recent study by
your agency of the wastewater problem in the community of
Sewanee. It is our understanding that comments on the various
proposals will be considered by your agency, and we are pleased
to have this opportunity to advise you of our client's reaction.
If Proposal No. 7 is followed (listed in your study as
Alternative No. 7) our client would be adversely affected. This
understandably concerns our client whose primary interest is the
continuation of its convent and retreat center in a manner and
atmosphere which is compatible with its purposes.
Among the reasons why Proposal No.
client are the following:
7 is unacceptable to our
The information concerning land ownership in the documenta-
tion is deceptive as it fails to reflect that land immediately
adjacent is already developed with privately owned residences in
-------
John E. Hagan, III, P.E.
October 29, 1981
Page Two
the drainage area of the lagoon and spray installations. A
pasture owned by our client, where cattle (which are raised
for food) graze, has a pond which would receive water from the
proposed well and spray areas. In general, the proximity of
the site proposed as No. 7 and the anticipated adverse effects
would not be compatible with our client's established program
at Sewanee.
Since there are obviously other alternatives to Proposal
No. 7, we respectfully request that Proposal No. 7 be rejected
and that attention then be given to more appropriate ways to
elminating the wastewater problem, particularly those which would
have less impact on the Sisterhood of St. Mary.
We shall appreciate your keeping us advised of any develop-
ments.
Yours very truly,
GUDLBTT, SANF063 & ROBINSON
JWR/jc
cc: Sisterhood of St. Mary
ENVIRONMENTAL IMPACT STATEME
BRANCH
(SSSBBJ
W 1,0V 02 1981
REGION IV
-------
DEPARTMENT OF THE ARMY
NASHVILLK DISTRICT, COUPS OF ENGINEER*
r. o. BOX IOTO
NASHVILLE. TENNESSEE 372O2
ORNED-P 2 9 OCT 1981
Mr. John E. Hagan III, PE Chief,
EIS Branch
EPA, Region IV
345 Courtland Street, HE
Atlanta, 6A 30365
Dear Mr* Hagan:
I received the Draft EIS Sewanee,. Tennessee, Wastewater Facilities, and submit
the following comments for your consideration:
a. The preferred alternative waste treatment system, Alternative 7, involves
replacing the existing STP with a combination storage pond/facultative lagoon
with pretreated effluent spray irrigated at sites approximately 3000 feet west
of the existing STP. Reference should be made to the holding capacity of the
system during winter freeze conditions and in the event that maintenance is
required.
b. Page II-7. Overland flow is considered unmanageable because of the
sloping terrain, however, some of the terrain is within the 9% slope limitation
according to Table A-2a.
c. Page II-19, 11-20. Table II-4 and II-5 footnotes refer to Table IV-4
for information on spray/sites. Table IV-4 lists cultural sites in the area.
d. Page III-3. Land Application Sites, paragraph 2, lines 3, 4, 5. Same
as b above.
e. Page IV. Reference to the detailed soil survey should be supplemented
by data indicating the suitability of the soils for spray irrigation.
f • Page IV. Odor, paragraph 3 was an aerobic lagoon considered? Aerators
could be added to reduce odor.
g. Page IV-1. Under NEPA Guidelines Section 1502.15, the experience of the
preparers should be included.
h. Page A-10. The table heading is Overland Flow Spray Irrigation, is this
correct?
I appreciate this opportunity for review and comment.
Sincerely,
ENVIRONMENTAL IMPACT STATEMEK
. C. MOORE
Chief. Engineering Division
<
U
NOVU21981
U
REGION IV - EPA
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
Southeast Region / Suite 1412 /Atlanta, Ga. 30303
Richard B. Russell Federal Building
75 Spring Street, S. W.
ER-81/1957 October 30, 1981
Mr. John E. Hagan, III, P.E.
Chief, EIS Branch
EPA, Region 4
245 Courtland Street, NE
Atlanta, Georgia 30365
Dear Sir:
We have reviewed the draft environmental statement for wastewater
facility at Sewanee, Franklin County, Tennessee, and have the
following comments.
General Comments
We suggest that the analysis of potential impacts of land application
by spray-irrigation methods should include more adequate consideration
of the fate of nitrates and any other constituents little affected by
traveling a short distance through soils. The type(s) of crops under
consideration for the irrigated areas should be assessed for their
nitrate uptake capacity, if this is fundamental to the plan. The fate
of effluent that reaches the resistent sandstone should be discussed;
presumably it would move downgradient along the top of the sandstone.
A map showing sufficient geologic detail to permit assessment of the
possibility of effluent seepage to drainage courses should be included.
A specific omission regarding endangered species has been noted and
the following related comments are recommended for inclusion in the
Department of the Interior's response. Although the DEIS addresses
endangered species, it does not address how Section 7 obligations
are being fulfilled. A list of endangered and threatened species were
provided to Claude Terry and Associates, Inc., by letter of January 12,
1981, with a copy to EPA, Atlanta, Georgia, pursuant to Section 7(c) of
the Endangered Species Act of 1973, as amended. Under the provisions
of Section 7(c), Federal agencies have 180 days to complete a biological
assessment for the species provided in the list furnished by the Fish
and Wildlife Service. To date the Fish and Wildlife Service has not
received a completed biological assessment or been advised as to
completion of the biological assessment. The January 12, 1981, letter
-------
provided an outline of Information that should be obtained In the
biological assessment. Once the biological assessment Is completed, the
Federal agency must determine If the proposed activities (alternatives
in the DEIS) may affect listed or proposed species and initiate consulta-
tion with the Area Manager, U.S. Fish and Wildlife Service, Asheville,
North Carolina, if a determination of "may affect" is made.
It should be pointed out that positive as well as adverse affects require
consultation. In reviewing the DEIS, a conclusion of beneficial "may
affect" seems to have been made regarding at least one mussel species,
thus indicating the need for initiating consultation.
Although the document includes an extensive listing of area historic
and cultural resources, there is no discussion of the significance of
the resources or the effect on the resources of the various alternatives.
We request that the State Historic Preservation Officer (SHPO) be
consulted concerning the survey for, and evaluation of, cultural resources
in the project area. A letter documenting that consultation should be
included in the final statement.
The proposed project will not adversely affect any existing, proposed,
or known potential units of the National Park System.
Specific Comments *
On page IV-54, the statement mentions that tentative main routes for
Alternatives 3 and 4 could result in negative impacts to historic
sites. Should either of these alternatives be selected, we suggest
close consultation with the SHPO to mitigate any negative impacts.
The St. Mary's spray site, utilized for the preferred alternative (7),
is adjacent to an existing Civil War overlook. We suggest close con-
sultation with the SHPO to minimize effect. The St. Mary's spray site
is also within 1 mile of the Barnes Branch of Lost Cove, an area listed
on page IV-33 as containing popular swimming holes. The statement
suggests that the wooded nature of the St. Mary's site will prevent
the-occurrence of airborne pathogens. We suggest that the area be
monitored to assure that airborne or water-carried pathogens do not
reach this adjacent recreation area.
Thank you for the opportunity to comment on this draft Environmental
Impact Statement.
Sincerely,
James H. Lee
Regional Environmental
BRANCH
MOV. 02 1981
-------
TENNESSEE
KARST RESEARCH
261 Cedarcreek Drive
Nashville, Tennessee 37211
(615) 834-2757
November 17, 1981
Mr. John E. Hagan III, P.E., Chief
EIS Branch
EPA, Region IV
3Uf> Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr* Hagan,
Please forgive the tardiness of my reply, but I found little of substance to
comment on in this well-prepared Environmental Impact Statement. We certainly
support the land treatment option for Sewanee.
One point of 'minor concern might be the disposal of potentially toxic materials
by the University of the South's chemistry and biology departments into lab
sinks. However, this should not have any effect on the chosen option.
Those areas of specific intrest to us, karst resources, were treated in an
unusually lucid and proffesional manner.
Thank you again for the opportunity to review this EISo
Sincerely yours, t
Brad Neff
Associate Director
-------
Chapter VIII
-LIST OF PREPARERS-
-------
fill. LIST OP PRBPAHBRS
Pro-iect Persoaael
The following is- a listing of those EPA officials responsible for
the evaluation of the Sewanee, TN EIS prior to its approval, and also
responsible for the scope and contents of the EIS.
Also listed below are the consultants responsible for preparation
of the EIS and background documents. included are their project
title, education and technical expertise.
Robert B. Howard
Eugene Baybuck
Ronald J. Hikulak
Chief, EIS Preparation Section
EIS Project Officer
EIS Project Officer
Consultants
id Cat
Thomas H. Bachford
B.S., 1964, Civil Engineering
M.S., 1966, Civil Engineering
Ph.D., 1972, Civil Engineering
ftichard B. Koch
B.A. , 1965, Political Science
H. B. P. f 1972, Regional
Planning
Lvnette J. Deuel
B.A., 1979, GeoenvironDental
Studies
Graduate Studies, 1980-1981,
Urban Planning/Environmental
Pollution Control
Andre DeGeorges
B.A., 1970, Biology
H.S., 1973, Fisheries/Agaatic
Biology
Jeffrey G. Iendie
B.S., 1971, Civil Engineering
Senior Project Hanager
Technical Specialties - Management,
Water Resources and Planning,
Environmental Engineering
Project Hanager
Technical Specialties - Management,
Environmental Planning, Public
Administration, Public Participa-
tion
Environmental Scientist
Technical Specialties - Environ-
mental Planning, Environmental
Science
Environmental Scientist
Technical Specialties - Aguatic
Biology, Fisheries, Environmental
Science
Project Engineer
Technical Specialties - Hater
VIII-1
-------
M.S., 1977, Environmental
Engineering
Harlot ha A. Kiaport
B,S.e 1976, Civil Engineering/
Engineering and Public Affairs
Graduate Studies, 1980-1981,
Civil Engineering
Resources Engineering, Facilities
Planning, Operator Training
Assistant Project Engineer
Technical Specialties - Hater
Resources Engineering, Computer
Modeling Applications
Claude terirr aad associates* IB.C.
Claude B. Terry
B.A., 1960, Biology
H.S., 1962, flierobioloqy
Ph.D., 1965, Hicrobiology
Robert J. Hunter
B.S., 1974, Biology
H.S.. 1978, Biology
Janes C. Hodges
B.S,, 1975, Biology
B.S., 1979, Biology
Thomas C. Rather
B.S-, 1978, Huaaa Ecology
Studies,
Two years. Environmental
Design
Anita ft. Patterson
B.S., 1970, Chemistry
H.l.T., 1973, Cheaistry
Louise B. Franklin
B. A. , 1961, History
H.A., 1977, City Planning
Project Executive
Technical Specialties - Hanageaent
Biology, Microbiology, Public
Participation
Project flanager
Technical Specialties - Hanageaenl
Biology
Environmental Scientist
Technical Specialty - Aquatic
Biology
Environmental Scientist
Technical Specialties - Ecology,
Botany, Environaental Design
Environaental Scientist
Technical Specialties - Water
and Vastewater Analysis,
Appropriate Energy Technology
Environaental Planner
Technical Specialties - Hanageaent
Environmental Planning, Energy
Management
CoaaoltMta
Soil Systeas, Inc.
525 letb industrial Drive
Marietta, GA 30062
Dr. HiIliaa E. Sopper
416 Oater Drive
State College, PA 16801
Soil Borings
Land Treataent Analysis
vm-2
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