EPA - 908/5-79-001B
FINAL ENVIRONMENTAL IMPACT STATEMENT
JACKSON WASTEWATER TREATMENT SYSTEM
TOWN OF JACKSON, WYOMING
PRO*60'
Prepared By
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
Approved
Alan Merson
Regional Administrator
Dates FEBRUARY 12, 1979
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DISCLAIMER
This report has been reviewed by the EPA, Region VIII, Water Division
and approved for publication. Mention of trade names or com-
mercial products does not constitute endorsement or recommenda-
tion for use.
DOCUMENT AVAILABILITY
This document Is available In limited quantities through the U.S.
Environmental Protection Agency, Environmental Evaluation Branch,
1860 Lincoln St., Denver, Colorado 80295. This document Is also
available to the public through the National Technical Information
Service, Springfield, Virginia, 22161.
This report 1s printed on 1002 recycled paper
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TABLE OF CONTENTS
PAGE NO.
I FINAL ENVIRONMENTAL IMPACT STATEMENT, 1
JACKSON WASTEWATER TREATMENT SYSTEM, TOWN
OF JACKSON, WYOMING
A. Type of Action 1
B. Brief Description of the Proposal 1
C. Lead Agency, Project Officer Contact and Address .... 2
D. Abstract of Proposed Action 2
E. Summary of Critical Issues 3
II PURPOSE AND NEED FOR THE PROPOSED ACTION 5
A. Town of Jackson Wastewater Needs 5
1. Overview of Existing System Flows 5
2. Other Point and Nonpoint Wastewater Contri-
butors in the Study Area 5
3. Water Quality Goals and Objectives 6
B. History of the Project and Decision Making 6
Process
III AFFECTED ENVIRONMENT 11
A. Physical Environment 11
1. Location, Physiography and Geology 11
and Visual Characteristics
2. Climate, Soils, Hazard Areas 11
B. Biological Environment
1. Vegetation, Wildlife and Fisheries 16
2. General Hydrology
3. Surface and Groundwater Quality
C. Human Environment 21
1. Land Use and Ownership 21
2. Population and Economic Base 21
3. Housing and Public Services and Utilities 26
4. Cultural Resources 29
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TABLE OF CONTENTS (CONT)
PAGE NO.
IV ALTERNATIVES AND PROPOSED ACTION 31
A. Description of Updated Alternative 31
1. Treatment 31
2. Interceptor Alignment 39
3. Major Environmental Considerations of 42
Alternatives
4. EPA's Preferred Alternative 46
V ENVIRONMENTAL CONSEQUENCES 48
A. Direct Effects of the Proposed Action 48
1. Impacts of the Proposed Action on Fish 48
and Wildlife
2. Water Quality Impacts 48
3. Air Quality and Odor 49
4. Economic Impacts 50
5. Affected Property Owners 52
6. Positions of Local Officials 53
7. Floodplain Hazards 54
8. Aesthetics and Scenic Problems 55
B. Indirect Effects of the Proposed Action 55
1. Growth Inducement and Land Use Changes 56
2. Impacts on Public Services and Utilities 58
3. Secondary Impacts on Local Water Quality 60
4. Indirect Effects on Air Quality 61
5. Fisheries and Wildlife Habitat Impacts 61
6. Effects on Major Development Proposals and 62
Other Federal, State and Local Programs
7. Indirect Commitments of Natural Resources 63
for the Proposed Action
C. Major Impacts of the Alternatives 63
1. Impacts of the Alternatives on Fish and 63
Wildlife Resources
2. Water Quality Impacts of the Alternatives 64
3. Air Quality and Odor 65
4. Aesthetics and Scenic Problems 66
5. Energy Utilization 66
6. Growth Inducement and Land Use Changes 67
7. Impacts on Public Services and Utilities 67
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TABLE OF CONTENTS (CONT)
PAGE NO.
VI LIST OF PREPARERS 69
VII REFERENCES 70
APPENDIX A. Tri-Party Agreement 72
APPENDIX B. Jackson, Wyoming Draft NPDES PERMIT 76
APPENDIX C. Coordination and Consultation 99
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LIST OF TABLES
TABLE
1
2
3
4
5
6
7
8
9
10
PAGE NO.
Summary of Climatic Data for
Jackson, Wyoming, 1931-1960
Flat Creek Water Quality Monitoring
Stream Profile, September 1975-June 1976
Summary of Groundwater Quality at the
Lower Bench Site
Population Data Summary and Projected
Growth Estimates; 1967-1995
Population Projects for Wastewater Facilities 25
Planning, Town of Jackson and Teton County,
Wyoming
Effluent Ammonia Concentration, Jackson Waste- 32
Water Treatment Plant
Alternative Treatment Cost Estimates, Town of 43
Jackson 201 Wastewater Facilities Plan
Alternative Interceptor Route Costs, Town of 44
Jackson 201 Wastewater Facilities Plan
Comparison of Direct Cost of Alternatives 51
Comments Received on Draft EIS
13
19
21
23
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LIST OF FIGURES
FIGURE
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
PAGE NO.
General Location Map 12
Alternative 1 - Aerated Lagoons/Rapid
Infiltration System at South Park Upper
Bench Site 34
Alternative 2 - Oxidation Ditch at South
Park Upper Bench Site 37
Alternative 3 - Aerated Lagoons/Rapid
Infiltration System at South Park
Lower Bench Site 35
Alternative 4 - Oxidation Ditch at South 38
Park Lower Bench Site
Interceptor Sewer Line 40
County Road Alternate Route
Interceptor Sewer Line 41
Flat Creek Alternate Route
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SOUTH PARK
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SECTION 1
FINAL ENVIRONMENTAL IMPACT STATEMENT
JACKSON WASTEWATER TREATMENT SYSTEM
TOWN OF JACKSON, WYOMING
( ) Draft EIS
(X) Final EIS
Prepared by the U.S. Environmental Protection Agency, Rocky Mountain
Prairie Region, Region VIII, Denver, Colorado, with assistance from
James M. Montgomery, Consulting Engineers, Inc., Boise, Idaho.
A. Type of Action: (X) Administrative
( ) Legislative
B. Brief Description of the Proposal
The Region VIII Administrator of the U.S. Environmental Protection Agency
(EPA) intends to approve Federal matching funds for wastewater treat-
ment facilities for the Town of Jackson, Wyoming, through Title II of
the Federal Water Pollution Control Act Amendments of 1972 (PL 92-500),
as amended in the Clean Water Act of 1977 (PL 95-217). Eligibility
requirements and procedures necessary to qualify for a grant are set
forth in 40 CFR,-Part 35, Construction Grants for Wgste Treatment Works,
The Federal share shall be 75 percent of the total cost found to be
eligible, with a portion of the facility being eligible for 85 percent
Federal Assistance as "innovative or alternative wastewater treatment
processes and techniques" referred to in Section 201(g)(5) of PL 95-217.
The purpose of the Final Environmental Impact Statement (EIS) is to pre-
sent an evalution of the primary and secondary environmental impacts of
those wastewater treatment alternatives to be analyzed as part of the
completion of the Jackson, Wyoming 201 Wastewater Facilities Plan Up-
date, completed by C.E. Maguire, Inc., in October, 1978. These alter-
natives include alternate interceptor rights-of-way, alternate plant
site locations, and alternate treatment techniques which include lagoons
and an oxidation ditch followed by either rapid infiltration basins or
discharge to the Snake River or Flat Creek. This additional evaluation
was necessitated by an EPA decision not to fund a previous alternative
recommended in the Facilities Plan, Jackson, Wyoming, 1974 Nelson, Haley
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Patterson & Quirk, Inc. (now C.E. Maguire, Inc.). This decision was
based on an analysis developed in the Draft Environmental Impact State-
ment Jackson Wastewater Treatment System, Town of Jackson, Wyoming, 1977,
prepared by EPA with assistance from James M. Montgomery, Consulting
Engineers, Inc. The analysis concluded that construction of an aerated
stabilization pond on the South Park Elk Feedground would pose legal
difficulties in land acquisition from the State of Wyoming, would ad-
versely affect the elk herd, was located in the 100-year floodplain,
would conflict with goals established by the Snake River Wild and Scenic
River Study, and ultimately result in widespread development of the
South Park area in direct conflict with the goals of the proposed master
plan.
The Final Environmental Impact Statement also includes responses to com-
ments on the draft EIS.
C. Lead Agency, Project Officer Contact and Address
The U.S. Environmental Protection Agency is the lead agency in a joint
effort with the Town of Jackson, Wyoming, and Teton County, Wyoming to
prepare the final EIS. Mr. Weston Wilson, U.S. Environmental Protection
Agency, Region VIII, is the designated Project Officer for the project.
Requests for free copies of the document should be addressed to:
Mr. Weston Wilson, Project Officer
U.S. Environmental Protection Agency
Rocky Mountain-Prairie Region
Suite 900, 1860 Lincoln Street
Denver, Colorado 80295
D. Abstract of the Proposed Action
The proposed alternative would involve construction of an aerated lagoon
treatment system with rapid infiltration as a means of final effluent
disposal. The lagoon/infiltration system would be located on approxi-
mately 50 acres of land at the Lower Bench site. The proposed alignment
for the interceptor route, would generally parallel Flat Creek southerly
for about four miles, to the Lower Bench Site (approximately 22,000 feet).
High groundwater conditions at the Lower Bench Site (distance to ground-
water ranges from 0.6 to 6.2 feet below the surface) would dictate that
embankment material for the lagoons and infiltration beds be excavated
from adjacent private land on the opposite side of Flat Creek. Due to
these conditions, EPA has determined that additional groundwater moni-
toring will be performed during May and June of 1979 to better define
flow rates and direction. The present land use at the lagoon site and
along the interceptor route is pasture and farmland.
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E. Summary of Critical Issues
Several key issues are involved in the implementation of the proposed
lagoon/rapid infiltration wastewater management alternative at the Lower
Bench Site. These issues range from potential surface and groundwater
degradation associated with the operation of an aerated lagoon/rapid
infiltration system at the site, to conflicting State statutues defining
interjurisdictional authorities and the effects of a subsequent sewer
tap-in agreement between EPA, the Town of Jackson, and Teton County on
the local growth rate and development patterns. The critical issues
are summarized as follows:
• Some contamination of surface and groundwater during construction
of the South Park Interceptor and proposed wastewater treatment
facilities due to increased sedimentation and erosion.
• Potential for increased nutrient levels in the groundwater and sur-
face water (Snake River and Flat Creek) systems downgradient from
the infiltration bed locations.
• Adverse visual and aesthetic impacts associated with a lagoon/infil-
tration system which would occupy between 40 and 50 acres of rural
undeveloped land at the Lower Bench Site.
• Attitudes of adjacent land owners concerning the proposed location
of the system.
• Conflicting State statutes concerning jurisdictional authorities
of towns, cities, and counties as related to property acquisition
for waste management facilities and planning and zoning in "areas
of impact."
• Potential impacts of developing priorities for an annual number of
out-of-city taps per year by Teton County on the County's Compre-
hensive Planned Implementation Program.
• Corresponding growth rate and development trends associated with the
tap-in policy.
• Potential for substantial public service and facilities investment
demands in the South Park area (i.e., schools, transportation,
police and fire protection, storm drainage) facilitated by central
sewer availability.
• Long-term impacts of suburban and urban level development in the
South Park area on local water quality and fish and wildlife
(primarily elk) populations.
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• Life expectancy of the proposed facilities in relationship to the
tap-in policy and its impact on the Teton County Comprehensive Plan
and Implementation Program.
These critical issues and/or areas of controversy, along with major
conclusions and issues to be resolved are discusssed in more detail in
later sections of this document. The Summary Final Environmental
Impact Statement, Jackson Wastewater Treatment System, Town of Jackson,
Wyoming also discusses these issues. This summary was prepared by
EPA as a separate document to encourage public review and comment.
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JACKSON'S EXISTING WASTEWATER
TREATMENT FACILITY
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SECTION II. PURPOSE AND NEED
FOR THE PROPOSED ACTION
A. TOWN OF JACKSON WASTEWATER NEEDS
1. Overview of Existing System Flows
The Town of Jackson municipal sewage treatment plant is the largest
wastewater facility in Teton County. The existing plant is located
south of the Town, and was constructed in 1969, for a peak design popu-
lation of 5,000. Excess summer infiltration, the addition of new ser-
vice areas, and the popularity of Jackson as a vacation resort resulted
in the facility exceeding design capacity in 1971. It is estimated that
the plant serves as many as 13,800 residents and seasonal visitors
during the summer months. Subsequent modifications to the plant (instal-
lation of sludge bed modifications and a mechanical aerator) as a result
of a 1973 study did not result in any significant improvement to the
operation or treatment efficiency of the system. A Step 1 201 facilities
plan developed by NHPQ in 1974 resulted in two significant actions which
included an EPA grant to study inflow/ infiltration problems of the
collection system (an estimated 850,000 gpd was attributed to infiltra-
tion) , and the Town Council's rejection of the consulting engineer's
recommended alternative. The draft EIS prepared for the project by EPA,
with assistance from James M. Montgomery, Consulting Engineers, Inc., in
1977 evaluated six potential sewage treatment plant sites. As a result
of the findings of the study and public meetings held on the draft EIS,
the decision was made by EPA not to fund the proposed project (an aerated
stabilization pond in the South Park Elk Feedground.
The plant is currently treating approximately 0.93 million gallons per
day (mgd). The facility serves about 95 percent of the developed land
within the Town limits, including restaurants, motels, schools, mixed
commercial, condominiums, trailers, single family residential and a
hospital. There are no major wastewater producing industries connected
to the system.
The Jackson, Wyoming 201 Wastewater Facilities Plan Update, (1978)
identified a 1995 design flow for an aerated lagoon/rapid infiltration
system of 2.65 mgd plus the capacity to treat an estimated 0.85 mgd of
uncorrected infiltration. The total hydraulic capacity for the treat-
ment facilities would be 3.5 mgd.
2. Other Point and Nonpoint Wastewater Contributors in the
Study Area
A number of point and nonpoint wastewater sources have also been identi-
fied by the Teton County 208 Water Quality Management Program (1977) as
potentially contributing to local water quality problems in the study
area. Existing water quality conditions in the Jackson study area are
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discussed in detail in Section 3 of this document. Potential pollution
sources are summarized as follows:
• Town of Jackson existing municipal sewage treatment plant.
• Stormwater runoff from the Town of Jackson and other high
density growth areas in the County.
• Irrigation diversion and return flows from the Gros Ventre
River.
• Numerous individual wastewater treatment systems (approxi-
mately 1/3 of the Teton County resident population is served
by these systems) which currently serve the rural and low
density developments in the County.
• Numerous grazing and agricultural activities throughout the
County.
• Natural and man-induced soil erosion.
3. Water Quality Goals and Objectives
The primary objective of the Federal Water Pollution Control Act Amend-
ments of 1972 (PL 92-500) as amended by the Clean Water Act of 1977
PI 95-217) is "to restore and maintain the chemical, physical, and
biological integrity of the Nation's waters." Consistent with this
objective, the Act provides where possible for the attainment of water
suitable for swimming and fishing by 1983. Section 201 of the act
provides funding for municipalities to plan, design and construct waste-
water facilities to achieve the objectives of the Act. Section 208
provides further federal assistance to develop areawide waste treatment
management plans to solve local water quality problems including both
point and nonpoint pollution sources.
In 1974, following a series of wastewater planning and design studies
and projects, the Town of Jackson received a Section 201 facilities
planning grant from the EPA to prepare a cost-effective, environmentally
sound program for the Town of Jackson and surrounding area. The primary
objective of the facilities planning effort, as identified in the
Facilities Plan, Town of Jackson, Wyoming (1974, was the "fulfillment of
effluent limitations accomplished through secondary treatment followed
by disinfection." Early in 1975, Teton County received a Section 208
water quality planning grant to prepare a comprehensive water quality
management program for the County. The goals and objectives outlined in
the plan were to identify the best technical and management plan alter-
natives necessary to meet the goals and objectives of PL 92-500; and to
meet instream water quality standards and wastewater treatment require-
ments established by the Wyoming Department of Environmental Quality.
Collectively, these goals and objectives form the basis for the Town of
Jackson 201 facilities planning effort.
B. HISTORY OF THE PROJECT, AND DECISION MAKING PROCESS
The history of the decision making process for the EIS, Town of Jackson,
Wyoming, wastewater treatment system, began in March, 1974, when EPA
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approved a grant to the Town authorizing the development of a wastewater
facilities plan for a new or expanded sewage treatment plant. The firm
of Nelson, Haley, Patterson and Quirk, Inc., (NHPQ) was retained by the
Town to develop this plan. Their initial studies indicated the need for
an extensive inflow and infiltration study to analyze sewer problems.
This study was subsequently authorized and funded by EPA.
In October, 1974 the facilities plan was completed by NHPQ. The plan
identified considerable infiltration/inflow problems, hydraulic over-
loading of the existing treatment facilities, and the need for expansion
of the facilities to handle increased flows due to additional resident
and tourist populations. The plan recommended as the most cost-effec-
tive alternative a mechanical treatment plant at the present plant site
at an approximate cost of $2.9 million. The third option involved
construction of a waste stabilization lagoon 4.5 miles south of the
Town, at an approximate cost of $1.8 million. The facilities plan
recognized several problems for these alternatives including the fact
that the location for the proposed alternative (upgrading the existing
plant) was directly in the path of the Town's current growth expansion.
Major consequences of the Boyle's Hill alternative included the require-
ment for additional high cost lift stations and pumping facilities to
serve future South Park development, and complications involving dis-
charge to the Snake River. The stabilization lagoon at South Park
involved the most Game and Fish property for the lagoons, effects on elk
populations (approximately 2,000 elk feed in the grounds during the
winter months), and secondary growth implications of extending an inter-
ceptor into the undeveloped South Park area.
After the Town of Jackson's November, 1974 hearing on the plan, and
largely due to EPA's notification to the Town that an EIS would be
required if the decision were made to locate the facility in the South
Park Elk Feedground, NHPQ was requested to reevaluate the comparative
costs of the treatment plant at the present site versus the Elk Feed-
ground alternative. A January 5, 1975 supplement to the facilities plan
by NHPQ concluded that the total cost of upgrading the existing treat-
ment plant was less expensive than the South Park lagoon.
On April 30, 1974, the Wyoming*Department of Environmental Quality,
(DEQ), issued a National Pollution Discharge Elimination System (NPDES)
permit to the Town of Jackson. Provisions of the permit included the
requirement that the Town submit a final wastewater facilities plan to
DEQ by September 30, 1975. On November 4, 1975, following delays in
submittal, the Town was issued a Notice of Violation requiring the plan
in 30 days. The Town's reply to DEQ indicated that the Town Council did
not concur with the recommended alternative of the' Facilities Plan, and
that the South Park Elk Feedground alternative had been selected by the
Council. This decision was based on the following criteria:
1) Lower operation and maintenance costs .of a lagoon system;
2) Ultimate unlimited service capacity of a plant located at the
South Park Elk Feedground site; and
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3) The Town Council's assumption that being public lands, the South
Park Elk Feedground site would be available for the Town's use
as the location for the selected lagoon treatment system alter-
native.
On January 30, 1976, following review of the facilities plan by EPA, the
decision was made to prepare an EIS on the selected alternative based on
anticipated public controversy and potential adverse environmental
impacts associated with the South Park Elk Feedground site. On July 23,
1976, EPA contracted the firm of James M. Montgomery, Consulting Engi-
neers, Inc., to assist the agency in preparing the EIS. A "Notice of
Intent to Prepare an EIS" was issued by EPA on August 26, 1976 and
mailed to all interested individuals and agencies.
As a result of the analysis developed in the draft EIS which concluded
that the South Park Elk Feedground option would pose serious legal
difficulties in acquiring the land in the .feedground and adversely
affect the elk herd; that the proposed site was located in the l(X)-Year
floodplain; and would conflict with the goals established by the Wild
and Scenic River Study; and that the proposal would "open up" the entire
rural South Park area to urban/suburban level development; the decision
was made by EPA not to fund the selected South Park Elk Feedground
option.
During the draft EIS process, it became apparent that although the major-
ity of the Town Council continued to support the South Park Elk Feed-
ground alternative, several council members and a number of Teton County
officials were concerned over potential growth impacts of locating the
treatment facility in Lower South Park. Town Council members in oppo-
sition to the selected alternative maintained the treatment facility
would become a County rather than Town of Jackson system. The County,
which was involved in a Section 208 Water Quality Management Study as
an element of a Comprehensive Plan and Implementation Program, did not
endorse the selected alternative due to the fact that the treatment plant
location and interceptor route were in direct conflict with the proposed
comprehensive plan goals and policies of supporting the retention of
the rural character and ranching economy, of Teton County; encouraging
compact urban growth with minimization of costs for public services
and facilities necessary to support new development; and directing
development out of areas subject to flooding and other natural hazards.
In addition, at a public workshop conducted by EPA during the EIS pro-
cess, a large majority of citizen participants rejected the proposal
stating reasons including adverse effects of development facilitated
by extending sewers into Lower South Park, reservations over lagoons
as a method of treatment, and impacts on the elk herd. A majority of
citizens polled preferred expansion of the existing Jackson treatment
plant.
Following the decision by EPA not to fund the South Park Elk Feedground
option, a majority decision was made by Jackson Town Council to locate
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the new sewage treatment plant at the South Park Road site. This deci-
sion was again challenged by two of the thr.ee Teton County Commissioners
who indicated their opposition to the proposed location. These com-
missioners maintained their position that a large treatment facility at
the South Park Road site would open South Park to widespread develop-
ment, and conflict with the goals and'policies of the proposed Teton
County Comprehensive Plan and Implementation Program. Two conflicting
State of Wyoming statutes concerning a town's authority to go beyond its
boundaries to acquire property for liquid waste facilities and County
authority to conduct planning and zoning and restrict land users out-
side city limits further complicated the situation.
The conflict continued through the summer of 1977. Those in opposition
to the South Park site favored expanding the existing treatment plant,
or construction of a new mechanical plant at Boyle's Hill contending
that the South Park location constituted a "government subsidy of
development." Proponents of the South Park site maintained that the
valley was going to develop regardless of where the plant was located.
They further noted that a central treatment and collection system was
preferable to individual septic tank systems, in terms of groundwater
protection and that the Comprehensive Plan and Implementation Program
would control growth in the area.
In early October, 1977, the EPA Regional Administrator met with the
Town's mayor and Council and the County Commissioners to discuss the im-
passe. After reviewing the various advantages and disadvantages of the
respective sites, a proposal for limiting the rate of new tap-ins out-
side the Town of Jackson and the Jackson Planned Expansion District was
made. Potential problems with this approach included legal implications
of preparing a contract that would bind a legislative body beyond its
term of office, and difficulties in obtaining easements under such a
plan.
On October 25, 1977, EPA notified the Mayor of Jackson that while it
preferred the alternative which included expansion of the existing
treatment facilities, the agency could approve a South Park site under
the following conditions developed jointly by the Town of Jackson and
Teton County:
1. New taps along the proposed interceptor line outside the Town
of Jackson should be approved by Teton County, or jointly by
the town and county.
2. The maximum number of residential units outside the Town
tapping into the line each year should be specified (allow-
ances for an increase each year should also be considered).
3. All residential units tapping into the proposed interceptor
should comply with the provisions of the Comprehensive Plan,
or at least be compatible with its provisions dealing with
physical environmental constraints (i.e., floodplains, steep
slopes, and high groundwater).
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4. The period of effect of these conditions must be specified
(i.e., ten, 20, or 40 years, life of the project, or life of
the interceptor).
5. The Town and County should enter into a contractual arrange-
ment with EPA, or develop another mechanism to assure that
conditions are binding, including a provision allowing any
citizen of Teton County to enforce these restrictions. The
restrictions agreed to by the Town of Jackson, Teton County,
and EPA could then be incorporated as grant conditions to the
Step III construction grant.
Initially, these conditions were not met favorably by either the Town or
the County. As a result, the firm of Biscoe, Murray, Maphis and Lamont
was hired by EPA ontDecember 14, 1977, to negotiate a settlement. The
proposed set of conditions developed by the mediator in the ensuing
months included a plant capacity based on a six (6) percent growth for
1995, and an "out-of-city" tap-in allocation of 51 equivalent taps per
year. Following a legal opinion from EPA on February 8, 1978 which
stated that such contractual arrangements were indeed binding, a subse-
quent meeting was scheduled in Washington, D.C. to sign the proposed
agreement. However, at the meeting a significant amendment was substi-
tuted to the agreement permitting Teton County to independently estab-
lish its own growth management policy as an element of the County's
Comprehensive Plan. The amendment stipulated that the tap-in rate be
determined no later than the date the treatment plant became operational.
On April 13, 1978, the agreement was signed and all parties conceded to
proceed with the updated facilities plan considering only alternative
locations near the proposed South Park Road site. A copy of the agree-
ment is included as Appendix A. C.E. Maguire, Inc., (formerly NHPQ) was
selected to update the plan. Due to difficulties in construction of an
outfall line to the Snake River that would remain hidden (a probable
requirement of the Wild and Scenic River Study identified in the draft
EIS), it was decided to investigate a non-discharging lagoon/rapid
infiltration land application system. Also, because land costs are
extremely high in the area, the decision was made to consider the option
of constructing a mechanical plant (oxidation ditch) in order to reduce
these costs and land requirements.
On September 11, 1978, the facilities plan alternatives were presented
to the Jackson Town Council, at which time agreement was reached that
the South Park Lower Bench site with an aerated lagoon/rapid infil-
tration system should be the recommended plan. Formal approval of the
recommended plan was received from the Town of Jackson by C.E. Maguire,
Inc., on September 29, 1978.
In late October, 1978, the draft Jackson, Wyoming 201 Wastewater Facil-
ities Plan Update was completed by C.E. Maguire, Inc. The following
sections of this document present an evaluation of the primary and
secondary environmental impacts of the wastewater treatment alternatives
analyzed m the Facilities Plan Update. The document also presents the
response to comments received and issues raised in the draft EIS.
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SOUTH PARK
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SECTION III. AFFECTED ENVIRONMENT
A, PHYSICAL ENVIRONMENT
1. Location, Physiography and Geology and Visual Characteristics
The Town of Jackson is located in Teton County, Wyoming, east of the
Idaho-Wyoming border in a valley generally known since the days of the
early trappers as Jackson Hole (Figure 1). Teton County includes
approximately 2,873 square miles of land area. The area is character-
ized by spectacular scenery including the Teton Mountains, numerous
morain lakes and the Snake River floodplain.
The physiography of Teton County is the result of relatively recent
geologic processes. Jackson Hole is a north-south oriented basin formed
by fault movements. Glaciers sculpted the "hole," with most of the
valley floor formed by deposition of gravel along the Snake River. For
a more detailed description of the physiography and geology of the area,
the interested reader is referred to Creation of The Teton County Land-
scape (Love and Reed, 1971), and Teton County Growth And Development
Alternatives (Livingston and Associates, 1976).
The County is rich in scenic resources. To assist in the preservation
of these resources, the Teton County Comprehensive Plan and Implementa-
tion Program (1977) was developed to include a Scenic Preservation
Element. Legislation to create the Jackson Hole Scenic Area was also
introduced to the 95th Congress. This legislation would provide funds
(up to $200 million) to purchase easements on the most scenic private
lands in the valley. The bill was modified late m the session to study
priority land acquisition areas, and will be re-introduced in the next
session.
2. Climate, Soils, Hazard Areas
Climate in the Jackson study area is characterized by comparatively
harsh, long winters and cool, dry and short summers. Climatic condi-
tions are predominantly influenced by the Teton Mountain Range (ele-
vations of 7,000-13,000 feet). Precipitation in the mountain areas may
exceed 70 inches annually.
The elevation at the Town of Jackson is approximately 6,244 feet. Mean
monthly temperature and precipitation data is summarized in Table 1.
The average annual precipitation at Jackson is 14.83 inches.
Precipitation is highest during the winter months of December through
February, and the spring months of May and June. The mean annual tem-
perature is 34.2°. July is the warmest month with temperatures averaging
60.9°F. January is the coldest month with temperatures averaging 14.2°F.
The length of growing season in the Jackson area is approximately 186 days.
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Table 1. Summary of Selected Climatic Data for
Jackson, Wyoming, 1931-1960*^
Mean Temp.
Month °F
January 14.2
February 18.2
March 26.1
April 38.4
May 46.8
June 54.0
July 60.9
August 59.0
September 51.5
October 41.8
November 26.9
December 18.1
^Source: Lower Valley
Precipitation
(Inches)
Mean Mean Snowfall
1.43
15.7
1.32
15.2
1.20
11.7
1.20
4.0
1. 50
1.2
1.51
Trace
0.75
0.0
1.12
0.0
1.04
0.5
1.11
2.1
1.11
9.2
1.54
16.0
and Light, Inc., 1974.
13
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Average relative humidity ranges from 55 percent to 60 percent. Wind
directions are variable, but predominantly blow from the southwest.
Air quality, which is described in more detail in the Draft Environmental
Impact Statement, Jackson Wastewater Treatment System, Town of Jackson,
Wyoming, (Draft EIS Jackson Wastewater Treatment System)(EPA, 1977), is
determined by local topography and meteorological conditions. Air qual-
ity is generally good, although monitoring data for the area is limited.
However, Jackson Hole is subject to frequent inversions which affect the
dispersion of particulates. Compliance with state standards will un-
doubtedly require that reasonable precautions are taken during the
construction phases of the project to prevent dust from becoming air-
borne. The major odor problem in the area is associated with the exist-
ing wastewater treatment facilities during the warmer months of the
year.
Soil types in the study area are diverse, and related closely to the
geologic processes that form them. For the purposes of this discussion,
soils of the valley floor and adjacent uplands are of three general
types based on their geologic origin. Glacial outwash soils occur
extensively throughout the valley and are characterized by large cobbles
and generally coarse soils. Soils formed on glacial moraines are also
common throughout the valley, consisting of finer textured outwash
materials. Coarse to fine textured alluvial and loess soils are present
along all of the main tributary streams in the valley. The mountair?
areas are formed from hard sedimentary parent materials.
Development constraints associated with soils conditions have been
identified for much of the study area by Livingston and Associates
(1976). These constraints are based on vulnerability to erosion, suit-
ability for septic tanks, value for agricultural production, and poten-
tial for revegetation.
Physical hazards which exist in the study area are generally of four
types and include: 1) fault zones and seismic risk; 2) slope stability,
3) high groundwater problems; and 4) flooding. Many of the land areas
have more than one of these hazards.
Fault Zones and Seismic Risk
The Jackson area is considered among the most active seismic areas in
the United States. A number of active and inactive faults criss-cross
the valley floor. According to the National Oceanic and Atmospheric
Administration (1978), 28 earthquakes of a magnitude of V or greater on
the Modified Mercalli Scale have occurred in the past 70 years. Informa-
tion on general fault locations for the area has been compiled by Leopold
and Twiss (1976). Major fault zones (zone widths over 1,000 feet) are
identified in the Draft EIS, Jackson Wastewater Treatment System (EPA,
1977). Of particular interest in the Jackson, Wyoming 201 Wastewater
Facilities Plan Update (C.E. Maguire, 1978) is the Flat Creek Fault
which runs in a southwesterly direction along the Flat Creek floodplam
through the Town of Jackson, south to the Snake River.
14
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Slope Stability
Rock falls and avalanching occur frequently throughout the study area on
slopes steeper than 30 percent. Examples of this geologic activity
include portions of the Boyle's Hill area southwest of the Town of
Jackson, and the bench area east of Flat Creek. Many naturally unstable
slopes also exist along the east flank of the Snake River below South
Park. Slope hazard information for the Jackson area has been mapped by
Haible (1976), and is shown in the Draft EIS, Jackson Wastewater Treat-
ment System (EPA, 1977) . These areas are generally not suitable for any
land use which disturbs vegetation, soil, or the natural drainage sys-
tem.
High Groundwater
Groundwater hazard areas in the Jackson study area occur generally in
the lowlands south of the Town. These hazards take the form of poorly-
drained soils with groundwater levels less than five feet below the
ground surface. Saturated or near-saturated soil conditions within and
adjacent to the Flat Creek and Snake River have created some water
quality problems due to malfunctioning septic tanks. It has been esti-
mated that individual waste disposal systems currently service more than
one third of the County's population. Groundwater conditions have been
mapped by Haible (1976) utililizing soils data from the U.S. Soil Con-
servation Service. This information is periodically updated as an
element of the Teton County Comprehensive Plan and Implementation Pro-
gram, 1977.
Flooding
The Snake River dominates the western portion of the Jackson study area.
Much of this land area adjacent to the river has been designated within
the boundaries of 100-year floodplain of the Snake River by the U.S.
Army Corps of Engineers (Corps, 1976). Boundaries of the 100 and 500-
year floodplams for the Snake River are also identified in the Draft
EIS, Jackson Wastewater Treatment System (EPA, 1977) . Portions of Flat
Creek are also subject to less frequent, but periodic winter flooding
caused by ice blockages. Flood hazard constraints through much of the
study area limit development potential. These limitations are defined
in the Teton County Comprehensive Plan and Implementation Program, 1977.
Executive Order 11988 (issued May 24, 1977) also directs Federal Agen-
cies to "avoid direct and indirect support of floodplain development
wherever there is a practicable alternative." Requirements of the
National Flood Insurance Program, and EPA Flood Insurance Requirements
(PRM-77-1) further define pertinent floodplain development requirements.
15
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B. BIOLOGICAL ENVIRONMENT
1. Vegetation, Wildlife and Fisheries
Vegetation in the Jackson study area is mainly of the Great Basin and
Rocky Mountain transition zone. The predominant species in the valley
floor are the big sagebrush (Artemesia tridentata) and crested wheat-
grass (Ayropyron spicatum). Bush willows (Salix lasiandra) and alders
(alnus tenuifolia) are prevalent along the Snake River and Flat Creek
flood plains. Mixed stands of conifer and aspen characterize the lower
upland areas. Lodgepole pine (Pinus contorta) and Douglas fir
(Pseudotsuga menziesii) are the predominant forest type.
A comprehensive listing of plant types of the Jackson Hole area can be
found in Plants of Yellowstone and Grand Teton National Parks (Shaw,
1974). A more detailed discussion of vegetation and watershed protec-
tion is included in the Draft EIS, Jackson Wastewater Treatment System
(EPA, 1977).
Wildlife in the study area are numerous and diverse. The area provides
important habitat and migration routes and feeding areas for a number of
animal species. Major big game species include elk, moose, and deer.
Black bear, bobcat and mountain lion are also present in the area.
Smaller species include beaver, otter, racoon, marmot, chipmunk, ground
squirrel, and skunk.
The National Elk Refuge and the South Park Elk Feedground are particu-
larly important to the local economy. The National Elk Refuge, which
was established in 1911, winters over 8,000-10,000 head of elk each
year. In 1939, an additional 636 acres of land in Lower South Park was
established by the Wyoming Game and Fish Commission for maintenance of
an additional 800-1,000 head of elk. A proposal to locate the Town of
Jackson wastewater treatment plant on 20 acres of land inside the Feed-
ground was dismissed by the EPA as a result of the findings of the Draft
EIS, Jackson Wastewater Treatment System (EPA, 1977).
Numerous bird species inhabit or migrate through the region. Geese, and
a variety of ducks and wading birds inhabit the area. Raptors including
asprey, bald eagle, peregrine falcon, and other more common hawks and
falcons are also prevalent. Other birds include mourning doves, owls,
sparrows, numerous songbirds, magpies and raven.
Both Flat Creek and the Snake River (through the study area) support an
active, self-sustaining cold water fishery. Although the Wyoming Depart-
ment of Game and Fish has done only a limited amount of studies on Flat
Creek, according to the Department the stream does support a fair cut-
throat population. The Snake River is considered a trophy stream for
the Snake River cutthroat species. Other important species include
rainbow and eastern brook trout, and whitefish.
16
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No threatened or endangered plant species have been observed in the
study area. According to the U. S. Fish and Wildlife Service, two rare
or endangered species may be found as either transient or resident in
the South Park area. These species include the American peregrine
falcon and the blackfoot ferret. Both the Canadian lynx and wolverine,
which are considered threatened in the western United States, have also
been observed in the undeveloped areas of South Park. A number of fish
species have been identified as warranting special preservation consid-
eration (Lower Valley Power and Light, 1974). Probably the most impor-
tant in terms of the existing sport fishery is the Snake River cutthroat
trout.
2. General Hydrology
The Snake River Basin encompasses approximately 5,139 square miles in
western Wyoming (DEQ, 1976). This area includes all of Teton County, a
sizeable region in Lincoln County, and small portions of Sublette and
Fremont Counties. Part of Yellowstone National Park and all of Grand
Teton National Park lie within the Snake River drainage. The area is
the only portion of Wyoming which drains to the Columbia River system.
Most of the streams in the Jackson area originate in the uplands sur-
rounding Jackson Hole and flow to the Snake River. Major tributaries to
the Snake River in terms of discharge by downstream order include:
Pacific Creek, Buffalo Fork, Cottonwood Creek, Gros Ventre River, Fish
Creek, Flat Creek, and Hobach River.
Approximately 4,632,500 acre-feet of surface water flow drains from the
Snake River Basin annaully (WDEQ, 1976). Major water users include
irrigation, the timber industry, and municipal. For a more detailed
description of the water resources, and streamflow characteristics of
the Snake River Basin, the interested reader is referred to Water Re-
sources of Northwestern Wyoming (USGS, 1974), and Discharge Measurements
and Chemical Analysis of Water in Northwestern Wyoming (USGS, 1975).
4. Surface and Groundwater Quality
The assessment of current water quality conditions in the Jackson study
area, and the evaluation of wastewater treatment alternatives, is depen-
dent on the classification of specific waters according to downstream
use classification. The existing water quality standards for the State
of Wyoming are described in Chapter 1 of the Wyoming Water Quality Rules
and Regulations revised in June, 1978. These regulations, which are
discussed in more detail in the Draft EIS, Jackson Wastewater Treatment
System (EPA, 1977), define three principal water use classes based upon
nondegradation and the stream's ability to support fish species.
Class I waters have the most restrictive standards, with no further de-
gradation by point sources allowed. Class II water's restrictions are
based on the ability to support game fish; with Class III waters require-
ments being less restrictive. For the purposes of this discussion,
major attention is given to describing water quality conditions in Flat
17
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Creek and the Snake River. These two water courses will be directly
affected by wastewater treatment alternatives developed for the Town of
Jackson.
A majority of the major watercourses in Teton County, including Flat
Creek and the Snake River below Wilson, are designated as Class II
streams. The Snake River from the Wilson Bridge to the head waters,
Fish Creek, and all waters within Teton National Park are presently des-
ignated as Class I waters. Flat Creek, which originates in the Gros
Ventre Range, has been identified as the "most critical stream segment
in the Snake River Basin in terms of possible impairment of water qual-
ity" (DEQ, 1976). Flat Creek water quality is generally good above the
Jackson Hole National Fish Hatchery. Below the hatchery, the stream is
impacted by a number of point and nonpomt sources including stormwater
runoff, discharge from the Town of Jackson sewage treatment plant and
agricultural activities (Teton County 208 Planning Agency, 1977).
Flat Creek
Table 2 summarizes Flat Creek water quality. From the profile informa-
tion, the general trend appears to be a deterioration m water quality
downstream from the National Fish Hatchery. Temperature ranges from a
mean value of 5.0°C at the hatchery, to 6.3°C at the South Park Bridge
below the treatment plant. D.O. concentrations demonstrate a corre-
sponding trend, with values highest at the upstream sites and gradually
decreasing as the stream approaches the more highly developed "urban"
areas. BOD elevates below the Jackson treatment.plant, indicative of
the wastewater effluent discharge. A maximum BOD of 3.2 was measured at
the sampling station below the treatment plant during the month of
March, 1976. Ortho-phosphate and nitrate levels show substantial in-
creases below the plant, with mean levels of 0.012 mg/1 ortho-phosphate
and 0.044 mg/1 nitrate observed at the two downstream sites. These
phosphate levels are well above the concentrations capable of promoting
algal blooms. Fecal coliform counts showed the most significant indica-
tion of water quality degradation, with mean values at the two lower
sites of 440/100 ml and 231/100 ml recorded. These values do not include
several TNTC recordings. Results of a November, 1975 monitoring program
for Flat Creek showed similar trends. This study is discussed in more
detail in the Draft EIS, Jackson Wastewater Treatment System, (EPA, 1977).
The Wyoming Department of Environmental Quality (DEQ) maintains a
monitoring station on the Snake River above the Flat Creek confluence.
Information for the station summarized in the Draft EIS, Jackson Waste-
water Treatment System, (EPA, 1977) for the period November, 1973 -
November, 1975, indicates water quality is excellent. Dissolved oxygen
concentrations are high, ranging from 8.0 to 13.2 mg/1. Turbidity
levels are low. Nitrate and phosphate concentrations are also relatively
low, with mean levels of 0.20 and 0.04, respectively, reported for the
sampling period. Fecal coliform counts ranging from no colonies ob-
served, to 172 colonies/100 ml were also reported. The present State of
18
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Table 2
Flat Creek Water Quality Monitoring Stream Profile
September, 1975 - June, 1976
Water Quality Monitoring Parameters/Mean Values
Sampling Temp. D.O. pH BOD TSS Ortho- NO.J-N
Station °C (mg/1) (mg/1) P(mg/1) (mg/1)
Fecal Coliform
#/100 ml
F3-Flat Creek,
at National
Fish Hatchery
5.0
9.4
7.8
1.6 7.3
0.006
0.022
F6-Flat Creek,
North of Jackson
at Highway 26
Bridge
5.0
9.0
7.9
2.0 6.9
0.007
.030
130
2/
F7-Flat Creek,
South of Jackson
at South Park
Road Bridge.
6.3
9.5
8.1
2.8 30.5
0.012
.047
440
2/
F8-Flat Creek,
North of Snake
River Con-
fluence
6.2 9.2(8.1)3/ 7.9(33) 2.4 23.7 0.044(0.26 .064(0.01) 231
2/
^Source: Teton County 208 staff, 1977.
2/
Does not include TNTC recorded counts.
"^Levels shown in () are from a recent September 27, 1978,
sampling by C.E.-Maguire, Inc.
-------
Wyoming fecal coliform standard for the Snake River (Wyoming-Idaho
stateline, upstream to the south boundary of Yellowstone Park) is 200
fecal coliform groups/100 milliliters during the recreation season
(May 1 to September 30), based on a minimum of not less than five samples
obtained during separate 24-hour periods for any 30-day period. Subse-
quent monitoring at the site by the Teton County 208 Agency in 1976
further substantiates these findings.
Below the confluence with Flat Creek, water quality conditions in the
Snake River deteriorate due to discharge from the Jackson treatment
plant, agricultural activities, and numerous nonpomt source sediment-
producing activities. A number of violations in the fecal coliform
standard have been recorded. A more detailed discussion of these activ-
ities is presented in the Teton County Water Quality Management Program
(Teton County 208 Planning Agency, 1977). This study includes recom-
mendations concerning minimum flow requirements, irrigation diversions,
additional monitoring needs, and instream phosphorus limitations criteria
for the Snake River. These recommendations, and wastewater management
options considered by the Town of Jackson and Teton County are particu-
larly important with respect to the potential for increased eutrophica-
tion at Palisades Reservoir. Until more water quality data is obtained,
the 208 Plan has recommended a maximum allowable in-stream phosphorus
criteria of 0.1 mg/1 for all surface waters in Teton County. This cri-
teria is designed to serve as a guideline for establishing discharge
permit limitations and developing best management practices for the
control of nonpoint pollution sources.
The primary sources of groundwater in the Jackson study area are precip-
itation and infiltration from surface streams, irrigation drains and
lakes. The depth to groundwater varies from zero in marshland areas to
nearly 200 feet along the Gros Ventre Range front. Depth to groundwater
is also dramatically affected by Snake River streamflow.
Groundwater quality throughout the study area is good. Quality is
affected by the chemistry of nearby streams. Groundwater is generally
of the calcium bicarbonate type and moderately to very hard. Chloride,
fluoride and nitrate levels are low in comparison to drinking water
standards.
Table 3 summarizes groundwater quality monitoring performed at the
proposed Lower Bench site during the summer of 1978. Depth to ground-
water at the site varied from 0.64 to 6.81 feet depending on the loca-
tion of the test wells. From this information, it can be seen that
quality is generally good. Total dissolved solids, mercury, and nitrate
levels are well below the established drinking water standards. How-
ever, maximum BOD levels of 48.0 (Site A, NW well) were relatively high
for groundwater. Similarly, mean recorded phosphate concentrations were
above levels known to accelerate algal growth and eutrophication (the
maximum recorded concentration was 0.52 mg/1). Coliform concentrations
were not measured during this sampling.
20
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Table 3 . Summary of Groundwater Quality at the Lower Bench Site
August 24, 1978*/'
Parameters
Mean Level Observed
(mg/1)
Recommended U.S.
Public Health Service
Drinking Water
Standards (mg/1)
TDS
278
500
Tot. Alk.(CaCO^)
250
Tot. Hard.
259
Chloride
5.3
250
Fluoride
0.36
1.7-2.4
Iron
0.93
0.30
Nitrate(as N)
Mercury
0.07
ND
2/
10
0.005
Phosphate (PO^)
0.18
0.10
BOD, 5-day
30
1/
i
2/,
C.E. Maguire, Inc., 1978
N.D. - Not detected.
21
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C. HUMAN ENVIRONMENT
1. Land Use and Ownership
Teton County is a sparsely settled land area which includes approximately
2,873 square miles. The County contains some 1,838,720 acres of land;
1,795,328 of which are land surface, and 43,392 acres of water area
(EPA, 1977) . Approximately 97 percent of the County is federally owned.
The U.S. Forest Service and U.S. Park Service administer the majority of
this land (1.74 million acres). About 75,000 acres are privately owned.
In 1969, there were approximately 64,403 acres of farmland in the County.
However, since 1969 the general trend has been toward increasing urbani-
zation. In 1976, it is estimated that some 55,483 acres were in agri-
cultural use (WRRI, 1977). The four basic categories of land develop-
ment in Teton County can be summarized as relatively urbanized areas
around the Town of Jackson and Moose; mixed urban/agricultural areas of
Alta and Wilson; predominant agricultural and rural residential areas
like those in South Park; and scattered commercial uses at highway
junctions and strip commercial development along highway frontage.
\
Most of the land area located within the present Jackson town limits has
been developed for residential, visitor and retail/service commercial,
and light industrial uses (approximately 1,160 acres). An additional
approximately 9,400 acres of land located primarily south of Town in
South Park, which would be affected by the location and size of waste-
water treatment facilities being planned for Jackson, are primarily
ruralundeveloped or used for agricultural purposes, with sparse resi-
dential development along the main transportation routes. The site pro-
posed for location of the treatment facilities (Lower Bench site) is
privately owned. The owner has indicated the site (approximately 40
acres) will be dedicated to the Town of Jackson for the treatment plant.
2. Population and Economic Base
Reliable population forecasts for Teton County and the Town of Jackson
are extremely difficult to make. Both the County and Town have high
rates of migration, substantial seasonal and part-time employment, and
significant numbers of seasonal and part-time residents.
Historically, the Town of Jackson population has shown a steady increase
since 1940. During the last seven years, the population has increased
at an annual rate of six (6) per cent, from approximately 3,196 to 4,505
(1977).
Figures prepared by Livingston and Associates (1976) as part of the
development of the overall Teton County Growth and Development Alterna-
tives projected the County would experience a minimum three (3) percent
growth annually through 1990, while the maximum growth would probably go
no higher than five (5) percent annually. These projections, along with
historic Teton County and State of Wyoming population data, are summa-
rized in Table 4.
22
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TABLE 4_ POPULATION DATA SUMMARY
AND PROJECTED GROWTH ESTIMATES, 1967-1995 ^
Year Teton County State of Wyoming
1967 4,295 331,711
1968 4,471 331,946
1969 4,647 332,181
1970 4,823 332,416
1971 5,1'50 339,278
1972 5,475 346,139
1973 5,800 353,000
1974 6,400 359,000
1975 7,000 365,861
1976 7,500
@ 3% Growth @ 5% Growth
1978 7,956 8,268
1980 8,441 9,116
1985 9,785 11,634
1990 11,344 14,849
1995 13,046 18,561
1/Source: Water Resources Research Institute, University
of Wyoming, 1977.
23
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For the purposes of projecting future wastewater needs for the Town of
Jackson, a six (6) percent annual growth rate was used in the Draft
EIS, Jackson Wastewater Treatment System, (EPA, 1977). These projections
are presented in Table 5. This figure was used primarily because it was
necessary, for facilities planning purposes, to determine the maximum
seasonable population that could be expected in the 20-year planning
period. These projections show a 1995 Town of Jackson population of
12,857. For the purposes of wastewater planning and cost estimating,
this figure represents the adopted 1995 population for the facilities
service area.
Projections for Teton County shown in Table 5 were revised during the
preparation of the final EIS. These revisions were made using a five
(5) percent growth rate. The five (5) percent figure was adapted up-
ward, based on the following assumptions:
• A primary consideration in developing population forecasts for
the Jackson service area is the availability of developable
land, as identified in existing or proposed land use plans.
• The majority of development that takes place in Teton County
during the facilities planning period (1977-1995) will occur
within an area that could be served by central sewer, given
the proposed South Park Lower Bench site for the treatment
plant.
• With the removal of a primary constraint to development in the
South Park area (i.e., wastewater treatment facilities), the
growth rate for the Town of Jackson and the rest of the area
which could conceivably be served by central sewer will exceed
the maximum rate projected by Livingston.
• The proposed expansion of Teton Village described in the
Jackson Hole Ski Area Master Plan, coupled with the availabil-
ity of improved sewer facilities at Jackson, will result in
additional development pressures in the Town and the South
Park area associated with the required for support personnel
housing.
Using this set of assumptions, the 1995 Teton County population is
expected to be approximately 18,953. This figure is probably reason-
able, given the fact that existing Teton Village hotel-motel facilities
which currently accomodate 2,612 persons are programmed for expansion to
handle a population of 8,452 by 1992 (Jackson Hole Ski Corp, U.S.F.S.;
1978). Although expansion of Jackson Hole Ski Area will not directly
affect the Town of Jackson wastewater treatment facilities, some pres-
sure to supply support housing will undoubtedly occur in the Jackson
area. These estimates also appear to be in line with the growth rate
experienced during the ten-year period 1960 to 1970, when the Teton
County annual rate averaged ]ust over six (6) percent (WRRI, 1977).
It should be emphasized, however, that reliable figures for Teton
County have been difficult to obtain in the past due to the dynamic and
24
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TABLE _5 POPULATION PROJECTIONS FOR
WASTEWATER FACILITIES PLANNING, TOWN OF JACKSON
AND TETON COUNTY, WYOMING 1/
Town of Jackson 2/
Year @ 6% Teton County @ 5%
1977
4,505
7,875
1978
4,775
8,268
1979
5,062
8,682
1980
5,365
9,116
1981
5,687
9,572
1982
6,028
10,050
1983
6,390
10,553
1984
6,773
11,080
1985
7,180
11,634
1986
7,610
12,216
1987
8,064
12,827
1988
8,552
13,468
1989
9,065
14,142
1990
9,608
14,849
1991
10,184
15,591
1992
10,796
16,371
1993
11,443
17,190
1994
12,129
, 18,050
1995
12,857
18,953
1/ Source: James M. Montgomery, Consulting Engineers, Inc.
2/ This projection includes future population that would
reside on the fringe areas of Jackson, generally
within the one (1) mile jurisdictional area.
25
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seasonal nature of the area, and the many outside factors which can
dramatically affect the tourism industry (i.e., national economy, weather,
energy availability, etc.). A number of variables including decisions
by the Town or County to increase treatment plant capacities for the
Town of Jackson facility over the proposed 3.5 mgd capacity, or relax
out-of-city tap-in requirements could have major impacts on population
growth in the area.
The Draft EIS, Jackson Wastewater Treatment System, ("EPA, 1977) identi-
fied a non-resident full over-night capacity of 9,600 individuals for
the year 1976. The projected 1995 peak non-resident population shown in
the document was 13,985. These forecasts were based upon the 1976
contribution this segment of the population had on the amount of waste-
water generated, and not estimates of actual people in the Town. These
forecasts are factored into the 1995 projected design flow for the
wastewater system.
General population characteristics in Teton County are similar to those
for the rest of the state. There are slightly more persons in the 25 to
44 age bracket, and slightly fewer in the 55 and over age categories
(WRRI, 1977). Only 39.6 percent of the persons living in the County
are Wyoming natives.
The economic base of Teton County focuses on tourism. In both 1970 and
1974, services employment accounted for approximately 40 percent of the
total County employment. Services include hotels, motels, personal ser-
vices, automobile services, amusement and recreation and other miscella-
neous services. Related wholesale and retail trade accounted for an
additional 24 percent of the local employment. Services also accounted
for the largest percent of personal income for County residents (approxi-
mately $9,049,000) in 1974. Wholesale and retail trade produced approxi-
mately $6,025,000 in earnings. Government and construction accounted
for $9,315,000; while agricultural earnings totaled $1,431,000 (WRRI,
1977).
Of the service category, accomodations (hotel, motels, trailer parks and
campgrounds) was the leader in the total County receipts, with receipts
totaling over $11 million. Approximately 85 of these types of establish-
ments generated the income. Amusement and recreation brought in about
$2 million to the local economy.
During the past ten years (1967-1977), tourism (number of Jackson Hole
visitor days) has increased substantially. Annual park visitation and
skier days increased 4.16 and 11.6 percent, respectively (TCGSC, 1978).
This situation is an important consideration in determining non-resident
populations and associated wastewater requirements for the Jackson area.
The per capita income of people living in Teton County is substantially
higher than the State average (up to 37 percent higher). In 1973, for
example, the per capita income for the County was $6,422, as compared to
$4,696 for the State of Wyoming. This difference is attributed in part
26
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to a greater number of individuals residing in the County with incomes
exceeding $25,000.
Revenue for operating Teton County comes from five principal sources
which include revenue-sharing funds, property tax levies, gasoline tax
levies, gasoline tax receipts, sales and use tax receipts, and other
sources of revenue. In FY 1975-76, the other category (licenses, ciga-
rette and liquor taxes, etc) accounted for 41 percent of the County's
revenue, (approximately $600,000) sales and use tax 32 percent ($467,000),
property tax 12 percent ($175,000), gasoline tax nine percent ($130,000),
and revenue sharing six percent ($85,000). The total operating budget
for Teton County during this year was approximately $1.5 million.
Historically, Teton County has received a higher amount of their total
revenue from the sales and use tax category and less from the property
tax category, and as opposed to the state as a whole. It is estimated
that over 55 percent of the total sales in the County are attributed to
tourism ($25 million in sales in 1976). For a more detailed discussion
of the Teton County economy, the interested reader is referred to Teton
County and the Proposed Comprehensive Plan and Implementation Program;
An Economic Analysis (WRRI, 1977).
3. Housing and Public Services and Utilities
Housing Types, Availability: The number of housing units in Teton
County has increased nearly 54 percent since 1950. This figure compares
to a 21 percent increase statewide. In 1970, there were 1,995 housing
units in the County. Of this total, 1,373 were single-family residen-
tial, 321 were trailers, and 301 were multi-family residential (WRRI,
1977). Many of the new housing units in the County are mobile homes and
trailers. During the same period, the number of mobile homes and trail-
ers increased from 17 to 321. The number of apartments and condominiums
also increased sharply during this period. Much of the increase m
apartments and condominiums is attributed to seasonal homes. Approxi-
mately six percent of the total housing in the County is seasonal or
nonresident. This compares to 1.7 percent statewide.
The housing supply in the Jackson area is limited. The cost of land,
physical constraints (i.e., high groundwater, floodplains, etc.), high
development costs, and restrictions on mobile homes have resulted in a
shortage of houses in the study area and Teton County. Although de-
tailed information on housing availability and conditions has not been
prepared for the County, a comprehensive housing survey has been sched-
uled as an element of the overall work program for 1979. Information
from the survey will be used to develop a housing plan for the area.
This is particularly important in view of a number of development pro-
posals which could have a major impact on supply of housing in the
Jackson Hole area. Probably the most significant of these proposals is
the proposed expansion of the Jackson Hole Ski area.
Transportation: The Jackson Hole area's traffic and parking problems
have traditionally been associated with the area's summer tourist econ-
27
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omy. While the existing transportation system in Teton County presently
meets local needs, transportation facilities are limited due to the
mountainous terrain, and transportation facilities are heavily impacted
by tourism. The major highway is U.S. Highway 26,89, and 187, which
runs the entire length of the County. The highway provides major access
to Grand Teton National Park and Yellowstone National Park from the Town
of Jackson. In 1974, the facility provided for 3,800 trips per day
(LVP&L, 1974). During the tourist season, however, this number of trips
could be exceeded in a matter of hours. The situation is exemplified by
the estimate that approximately 4 million people visit the Grand Tetons
each year,. Park visitation has increased some 50 percent since 1967.
Highway 22 also provides main access to Grand Targhee Ski Resort. Some
discussions have occurred concerning the feasibility of constructing a
second access from West Jackson to the Town. These discussions are
preliminary in nature, and the emphasis has been on local traffic flow
improvement. The Town of Jackson and the State of Wyoming share the
responsibility of maintaining the Town's roads. Maintenance and snow
removal for County roads is contracted out to private business.
No rail service exists in the County. Freight is handled by trucks.
The Jackson Hole Airport, which serves the area, is located in Teton
National Park. The airport is served by Frontier Airlines. During the
past ten years, airline trips have increased an average of ten percent
per year (TCGSC, 1978). Although there has been a good deal of discus-
sion and debate over expansion of the facility to accomodate larger
jets, and EPA has opposed any additional development of the airport.
The current lease will expire in 1995.- The likelihood of any expansion
of the facility is remote.
Schools: The Jackson study area lies within the jurisdiction of Teton
County School District No. 1. The District includes the Jackson,
Kelly, Afton and Wilson Elementary Schools, Jackson Hole High School,
and Jackson Hole Middle School. According to the District, the ele-
mentary facilities (Grade K-5) are currently at, or over capacity. The
Middle School (Grades 6-8), with an enrollment of 400 students, is
slightly under capacity. The Jackson Hole High School (Grades 9-12) , is
currently at capacity with 500 students. A new 750 student high school
is being constructed on land located adjacent to the existing Town of
Jackson Sewage Treatment Plant. The projected costs for the facility is
$4.5 million. When the school opens, it is projected that enrollment
will be approximately 600 students.
School enrollment: figures for Teton County have shown an overall average
increase of approximately 1.93 percent since 1968. This growth rate is
slower than the community as a whole, but considerably above the nation-
al norm (TCGSC, 1978).
School District revenues are received from local, state and federal
sources. A study conducted by the Water Resources Research Institute,
University of Wyoming in 1978, showed that the District's revenues and
expenses have steadily grown as a function of population growth (WRRI,
1978).
28
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Fortunately for the County, the population growth has occurred much
faster than the proportional number of school age children. This situ-
ation is discussed in more detail in Section VI of this document.
Fire Protection: Fire protection in the Town of Jackson and the out-
lying areas of South Park is provided by a combined Town/County volun-
teer fire group. Equipment and manpower include four Class A pumpers
(750-1200 gpm capacities) and 32 volunteer personnel. Two auxiliary
units are maintained at Hoback and Wilson. According to local fire
department officials, the main fire protection problems in the area are
associated with service distance and response time, and access during
the winter months. The Town of Jackson currently maintains a Class 8
fire insurance rating, while the County maintains a Class 10. Ratings
are established by the Insurance Services Office of New York, Wyoming
Survey and Rating Service Local Branch. Ratings are based on a 1-10
scale, with Class 1 representing the best possible rating, and Class 10,
no fire protection available. The Town of Jackson currently requires
that new subdivisions be served by hydrants. The County has adopted
Wyoming State regulations for commercial building types.
Police Protection: Polic protection within the Town limits of Jackson
is provided by the Town of Jackson Police Department. The work force
consists of 12 full-time and two part-time.(summer) officers, and sup-
port personnel. Equipment includes five marked and three unmarked
patrol cars, all of which are in good condition. Major law enforcement
problems are summer traffic and crowd control, and theft and burglary.
Teton County is served by the Teton County Sheriff's office. The force
consists of 13 full-time officers, and eight support personnel. Three
additional personnel are utilized at the airport for security. Person-
nel operate out of the Town of Jackson. Equipment includes ten patrol
cars, all of which are in good condition. Problems vary from dog control
to armed robbery. The Department also maintains substations at Alta and
Moran.
Public Water: The Town of Jackson public water supply is provided by
four deep water wells. The system also includes a two million gallon
reservoir. The service area includes the Jackson town limits and several
small adjoining areas. Pumping and storage facilities for the system do
not include reserve capacities for fire protection.
Supplies are generally adequate to serve the Town and tourist popula-
tions. However, during peak visitor days in the summer, controls are
required (i.e., alternate day sprinkling). The Town of Jackson is
currently considering the feasibility of extending service to the desig-
nated Jackson Planned Expansion District. The area includes some 540
acres of sparsely developed land.
Power: The power supply to the Town of Jackson and surrounding area is
provided by Lower Valley Power and Light, Inc. (LVP&L). The Bonneville
Power administration supplies most of the energy to LVP&L. Although
29
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existing facilities are adequate to meet current demands, some shortages
have occurred in the past. During the ten-year period 1967 to 1977,
utility hookups showed an average annual increase of 12.48 percent per
year, with the County sustaining the bulk of growth. Town of Jackson
hookups more than doubled during this period, while County hookups more
than tripled (TCGSC, 1978).
Solid Waste: The existing County solid waste disposal site is situated
on 28 acres of land located approximately eight miles south of Jackson
in Horsethief Canyon, off U.S. Highway 26,89 and 187. The site is owned
by the U.S. Forest Service and the U.S. Bureau of Land Management. At
present, it is estimated that about 7,100 tons of solid waste are dis-
posed of annually at the facility. The operation has approximately two
years of effective life remaining under current operating conditions.
The potential for expansion of the existing facility is remote due to
land requirements and availability.
The disposal site does not meet landfill requirements defined in the
Wyoming Department of Environmental Quality Solid Waste Management Rules
and Regulations. The County is currently studying alternate site and
solid waste disposal facilities to meet future needs. This study is
also considering the feasibility of a separate hazardous waste facility
for disposal of septic tank wastes and sludge (Nelson Engineering, 1977).
4. Cultural Resources
¦s.
The Jackson Hole area has a rich history going back to the early 1800's.
The area was named for the trapper, David E. Jackson. Many years earlier,
the Shoshone Indians had named the surrounding Teton Mountains "Teewmot,"
or pinnacles. Traces of Indian history can be found throughout the
valley. Permanent settlement began about 1878, as the trapping industry
transformed to a primarily agricultural base.
Discussions with the Wyoming Recreation Commission, the Wyoming State
Archives and Historical Department, and the Archeologist conducted
during the evaluation of the alternatives in the Draft EIS, Jackson
Wastewater Treatment Facilities, indicate there are no historic sites
currently enrolled in, or nominated for, the National Register of
Historic Places, that are located on the proposed treatment plant sites
or pipeline routes. However, it should be noted that the State Archae-
ologist recommended in the Draft EIS that since the project will involve
a significant amount of trenching for pipeline alignment, that a field
survey be initiated prior to construction, and that a member of this
staff be available during ditching should the survey indicate potential
finds. EPA and the Town have determined that a pre-construction survey
will be conducted. In the event finds are made, or artifacts are found
during construction, they will be reported to the State Archaeologist
for further evaluation.
30
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FLAT CREEK AT THE SOUTH PARK
ELK FEEDGROUNDS
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SECTION IV. ALTERNATIVES AND PROPOSED ACTION
A. DESCRIPTION OF UPDATED ALTERNATIVE
The Jackson Wyoming 201 Wastewater Facilities Plan Update considers four
previously undiscussed alternatives for providing an adequate level of
wastewater treatment for the study area. The four alternatives are:
Alternative 1 - Aerated lagoon with rapid infiltration at
South Park Upper Bench site.
Alternative 2 - Oxidation ditch at South Park Upper Bench site
discharge to Flat Creek.
Alternative 3 - Aerated lagoon with rapid infiltration Lower
discharge to Flat Creek.
Alternative 4 - Oxidation ditch at South Park Lower Bench site
discharge to Flat Creek.
The report also presents the two alternative South Park pipeline align-
ments that the design engineer evaluated.
The "No Action" alternative was considered in the Facilities Plan Up-
date, but dismissed for the same reasons cited in the Draft EIS. These
reasons included:
• Continued water quality degradation
• Escalating costs by further delaying the project.
• Need for an overall solution to the cost effective wastewater
treatment problems experienced in Jackson
Six additional alternatives were also considered in detail in the Draft
EIS. While several of these alternatives presented practical solutions
to the wastewater problems experienced by the Town of Jackson, they were
not politically acceptable and would not, according to Town officials,
meet local long term wastewater treatment needs.
1. Treatment
Two alternative methods of treatment were evaluated in the Facilities
Plan Update, and their relative impacts on both surface and ground water
resources analyzed in the Facility Plan Update. The required level of
treatment is dependent upon the ultimate point of discharge. One treat-
ment method proposed provided secondary treatment plus nitrification
through use of an oxidation ditch system. This alternative would require
year round effluent discharge to Flat Creek. The design engineer states
that with the oxidation ditch process, "all parameters (discharge) can
be met on a year round basis." The critical parameter considered in the
alternative is the toxicity of ammonia nitrogen to fish and other species.
The reader is referred to the Draft EIS for a more complete discussion
of atnjmonia-related water quality problems. The EPA document A Compari-
son of Oxidation Ditch Plants to Competing Processes for Secondary and
31
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Advanced Treatment of Municipal Wastes (EPA 600/2-78/051) presents an
evaluation in the oxidation ditch system including nitrification. This
report indicates that ammonia removal rates in the 90% plus range are
readily attainable. The proposed discharge limit for ammonia at Jackson
is 10 milligrams/liter (mg/1) (Appendix B). Assuming an influent (raw
sewage) ammonia nitrogen strength of 25 mg/1 (page V-2 Draft EIS) only
60% ammonia removal would be required to meet permit requirements.
Effluent ammonia concentration measurements were to be made on a monthly
basis for the existing wastewater facility. Table 6 presents a monthly
summary of this information from January 1977 to January, 1979. As
indicated, the present mechanical system is not capable of consistently
meeting the proposed 10 mg/1 standard.
The major problem in meeting this requirement with an oxidation ditch
treatment process occurs in the winter, when nitrification in the oxida-
tion ditch can be severely affected by extreme cold. During this period
(January and February), it is possible that the effluent from an oxida-
tion ditch may exceed the ammonia requirement in the Jackson area.
The second alternative proposed by the design consultant would com-
pletely eliminate the need for surface water discharge from May to
October 14, by relying on aerated lagoons followed by rapid infiltration
to ground water as a final disposal process. The ammonia toxicity
problems related to a surface water discharge are eliminated and the
effluent flow is confined to land disposal. During the October to April
period the permit allows an average ammonia nitrogen discharge of 25
mg/1. Because toxicity of ammonia is lower at cold temperatures, the
EPA determined that a higher loading was acceptable. No discharge to
Flat Creek would be required with this alternative provided that the
infiltration basins can be operated to avoid icing. In the event severe
icing prevents the use of the basins, any discharge from the lagoons
would be required to meet instream standards for ammonia.
Alternative 1
Alternative 1 utilizes an aerated lagoon/rapid infiltration system at
the Upper Bench site. A winter discharge line would be provided to Flat
Creek in the event the infiltration basins are not operable during the
winter months. Discharge to Flat Creek during the winter months will
not require disinfection. No discharge during the recreational months
(May through October) would be permitted. The lagoon system would
provide an adequate level of treatment to allow the infiltration basins
to operate properly with a 10-day dosing cycle between applications. As
shown by the designer, the facility would consist of a three-celled
system with the first two cells being aerated, and the third serving as
a three-day storage basin for dosing the rapid infiltration basin. A
seven bed infiltration system would be constructed to contain a day and
a half of effluent each. Figure 2 shows the general layout and location,
as developed by the design engineer.
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TABLE 6
EFFLUENT AMMONIA CONCENTRATION
JACKSON WASTEWATER TREATMENT PLANT
Ammonia-N Concentration
mg/1
Minimum Average
January 1977
February
March
April
May
June
July
August
September
October
November
December
January 1979
13
12
10
12
10
8
17
14
27
11
24
13
10
16
12
12
13
12
15
28
16
26
11
Maximum
20
13
13
17
14
16
23
21
30
18
28
15
14
33
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The upper bench site consists of approximately 50 acres, essentially all
of which would be utilized in the proposed configuration. No additional
area is readily available for future expansion of the system. The site
appears to have adequate soils conditions to operate the infiltration
ponds and depth to ground water is sufficient to provide relatively
problem free construction and reliable operation.
Alternative 2
The second alternative utilizes an oxidation ditch at the Upper Bench
site (Figure 3) . This system requires only a small portion of the total
available land area (less than 5 acres), but a reliable sludge disposal
site must be secured. The treatment site is of sufficient size that any
future expansion could be accommodated. The Facilities Plan Update
suggests that a 320 acre site be developed from surrounding dry farm
land for this purpose.
The final discharge to Flat Creek will be required to meet the effluent
limitation presented in the draft National Pollutant Discharge Elimina-
tion System Permit (Permit No. WY-0021458). A properly operated system
of the type proposed should provide the level of treatment required,
given that the requirements change in winter allowing a less stringent
level of ammonia removal (see Appendix B).
The mechanical system proposed is more energy intensive than an aerated
lagoon system. This system would require both chlorination and dechlo-
rination during May through September to satisfy recreational contact
water quality requirements.
Alternative 3
The third alternative identified by the design engineer proposes an
aerated lagoon and rapid infiltration system at a Lower Bench site,
adjacent to the State's Elk Feedground. (Figure 4). The system proposed
is similar to Alternative 1, but may be more difficult to construct and
operate due to high groundwater in the area. It will be necessary to
utilize imported material for construction of the lagoon and infiltra-
tion basin. As indicated in the Updated Facility Plan, excavation would
produce several small lakes connected by Flat Creek. The facility plan
points out that these lakes and island would be managed for waterfowl
and wildlife habitat. A discharge line to Flat Creek would be constructed
to allow disposal of treated final effluent during winter months when
the rapid infiltration system may not operate due to icing conditions.
Alternative 4
Alternative four utilizes the oxidation ditch mechanical system with a
continuous discharge to Flat Creek at the Lower Bench site (Figure 5).
The process will be required to meet all the requirements outlined in
the draft discharge permit. A suitable sludge disposal site would need
34
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INFILTRATION
CEtL 1
r ¦ ¦
|5< »¦" r* ^Wrr Jfafe*,*•
STATE ELK FEEDING REFUGE
at,
FIGURE 2
ALTERNATIVE 1 - AERATED LAGOONS/RAPID INFILTRATION SYSTEM
AT SOUTH PARK UPPER BENCH SITE
-------
LAKE
JTURE
PANSlON _
LAKE
CELL 1
EXPAl
EAS
FIGURE 4
ALTERNATIVE 3-AERATED LAGOONS/RAPID INFILTRATION SYSTEM
AT SOUTH PARK LOWER BENCH SITE
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5.- AEROBIC DIGESTER/SLUDGE
INTERCEPTOR
LEGEND
1.- LAB. SLUDGE HANDLING CONTROL BUILDING
2.- OXIDATION DITCHES
3.- CLARIFIERS
4.- CHLORINE CONTACT CHAMBER
STORAGE
SOUTH PARK
FIGURE 3
ALTERNATIVE 2
OXIDATION DITCH AT
SOUTH PARK UPPER BENCH SITE
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INTERCEPTOI
SOUTH PARK
FIGURE 5
ALTERNATIVE 4
OXIDATION DITCH AT
SOUTH PARK LOWER BENCH SITE
LEGEND
1.- LAB, SLUDGE HANDLING CONTROL BUILDING
2.- OXIDATION DITCHES
3.- CLARIFIERS
4.- CHLORINE CONTACT CHAMBER
5.- AEROBIC DIGESTER/SLUDGE STORAGE
SOURCE: C.E.MAGUIRE 1978
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to be secured, and an adequate haul road would have to be constructed
over Flat Creek to accommodate sludge trucks for this option. The
land disposal of sludge may also present a problem during the winter
months. It may also be necessary to provide provisions for on site
sludge storage during the winter.
2. Interceptor Alignment
Two Alternative Alignments were evaluated in the Facilities Plan Update
These alternatives included:
County Road Alternative - A route which follows the South Park
County Road.
Flat Creek Alternative - This route generally follows the
meander line of Flat Creek.
A third route along highway 187-189 was initially evaluated. This route
was eliminated from further consideration due to excessive trench depths
over much of its length, and the associated high costs.
County Road Alternative
The County Road Alternative starts at the existing Jackson wastewater
plant and proceeds west until the County Road is intercepted. The
alignment then follows the County Road south for approximately three
miles before heading east to Flat Creek. At Flat Creek, the route would
go to either of the treatment sites selected (Figure 6). The length of
line would be between 31,490 feet and 32,920 feet, depending upon
the site selected. The interceptor would be between 24 and 36 inches in
diameter, depending upon the slope. Several construction problems have
been anticipated. The easements necessary for construction may also be
difficult to acquire. Extensive trench dewatering will be required for
all deep cuts, and the roadway will need to be resurfaced following
construction. All of these problems have the effect of increasing the
overall construction cost of the project.
Flat Creek Alternative
The Flat Creek Alignment would again initiate at the treatment plant,
and proceed generally south along the western bank of Flat Creek to
either of the Alternative treatment Plant Sites (Figure 7). The length
of the line would be 22,000 feet or 23,400 feet, depending upon the
alternative selected. Line sizes will vary from 24 to 33 inches in
diameter. No right of way problems are anticipated, and restoration
costs are expected to be minimal. Trench dewatering would be expected
to be required in the area along Flat Creek.
Cost Comparison of Alternatives
The facility plan engineer has identified the cost of the alternatives
considered in his evaluation. These costs are necessary to bring the
39
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facility up to the required capacity of 3.5 mgd (see page III-2 of the
Updated Facility Plan). Table 7 presents the cost estimates of the
alternative treatment processes, and sites considered. Table 8 presents
cost estimates for the alternative interceptor alignments.
As seen from an analysis of combinations of alternative treatment works
and pipeline alignments, the aerated lagoon plus rapid infiltration at
either the Upper or Lower Bench sites utilizing the Flat Creek inter-
ceptor alignment have approximately the same capital costs (Upper Bench-
$4.48 million; Lower Bench-$4.41 million). The Facility Plan consultant
has determined the annual operation and maintenance costs on the Lower
Bench (Flat Creek) interceptor as somewhat lower. These costs are
subject to final design alterations and final construction bidding
costs, but are suitable for planning purposes and for comparing alterna-
tives.
The aerated lagoon/rapid infiltration represents approximately $500,000
in capital savings over the oxidation ditch process. The lagoons also
provide a savings of over $60,000 a year in operation and maintenance
costs. The selection of the Flat Creek alignment to either of the
alternative treatment sites will provide a capital construction cost
savings of nearly $1,500,000.
- 3. Major Environmental Considerations of Alternatives
Three major environmental issues have arisen regarding this project.
These issues include:
1. The impact on both surface and groundwater quality the select-
ed project will have. This issue becomes a question of whether
to discharge to Flat Creek, or rely on land disposal through
the rapid infiltration basins.
2. The secondary impacts on land use, existing planning processes,
and available services to support increased development in
South Park. This issue is by far the most controversial
aspect of this project, and the one most frequently discussed
throughout the facilities planning and EIS*processes.
3. The impacts of the alternatives on the natural scenic and
physical resources of the area affected.
A detailed discussion of these issues as well as the other environmental
and socio/economic considerations is presented in later sections of this
document.
Water Quality Issues
The treatment alternative utilizing land disposal (rapid infiltration)
will obviously have a less direct impact on Flat Creek water quality
than a direct secondary discharge. Regardless of the level of secondary
treatment provided, a discharge in the summer will increase the nutrient
loading to Flat Creek, which in turn could promote the proliferation of
40
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existing wwtp
FIGURE 6
INTERCEPTOR SEWER LINE
COUNTY ROAD ALTERNATE ROUTE
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h\V.V..—*'
WWTP
FIGURE 7
INTERCEPTOR SEWER LINE
FLAT CREEK ALTERNATE ROUTE
p 1! 111! Ijt
i!! !iS! j i
1! S !i!i III
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TABLE 7 .
ALTERNATIVE TREATMENT COST ESTIMATES,
TOWN OF JACKSON 201 WASTEWATER FACILITIES PLAN
Average
Capital Equivalent Annual
Alternative Cost Annual O/M Annual Cost to
No. Description ($) Cost ($/YR) Cost ($/YR) Town ($/YR)
Aerated 2,286,000 61,700 271,200 140,200
Lagoon/Rapid
Infiltration
At Upper
Bench Site
Oxidation 2,903,000 123,000 389,100 198,600
Ditch At
Upper Bench
Site
Aerated 2,342,000 61,700 277,100 110,800
Lagoon/Rapid
Infiltration
At Lower
Bench Site
Oxidation 2,801,800 123,000 379,800 189,100
Ditch At
Lower
Bench
Site
1/
Source: c.E. Maguire, October, 1978
43
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TABLE ft .
ALTERNATIVE INTERCEPTOR ROUTE COSTS,
TOWN OF JACKSON 201 WASTEWATER FACILITIES PLAN.
1/
Interceptor Route
Capital
Cost
($)
Annual
O/M Cost
($/YR)
Equivalent
Annual Cost
($/YR)
Average Annual
Cost to Town
($/YR)
County Road
Upper Bench
3,627,300 14,510
344,480
87,150
County Road
Lower Bench
3,497,700 13,990
332,170
84,040
Flat Creek
Upper Bench
2,197,300 8,790
208,670
52,790
Flat Creek
Lower Bench
2,065,900 8,300
196,190
49,650
1/
Source: C.E. Maguire, October, 1978
44
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both phytoplankton and emergent vegetation and/or ammonia toxicity
problems in the lower backwatered section of the creek on the State Elk
Feedground. While these effects may be minimal in most years, given the
right set of circumstances (warm weather, low summer flows, higher
loading to the treatment plant, or a decrease in treatment efficiency),
water quality degradation could occur in the lower reaches of Flat
Creek.
The land disposal alternative minimizes these possibilities. The only
allowable direct discharges would occur in the winter time when biologi-
cal activity is restricted by climatic conditions, and ammonia toxicity
is minimized due to the synergistic effects on toxicity of temperature
and concentration (less unionized ammonia is formed). While groundwater
quality degradation could occur as a result of land disposal, the actual
impact of this is expected to be minimal given the reported high degree
of groundwater movement in the area. The design engineer has projected
a 5:1 water quality dilution ratio between the groundwater and infil-
trated wastewater. Further studies will be performed during the spring
of 1979 to verify this estimate. Regardless of the dilution rate, no
potable wells are found downgradient of the disposal sites. No future
development of drinking water supplies would be expected since the land
is controlled as a State Elk Feedground, and all development activities
are restricted.
Secondary Land Use Issues
These issues are by far the most controversial surrounding this project.
Regardless of the South Park alternative selected, the development of a
gravity interceptor and wastewater treatment system in the southernmost
portion of South Park will undoubtedly place accelerated development
pressures on this area of Teton County. Since the acceptance and use of
individual wastewater disposal systems has proven to be a limiting
factor to development in areas of high groundwater, the availability of
central collection and treatment facilities would facilitate a high
density of development. This higher level of development will in turn
increase the pressure on available services (i.e., fire protection,
schools, etc.), and increase the total public costs in the area.
Resource Commitment
The land being considered for potential treatment plant sites is all
under single ownership, and is presently utilized for light grazing with
some irrigated pasture. The sections of Flat Creek that run near the
potential plant sites are on private land, and generally not accessible
to the public. The closest readily accessible public land is the neigh-
boring State Elk Feedground. While the tracts being considered as
treatment sites are in the general migration area of wintering elk, it
is unlikely that the specific sites themselves play a significant role
in elk migration. It will be necessary to relocate one access gate to
the feedground to assure unrestricted migration.
45
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In terms of scenic compatibility, the Upper Bench site is the most
intrusive. The site is visible from Highway 187-189, and from the South
Park County Road area. The Lower Bench site could only be seen by the
land holders surrounding the facility, and by summer visitors to the Elk
Feedgrounds. Noise and human activities at the treatment facility
during the winter could have some affect on the behavior of the winter-
ing elk herd.
As discussed, several small lakes will be created at the Lower Bench
site in the process of obtaining fill for berms and dikes, and the
infiltration beds. It has been indicated by the design consultant that
these lakes would be managed as waterfowl habitat as partial mitigation
for any land disturbed during construction. Coordination with the
Wyoming Department of Game and Fish will be accomplished to determine if
how this area could be designed and maintained to enhance wildlife use
and fisheries management. This cooperative effort will also ensure that
proper precautions must be taken in constructing the lakes.
The major impact on scenic resources involves the commitment of land for
the facility, and secondary impacts associated with increased develop-
ment in the South Park area. The expected proliferation of high density
dwellings and other building activities will, in time, have a very
definite impact on the scenic resources of South Park independent of the
alternative selected.
4. EPA's Preferred Alternative
After a critical analysis of the numerous documents, letters, and
public testimony regarding this project, the Regional Administrator of
the U.S. Environmental Protection Agency Region VIII, Denver, following
lengthy deliberation with his evaluation staff, has concluded that the
aerated lagoon/rapid infiltration treatment and disposal process at the
Lower Bench site is the preferred alternative. This decision was based
upon:
1. The need to assure maximum protection of water quality
2. Cost effectiveness
3. The need to arrive at a politically acceptable and lmplementa-
ble project.
It was likewise concluded that the Flat Creek interceptor alignment was
the preferred alternative because it has significantly lower capital
costs.
5. Mitigation Measures for Alleviating Potential Adverse Environmental
Impacts of the Proposed Project
The design consultant and the EPA, through their review process have
developed several mitigation measures to reduce the overall impact of
the proposed project. These include measures that affect not only the
natural environment but social and cultural resource impacts as well.
46
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A planted and landscaped buffer area will be included in the final
design that will shield the built up sections of the facility from
neighboring property owners. All construction will be on the south
shore of Flat Creek and roadways and the access bridge will be designed
to minimize visual intrusion.
All construction scheduling will be developed in concert with the
Wyoming Department of Game and Fish in order to reduce the potential
impacts on the migrating winter elk herd and any fish spawning activites
in Flat Creek. No construction activity will be conducted during periods
that the Game and Fish Department indicate could have adverse effects on
wildlife. If it appears that sufficient fill material can not be
imported from a recognized and approved site for construction of the in-
filtration beds, it will be necessary to secure this material on adja-
cent land. It is proposed that several small lakes will be developed
and connected to Flat Creek to maintain water quality. These lakes
would be maintained as waterfowl habitat areas and remain under the
ownership of the present owner.
The pipeline alignment and any areas disturbed during construction will
be revegetated by the contractor prior to abandoning the site. Revege-
tation would be conducted under the guidance of a landscape architect,
following approval by the State of Wyoming.
Groundwater monitoring wells and a surface water monitoring station in
Flat Creek will be maintained by the Town to determine what effect on
local water quality the facility may exert. These stations would be
established prior to construction to develop the necessary background
information, and the results sent to the State of Wyoming as part of the
Town's self-monitoring activities. All groundwater encountered during
construction of the interceptor and treatment plant will be disposed of
in a manner acceptable to state and local regulatory agencies.
The Town of Jackson will submit to DEQ, for review and certification, a
Best Management Practices (BMP) Plan to minimize the impacts of construc-
tion on local water quality. Upon approval of the plan by DEQ, appro-
priate provisions will be incorporated into the construction contract.
The provisions of the Tri-Party Agreement dated April 13, 1978, will be
incorporated in their entirety as conditions of the Step III grant. The
procedure for allocating out-of-city taps is due prior to operation of
the new wastewater treatment system. According to the present schedule,
the new system should be fully operational by July, 1980.
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SEGJJONKRM
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FLAT CREEK
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SECTION V. ENVIRONMENTAL CONSEQUENCES
A. DIRECT EFFECTS OF THE PROPOSED ACTION
Parts A and B of the following section analyze the potential direct and
indirect impacts of the proposed project. Part C of the Section in-
cludes a similar discussion for the three basic alternatives. Special
attention is focused on part B, which analyzes the effects of additional
treatment capacity and sewer availability on local land use development
patterns, and corresponding impacts on public services and utilities.
Wastewater facilities can influence and even direct land use. This is
particularly the case in the Jackson area where high groundwater condi-
tions limit development on individual waste disposal systems, and these
limitations are a primary factor in the County's overall growth policy,
as defined in the Teton County Comprehensive Plan and Implementation
Program.
1. Impacts of the Proposed Action on Fish and Wildlife.
Discussions with the Wyoming Game and Fish Department (WG&F) indicate
general agreement with the proposal to remove the existing wastewater
facility discharge from Flat Creek. Consensus is that this situation
will have a generally positive effect on the existing fishery. However,
there is concern in the Department over the proposal to excavate material
from the east bank of Flat Creek to construct the infiltration beds.
Although the project, as proposed, provides the potential for creating
new fish and wildlife habitat, a number of considerations will need to
be addressed prior to excavation at the site. The Facilities Plan
Update does not provide specific estimates of the amount of fill material
which would be required, or dimensions for the proposed lakes. The WG&F
has recommended that the Town consult with the Department prior to any
work in the streambed. This consultation will also be required for a
Corps of Engineers Section 404 permit, in the event the stream channel
is disturbed. However, current plans call for all work being performed
above the mean high water mark of Flat Creek. Long-term indirect im-
pacts of the proposed action 'on important fish and wildlife resources
are mainly associated with the loss of critical habitat due to growth
inducement and changes in land use. These effects are discussed in more .
detail in part B of this section.
2. Water Quality Impacts
Primary impacts of construction of an aerated lagoon/rapid infiltration
system at the Lower Bench site (Flat Creek interceptor route) would be
- associated with potential short-term surface and groundwater degradation
during excavation work for interceptor alignment and construction of the
lagoons, and long-term improvements Flat Creek water quality due to
removal of the Jackson treatment plant discharge to the watercourse.
Where high water tables persist during the construction season, disrup-
tion of soil for interceptor installation will create turbidity problems
in the groundwater. Similar problems will probably occur at the lagoon
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site, where groundwater is 0.6 to 6.2 feet below the surface. These
conditions will require that adequate controls are imposed to ensure
water removed from the pipeline trench and the lagoon site will be
properly treated to reduce sedimentation prior to discharge to Flat
Creek and/or disposal by" reuse for irrigation. Potential controls
include screened wells to prevent intake of soil particles by the de-
watering pumps, sedimentation basins to remove suspended solids before
discharge to streams, diffusers to reduce soil erosion and ditch bank
slumping, buffer areas, and careful design and construction specifica-
tions and inspections during -^construction.
Flat Creek water quality can be expected to improve as a result of
construction of the proposed aerated lagoon/rapid infiltration system
which does not involve a discharge (except during service winter icing
conditions). Although Flat Creek is presently designated a Class II
stream, existing water quality is impaired due to the Jackson treatment
plant discharge (Section III). The no-discharge alternative will result
in significant decreases in BOD^, total suspended solids, fecal coliform,
total residual chlorine, ammonia nitrogen, and total phosphate levels 3n
Flat Creek.
Some degradation of groundwater quality would be expected to occur as a
result of the high groundwater table conditions at the site. Removal
efficiencies for these parameters provided by selected rapid infiltra-
tion systems are identified in Appendix C, Table 1, of the Facilities
Plan Update. From this data, nitrogen would appear to be the limiting
parameter for aerated lagoon pre-application systems. The importation
of fill material for construction of rapid infiltration beds would mini-
mize these effects. The 5:1 dilution factor identified by the design
engineer in the Facilities Plan Update would appear to be adequate to
provide the required treatment levels. However, careful design and
operation management will be required to avoid problems of groundwater
mounding. Although no potable water supplies are located downgradient
from the proposed site, a monitoring network will be installed and that
routine sampling will be required to ensure adequate treatment is pro-
vided. The 0.1 mg/1 instream phosphorus criteria recommended by the
Teton County 208 Plan as a limiting factor with respect to potential
eutrophication on Palisades Reservoir will be considered in this moni-
toring program. Although this criteria has not been approved as a stan-
dard by DEQ, the recommended limit is intended to serve as a guideline
for setting discharge permit limitations and developing best management
practices for the control of nonpoint pollution sources.
3. Air Quality and Odor
The primary impacts of the proposed action on air quality in the Jackson
study are are related to odor reductions at the existing treatment
plant, and short-term increases in particulate levels during excavation
and construction work on the lagoons and infiltration beds. The over-
loaded conditions of the existing treatment facility, and problems
associated with sludge handling, have resulted in odor problems. A pro-
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perly aerated lagoon/rapid infiltration system would not be expected to
create odor problems. The proposed location for the treatment facility
is relatively remote, further minimizing potential odor problems. Re-
ducing construction easements, dust abatement practices during excava-
tion, and revegetation of the interceptor trench alignment following
installation will minimize increases in particulate concentrations
associated with the project.
4. Economic Impacts
The direct economic impacts of a wastewater treatment system are mea-
sured in their capital construction costs and the annual operation and
maintenance liabilities. For many communities the availability of local
matching funds for capital construction may be the most important
single factor in determining the "best" alternative system. Unfortun-
ately, as many communities have discovered, the annual cost and reli-
ability problems associated with many systems may play a more important
role in the actual cost of providing wastewater services. Systems which
are highly mechanical and energy intensive are expensive to operate and
require a much higher degree of operations attention and maintenance
skills. They also tend to be less reliable for smaller isolated com-
munities where parts, and specialized repair and service personnel may
not be readily available.
The EPA's Construction Grant Program (PL 92-500) normally will fund 75%
of the eligible cost for the planning, design and construction of munic-
ipal wastewater systems. Under the 1977 amendments to the Clean Water
Act, communities that install "Alternative or Innovative" treatment or
disposal systems may be eligible for an 85% grant for that portion of
the system that qualifies as "Alternative or Innovative." The usual
eligible costs (75%) of a wastewater system are evaluated on a case by
case basis as discussed in the draft EIS, but normally it includes all
items except such things as land, excess capacity and demolition of
standing facilities. To be eligible for 85% funding, EPA will carefully
evaluate all aspects of the proposed system and accept only those items
that involve "Alternative and Innovative" technology. In this case,
only those portions of the system directly related to rapid infiltra-
tion will be eligible for 85% funding.
As pointed out in the draft EIS, EPA participation in funding projects
is based upon the availability of federal grant funds within the state.
The Jackson wastewater facilities is currently high enough on the
priority list to ensure a 1979 funding commitment. The delay of approxi-
mately 22 months (May 1977-February, 1979) between the issuance of the
draft EIS and this document has resulted in an increased project cost of
between 0.5-1.0 percent per month. Table 9 presents the direct cost
that the Town of Jackson would have to assume, including both capital
and O & M, for the recommended project and the three alternatives being
considered at this time. These costs consider only the Flat Creek
pipeline alignment due to its significantly lower cost and the antici-
pated availability of land and easements.
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TABLE _9 .
COMPARISON OF DIRECT COST OF ALTERNATIVES 1 (SOURCE: C.E. MAGUIRE, OCTOBER, 1978)
Capital Cost
EPA Share ^
75% and Anti-
cipated 85% Local Share
Alternative (Million $) (Million $) (Million $)
Annual Present Worth Total Present Life of Pro]. Present
O & M Cost 0 & M Cost Worth, Town Cost Per P.E. Worth
(Thousand $) (Thousand $) (Million $) ($) Ranking
Alt. 1
4.483
3.36
1.120
70.5
603.4
1.723
92
Alt. 2
4.968
3.726
1.242
131.3
1,123 8
2 366
127
Alt. 3
4.539
3.404
1.135
70.5
603.4
1.734
93
Alt. 4
4.866
3.650
1.216
131.3
1,123 8
2.340
125
Estimated from available data
2
With Flat Creek Alignment
''where applicable
4
@ 8% annually for 15 years
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Table 9 presents the cost information for the Proposed Project and the
alternatives for the 1995 design flow. In terms of actual cost per
Population Equivalent (P.E.) not differentiated between residential,
commercial, or tourist in the Town of Jackson, the aerated lagoon/rapid
infiltration systems (alternative 1 and 3) are the least expensive.
There appears to be very little difference in cost between the two
treatment schemes (aerated lagoon vs oxidation ditch) when taken on a
present worth cost to the Town of Jackson. The difference in the direct
economic impacts between the two are primarily a function of the higher
0 & M cost associated with the more mechanically intensive processes.
5. Affected Property Owners
During the course of preparing this document, discussions were conducted
with the Town Engineer, Town Attorney, Mayor, property owners whose land
would be involved in pipeline routg easements, and a representative for
the owner of the proposed site. The property owners of the land area
adjacent to the proposed site were interviewed regarding the treatment
plant location. During the internal review period for the Final EIS,
discussions were conducted with the second land owner whose property is
located in close proximity to the proposed site.
In summary, dicussions with the Town Engineer and Attorney, and infor-
mation from their files show that all of the involved property owners of
land which would be required for pipeline alignment have indictated
they would consider providing without fee, the necessary easement which
the Town has identified will be required for the route. It should also
be noted that their respective willingness included a formal applica-
tion for annexation of the same easements to the Town of Jackson.
According to the Town Engineer, and Attorney, the parties have since
indicated the necessary easements will probably be donated to the Town
of Jackson, regardless of whether or not the lands are annexed. The
owner of the proposed Lower Bench site has also officially notified the
Town that he will consider providing the 40 acre site and nepessary
easements without fee. This notification also included an official re-
quest for annexation of the indicated lands.
Both property owners of land adjacent to the treatment plant location
have indicated concern over the effect the facility may have on the
value of their land, as well as objections to potential odor problems
and landscaping provisions identified in the Facilities Plan Update. As
a result of these objections, additional landscaping is planned for the
treatment plant to reduce visual impacts. Special provisions will also
be incorporated into the design of the facility and the operation and
maintenance manual to control odors. However, the second property owner
interviewed during the internal review of the Final EIS has indicated
that if the proposed Lower Bench site is approved, legal action will be
initiated to prevent construction of the facility at the site.
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6. Positions of Local Officials
Efforts were made during the preparation of this document to interview
and/or review records on position statements of local Town of Jackson
and Teton County elected and appointed officials, in order to identify a
general consensus of attitudes concerning locating the proposed facility
at the Lower Bench site. The Mayor of Jackson, several Council Members,
the Town Attorney, a majority of the Teton County Commissioners, several
County Planning Commission Members, and the Town Engineer and Town and
County planning staffs were interviewed concerning the proposal. Local
newspaper files were also researched to determine attitudes and position
statements which were made in recent months concerning the treatment
plant location, the Tri-Party Agreement, and the effects of these issues
on the Teton County Comprehensive Plan.
In general, the consensus was that both Town and County officials re-
cognized the need for improved wastewater facilities in the Jackson
area. It was acknowledged that growth in the area was inevitable, and
probably would occur at a rate greater than that projected by Livingston
and Associates during the development of the Comprehensive Plan. Reasons
given for the higher anticipated growth rate included a number of pend-
ing development proposals associated with the local recreation industry,
the fact that the area is a "very attractive place to live," and the
relatively strong economy currently experienced in the area.
The main point of contention during these discussions and the newspaper
review concerned the proposed location of the wastewater treatment
plant. Opinions were definitely polarized, with about half the people
interviewed contending that higher density development in South Park was
unavoidable, and in fact desirable. Major pending development proposals
such as the planned Teton Village and Jackson Mole Ski Area expansions
were viewed as stimulants to the local economy. The conflict in this
viewpoint appears to be that while individuals expressed they generally
favored this level of development, they also wanted to see the County
develop in accordance with the Comprehensive Plan. These individuals
felt the eventual tap-in rate developed by the County for out-of-city
sewer hook-ups would provide adequate safeguards to ensure "managed
growth."
The other half of the opinions viewed the proposed location as a "gov-
ernment subsidy to growth," and saw major conflicts between the location
of the plant and the continued effectiveness of the Teton County Com-
prehensive Plan and Implementation Program. The whole sewer issue was
viewed as a "high growth vs. managed growth" question.
As a result of the discussions held by the EIS consultant with local
elected and appointed officials, the following compendium of statements
recorded during the interviews is provided to further demonstrate the
apparent polarization within the community concerning the proposed loca-
tion and treatment capacity of the Town of Jackson wastewater treatment
plant:
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• Future development in the Jackson area should occur in compli-
ance with the Comprehensive Plan, and be provided central
sewer-
• The proposed location for the treatment plant will effectively
destroy the Comprehensive Plan.
• New growth in Jackson and vicinity should occur contiguous to
existing growth, within the defined sewer service area where
other necessary services and utilities can be provided at
reasonable costs.
• The facilities plan does not define a service area.
• The Comprehensive Plan designates the lower South Park area
for low density development. These densities are based on
physical limitations, and local attitude preferences.
• Once central sewer is available in the lower South Park area,
higher density development will be feasible. It is probable
that the existing Comprehensive Plan will need to be totally
revised to better accomodate this level of development.
• The County has no desire to get into the sewer business by
funding additional capacity at the treatment plant to accom-
modate potential high density development in lower South Park.
• In reality, the1 issue is a question of whether EPA is funding
a wastewater system for the Town of Jackson or Teton County.
• The Tri-Party Agreement prepared by the Town of Jackson, Teton
County and EPA will effectively limit out-of-city tap-ins and
promote managed growth.
• The present Agreement includes no provisions for limiting out-
of-city hook-ups. There is in fact no guarantee that the
County will not provide additional capacity at the plant to
promote development in the outlying areas of the County as a
result of pressure from local developers.
• Growth, and in fact, urbanization of the Jackson area, is
inevitable.
• People live in the area because of its amenities and life-
styles.
• It is time to make the commitment for improved sewer service
in the Jackson area, while federal funding assistance and free
land for the treatment facility is available.
• The .whole facilities planning program is a problem. It is
like pumping an injured athlete full of pain killer to get him
through an important game, and worrying about the end result
later.
7. Floodplain Hazards
The National Flood Insurance Program has established the 100-year flood
as the basis for determining minimum land use measures for construction
or substantial improvements to existing development in flood hazard
areas. Executive Order 11988 (issued May 24, 1977) and EPA Flood In-
surance Requirements (PRM-77-1) define requirements for flood-proofing
of wastewater treatment facilities in accordance with the National Flood
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Insurance Program. The U.S. Army Corps of Engineers has completed a
Special Flood Hazard Information Survey for the Snake River and vicinity
(Corps, 1976). The results of this study indicate that neither of the
sites considered for locating the Town of Jackson wastewater treatment
plant are in the 100-year floodplain. However, the proposed site does
lie within the 500-year floodplain of Flat Creek. Revegetation of the
exposed diking will be performed to protect the dikes from any low
velocity flooding that could occur.
8. Aesthetics and Scenic Problems
The Lower Bench site is in a relatively undeveloped area of South Park.
Construction of an aerated lagoon/rapid infiltration system at the site
will involve the conversion of approximately 40 to 50 acres of agri-
cultural land for the lagoons and related facilities. This will require
that provisions are included in the planning stages of the facility to
reduce visual impacts. Approximately $60,000 has been included in the
Facilities Plan Update for landscaping and fencing. A number of addi-
tional methods to minimize visual impacts during construction of the
facilities should be considered in developing the site, due to the
scenic nature of the area and its close proximity to the Elk Feedground.
These include limiting clearing to minimize erosion and reduce visual
impacts of a denuded landscape; planning the earthwork and lagoon and
infiltration bed locations to fit the drainage patterns to the best
degree possible; avoiding the unnecessary removal of trees and surface
vegetation where feasible; revegetating exposed 'slopes at the site and
the interceptor route following construction; and development of a site
plan design to maximize shielding of the treatment works from adjacent
properties.
B. INDIRECT EFFECTS OF THE PROPOSED ACTION
The availability of sewers can be an incentive to development. Routing,
sizing and timing of interceptor construction can also be an important
tool for guiding residential development as a part of the overall com-
prehensive plan. This part of Section V identifies the major potential
land use changes, and public services and utilities investment likely to
occur as a result of, or be facilitated by, the availability of central
sewers. Other indirect or secondary impacts described in the discussion
are related to these changes, and involve the effects of increasing
encroachment on critical wildlife habitat, impacts on fisheries resources
associated with long-term water quality degradation, and energy and
natural resource commitments. Due to the numerous variables present in
the economy of a tourist-related economy like Jackson, and the extreme
difficulty in forecasting long term secondary environmental impacts of
providing improved wastewater facilities to an area, the analysis is
based on discussions with local elected officials and involved regula-
tory and planning agencies. The situation is further complicated by the
uncertainty of future policy decisions concerning the tap-in rate which
must be determined by the Town of Jackson and Teton County. The results
of several case studies on the development of large^cale wastewater
55
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treatment facilities and major interceptors were also studied to assist
the EIS consultant in preparing the analysis.
1. Growth Inducement and Land Use Changes
Numerous studies have demonstrated that sewer availability can result in
significant changes in development patterns and land use in an area
(CEQ, 1976; CEQ, HUD, EPA, 1974). As previously discussed in the draft
EIS, new development in the Jackson area will be attracted to areas
served by sewei for a number of reasons which include:
• Land development restrictions in the area are presently based
primarily on physical constraints which limit the use of on-
site systems (i.e., high groundwater, soils, steep slopes).
The availability of sewers would effectively remove these
constraints.
• Several major development proposals, the most important of
which is the proposed Jackson Hole Ski Area expansion, are
likely to result in significant pressures for providing hous-
ing to serve the facility's support personnel.
• The high costs of land in Jackson and South Park ($2,600/acre
to as high as $60,000/acre for subdivision land located in the
County, and $93,000/acre in Jackson) makes low density develop-
ment unattractive.
• Evidence exists that some groundwater contamination is occur-
ring in the County due to improperly functioning septic tanks.
This situation is complicated by the fact that no official wastewater
facilities service has been defined or adopted for the 20-year planning
period (1978-1995); the number of out-of-city tap-ins have not been
agreed upon by the Town of Jackson and Teton County; and the Teton
County Commissioners (1979 term) have indicated in interviews and posi-
tion statements prior to the recent election that a consensus exists to
develop the South Park area to accomodate future growth.
The Teton County Comprehensive Plan and Implementation Program, which
was adopted by the County in 1977, is comprised of three major elements
which include plan goals and policies, a land use component, and a
scenic preservation element. Goals and policies in the plan stress
compact urban development, retention of the rural residential/agricul-
tural atmosphere in relatively undeveloped areas of the County, protec-
tion of physically limiting areas (i.e., floodplains, hillsides, etc.),
protection of important fisheries and wildlife habitat, and scenic
preservation. Density requirements for the land use element are defined
according to existing physical limitations by development districts with
supporting performance standards. The scenic preservation component
identifies priorities for future acquisition.
The major long term effect on existing land use and growth in the study
area of constructing a wastewater treatment facility at the Lower Bench
site will most likely be increased pressure on the County's Comprehensive
56
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Plan for allowing higher density development in areas of South Park
where such development is currently restricted by wastewater constraints.
The majority of this portion of the County is designated R-A-3 (1 unit/3
ac.) or R-A-6 (1 unit/6 ac.). These density provisions are based pri-
marily on groundwater condand tions and septic tank limitations.
The Town of Jackson includes approximately 1,160 acres of land. Ac-
cording to a 1977 land use inventory prepared as an element of the
overall comprehensive plan, there were 350-400 vacant lots in the Town,
and 260 additional acres of land available for residential development
within the town limits (Livingston and Associates, 1976). Assuming an
average overall density of 3 units/acre, this land would accomodate
approximately 1980 new residential units. Although the County Comprehen-
sive Plan designates the Jackson Planned Expansion District (approxi-
mately 540 acres of land) as the secondary urban development area, the
availability of this land for urban expansion is still in question, and
there has been discussion concerning the feasibility of relocating the
expansion area in closer proximity to the treatment plant site location.
This area also has not been identified specifically as being located
within the Town of Jackson wastewater facilities service area. In order
to meet the population needs identified in Table 5 for the projected
combined 1995 populations of Jackson and Teton County (approximately
18,953), an estimated 4,500 new housing units will be required in the
County. This estimate becomes more realistic when considering the
potential effects on housing of the proposed Teton Village expansion
program.
Within the Town of Jackson, undeveloped land is limited and costs are
substantially higher than in the outlying areas of the County for com-
parative lot sizes. According to local appraisers and planning offi-
cials, for example, the average cost for a 50 x 150 ft. residential lot
within the Town limits varies from $25-30,000. Land costs for larger
(.25-.33 acre) residential lots south of the Town (Rafter J Development)
are currently ranging between $18-25,000. Further south in the County
at South Park Ranch, the cost for 2.5 acre lots is ranging between
$30-35,000. The cost of land in the Town of Jackson has increased
sharply since 1974, when the Town adopted a policy which required devel-
opers to provide the necessary sewer and water lines and roads for new
developments. These costs have been passed on to the buyer. With the
availability of central sewer m the South Park, higher density devel-
opment is likely to occur. Land owners will be able to subdivide their
property in smaller lot sizes, reducing comparative costs to the buyer.
In summary, as lower land costs and sufficient sewer capacity in the
outlying areas of South Park are likely to make much of the area more
attractive to local developers, the existing agricultural and undevel-
oped land will probably be replaced by residential development. This
situation will undoubtedly result in the need to refine the existing
Teton County Comprehensive Plan and Implementation Program to better
accomodate a more intensive use, particularly as related to provisions
which would place more of the burden for providing necessary services
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and utilities on the developers. Town and County officials may also
find it necessary to stage future interceptor extensions and sewer hook-
ups to the proposed treatment facility to minimize impacts on land
use, and related public services and utilities investments (these invest-
ments are discussed in more detail in the following subsection). Pro-
visions of the Tri-Party Agreement formulated by the Town of Jackson,
Teton County and EPA, which would allow the County to fund additional
treatment capacity at the plant, may make these types of considerations
necessary to ensure that growth pressures do not result in uncontrolled
development patterns.
2. Impacts on Public Services and Utilities
As briefly discussed in the Summary section of this document, land use
changes resulting from the availability of central sewer facilities in-
variably result in substantial additional requirements for public ser-
vices and utilities. These services and utilities include schools,
police and fire protection, public water systems, highway and secondary
road networks, and power supplies. The investment required to supply
these necessary facilities affects the public, either from the stand-
point of increased taxes to support the needs,1or from increased costs
for land provided the facilities, which is passed on to the buyer from
the developer. For this reason, local governments should have a legiti-
mate concern regarding secondary public costs associated with providing
sewers.
Teton County service expenditures are higher than other Wyoming counties,
due mainly to the larger number of tourists, and seasonal and temporary
workers and residents. This results in rather high per capita costs
which ranged from a low of 112 percent higher than the state average in
1972, to a high of 175 percent, the average in 1968.
The public service in the Jackson study area most likely to be adversely
affected by construction of an aerated lagoon/rapid infiltration system
at the Lower Bench site is schools. School attendance in Teton County
School District No. 1 has increased an average of 1.93 percent a year
during the past ten years. This growth is well above the national
average. Expenditures for school facilities have also increased 165
percent during this period. The Teton County Commissioners went on
record in opposition of the proposed Jackson Hole Ski Area expansion.
In an October 19, 1978, correspondence to the supervisor of the Bridger
Teton National Forest, the Commissioners cited a number of potential
growth-related problems with the expansion as proposed. These problems
generally centered around concerns over the surrounding communities'
ability to provide services through Phases II and III of the project,
particularly adequate school facilities. This particular problem is
vividly demonstrated by the financial difficulties recently encountered
in funding the construction of the new high school.
%
Discussions with District personnel indicate that locating the treatment
plant at the proposed site will probably require that a new elementary
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school be built in lower South Park within three to four years. This
facility would be required to service grades 4 and 5, which are projected
to be the most highly impacted at that time. It is also likely that the
District will be forced to go to a double bus schedule to provide ade-
quate service. This situation creates a special burden on residents of
Teton County, due to the fact that the County does not receive substan-
tial revenues from mineral resource taxes, and the assessed valuation
for the County is low due primarily to the high proportion of federal
lands. Too rapid growth in the study area could in fact result in a
situation where construction dollar needs exceed the District's bonding
capacity, and operating funds exceed the ability of the local tax base
to generate them. During the past ten years, property tax assessments
in the County have increased roughly 159 percent. Approximately half
the increase is attributed to inflation, while the balance is due to
improvements m services (TCGSC, 1978).
Other public services and utilities most directly affected by the
proposed project include police and fire protection, and domestic water
supplies. The scope of these services is directly related to the number
of people who must be served. For example, there will undoubtedly be a
requirement for additional police officers to serve the increased popu-
lation served by the proposed project to maintain adequate police protec-
tion. The Town of Jackson Police Department and the County Sheriff's
Office are currently meeting the recommended FBI guidelines for officer-
to-population ratio (two officers/1,000 population). The projected
combined 1995 population for the Town and County will require a total of
approximately 40 full time officers (an increase of 15) , along with the
necessary support personnel, facilities and equipment. The revenue to
meet these needs must come from taxes. There is also a good likelihood
that resulting development patterns will create additional police en-
forcement problems by virtue of expanding the respective department's
general service area.
Fire protection ratings in the County currently result in high insurance
premiums. Additional development in the outlying areas of the County
facilitated by the availability of central sewer will place an additional
burden on the existing volunteer force. This burden may require that a
substation is constructed in South Park to reduce response times.
Central water systems to provide adequate hydrant protection to new
subdivisions in the County may also be required. This is presently not
a requirement, although the County has adopted State of Wyoming regula-
tions which comprise the minimum standards for commercial and industrial
development.
Teton County currently requires developers to provide such services as
roads, road maintenance and snow removal. These costs associated with
increased residential development in lower South Park, along with the
costs for providing and maintaining centralized water systems, will un-
doubtedly be passed on to the buyer in the form of higher land and con-
struction costs. Construction of the proposed wastewater facilities.
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and the accompanying increase in development, can be expected to result
in the need for improved transportation facilities, particularly in the
South Park area. Local vehicular traffic problems are currently experi-
enced in the area, according to local planners. The problem is compound-
ed by tourist traffic. A second access from west Jackson to the Town
is currently in the discussion stages. Additional facilities will also
be required to handle the projected population increase and trips gener-
ated during the 1978-1995 facilities planning period.
The Teton County and Proposed Comprehensive Plan and Implementation
Program, prepared by the University of Wyoming Water Resources Research
Institute in 1977, analyzed the cost of a $40,000 housing value on
county government. The study showed that a development with a current
average housing value of $40,000 would cause a burden on County govern-
ment of approximately $2,000. The study also showed that to a large
degree, the value of the housing in a particular development determines
the associated costs to the County and the taxpayer. The comparison of
revenues vs. expenditures for a $100,000 house in fact showed a net
revenue of approximately $40,000, indicating that the right type of
residential development can pay for itself, and not be a burden to
County finances.
The existing solid waste disposal facilities are not adequate to meet
the projected needs for Teton County. Regardless of whether of not the
proposed treatment facilities are constructed, the County will need to
develop an alternative solid waste management strategy to serve the
projected future population. Alternative strategies are currently being
considered by the County, as previously discussed in Section IV of this
document.
3. Secondary Impacts on Local Water Quality
Indirect or secondary impacts of sewers on local surface and groundwater
conditions are very difficult to project, and are primarily dependent on
population growth and land development patterns. These impacts are
associated with the potential for long term degradation of groundwater
in the lower South Park area downgradient from the infiltration beds,
and problems related to the increase in volumes of storm water runoff
and discharge to the Snake River and Flat Creek. While it is likely
that the proposed alternative will probably result in a reduction in the
numbers of individual waste disposal systems in South Park thus reducing
nutrient loadings and bacteria levels, the facilities plan engineer has
identified relatively low nitrogen and phosphorus removal efficiencies
for similar rapid infiltration systems presently in operation. - These
two parameters are particularly important from the standpoint of poten-
tial degradation of drinking water supplies (excessive nitrates), and
eutrophication of surface water via surface and groundwater exchange
(phosphorus). Although it is unlikely that any new domestic water
supplies will be drilled downstream from the Lower Bench site, it is
important that a groundwater observation network be Installed to monitor
these parameters. Careful system design, hydraulic loading and operation
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and maintenance requirements will be necessary to further reduce the
potential for impairment of the groundwater system at the treatment
plant site.
Increased development in the Town of Jackson, and outlying areas of
South Park facilitated by the availability of central sewer will un-
doubtedly result in additional impervious ground surface (rooftops,
roads, driveways, parking lots, etc.). These alterations in the natural
drainage systems will augment urban runoff flows and increase runoff to
Flat Creek. The Town of Jackson does not enforce specific stormwater
management controls. The Teton County 208 Water Quality Management Plan
has identified stormwater runoff as a priority wastewater problem in the
Town of Jackson and vicinity, and recommended additional monitoring and
regulatory programs which would assist in maintaining overall water
quality in the area. A study conducted by the agency showed four major
drains in the Town discharging significant loadings of organic matter,
bacteria, nutrients, suspended solids and toxic chemicals to Flat Creek.
During rainstorm episodes, the loadings exceeded the suspended solids
and organic loading discharged by the Town's treatment plant. Without
proper land use, construction and storm drainage controls (i.e., grading
requirements, buffer zones, retention and treatment basins), and effi-
cient street cleaning and maintenance programs, the benefits of increas-
ed wastewater treatment efficiency on local surface and groundwater
quality may be negated by urban/suburban nonpoint pollution sources.
4. Indirect Effects on Air Quality
The long-term indirect effects on Jackson Hole air quality are dependent
on increased population and resultant development patterns in the area.
These effects are very difficult to project, due to the limited amount
of air quality data available for the area. However, because the
availability of sewers will remove existing development constraints
associated with wastewater treatment (depending on the County tap-in ar-
rangements) , general impacts which can be expected to occur include in-
creased carbon monoxide (CO) and other automobile-related pollutants,
due to additional trips generated and miles traveled from South Park to
the employment center of Jackson.
5. Fisheries and Wildlife Habitat Impacts
Based on discussions with WG&F personnel, no significant long-term
impacts on the local fishery would be expected to occur as a result of
implementation of the proposed project. Department officials generally
indicated that the project could be expected to improve water quality in
Flat Creek by removing the existing discharge. However, some concern
was expressed by WG&F personnel that the proposed location, while not on
the Elk Feedground, could result in some disturbance to the elk popula-
tion because of related human activity at the plant for operation and
maintenance. Continued disruption of existing feedground access points
for elk would result in the eventual long-term loss of the elk feedground
due to the continued urbanization of South Park. Department personnel
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further indicated that an official WG&F position statement will be
issued by the Cheyenne office on the Facilities Plan Update and Final EIS.
While the peregrine falcon has been observed in the South Park area,
information on frequency of occurrence or numbers is limited and impact
assessments are difficult to make. However, the proposed project is not
expected to affect any rare or endangered wildlife species.
6. Effects on Major Development Proposals and Other Federal, State and
Local Programs
Construction of the proposed wastewater treatment facilities will
affect a number of proposed and ongoing development proposals and govern-
mental programs. Two of the most important developments include the
pending Wild and Scenic Rivers designation of the Snake River through
the study area, and the Jackson Hole Scenic Area'proposal. The Wild and
Scenic River Study of the Snake River by the U.S. Forest Service, which
was discussed in detail in the Draft EIS, Jackson Wastewater Treatment
System, (EPA, 1977), has recently been completed. Although the results
of the study were not ready for official release at the time this docu-
ment was drafted, according to Forest Service officials, the reach of
the river through the study area will probably be designated a "recre-
ation" classification. The management objectives for this classifi-
cation, which include optimization of public use, and permitting new
structures for habitation and recreation, would appear to be compatible
with improved wastewater facilities and the probable growth facilitated
by sewer availability.
The Jackson Hole Scenic Area Bills (S.2162 and H.R. 9135), which were
introduced to the last session of Congress to establish funds (up to
$200 million) to purchase scenic easements, have been modified sub-
stantially to study priority purchases within the 75,000 acre study
area. The intent of the proposed legislation will undoubtedly be im-
pacted by potential changes in the County's existing land use policy
which would allow for higher density development in the areas south of
Jackson. Development pressures on rural scenic lands in Teton County
are currently significant, and will undoubtedly be increased with the
potential availability of sewers in these areas. This pressure is
demonstrated by the approximately 10,000 acres of prime farmland in the
County which has been converted to more urbanized uses since 1969 (WRR1,
1977). Although it is not known at this time to what degree the new
Teton County Commission and residents of the County will support the
proposal, the concept of the scenic area is of national importance and
interest.
Other major programs and development proposals likely to be affected by
recommended Jackson wastewater facilities alternative include the Teton
County Comprehensive Plan and Implementation Program (which was discussed
earlier in this section), and the Jackson Hole Ski Area Master Plan,
prepared by the Jackson Hole Ski Corporation and the U.S. Forest Service.
The Master Plan, which was revised in March, 1978, identifies a signifi-
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cant increase xn the existing recreation facilities necessary to accomo-
date a projected skier demand increase of from 175,000 skier days in
1975 to 681,496 skier days by 1992 (JHSC, USFS; 1978). Available over-
night facilities at the resort presently are capable of accomodating
2,612 persons. At full development level, the planned housing would
handle 8,452 persons. The Teton County Commission and the Teton County
School District No. 1 have expressed concerns over the potential impacts
of this level of development on local housing availability and services
including schools, transporation, and police and fire protection. One
of the major limiting factors to this level of development in the past
has been adequate wastewater facilities to accomodate the growth neces-
sary to serve such development.
7. Indirect Commitments of Natural Resources for the Proposed Action
The major indirect commitments of natural resources for the proposed
action are related to the long-term changes in land use gradually brought
about by development pressures and the availability of central sewers.
These impacts have been discussed in previous sections of this document.
While increasing urbanization, with its corresponding impacts on lQcal
water quality, fish and wildlife resources, and aesthetic and scenic
values, is probably irreversible in the Jackson area, providing adequate
wastewater collection and treatment systems will undoubtedly accelerate
this process.
C. MAJOR IMPACTS OF THE ALTERNATIVES
This section will assess the major impacts of the three basic alternatives
for the Facilities Plan Update which include:
• Alternative 1 - Aerated Lagoon/Rapid Infiltration System at
the Upper Bench Site.
• Alternative 2 - Oxidation Ditch at the Upper Bench Site.
• Alternative 4 - Oxidation Ditch at the Lower Bench Site.
Particular attention is focused on evaluating those impacts which
differ between the proposed action and the alternatives. This format is
intended to provide the reader with a concise description of potential
direct and indirect impacts for alternatives so that the reviewer may
evaluate the alternatives by comparative merits. A comparison of several
of the main impact categories for the proposed action and alternatives
was provided in part A. For this reason, these categories (specifically
economics, flood hazards, affected property owners, and political sup-
port) will not be included in this discussion.
1. Impacts of the Alternatives on Fish and Wildlife Resources
Alternative 1 (Aerated Lagoon/Rapid Infiltration, Upper Bench Site)
Discussions with the WG&F indicate that the major impacts of this
alternative on local fish and wildlife resources are similar to those
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for the proposed action, and involve improved water quality in Flat
Creek, and increased disturbance to the elk population in the State
Feedground with the long-term potential for loss of the Feedground due
to encroachment by more urbanized development in South Park. Department
personnel also indicated that any facility at the Upper Bench site would
potentially interfere with the existing elk jump located adjacent to the
site. This facility is used by the Department during the winter months
to herd elk by snowmobile into the feedground. Locating the treatment
plant at the site would require relocation of the elk jump.
Alternative 2 - (Oxidation Ditch, Upper Bench Site)
The primary difference in the impacts of this alternative on fish and
wildlife resources is associated with the proposed discharge to Flat
Creek. However, treatment efficiencies identified in the Facilities
Plan Update for the oxidation ditch process indicate that the level of
treatment would in fact be higher than for the proposed alternative.
Although the process is more compact, requiring only ten acres of land,
the additional mechanical processes would undoubtedly result in some
disturbance to feeding elk populations:
Alternative 4 - (Oxidation Ditch, Lower Bench Site)
This alternative would be expected to have minimal direct impacts on
fish and wildlife resources in the project area. The facility would
require less land, but involve a discharge to Flat Creek.
2. Water Quality Impacts of the Alternatives
Alternative 1 - (Aerated Lagoon/Rapid Infiltration, Upper Bench Site)
This alternative would be expected to have similar direct and indirect
impacts on local water quality as the proposed action. Flat Creek water
quality would be expected to improve as a result of implementation of
this option. At present, the existing plant is overloaded. Improved
facilities would result in a reduction in coliform, total suspended
solids, residual solids, ammonia, nitrate and phosphate concentrations.
Groundwater conditions at the Upper Bench site are more conducive to
locating a rapid infiltration disposal system. Long-term water quality
impacts associated with increased urbanization of South Park would be
identical to those of the proposed project.
Alternative 2 - (Oxidation Ditch, Upper Bench Site)
Alternative 2 would require a discharge to Flat Creek. However, projected
treatment efficiencies would result in improved water quality conditions
in Flat Creek. Section V of this document analyzes efficiencies for the
two treatment processes. With only 60 percent ammonia removal effi-
ciencies (rates in the 90% range are attainable), the process would meet
NPDES permits. Groundwater quality conditions at the site would not be
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impaired to the extent that would occur for the rapid infiltration
alternatives. As previously discussed for the proposed project, although
the effluent for a rapid infiltration system would be heavily diluted by
the groundwater system, there is some concern over the level of nutrient
removal this system will provide as related to increased eutrophication
and potential groundwater contamination. Sludge handling and ultimate
disposal would be required with this alternative. A disposal plan which
considers water quality protection would need to be developed for this
option.
Alternative 4 - (Oxidation Ditch at the Lower Bench Site)
This alternative would have similar impacts on local water quality as
Alternative 2. Although a discharge to Flat Creek would be required
existing literature indicates that treatment efficiencies attained by
this process would meet or exceed NPDES permit requirements.
3. Air Quality and Odor
Alternative 1 - (Aerated Lagoon/Rapid Infiltration)
Odor problems for a properly operating aerated lagoon/rapid infiltration
system would be minimal. Construction of the facility (particularly
excavation of the lagoons) would be expected to result in short-term
increases in particulate levels at the site. Long-term indirect effects
of an improved wastewater facility on local air quality would be the
same for all alternatives, and related to growth inducement and addi-
tional trips generated and miles traveled to adjacent employment centers
in the Jackson study area.
Alternative 2 - (Oxidation Ditch, Upper Bench Site)
Odor is not a major problem for a properly operated and maintained
oxidation ditch treatment plant. A study completed by EPA in 1978 for
20 treatment facilities utilizing this process identified no nuisance
complaints or odor problems at the plants. However, improper handling
of sludge during the drying process could result in potential odor pro-
blems at the facility. Dust emission would occur at the site during the
construction stages of the project. This problem would be localized and
short-term. Secondary growth related impacts on local air quality would
be identical to those discussed for the proposed action.
Alternative 4 - (Oxidation Ditch, Lower Bench Site)
Although some odors would be expected to be associated with the treat-
ment process, the remoteness of the location would minimize these im-
pacts.
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4. Aesthetics and Scenic Problems
Alternative 1 - (Aerated Lagoon/Rapid Infiltration, Upper Bench Site)
The Upper Bench site is located between 400 and 500 feet from U.S.
Highway 189. The proposed treatment process for this alternative would
require 40-50 acres of land, and would result in severe visual impacts
from the highway. Visual buffering would probably not be feasible for
this alternative, given the land area involved. Additional land area
for future expansion is also extremely limited.
Alternative 2 - (Oxidation Ditch, Upper Bench Site)
Although this alternative would require only ten acres of land, the
proposed siting layout shown in the Facilities Plan Update indicates the
facilities would be located in close proximity to the highway. While
compact site planning, visual screening {landscaping, berming, etc.) and
plant design would reduce the visual effects of the facility, impacts at
this site would be far more obtrusive than at the Lower Bench site.
Alternative 4 - (Oxidation Ditch, Lower Bench Site)
The visual impacts of constructing the oxidation ditch alternative at
the Lower Bench site would provide the least adverse impact of the
alternatives considered in the Facilities Plan Update. The general
neighborhood is relatively undeveloped at this location. The relative
"compactness" of the facility, as compared to the aerated lagoon/rapid
infiltration system alternative, would reduce site design problems.
Problems with visual screening and landscaping would also be reduced.
5. Energy Utilization
Alternative 1 - (Aerated Lagoon/Rapid Infiltration System, Upper Bench Site)
Energy requirements for an aerated lagoon/rapid infiltration system at
either the Upper or Lower Bench sites identified by the facilities plan
consultant are 100 connected horsepower. This requirement is low, as
compared to the mechanical oxidation ditch treatment process. Addi-
tional energy comsumption for sludge handling and removal is not re-
quired for this option. It should be noted, however, that the identi-
fied energy requirements of 100 horsepower may be low, considering the
cold climate m the Jackson area.
Alternative 2 - (Oxidation Ditch, Upper Bench Site)
Energy requirements for this option identified ,in the Facilities Plan
Update include 150 connected horsepower, plus power requirements to heat
the sludge handling area and haul the sludge.
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Alternative 4 -
(Oxidation Ditch, Lower Bench Site)
Energy requirements for this alternative would be identical to those
discussed for Alternative 2.
6. Growth Inducement and Land Use Changes
Alternative 1 - (Aerated Lagoon/Rapid Infiltration, Upper Site)
The potential growth inducement and land use changes likely to occur as
a result of this alternative are similar to those discussed for the pro-
posed project. These impacts are more directly related to the treatment
plant location and capacity, rather than the type of treatment process
selected. All the proposed alternatives will have similar direct and
indirect changes on existing land use and development patterns in the
study area by removing a primary development constraint, adequate waste-
water facilities. The rate of land use changes in the area will be
determined by development pressures, the final provisions of the Tri-
Party Agreement to be formalized by the Town of Jackson, Teton County
and EPA, and the effectiveness of the Comprehensive Plan and Implementa-
tion Program in managing future growth in the planning area. It should
be noted, however, that this location does not include adequate land
area for future expansion. This situation in itself could limit growth
beyond the 1978-1995 facilities planning period, in the event some of
the ma^or development proposals discussed in this document occur.
Alternative 2 - (Oxidation Ditch, Upper Bench Site)
As discussed for the previous alternative, future growth and land use
impacts of providing improved wastewater facilities are primarily depen-
dent on treatment capacity, plant location, and amount of vacant land
served, along with the effectiveness of existing land use controls. Ex-
cess capacity at the plant will undoubtedly result in additional pres-
sure for development in the outlying areas of the County. This is
particularly the case without a defined service area, and out-of-city
tap-in rate agreement.
Alternative 4 - (Oxidation Ditch, Lower Bench Site)
The impacts of implementation of this alternative on land use and
development patterns are similar to those described for the proposed
alternative.
7. Impacts on Public Services and Utilities
Alternative 1 - (Aerated Lagoon/Rapid Infiltration, Upper Bench Site)
As already discussed earlier in the Section, land use influences in-
frastructure (public services and utilities) needs, demands and invest-
ment. While land use controls (notably zoning) in most areas can hold
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land out of development for the short term, the availability of sewers
in the Jackson area will probably have the effect of stimulating growth,
particularly in the lower South Park.area. This growth will require
additional public services and utilities. Impacts on public services
and utilities of locating an aerated lagoon/rapid infiltration system at
the Upper Bench site will probably not be appreciably different than
those described for the proposed alternative. Although the County
presently requires that developers provide a portion of these necessary
services, requirements to provide others such as police and fire pro-
tection are placed on the public sector. This situation.will undoubt-
edly result in higher taxes, or if the County decides to place addition-
al requirements on developers, increased property and construction
costs. A more detailed discussion of the potential impacts of construct-
ing improved wastewater facilities in lower South Park is included in
the description of impacts for the proposed project.
Alternative 2 - (Oxidation Ditch, Upper Bench Site)
The effects on local public services and utilities of constructing an
oxidation ditch treatment facility at the Upper Bench site are similar
to those described for the proposed alternative.
Alternative 4 - (Oxidation Ditch, Lower Bench Site)
The direct and indirect impacts this option are also similar to those
discussed for the proposed project. These effects will be dictated by
the demand for development in the lower South Park area, which will in
turn be increased by the availability of sewers. For these reasons,
project staging will probably play an important role in determining the
level of impacts, as well as the final arrangements of the Tri-Party
Agreement.
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SECTION VI
LIST OF PREPARERS
The Final Environmental Impact Statement, Jackson Wastewater Treatment
System Town of Jackson, Wyoming was prepared by the U.S. Environmental
Protection Agency, Rocky Mountain Prairie Region, Region VIII, Denver,
Colorado; with assistance from James M. Montgomery, Consulting Engineers,
Inc., Boise, Idaho. Persons primarily responsible for preparing the
final EIS include:
Mr. Weston Wilson, Project Office
U.S. Environmental Protection Agency, Region VIII
Suite 900, 1860 Lincoln Street
Denver, Colorado 80295
Mr. Ed Cryer, Project Engineer
James M. Montgomery, Consulting Engineers, Inc.
1301 Vista Avenue
Boise, Idaho 83705
Mr. Rick Richins, Environmental Planner
James M. Montgomery, Consulting Engineers, Inc.
1301 Vista Avenue
Boise, Idaho 83705
Secretarial and graphics for the report were prepared by Ms. Colleen
Collier and Mr. Jim Hurry of James M. Montgomery, Consulting Engineers,
Inc., Boise, Idaho.
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SECTION VII
REFERENCES
NHPQ, 1974. Facilities Plan, Town of Jackson, Wyoming.
NHPQ, 1975. Supplemental Report to the Facilities Plan for the Town
of Jackson, Wyoming.
Teton County Board of County Commissioners, 1977. Teton County Compre-
hensive Plan and Implementation Program.
C.E. Maguire, Inc., 1978. Jackson, Wyoming 201 Wastewater Facilities
Plan Update.
EPA, 1977. Draft Environmental Impact Statement, Jackson Wastewater
Treatment System, Town of Jackson, Wyoming.
NHPQ, Inc., 1975. Sewer System Analysis and Evaluation, Report of
Sewer System Evaluation Study of the City of Jackson, Wyoming.
CEQ, 1978. National Environmentl Policy Act Regulations, Proposed
Implementation and Procedural Provisions.
Lowe, J.D. and J.C. Reed, 197>1. Creation of the Teton County Landscape.
Livingston and Assoc., 1976. Teton County Growth and Development
Alternatives.
U.S. 95th Congress, 1977. Congressional Record, Jackson Hole Scenic
Area, September 30.
Lower Valley Power and Light, Inc., 1974. Environmental Analysis,
Teton-Jackson 115,000 Volt Electric Transmission Line.
National Oceanic and Atmospheric Administration, 1973. Earthquake
History of the United States.
U.S. Corps of Engineers, 1976. Special Flood Hazard Information Snake
River Wilson, Wyoming and Vicinity.
EPA, 1977. Flood Insurance Requirements (PRM-77-1).
Wyoming Department of Environmental Quality, 1976. Snake River Basin
Water Quality Management Plan.
U.S.G.S., 1974. Water Resources of Northwestern Wyoming.
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U.S.G.S., 1975. Discharge Measurements and Chemical Analysis of Water
in Northwestern Wyoming.
Teton County 208 Planning Agency, 1977. Draft Teton County Water
Quality Management Program.
Water Resources Research Institute, 1977. Teton County and the Proposed
Comprehensive Plan and Implementation Program: An Economic
Analysis.
Livingston and Assoc., 1977. Proposed Comprehensive Plan, Implementa-
tion Alternatives, and Water Quality Management Program.
Jackson Hole Ski Corp. U.S.F.S., 1978. Jackson Hole Ski Area Master
Plan Revision, Bridger-Teton National Forest.
Teton County Growth Study Committee, 1978. Growth in Teton County,
1967-1978.
Nelson Engineering, 1977. Solid Waste Study for Teton County, Wyoming.
EPA, 1978. A Comparison of Oxidation Ditch Plants to Competing
Processes for Secondary and Advanced Treatment of Municipal Wastes.
CEQ, 1976. The Growth Shapers - The Land Use Impacts of Infrastructure
Investment.
CEQ, HUD, EPA, 1974. The Costs of Sprawl - A Detailed Cost Analysis.
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APPENDIX A
AaasacEvr
THIS ASREEMEST made and entered into by and batwaan The Town of
Jackson, Wyoming, a municipal, corporation (hareinaftar "City"); Teton
County (hareinaftar "County")j and the U.S. Environmental Protection
Agency, Region VIII, (hereinafter "EPA").
WHEREAS the City acting in the best interest of its inhabitants
desires that its public health and water quality concerns be met by ex-
panding its wastewater treatment eystemr desires that the proposed
wastewater treatment facility be sited in South Park} and desires that
ths SPA fund that facility.
WHEREAS The County acting in' the beat intereets of its inhabitants
desires that any waatewater treatment facility to be sited in the unin-
corporated portions of Teton County not adversely impact on the welfare
of its inhabitants; and will not agree to such a site without certain
assurances.
WHEREAS the EPA desires that the proposed wastewater treatment
facility be built as expeditiously as possible ao as to resolve serious
water quality problems.
SOW THEREFORE, the parties hereto in consideration of the mutual
covenants made herein, make the following agreements*
TOWN OP JACKSON AGREES TO:
1. Design, build, operate and finance an appropriate sewage treatment
plant at a proposed South Park location. The facility will include
adequate land for- future expansion including possibility of more ad-
vanced levels of treatment, and will be designed with a capacity of
2.63 M.G.D. to adequately handle and treat the sewage generated only by
the Town of Jackson and its proposed expanaion area or areas through
the year 1995.
2. Design, construct and finance the interceptor sewer to the South
Park treatment facility. The exact Location of interceptor will be
determined after counsulting with the County and land owners in the area.
3. Design, construct and finance (with County assistance) appropriate
receiving and proceesing facilities for disposal of septic tank wastes.
4. Provide full local share of funding requirements for the sewage
treatment project (except, special County assistance on septic tank
waste disposal facility).
5. Submit to the County for review and approval all structures to be
built at the South Park treatment site.
6. Begin as soon as possible to develop a new sewer system pricing
policy that incorporates a "full cost" pricing concept for a LI custo-
mers for both capitaL and maintenance and operations costs, and for
returning the county's capital contribution foe septic tank waste dis-
posal facilities.
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7. Consider only requests for eewer service from out-of-city potential
customers that have county development permits and County approval
for sewer services.
8. Limit new taps to out—of-cIt/ customers ao that they will only be
granted to potantial euatomara that have County approval and that are
subject to a new City policy and detailed criteria that determines
prioritlea for auch connection*.
The new City policy for distributing out-of-city tapa will include
at laaat the following claaaea of euatomarax
(1) existing sya#«*ms with health and safety problems;
(2) existing systems with water pollution problems;
(3) City Expansion Area — aa delineated in the Teton County
Comprehensive Plan adopted December 6, 1977 or aa amended;
(4) old and new developaienta adjacent to City limits;
(9) other existing developments; and*
(6) other naw developmenta.
9. Limit the number of "out-of-city" equivalent taps, permitted on an
annual basia ao they ahall not exceed the annual allowable number of
"out-of-city* tapa as set forth in the comprehensive plan or as amended.
For- purposes of allocating theae equivalent taps, "out-of-city" taps
are defined as taps allocated to potential cuatomers located outside
the corporate limita of the Town of Jackson as of the date of this
agreement. Such definition shall exclude any taps located in the Ex-
pansion Area (aa delineated in the Teton County Comprahenaive Plan
adopted December 6, 1977 or aa amended) or in any area which meets the
following requirements: (1) the area haa been annexed subaequent to
thia agreement or is subject to the provisions of a written annexation
agreementr and. (2) tha area is adjacent to the present city limits
(i.e. situated so that the City is newly constituted is geographically
compact).
Allowances may be made for reallocating any unuaed "out-of-city" taps
in any one year as additional permitted "out-of-city" taps in future
years. Existing residences outside the present City limits, on private
sewerage systems as of the date of this agreement, may be connected to
the City's system, (after receiving approval from first the County and
then the City) without reducing permitted "out-of-city" tap limits for
the year in which they connect.
10. Take all reaaonable stepa to aaaist the County in administering
the County's comprehensive Plan.
11. Require all new connections to City sewer system (whether or not
within the City) to meet all the City's minimum design standards for
connection and require ail subdivisions within the Town expansion area
or adjacent to the Town limits desiring sewer service to meet the
Towns subdivision requirements.
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12. TBka all steps legally available to aasara all elements of thia
agreement are enforced until at laaat 1999 (approximately 15 yaars
from completion of naw plant).
TETOH COPHTY AGREES TOI
1. Approve any South Park aits aelacted by the City which ia consis-
tent with engineering recommendationa and analyaia and otherwise in
substantial or reasonable compliance with Chapter VI Sac. 8b thru q
and Sec. 9 of the County Comprehensive Plan.
2. Approve the location of the interceptor line aa finally deaigned
by the City and iaaua all required County permits for ita construction
in accordance with State and County Lawa. Recommend to City the loca-
tion for interceptor that baat meets naada of County.
3. Provide pro-rata share of facility capital coat for appropriate
receiving and processing facilities for diapoaal of septic tank waates.
4. Adviae City of desired deaign criteria for all atructurea at the
South Park Site.
5. Advise the City of all existing and future developments that the
County wishes to be connected to the City's sewer system. Develop a
policy and detailed criteria for making such decisions.
6. Take the lead in further addressing rate of growth issues in the
County and develop an annual number of out-of-city taps per year as
a part of the comprehensive plan taking into consideration fiscal and
other forma of impact upon the County, scenic preservation activities,
schools and other urban service systems. The development of the annual
number of out-of-city tapa shall be done prior to completion of the
aewage treatment facilitiea.
7. Take all reaaonable steps to carry out the new County Comprehensive
Plan.
8. Require all County subdivision within the City expansion area or
adjacent to the City limits that are to be served by the City of
Jackson's sewer system to conform to development standards that meet
or exceed the City's standards.
9. Take all steps legally available to assure all elements of this
agreement are enforced until at least 1995 (approximately 15 years from
the completion of new plant).
EPA. REGION VXII. AGREES TOi
1. Approve location of South Park treatment facility and provide stan-
dard design and conatruction funding assistance as per their existing
rules and regulations and per their agreement with the State of Wyoming.
Department of Environmental Quality (DEQ).
2. Approve location of South Park interceptor sewer and provide stand-
ard design and construction funding assistance as per their existing
rules and regulations and per their agreement with the State of Wyoming,
DEQ.
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3. Approve addition of septic waate handling facilities and provide
standard design and construction funding assistance as per their ex-
isting rules and regulations and par their agreement with the State of
Wyoming, DEQ.
4. Approve all reasonable structural designs developed jointly by the
City and County and provide standard design and construction funding
aaaistance as per their existing rules and regulations and per their
agreement with the State of Wyoming, DEQ.
•
5.- Review the City's new sewer system pricing policy for consistency
with BPA regulations and guidelines on user fee requirements and
industrial cost recovery requirements.
6. Require an annual report (and access to documentation of said report)
of th* City stating the number and location of in-city and out-of-city
taps granted in that year.
7. Recognize goals of the County Comprehensive Plan in making EPA
decisions in the area.
8. Make funding aaaistance in accordance with EPA rules and regulations
to build new plant and interceptor, said grant to be conditioned upon
full and continued performance of this agreement Cor the design life
of the facility which shall be until 1995. Further, will agree to seek
other sanctions as might be necessary to assure full and continued per-
formance with this agreement by all parties. Such sanctions may include,
but not be limited to, the following:
~Court directed mandatory compliance with provisions
of agreement by all parties
•Court directed repayment of federal sewer grant funds
~limitation on future EPA funds to area
WHEREFORE, the parties hereto have executed this Agreement through
their duly authorized representatives, the date of signing as set forth
below. This agreement shall not be binding until it has been executed
by all parties.
TOWN OF JACKSON
CXtL^/]+/.: uuttz. Oau.1 197%
( date
date
U.S. ENVIRONMENTAL PROTECTION AGENCY
date
/sJ. 4-/3-7f
dace
-75-
-------
APPENDIX B
Permi t No.: U) O o 2. I
DRAFT DISCHARGE PERMIT *
Effective Date: Date of Issuance
Expiration Date:
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
Ci-rr^rtJ
In compliance with the provisions of the -Federal Water fte-1-1utinn fnntrnl _
Act, as amended (33 U.S.C. 1251 et. seq.) (hereinafter referred to as
"the Act"),
"Tw«- 7oo>Ai 15F ^
/ *
is authorized by the United States Environmental Protection Agency
to discharge from THG /£x-STZT*5 U^TfiuAre*
f" f\C.TLZ TY ool^ T?'s,UT pncrurTY (Oot^All CO"2.^
t0 ^ctVr Cft-^r-fc
in accordance with effluent limitations, moni^o^ng requirements and other
conditions set forth in Parts I, II, and l\K^ hereof
Is
Authorized Permitting Official V~^ Date
Title
*
Thirty (30) days after the date of receipt of this permit by the Applicant.
76
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Part I STP
Page ^ of "Z&
Permit No." e. /4-£"£>
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SEE ANY ADDITIONAL
REQUIREMENTS UNDER PART III.
T |vMfA£S>:=V\rS. . _ ,
1 Effluent Limitations— UOI
Effective immediately^"the quality-of effluent discharged by
the facility shctl 1, aoy a minim^mT-fneet-th^H-mftations-as s et-
forth •below. ¦ J
There ahnll^jjg^norchange in opera t'iuii bhat will significantly
dotopiopfrto the quality of tfre itibUrarytrbelOH that~pr&-9gfrted*
4*>-4fag^penn>t app4-ication-.
>V\rJ t> LfirsTTfJA U^TZ_ 7>rS rrcirJ AMO fa t /^rNi*3roT
OP CWKiTs o£is£jVT»*Jrtt- STATUS oF^WEiO Oi*-
pPniT 31 3. a? t-^ts t) ) l^tm
Fvrtbs A-rJb bSfS^^r) -Tfc twFcT- TW5 3F
- — tV-Ic. Olj/H-J- / f V
V-T» IA.2. AN* OF rWTS P.^^TWC «A">i f'A^. v:T TH-t UO**-^ /-
-------
Part I STP
Page 3 of 'zo
Penult No.: iiiS-oo2.1 t-S'B
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SEE ANY ADDITIONAL
REQUIREMENTS UNDER PART III.
^^Efffuent Limitations - 003-
Effective SepTt^fbEfc.3^ '^SOand lasting through 0ar-i0<3. c Ftou**- p\AY I —'CTiSBAiT^
Average Effluent Concentration
30 Consecutive 7 Consecutive
Parameter Day Period Day Period
BOD5 - mg/1 $
Total Suspended Solids - mg/1 Jl)
Fecal Coliform - number/100 ml ^ 0 £> .£/£_[
Tor^C ^jiSTTiUtarC. C.VHoir>Jt. — r^^/j?. O.oSjJ
f\f>( a.v owrA A^rTTco^f,^ —^ ^
(OxT^or,FM V) I 33. j/
2-^i/
pH - units Shall remain between £.Oand ^.0 v d/
a/ This limitation shall be determined by the arithmetic mean of a
minimum of t,hree (3) consecutive samples taken on separate weeks in a
30-ciay period (minimum total of three (3) samples); not applicable t.o
fecal coliforms - see footnote c/.
b/ This limitation shall be determined by the arithmetic mean of a
minimum of three (3) consecutive samples taken on separate days in a
7-day period (minimum total of three (3) samples); not applicable to
fecal coliforms - see footnote cj .
cj Averages for fecal coliforms shall be determined by the geometric
mean of a minimum of three (3) consecutive grab samples taken during
separate weeks In a 30-day period for the 30-day average, and during
separate days in a 7-day period for the 7-day average, (minimum total
of three (3) samples)
d/ Any single analysis and/or measurement beyond this limitation shall
be considered a violation of the conditions of this permit.
Q.J CouTF^C~»N. m--, 'J J fU-£ i-;--c.T?v\2=fc o? c !*«.•: Y^t- .
78
-------
y 77f^ wnTAr**'* * ^
-r-uc >?/? / TMSTE. 77 C_
•"•"* - UW-* TM>J< "O
/*)£:&as a/? T+r/r -A qwyr/ry
PWf-ne-TB-Z . £>JSC. wax ee D ; A
/1//y'rjess*l f=- ^3J) Co^s SCvr/r^
-.pi-771"
^ 04YS /" # 7-0*y P£*'*d. Tme. o+,uy
QwsrrTy D/Sc.H4r&£: o Smail* 8£¦
DE- rEzm/s^en /=^0/^ <4i/eAAc-a.
fuo t*s a fVQ P4A* rie. TEZ r,
(p**t»2£> F Rem ¦ c CSV Pes/re. 5 #<~)pL>sr& /$ 5
PE~F //V P*AT
-------
Part I STP
Page of ~2-0
Permit No.: OJ^—co
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SEE ANY ADDITIONAL
REQUIREMENTS UNDER PART III.
Effluent Limitations — Ootfau.
Effective •^Eprs-,fAeefe-^i and lasting through 3°j
the quality of effluent discharged by the facility shall, as a
minimum, meet the limitations as set forth below:
Pffciob txjwrr-ks (^prtZWriL TlUiv^ O C7"3Gc£. IS" THOUGH
Average Effluent Concentration
30 Consecutive 7 Consecutive
Parameter Day Period Day Period j[J<5-^-^1
BOD5 - mg/1
3o *rskj
Total Suspended Solids - mg/1 5"o Jj Qj
-Eocal -Coliforffl numbci-/100 ml1
~Tt>-rf\L ^ O.OS —
iO-tp* N-rT^OfTP^— (fis Ai3
A.I-T*DoE/01 — (fir V) f £ 4
/JrT^o,o . d/
a/ This limitation shall be determined by the arithmetic mean of a
minimum of three (3) consecutive samples taken on separate weeks in a
30-day period (minimum total of three (3) samples); not applicable to
fecal coliforms - see footnote c/.
b/ This limitation shall be determined by the arithmetic mean of a
minimum of three (3) consecutive samples taken on separate days in a
7-day period (minimum total of three (3) samples); not applicable to
fecal coliforms - see footnote c/.
cj Averages for fecal coliforms shall be determined by the geometric
mean of a minimum of three (3) consecutive grab samples taken during
separate weeks in a 30-day period for the 30-day average, and during
separate days in a 7-day period for the 7-day average, (minimum total
of three (3) samples)
d/ Any single analysis and/or measurement beyond this limitation shall
be considered a violation of the conditions of this permit.
80
-------
j£/ Llrv)l7Ar>os>' sw-t-
Atx, -r*F~ /)R*T»so*rs c~
/\c o ay / r7
* oA'uy E r/j,< \">
/>)j£/iaS 0* 1~»s? * qcssy^r/TY o* TH 5
PAt/tlc-rEi-i? X)/S(LH/}*6:££> Co»S :
W/ysn^sn rV c*~s ecrr/re.
_ .^4
$*"F D*ys /~ /} 7-£>*y P£fco. r»£L o^,^y
QuA'spry O/Sc.w#q6-je O Smal.^ &£-
De. r£xr?>^bj> fZ8or*j . tm^- >? re/?*£.&
0>*Ht>eD pf>a?~Y ' CC/VPG5 JT£_
j as pAftT cSy FaR T#s*7~~
D*y,
81
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pAS/5 a?
pe^r 'Jo. i Or-
r"°°~n^TTi ga^r.-»ogo i*ti 77-*^T ^;M^r _
f?E /^ceowtlf K£fl SaL-tlM g V /^t?ie>/>rlg^ FOt-<-^*A fly 3NE
p£- (M-ppg. ^C(vmjt urrtt prr<-fcr pj^cf-v^sr To 77*e
^-gg-£2n/T>/c; STLtL/W M17M£.Z^€r\ ONLY Oog.^M^ ~T7±E P££^>(\ ?,
f^grwE . Tf rrrrs system a* Pftjfjygp _r< a^t- g.^j^TUuert-oj T^rs
JVCe^CE-TL-CJT3X,. gg" Tt) ?EFig:u,\u..y 1 XP 77-^r-s ? Y/T-,^ -S CQMfT^XT^D
j£/
t4-< PE-aP/isr* A^Q ofiE.X^Tr^AJs bar* ir^^^rAT? 77^~ T>~£sr ut^ttat^^s
r.A^iuor t?g ^o-pri/gft rvjg To .G.fcQcJ-r>f, 17+rs Pe^rT fjat re?
flu->SrfTEO To fiee-lect IESr ELCrmcT^/g D^Cf-^LcfE Ctkj ,
ZZMS^^t Hi**.
4*. f\ n>n~ TrpMfrL O.P^(5^T^=»^Ai fcE^orv-g^irrurs — A/?u t-^dn-z-rr
X F" PCocpsci)^ _^F,rz,2j^.l7^cJ /. r ££~cot^rrq.^ „Bd557^S_./i&s__
GC7~g 0 _ ^ ? T7V£~ Atrl77ra?) £>£ ULj-iy^Tc. _.cRcdU fWT .
^-'ID T? rr- , /v 1 c^-v;^j-~T3 „'j5r? 1
<.^t 1 P" AJO_ ^T5.C I-h^-y-r TciJu^-TNQ T%f~ pgft-oft fita-M. /'^iVri—Ocropgt'L
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uJ . _/F\ C^ U-Y.J .H-rtz iL& S*±fiLL. Il7 NO_DZXE-CT_ Q ^^.trr^.._7>^__
4^—- pc c^rvrrj^, 5tjc.cfav77-^r pgiP-tsq ¥&>**• [)<^T£>BEiz. h —
^f^T^L^O DF ?-ACH VNLZSS ONu__OpU C?_
.T'-P-. r_5L^Du. ^. c1 Trrnj5 A C^rVro ^ T)0cO'j. 1 (5 AiXC, D_:__
| Ly** P "^C- CowUrTiBAJi WVE p.e5ucea.F-£ rzx.T^A~r^>H A*b/a H. ?S.^CAL^rrV!
_ ?ATEj? To wHi\=C.eoLii)7-'T5^ TR'.^T. (3* Cowe _.p.c=.
82
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to = OP- FP-O^ PfFLUiMT C£^0lTroM$ j
"S. ^E\/^;p.e Ljrrirrr^-rrrAE A7" T7~r£^ XTJ"^ ^.C-TY Of J7^2.7^tz^m /
T^fccoU\~n=»vi of*- uoct-o
T^ZEhTZ:-^ er *7>"irfc- Qi^T^tJUc a Ui"'3 CAJ&tiL.
Tvt^e casibrT-rjN'x. T^-^s" oho CDv/ccursn E-jr rr uit
t?*? ~ r';: - "V '"*
/-fcrva:Ttt> of- 1/^-^5 or-- prprr-e? /3r /^ £esJtr
OF irFPLO^T - ,
E^A'P^\jcr_-DNi Ic^c Qyirr.'g /t^""£
f^j - :,-- ^ tr y;v: f uy_o vo,_g>j.\(c irrJF'-^Mr 7-3 r--E
P\<~- E .'. r\rr-"c 71 p - r -"c rL-~-- txac^s- 2l ,€> A''-," ^
77-t? P€£c-^ r.--;« /',AY l-Cc.-JC-" '1-
|.4-J\o""n Dj•"'iv.r} ~T<£ Pr^rofj ^c~^" £_ (C— /r?:,~-~c_3dj
7>r j.*-^it~t<~fL ;< jr r Ec-f^j °c-t<-i-"v.^'.^-T
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Ff\e: 7*-£"TY\
83
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rari. i
Page 4 of 2-0
Permit No.: "2.
Self-Monitoring Requirements — DrsCHAR/je? Tt> t*c~ P-eCEIVTNS strsatw
The permittee shall monitor his discharge(s) as shown below:
Parameter
Frequency a/
Total Flow, mgd C,o*
Total B0D5, mg/1 c/
Total Suspended Solids, mg/1 c/
Fecal Coliforms, number/100 ml
pH, units -fj bfrZl-X
"7o7t°vc ^CSrfiO^c
^ °C ej ^A-U-Y
^*.rA.DvirN fJxT^OC\C#Jj fcU) WfEW-Y
Sample Type b/
fuow
CjErv^po j-'rs
Co^otrTt
G fcAt*
cSi
C*WO*-te
G/wqs.
a/ Quarterly samples shall be collected during the months of January,
April, July, and October, if a continual discharge occurs. If the
discharge occurs on an intermittent basis, the quarterly sample shall
be collected during the period when that intermittent discharge occurs.
b/ See definitions, Parte.
c/ In addition to monitoring the final discharge, influent samples
shall be taken and analyzed for this parameter at the same frequency
as required for this parameter in the discharge.
elf fiAoiJLTofl. OM-Y JTF CjH,d2s*J£ ^ USTZD UJ*fT£<-J4~r£t- TZ€Jc5 6c/t?EPi-V P^-EQOEfJcy tr J /\$JT Q>l)ATCT
R>t.TW-fG Pft*M.er£ .
oj epee^T-rvE Cfpoio xmst^atsw oF * -sn^f^ fcsvjce *<;
OP Cb»ajrt4)c.7i-5»j
84
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Part I
STP
Page ^ of 2^
Permit No.:
Self-Monitoring Requirements —rfcoiM-Twr
L-A^oom T» 7Wf xNJRn-Tw^'YP£^-^,J BA»
The permittee shall monitor his discharge(s) as shown below:
-To F=oo"P^oTas ou pa<*£&
Parameter
Frequency a/
<10iOTZrxJOOJ5
UJ\5-E,KXY
Sample Type b/
Fux*i ^C.COfi-Pi££_
C^WOSSTE
C^-V-^PO^-7E
Total Flow, mgd
Total BOD5, mg/1 c/
Total Suspended Solids, mg/1 zj 1/JcEtCY
Fecal -Coliformo} number/100 ml—
•pH» units- .
Wecu-t
~7Zr*t, C**0
]£e frZPOUT T>££
Dl^TE-S Ari& T^Tta^T of frrVf "P-^T ^CH / Pf= <.COL*r:rc <0
Ti^S-rri -X-S rLOO^Sb UJI7"H 3 FPlOEi^Tj rTAWS l/OCO'.VAn or
EFFluEiOT frPPLZTEb TO 73ASrw PES. ^P^crc^-pro^, T!^
/^fp^Oxr?ArA-re AMDJMr o? 73ME ^ fv^SO TW T>r€ DewArc^jnv.ci Cr
EPc-W
Cs<*~-f*Sz:TZ
C-ixV^Joss74u]y» and October, if a continual discharge occurs. I£-ttte:
dischargeirecucs on an intermittent basis, the quarterly-sample shall
be collected durTrrg^the period wnvn that intermittent discharge occurs.
b/ See definitions, Parte
c/ In^ddi-ttOnto monitoring tut final discharge, influent samples
jj&H^Se taken and analyzed for this parameter at ~t"fi"e-same frequency
as required for this parameter in the discharge.
85
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Part I STP
Page 8 of "Z-O
Permit No.: UV — oo ~z 14-rS
Self-Monitoring Requirements—bacn
-— tcst ujEz.lc c^sra*JcT3o A-r A
The permittee shall monitor two discharged) aa shewn below: ,
"£•£.QorGLe./M5.tfT DUtherms o? to r-» XT-rirwicoM/
PaPrgmot^r>T^TlKi b»<^£xn5 ^equency aifJ>y^ ¦ Sample Type b/
To poftr^ont^ »/-> PF^t U
•Tota-1 Flowi mgd
Total BOD5, mg/1 c/
Total Suspended Solids, mg/1 c/ UJfc.E.»«is
Tc» CiitSjOOfc'iivjJATCA.j "»*"
/Qlv-tw. a*Jrja< i^/4 (KM) l/teLY
fJrniLtGfSfij ^/JL (fi$N) CJetw-v ^ *aij
be collected during the months of January,
a continual discharge occurs._^J-f--the'
*>A^Quarterly samples shall
ApriTSkily, and October, if ^
discharge otcurs on an intermittent basis,, the quarterliesample shall
be collected durtng^the period when that intermittent discharge occurs
b/ See definitions,
c/ In additioa-to-"monitoring the final discharge, influent samples
shall^,be-taKen and analyzed for this parameter at tfi"e"~sam^frequency
as^fequired for this parameter in the discharge.
Part C.
86
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Pip 5 of 2o
Peimu No. IaDY-OQ Z,(jrr IW&rtKBLZ ^UhiS /Way /^t"^
4; /Vpp-ov/E. ft-ftrJ* am> ^eATiro>J5
¦5". (5i=$a>J Q»>rm/cTrDN/
5o9MrT C)WiT&ut-na*i Status
^ fl*T7fi£N*AZAr' OiW65r£
O Pt*J'H. ^*7^ TO 5
"3~v^. 16] 1^^
To^
/t/t^w ?l, 1^80
2. No later than 14 calendar days following a date identified in the above schedule of
compliance, the permittee shall submit either a report of progress or, in the case of
specific actions being required by identified dates, a written notice of compliance or
noncompliance. In the latter case, the notice shall include the cause of noncompliance,
any remedial actions taken, and the probability of meeting the next scheduled
requirement.
Compliance and interim reporting dates shall be for periods not to exceed
nine (9) months and to the extent practical shall fall on the last day of
March, June, September, and December.
87
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PART I STP
Pjgc (O of
Permit No 00^"" O0
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PARTI 3"*
Fjp.' I' ol ~ZO
fcrmil No B
d. The analytical techniques or methods used; and
e. The results of all required analyses.
6. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more
frequently than required by this jiermit, using approved analytical methods as specified
above, the results of such monitoring shall be included in the calculation and rnportinR of
the values required in the Discharge Monitoring Report Form (EPA No. 3320 1). Such
increased frequency shall also be indicated.
7. Records Retention
All recorde and information resulting from the monitoring activities required by tlm
permit including all records of analyses performed and calibration and maintenance of
instrumentation and recordings from continuous monitoring instrumentation shall be
retained for a minimum of three (3) yean, or longer if requested by the Regional
Administrator or the State water pollution control agency.
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Page I of2°
Pel mil No. U)y-00 2./
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Paje /3 of ^ ^
Peimil No. 1OoZ (
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or
control of wastewaters shall be disposed of in a manner such as to prevent any pollutant
from such materials from entering navigable waters.
7. Power Failures
In order to maintain compliance with the effluent limitations and prohibitions of this
permit, the permittee shall either:
a. In accordance with the Schedule of Compliance contained in Part I, provide an
alternative power source sufficient to operate the wastewater control facilities;
or, if such alternative power source is not in existence, and no date for its implementation
appears in Part I,
b Take such precautions as are necessary to maintain and operate the
facility under his control in a manner that will minimize upsets and
insure stable operation until power is restored.
B. RESPONSIBILITIES
1. Right of Entry
The permittee shall allow the head of the Sta^rc water pollution control agency, the
Regional Administrator, and/or their authorized representatives, upon the presentation of
credentials:
a. To enter upon the permittee's premises where an effluent source is located or in
which any records are required to be kept under the terms and conditions of tiiu
permit; and
b. At reasonable times to have access to and copy any records required to be kept under
the terms and conditions of this permit; to inspect any monitoring equipment or
monitoring method required in this permit, and to sample any dischaige of pollutants.
2. Transfer of Ownership or Control
In the event of any change in control or owner-hip of facilities from winch the authorized
discharges emanate, the petinittee shall notify the succeeding owner or controller of the
existence of this permit by letter, a copy of which shall In; forwarded to the Regional
Administrator and the State water pollution control agency.
3. Availability of Reports
Kxcept for data determined to be confidential under Section 30S of the Act, all n-porLs
piepaied in accordance with the terns of this permit shall be available for public
91
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r/sn i m
SIP
Page 14 of 2 5
Permit No. WY"*Oc>2l^<'
inspection at the offices of the State water pollution control agency and the Regional
Administrator. As required by the Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may result in the imposition of
criminal penalties as provided for in Section 309 of the Act.
4.- Permit Modification
After notice and opportunity for a hearing, this permit may be modified, susDended, or
revoked in whole or in part during its term for cause including, but not limited to, the
following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant
facts; or
c. A change in any condition that requires either a temporary or permanent reduction or
elimination of the authorized discharge.
5. Toxic Pollutants
Notwithstanding Part II, B-4 above, if a toxic effluent standard or prohibition (including
any schedule of compliance specified in such effluent standard or prohibition) is
'established under Section 307(a) of the Act for a toxic pollutant which is present in the
discharge and such standard or prohibition is more stringent than any limitation for such
pollutant in *his permit, this permit shall be revised or modified in accordance, with the
toxic effluent standard or prohibition and the perm'ttee so notified.
6. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II, A-5) and "Power
Failures" (Part II, A-7), nothing in this permit shall be construed to relieve the permittee
from civil or criminal penalties for noncompliance.
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or
relieve the permittee from any .responsibilities, liabilities, or penalties to which the
permittee is or may be subject under Section 311 of the Act.
8. State Laws
Nothing in this permit, shall bo construed to pt relink* the institution of any Ic^jI action or
relieve the permittee.* from any responsibilities, liabilities, or penalties established pursuant
to any applicable Slate law or regulation under authority preserved by Section 510 of the
Act.
92
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Pige /!>' of 2.°
Peimli No. tOY-OO 2 I +-5"2>
9. Property R igh ts
The issuance of this permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does'it authorize any injury to private property
or any invasion of personal rights, nor any infringement of Federal, State or local laws or
regulations.
10. Severability
The provisions of this permit are severable, and if any provision of this permit, or the
application of any provision of this permit to any circumstance, is held invalid, the
application of such provision to other circumstances, and the remainder of this permit,
shall not be affected thereby.
PART III
OTHER REQUIREMENTS
Additional Bypassing Requirements
If, for other reasons, a partial or complete bypass is considered
necessary, a request for such bypass shall be submitted to the State of
and 'co the Environmental Protection Agency at least sixty
(60) days prior *0 the proposed bypass. If'the proposed bypass is
judged acceptable by the State of and by the Environmental
Protection Agency, the bypass will be allowed subject to limitations
imposed by the Stite of ant4 the Environmental Protection
Agency.
If, after review and consideration, the proposed bypass is determined
to be unacceptable by the State of Wyju^saJ!?! and the Environmental
Protection Agency, or if limitations imposed on an approved bypass are
violated, such bypass shall be considered a violation of this permit;
and the fact that application was made, or that a partial bypass was
approved, shall not be a defense to any action brought thereunder.
Percentage Removal Requirements
Effective immediately, the arithmetic mean of the Total BOD5 and the Total
Suspended Solids concentrations for effluent samples collected in a period
of 30 consecutive days shall not exceed 15 percent of the arithmetic mean
of the concentrations for influent samples collected at approximately the
same times during the same period (85 percent removal). This is in
addition to the concentration limitations on Total BOD5 and Total Suspended
Solids.
93
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Page I (• of "2.0
Permit No. oof-oo-zi^'Td
OTHER REQUIREMENTS (Continued)
Industrial Wastes
A. Each major contributing industry must be identified as to
qualitative and quantitative characteristics of the discharge
as well as production data. Such information shall be sub-
mitted within one hundred twenty (120) days of the issuance
Of this permit. A major contributing industry is defined as
an industrial user discharging to a municipal treatment works
that satisfies any of the following: (1) has a flow of 50,000
gallons or more per average work day; (2) has a flow greater
than five percent of the flow carried by the municipal system
receiving the waste; (3) has in its waste a toxic pollutant
in toxic amounts as defined under Section 307(a) of the Clean
Water Act of 1977 (Federal Register dated January 31, 1978);
or (4) is found by the permit issuing authority to have a
significant impact on the treatment works or the quality of
effluent from the municipal treatment works.
B. The permittee must notify the permitting authority of any
new introductions by new or existing sources or any substantial
change in pollutants from any major industrial source. Such
notice must contain the information described in "A" above
and be forwarded no later than sixty (60) days following the
introduction or change.
C. Pretreatment Standards (40 CFR 403.5) developed pursuant to _
Section 307 of the Act require that under no circumstances
shall the permittee allow introduction of the following pollutants
into the waste treatment system from any source of nondomestic
discharge:
(1) Pollutants which create a fire or explosion hazard in the
publicly owned treatment works.
(2) Pollutants whicn will cause corrosive structural damage to
treatment works, but in no case, discharges with a pH lower
than 5.0, unless the works is designed to accommodate such
discharges.
(3) Solid or viscous pollutants in amounts which will cause
obstruction to the flow in sewers, or other interference
with the operation of the publicly owned treatment works.
(4) Any pollutant, including oxygen demanding pollutants
(BOD, etc.), released in a discharge of such volume or
strength as to cause interference in the publicly owned
treatment works.
(5) Heat in amounts which will inhibit biological activity in
the publicly owned treatment works resulting in interference
but in no case heat in such quantities that the temperature
at the treatment works influent exceeds 40° C.(104° F.)
unless the works is designed to accommodate such heat.
94
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Page ! ^ of 2-^
Permit No. U/Y-oo-ao-cfc
OTHER REQUIREMENTS (Continued)
Industrial Wastes
A. Each major contributing industry must be identified as to
qualitative and quantitative characteristics of tho discharge
as well as production data. Such information shall be sub-
mitted at six (6) month intervals on June 30, and December 31,
of each year. A major contributing industry is defined as
an Industrial user discharging to a municipal treatment works
that satisfies any of the following: (1) has a flow of 50,000
gallons or more per average work day; (2) has a flow greater
than five percent of the flow carried by the municipal system
receiving the waste; (3) has in its waste a toxic pollutant
in toxic amounts as defined under Section 307(a) of the Clean
Water Act of 1977 (Federal Register dated January 31, 1978);
or (4) is found by the permit issuing authority to have a
significant impact on the treatment works or the quality of
effluent from the municipal treatment works.
B. The permittee must notify the permitting authority of any
new introductions by new or existing sources or any substantial
change in pollutants from any major industrial source. Such
notice must contain the information described in "A" above
and be forwarded no later than sixty (60) days following the
introduction or change.
C. Pretreatment Standards (40 CFR 403.5) developed pursuant to
Section 307 of the Act require chat under no circumstances
shall the permittee allow introduction of the following pollutants
into the waste treatment system from any source of nondomestic
discharge:
(1) Pollutants which create a fire or explosion hazard in the
publicly owned treatment wo'ks.
(2) Pollutants which will cause corrosive structural damage to
treatment works, but in no case, discharges with a pH lower
than 5.0, unless the works is designed to accommodate such
discharges.
(3) Solid or viscous pollutants in amounts which will cause
obstruction to the flow in sewers, or other interference
with the operation of the publicly owned treatment works.
(4) Any pollutant, including oxygen demanding pollutants
(BOD, etc.), released in a discharge of such volume or
strength as to cause interference in the publicly owned
treatment works.
(5) Heat in amounts which will inhibit biological activity in
the publicly owned treatment works resulting in interference
but in no case heat in such quantities that the temperature
at the treatment works influent exceeds, 40° C.(104° F.)
unless the works is designed to accommodate such heat.
95
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Page of 2 o
Permit No.
OTHER REQUIREMENTS (Continued)
Industrial Wastes (Continued)
D. In addition to the general limitations expressed above,
more specific pretreatment limitations have been and will
be promulgated for specific industrial categories under
Section 307 of the Act, including but not limited .to,
those listed below. Compliance with these regulations is
required no later than three (3) years following the date
of promulgation: (See 40 CFR, Subchapter D, Parts 400
through 500, for specific information).
Automatic and Other Laundries
Coal Mining
Electroplating
Inorganic Chemicals Manufacturing
Iron and Steel Manufacturing
Leather Tanning and Finishing
Machinery and Mechanical Products Manufacturing
Miscellaneous Chemicals Manufacturing
Nonferrous Metals Manufacturing
Ore Mining
Organic Chemicals Manufacturing
Paint and Ink Formulation and Printing
Paving and Roofing Materials
Petroleum Refining
Plastic and Synthetic Materials Manufacturing
Pulp and Paperboard Mills and Converted Paper Products
Rubber Processing
Soap and Detergent Manufacturing
Steam Electric Power Plants
Textile Mills
Timber Products Processing
E. At such time as a specific pretreatment limitation becomes
applicable to an industrial contributor, the permit issuing
authority may, as appropriate, do the following:
(1) Amend the NPDES discharge permit to specify the addi-
tional pollutant(s) and corresponding effluent limitation(s)
consistent with the applicable National pretreatment
limitation;
(2) Require the permittee to specify, by ordinance, contract,
or other enforceable means, the type of pollutant(s) and
the maximum amount which may be discharged to the
permittee's facility for treatment;
96
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PART III STP
Page of 2.0
Permit No.OJY-Oozv^b"1^
OTHER REQUIREMENTS (Continued)
Industrial Wastes (Continued)
E. tContinued)
(3) Require the permittee to monitor its discharge for any
pollutant which may likely be discharged from the
permittee's facility, should the industrial contributor
fail to properly pretreat its waste.
The permit issuing authority retains, at all times, the right to
take* legal action against the industrial contributor or the treatment
works, in those cases where a permit violation has occurred because
of the failure of an industrial contributor to discharge at an accept-
able level. If the permittee has failed to properly delineate maximum
acceptable industrial contributor levels, the permitting authority
will look primarily to the permittee as the responsible party unless
the contributor's discharge is obviously unacceptable under 40 CFR,
Subchapter D - Water Programs.
97
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PART iU STP
Page of *2°
Permit No. uV-oo2a4^~B
OTHER REQUIREMENTS (Continued)
Violation's Resulting from Overloading
Should there be a violation of any conditions of this permit, the
United States Environmental Protection Agency has th& authority
under Section 402(h) of the Clean Water Act to proceed in a court
Of competent jurisdiction to restrict or prohibit further connec-
tions to the treatment system covered by this permit by any sources
not utilizing the system prior to the finding that such a violation
occurred. It is intended that this provision be implemented by the
Agency (or the State) as appropriate.
Reapplication
If the permittee desires to continue to discharge, he shall reapply
at least one hundred eighty (180) days before this permit expires
using the application forms then in use. The permittee should
also reapply if he desires to maintain a permit, even though
there was not a discharge from the treatment facilities during
the duration of this permit.
Compliance with Construction Grant
The permittee shall comply with those terms of any construction
grant implementing the provisions of Section 201(b) through (g)
of the Clean Water Act.
Staffing and Laboratory
Efficient facility operation contained in Part II, A.3., of this
permit shall include but not be limited to adequate ODerator
staffing and training as well as adequate laboratory and process
controls.
98
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APPENDIX C
COORDINATION AND CONSULTATION
This section contains letters of comments from individuals
and groups to the Jackson Wastewater Treatment System Draft
EIS. Those letters which commented directly on the Draft
EIS have been reproduced in this document. Where a
response is required of EPA to the letter, a response page
follows that letter.
The following table is a listing of the comment letters
received, the page in this chapter on which they can be
found, and a general category listing of their contents.
Comment categories are shown in a general attempt to indicate
those aspects of the proposed action about which the commen-
tors were most interested and concerned.
On June 28, 1977, at the Teton County Courthouse, Jackson,
Wyoming, the EPA held a public hearing on the Jackson Draft
EIS. The hearing was attended by approximately 4 5 people
of which 19 presented testimony into the official record.
Because of the length of the official hearing record and
the costs involved, EPA has not reproduced the document for
the final EIS. A summary is provided, however, listing the
speakers, their support or opposition to the project, and
the areas in which they were most concerned. The Public
Hearing Record is available for public scrutiny at the Town
of Jackson's city offices, and EPA's Region VIII Office,
Denver, Colorado.
The following is a brief summary of comments received at the
Jackson Wastewater Treatment System Draft EIS hearing:
1. Mr. Al Simpson (I) - Individual cost mid-South Park vs.
South Park Road?
2. Mr. Ross Porter (R) - Type of lagoon? Will there be
odors? Would rather pay for extra cost of a mechanical
lagoon to reduce odor problems.
3. Mr. Hans Buehler (R) - Questioned lagoon operation in
Jackson.
4. Mr. Gordon Bruchner (C) - (NHPQ Facility Plan Engineer)
Indicated that NHPQ would intend to design a completely
aerobic lagoon system to reduce odor.
5. Mr. Al Simpson (I) - Attorney representing Henry & Emily
Oliver against Site No. A-4 Mid-South Park. Favors A-5
(South Fork), if large service area is to be consideredt
6. Mr. Dick Ehrbright (A) - (Superintendent of Schools)
Indicated that the South Park Road or the do-nothing
alternative would have the greatest potential of impact
upon the county school district.
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7. Ms. Joyce Lucas (R) - Objected to the South Park Road
site on the basis of odors.
8. Ms. Rose Kepford (R) - Objected to South Park Road site.
9. Mr. Orin Soest (R) - Concerned about exact location of
South Park Road site.
10.
Mr.
Lou Wilson (R) - Favored a southern-most site.
11.
Mr.
Chuck Luton (R) - Favored a southern-most site.
12.
Mr.
the
Don Phillips (R) - Indicated he thought the elk on
Federal Refuge were polluting the valley's water.
13.
Mr.
the
Denny Becher (R) - Favored an effluent line entering
Snake River as far south as possible.
14.
Mr. Lon Wilson (R) - Questioned location of Boyles Hill
site.
15. Ms. Pam McCool (R) - Questioned whether population figures
included the proposed Brown Hill development in South
Park.
16. Mr. Ross Porter (R) - Questioned why a mechanical plant
at South Park wasn't considered.
17. Mr. Jim Gilbert (R) - Favored a mechanical plant over
a lagoon at any site.
18. Mr. Hans Buehler (R) - Questioned the cost effectiveness
of doing an I and I study at Jackson and the flow figure
related to I and I.
19. Mr. Reid Jackson (A) - (Teton National Forest) Questioned
why tertiary treatment wasn't considered as a method of
improving water quality to protect the wildlife and
scenic values of the area.
(A) - Agency
(C) - Consultant
(I) - Intervener
(R) - Resident
Table 10 presents a summary of the written comments that we
received by the EPA during the 45-day review period. Following
the table are the letters and responses prepared by the EPA.
The Environmental Protection Agency, Region VIII, wishes to
express its appreciation to all commenting agencies, groups
and individuals for the time and effort spent in reviewing the
Draft EIS. All comments were presented to the Regional Ad-
ministrator and were considered by him in the EPA's decisions-
making process.
-100-
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
TABLE _10
COMMENT RECEIVEfTON DRAFT
EIS
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United States Department of Agriculture
FOREST SERVICE
Bridger-Teton National Forest, Box 1888, Jackson, Wyoming 83001
June 10, 1977
John A. Green
Regional Administrator
Region VIII Office
U.S. Environmental Protection Agency
1860 Lincoln Street
(Denver, CO 80203
Dear Sir:
I appreciate the opportunity to review the Draft Environmental Impact
Statement for the Jackson Wastewater Treatement System. As you have
noted in the statement, the Forest Service is directly involved because
of responsibilities as Lead Agency in the Wild and Scenic River Study.
Also, we have much interest in the town of Jackson and County of Teton
due to our overall management responsibilities and involvement in county
and city planning. Following are our comments on your Draft EIS:
Summary Sheet, Paragraph B; You probably ought to mention that the
proposal is also located within the Wild and Scenic River Study
Corridor.
2. Page 1-4 and 11-14 and 16: There appears to be a misunderstanding
2-
between us on what PL 90-542 says regarding responsibility for
projects occurring during the study. As Lead Agency we do not have
the responsibility for making determinations on the effects of
projects developed by other agencies on potential Wild and Scenic
or Recreational River classifications. We do not have the respon-
sbility of developing mitigating measures that are necessary to
make a project we are not proposing or developing compatible with
a classification potential. Also, we do not have authority to
decide whether or not a project may be allowed to proceed. This
authority rests with the appropriate Secretary and is not delegated
to the Lead Agency.
As Lead Agency we have responsibility for seeing that the Wild and
Scenic River Study is completed in a proper manner and within time
frames. We feel we have responsibility to monitor interim projects
and assure that the involved agencies comply with procedures out-
lined in Sections 7(b) and (c). We also feel responsible to advise
and aid the involved agency where possible in meeting requirements
of the Act.
-103-
62DD-I1 (1/69)
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Section III; An additional problem you probably ought to expand
upon in thi6 section is the problem of constructing a lagoon within
the Wild and Scenic River Study Corridor in a manner that will not
affect classification potential. As you know, the "proposed site is
in one of the few public access and camping areas in this river
section. The Interagency Study Committee has identified classifi- '
cation potential as Recreational for this river section. It would f
seem that designing and constructing a facility of this size would
be difficult without adversely affecting the desired recreational
character.
Sections V and VI: You make no determination in your impact sec-
tions on how the proposal or alternatives affect possible Wild and
Scenic River Classification. As stated in our point number 2, we
feel this is an important aspect of the project EIS and your respon-
sibility. Section 7(b) of the Wild and Scenic River Act documents
this requirement. It would also seem that without identifying such
effects the statement is inadequate considering NEPA*s requirements.
Of particular concern is how the outflow of secondary effluent
would affect the water quality standards described in the "Guide-
lines For Evaluating Wild, Scenic And Recreational River Areas
Proposed For Inclusion In The National Wild And Scenic Rivers
System Under Section 2, Public Law 90-542." It may actually im-
prove classification potential if water quality is improved.
Another important potential effect is the outflow structure's
effect on recreational, scenic, wildlife or other attributes. As
we mentioned in our previous letter to you, the stream instability
of the Snake makes outflow structures a problem. The Statement
should specify what consequences may occur and mitigating measures
that can be taken to reduce effects and possibly make the structure
acceptable.
Your agency is the acknowledged expert in identifying consequences
of such projects. You also have expertise in developing design
features that can reduce adverse consequences of this type of
activity. In other words, your agency is the logical source of
such information.
Page 11-34: The reference to silvicultural activities is in need
"of revision corresponding to the information supplied in the
Technical Report to the 208 Agency, Water Quality Investigation on
the Bridger-Teton National Forest. Specifically, the third sen-
tence of the second paragraph should read, "may be" rather than,
"are all." In the fourth sentence, fertilizers should be ommitted
from consideration since fertilization of National Forest land in
Teton County is not taking place nor is it likely to be an accepted
practice in the futute.
-104-
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Also as indicated in the 208 Technical Report, the effect of re-
moving forest vegetation in streamside areas is not a factor in
Teton County since most of the riparian vegetation is willow or
other shrub species and a buffer strip is maintained along stream
channels where tree cover exists.
It may be advisable to qualify comments on pesticides lis applied to
timber harvesting. The only pesticide application for silvicultural
purposes in Teton County in the past 25 years was the use of
. diesel and ethylene dibromide by field crews on individual trees to
\) control the bark battle which had heavily infested lodgepole pine
in Grand Teton National Park and the Bridger-Teton National Forest.
It is our recommendation that this section of the report be kept
specific to Teton County rather than generalized to reports on
silvicultural efforts from studies conducted in other parts of the
limited states, since forest practices from other areas may not be
applicable to the forest conditions in Teton County.
Again, we appreciate the opportunity to comment on this important pro-
ject. We also appreciate the complexity of planning and analyzing it.
I suggest that the ,next time your planners are in the area, they stop in
to discuss the project and Wild and Scenic River Study with us. Let us
know if we can aid in any other way.
Sincerely,
REID JACKSON
Forest ISupervisor
-105-
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Response to Comments by the Bridger-Teton National Forest
1. In fact, only the effluent outfall lines to the Snake
River are located within the normally considered 1/4 mile
study corridor. All of the proposed treatment facilities
are located in areas outside the river corridor and for
the most part, adjacent to existing development. Re-
ference is made in paragraph D of the Summary to the
compounded problems of constructing an outfall line to
Snake River due to its potential inclusion in the Wild
and Scenic River system.
2. In describing the responsibility of the Forest Service
as "lead agency" for the Upper Snake Wild and Scenic
River Study, it was not the intention to imply that final
authority for any determination on use compatibility
rested with the Forest Service alone. While Secretary
of Agriculture will make any determination on the classi-
fication of the Snake River, the Forest Service, as his
agent, will prepare the necessary studies and recommen-
dations. As such, the EPA would want to work with the
Forest Service to develop the type of information that
it will need in its study, and cooperate in insuring
that mitigation measures that will enhance the environ-
mental qualities of the river are included in any final
design. The EPA acknowledges the fact that it has
responsibility for water quality and the impacts of
facilities constructed under its programs, but feels
that the "lead agency" for the Snake River Study must
be involved in the processes and provide salient input.
We feel that the draft statement discusses, in detail,
the water quality and engineering impacts the various
alternatives would have on the potential classification
of the river. In general, only the outfall structure
itself would visually intrude on the river corridor.
This, as stated in the document, would require significant
engineering and architectural modification to insure
its compatibility. However, it should be noted thattfte
proposed alternative involves disposal by infiltration
basins. The outfall line to the Snake River is no
longer under consideration.
3. EPA has decided not to fund a lagoon. This was the only
site that may have conflicted with the Wild and Scenic
River Corridor in a manner that could have effected
its classification potential.
-106-
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4. On the contrary, we feel that the information necessary
to make this determination is presented in adequate
detail. Due to the variety of requirements and specific
areas that must be met and addressed, our format analyzed
impacts on the basis of specific categories (i.e., water
quality, wildlife, aesthetics, etc.). This, we felt,
would include the Snake River's special value along
with those of the rest of the Jackson area. Our analysis,
and that of the National Eutrophication Survey, indicated
that secondary treated effluent from a proposed Jackson
wastewater treatment facility would not violate existing
water quality criteria at normally expected low flows.
We further pointed out that the outfall structure would
require extensive modification depending upon the classi-
fication that was to be adopted. However, this is no
longer a major concern as no outfall line to the Snake
River is being proposed. It should be noted that due
to the physiographic and geologic limitations of the
Jackson area, the Snake is the only available receiving
water that can accommodate the expected discharge of
a secondary plant for the Jackson area without degrading
the water quality of the area. The flow in Flat Creek
is not great enough to be depended upon for accommodating
the future effluent discharge from the population project
for the Jackson/South Park region.
5. Changed as noted.
6. The popularity of use of pesticides to control forest
insects has undergone a resurgence of interest. While
its use may be limited in the Teton County area, it
cannot be ruled out as a potential source of nonpoint
source pollution.
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United States Department of Agricultuhc
FOREST SERVICE
Bridger-Teton National Forest, Box 1888, Jackson, Wyoming 83001
2370
July 15, 1977
rJohn A. Green
Regional Administration
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
i_Denver, CO 80203
Dear John:
The planning and evaluation process for the Jackson Wastewater Treat-
ment Facility has our concerned interest because of possible ramifica-
tions to the Wild and Scenic Rivers Study and classification potential.
Specifically, it appears to us that EPA planners feel the Forest Ser-
vice, as lead agency for the Wild and Scenic River Study, is responsi-
ble to set standards, design mitigating measures and make decisions on
whether or not certain aspects of the project can actually occur.
This philosophy is evident in the project's Draft-EIS and the attached
statement published in a local paper following your recent public hearing.
We view our role as a cooperator in your evaluation process. At this
point in the Wild and Scenic River Study we can supply you with the
classification potential for the involved river section. Also, we can
help you define the impacts that the project may have on this poten-
tial. We do not feel qualified, nor responsible to design mitigating
measures or to make a determination on whether or not a certain phase
of the operation can occur. We look to EPA, as the national leader in
water quality matters, to provide technical expertise and to assure that
the eventual project will safeguard the environment of the Snake River.
Section 7 of the Wild and Scenic Rivers Act establishes the decision
making role with the appropriate Secretary and gives the proposing agency
the burden of identifying the impacts a project may have on classifi-
cation potential. It is also the proposing agency's responsibility to
inform the appropriate Secreatry of their project and its impacts in
light of the wild and scenic river potential.
Both the Wild and Scenic River Study and Jackson Wastewater Treatment
Facility Analysis are interagency in nature. To imply that one agency
is the sole entity in determining project appropriateness can lead to
public misunderstanding and poor interagency relations.
-108-
*100-11
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Page 2
As you know, resource values in Jackson Hole are high and every issue
sparks a hot controversy. It is therefore of utmost importance that
we work together on this issue in order to provide Jackson with an
adequate treatment facility and meet requirements of the Wild and
Scenic Rivers Act.
Sincerely,
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- ir< iiMuicvs I o ar»*• 7
Al* * " /A.
Response to the Comments by the Bridger-Teton National Forest
1. EPA appreciates the opportunity to assist the Forest Service
on the Snake River Wild and Scenic River Study. The design
and construction of the proposed lagoon/rapid infiltration
system meets several objectives of both EPA and the Forest
Service. This system eliminates the need for any outfall
line to the Snake River and the additional level of treatment
described by the design engineer as being provided by the
infiltration basins further perfects water quality beyond
that necessary to meet mandatory standards.
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. •>?>
-------
Response to Comments by the Federal Energy Administration
1. An aerobic treatment system does not generate methane
or other significant energy sources. With electrical
energy being as expensive as it currently is and will
continue to be, the use of energy-efficient electrical
components is a necessity. A competent engineer will
size the equipment in order to maximize its efficiency
factor.
2. The writer's questioning of whether the proposed design
will incorporate seismic and slope protection appears
inappropriate. The design and proper mitigation for
geologic hazards should be an integral part of any
engineering effort. The proposed site is not located
on or near an active fault, near any unstable slopes,
and is not in the 100-year floodplain.
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DEPARTMENT OF THE ARMY
WALLA WALLA DISTRICT, CORPS OF ENGINEERS
BLDG. 602, CITY-COUNTY AIRPORT
WALLA WALLA, WASHINGTON 99362
( r.v-dL--4
i
3 June 1977
6m
NPWEN-PL
Mr. John A. Green
Regional A±ninistxator
U. S. Environmental Protection Agency
Region VIII Office
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
This letter is in res pen se to your letter of 20 Hay 1977. We appreciate
the opportunity to review and comment upon the Draft Environmental Impact
Statement for the Jackson Wastewater Treatment System serving the town
of Jackson, Wyoming.
After reviewing the Staternent, we find that the proposed facilities would
not significantly affect any known project under the jurisdiction of the
Corps of Engineers; nor do we uncover any impacts associated with the
proposed project in the categories of navigation, flood control, or hydro-
power development.
OF:
General Counsel
Council on Environmental Quality
722 Jackson Place N.W.
Washington, D. C. 20006
Sincerely yours
W. E. SIVJ^Df
Chief, Engineering Division
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DEPAK I MtNT OF HOUSING AND URBAN OEVtLOPMENT
REGIONAL OFFICE
EXECUTIVE TOWER • 1405 CURTIS STREET
DENVER, COLORADO 80202
June 15, 1977
REGION VIII
IN REPLY REFER TOt
8DE
Mr. John A. Green
Regional Administrator
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
We are writing in regard to your draft environmental impact statement
(EIS) on the Jackson Wastewater Treatment System for the town of
Jackson, Wyoming.
Our review indicates that while your statement deals extensively
with the growth potential of the various alternatives, it does not
assess the impacts of growth. Your statement does not deal with
the growth-related impacts on education, recreation, social services,
health services, public safety services or a number of related
elements. The major consideration should be the ability of these
elements"to adequately serve the anticipated growth.
Because of the substantial growth which this project will enhance,
we feel it is essential that you deal with the impacts of that
growth of the major elements of the physical and social environment.
Sincerely,
Robert J. Matuschek
Robert J. Matuschek
Assistant Regional Administrator
Community Planning and Development
Insuring Offices
Ciiptr, Wyoming • D«nv«r, Colorado • Forgo, North Dakota • Heltna, Montana • Salt Lake City, Utah • Sioux Falla, South Dakoti
-114-
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C,'APt .JMICIJOK 5Q ..>¦ > fi V.-iU ,y |£ r«ini "
Response to the Comments by the Department of Housing and
Urban Development
1. The analysis of the growth impacts generated by a waste-
water treatment facility is a multi-faceted problem. It
entails both the primary and secondary consideration of
economic, social, cultural and land utilization changes
and .induced problems. These questions are dealt with
extensively in the draft EIS on pages V-15 through V-33.
The final EIS provides additional analyses of the growth-
related impacts of the proposed wastewater facilities.
HUD is referred to in the document for further information.
The impact the various alternatives would have on social
and municipal services are discussed in some detail.
The reader is referred to pages V-26 and V-27 which
provide a general framework of the discussion of these
impacts. In this section, the implications and inter-
relations between the expansion of available sewer
service, community growth and the necessary expansion
of other municipal services (i.e., fire and police
protection, recreation, education) is explained and
generally quantified. Given the many unknowns sur-
rounding future growth in the area, it's unrealistic
to become too specific and attempt to apply numbers to
each of the services mentioned in HUD's letter.
-115-
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/¦>* ~t-va
UNITED STATES
ENERGY RESEARCH AND DEVELOPMENT ADMINISTRATION
WASHINGTON. D C 20545
JUL ; 4 1977
Mr. John A. Green
Regional Administrator
U. S. Environmental Protection Agency
Region VII
1860 Lincoln Street
Denver, CO 80203
Dear Mr. Green:
This is in response to your transmittal dated May 20, 1977, in
which you invited the Energy Research and Development Administration
(ERDA) to review and comment on the U. S. Environmental Protection
Agency's draft environmental impact statement related to the Jackson
Wastewater Treatment System, Jackson, Wyoming.
We have reviewed the statement and have determined that the proposed
action will not conflict with current or known future ERDA programs.
We have no comments to offer on the statement itself.
Thank you for the opportunity to review and comment on the draft
statement.
Sincerely
. H-.""'Pennington,~Director
ffice of NEPA Coordination
Council on Environmental
Quality (5)
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DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE
REGION VIII
FEDERAL OFFICE BUILDING
I9tm AND STOUT STREETS
DENVER COLORADO 80294
kc
June 28, 1977
OFFICE OF THE REGIONAL DIRECTOR
Mr. John A. Green
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80203
Dear John:
Thank you for the opportunity to review the draft environmental impact
statement on the Jackson Wastewater Treatment System for the Town of
Jackson, Wyoming.
It appears that the impacts expected to result from this proposed pro-
ject and reasonable alternatives thereto have been adequately addressed.
cc:
Office of Environmental Affairs
HEW, Washington, D.C.
t
Council of Environmental Quality
Washington, D.C. (2 copies)
Sincerely yours
^OWwin^. LaPed
1,/Acting Regional Director
-117-
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DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE
PUBLIC HEALTH SERVICE
CENTER FOB DISEASE CONTROL
ATLANTA, GCORGIA 30333
ICLtPMCJNl |104| CJJJJH
November 10, 1976
Mr. John A. Green
Regional Administrator
United States Environmental Protection Agency
Region VIII
1860 Lincoln St.
Denver, Colorado 80203
Dear Mr. Green:
We have received the notice of your intent to prepare an EIS on the
Wastewater Treatment Facility Plan, Jackson, Wyoming. Water Resources
Activity's interest is in the area of mosquito vector problems; our
input to the draft EIS would be related to mosquito production which
might be caused by the project. We were contacted last June by Ms.
Jan Miller of the 208 Planning Agency for information on mosquito
control problems, and we furnished several informational articles.
Vector prevention should be included in the plan. Such structures as
sewage stabilization ponds have created serious mosquito problems
throughout the western United States and are well documented in the
scientific literature. Therefore, vector considerations should be
included in regard to structural developments.
Please place this office on your mailing list to receive future notices
on the Jackson facilities. If we can provide any further technical
information, please contact us.
Sincerely yours
v -dames M. Stewart
Senior Sanitarian
Water Resources Activity
Vector Biology Control Division
Bureau of Tropical Diseases
CC:
Dr. R. 0. Hayes
Dr. S. Breeland
-118-
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Response to the Comments by Department of Health Education
and Welfare.
1. By providing sufficiently steep slopes, lining with an
impervious day barrier will generally reduce the
potential for emergent vegetation, and the mosquito
problem associated with wastewater stabilization ponds.
These or similar measures will be included in any final
design.
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
REGIONAL OFFICE
EXECUTIVE TOWER - J40S CURTIS STREET
DENVER, COLORADO B0202
June 15, 1977
REGION VIII
IN REPLY REFER TO
8DE
Mr. John A. Green
Regional Administrator
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
We are writing in regard to your draft environmental impact statement
(EIS) on the Jackson Wastewater Treatment System for the town of
Jackson, Wyoming.
Our review indicates that while your statement deals extensively
with the growth potential of the various alternatives, it does not
assess the impacts of growth. Your statement does not deal with
the growth-related impacts on education, recreation, social services,
health services, public safety services or a number of related
elements. The major consideration should be the ability of these
elements to adequately serve the anticipated growth.
Because of the substantial growth which this project will enhance,
we feel it is essential that you deal with the impacts of that
growth of the major elements of the physical and social environment.
Sincerely,
Robert J. Matuschek
Robert J. Matuschek
Assistant Regional Administrator
Community Planning and Development
Injuring Office*
Casper. Wyoming• Denver, Colorado - Fargo, North Dakota • Helena, Montana* Salt Lake City, Uiah-Sioui Falls, South Dakota
-120-
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Response to the Comments by the Department of Housing and
Urban Development
1. The analysis of the growth impacts generated by a waste-
water treatment facility is a multi-faceted problem. It
entails both the primary and secondary consideration of
economic, social, cultural and land utilization changes
and induced problems. These questions are dealt with
extensively in the draft EIS on pages V-15 through V-33.
The impact the various alternatives would have on social
and municipal services are discussed in some detail.
The reader is referred to pages V-26 and V-27 which
provide a general framework of the discussion of these
impacts. In this section, the implications and inter-
relations between the expansion of available sewer
service,community growth and the necessary expansion of
other municipal services (i.e., fire and police pro-
tection, recreation, education) is explained and
generally quantified. Given the many unknowns sur-
rounding future growth in the area, it is unrealistic
to become too specific and attempt to apply numbers to
each of the services mentioned in HUD's letter.
The final EIS provides additional analyses of the growth-
related impacts of the proposed wastewater facilities.
HUD is referred to the document for further information
-121-
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United States Department of the Interior
oitk;i; ok im: sik.iu.i \ry
MISSOURI BASIN REGION
DENVER, COLORADO 80225
ER 77/511
July 11, 1977
Mr. John A. Green
Regional Administrator
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
We have reviewed the draft environmental statement for the Jackson Waste-
water Treatment System and offer the following comments for your consid-
eration in preparing the Final Statement.
General Comments
The U.S. Fish and Wildlife Service has expressed opposition to the pro-
posal to build a wastewater treatment plant on the South Park Elk Feedground.
The land in question was acquired through the Federal Aid in Wildlife
I Restoration Act (P.L. 75-415) to help preserve the Jackson Hole elk herd.
Use of portions of these lands for sewage treatment would result in the loss
of control by the State Fish & Game Department and constitute a diversion
of land requiring mitigating measures. Also, building in this area would
encourage residential development to accelerate near a critical area,
further impacting wildlifeand could be*a "detriment to the downstream water
quality during periods of flooding.
The draft environmental statement recognizes the ongoing study of the Snake
River to determine it& eligibility for inclusion in the National Wild and
Scenic Rivers System. However, the document does not adequately assess the
impacts of the various alternatives on the river's potential for inclusion
in the national system. We recommend that the project sponsor consult with
the Snake River Study Team leader (Forest Supervisor, Bridger-Teton National
o Forest) before publication of the final environmental statement to evaluate
each alternative and its impacts to the study. This analysis should be
included in the final document. The discharge of effluent directly into the
Snake River could jeopardize the river's eligibility by damaging aesthetic
values and diminishing water quality. In addition, such discharge would, as
the document notes, necessitate concealment of the outfall system—a
significant engineering problem in view of the river's unstable channel.
It should be noted that such water lines are discouraged under "Guidelines
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UUJ.^ IX, xy / /
Page twp
3
+
5
d
for Evaluating Wild, Scenic, and Recreational River Areas Proposed for
Inclusion in the National Wild and Scenic Rivers System under Section 2,
Public Law 90-542." The Forest Service can also provide information
regarding the progress of the study and any preliminary findings.
The South Park area reportedly receives heavy recreational use. The final
document should describe this present use and quantify the loss of recre-
ational opportunity resulting from implementation of each alternative.
The statement should include a discussion of requirements for monitoring
in the vicinity of any sewage impoundment facilities to permit quick
detection of the movement of pollutants and remedial measures in the
event of leakage. On the basis of the geohydrology of the project area,
your conclusion that the proposed stabilization lagoon system in the
South Park Elk Feedground could result in serious ground-water impacts
appears correct.
The statement should indicate that all lagoons or impoundments used in
the wastewater treatment systems will be constructed entirely above the
water table. The latter premise would probably require that any impound-
ment used be raised and mounded above the land surface because of extremely
shallow water-table conditions and would be sealed and/or lined to assure
containment and prevention of ground-water contamination.
The impact of the proposed action upon Grand Teton National Park should be
addressed. If there will be no effect,the final environmental statement
should reference this fact.
iWe concur with the State Archeologist that an intensive archeological
|survey of the project area prior to construction is needed. It should
I include extensive testing for subsurface archeological remains as out-
llined in the proposed guidelines for "Recovery of Scientific, Prehistoric,
(Historic, and Archeological Data: Methods, Standards and Reporting
y ! Requirements" (36 CFR, Part 66). The results of the professional survey
I should guide the decision as to whether a professional archeologist should
be present during project development to ensure compliance with Executive
Order 11593; this requires an undertaking agency to evaluate the significance
of any uncovered cultural resources and nominate to the National Register
of Historic Places any sites that meet the criteria. The final environmental
statement should include a copy of the State Historic Preservation Officer's
letter of comment concerning the project. Such correspondence would
facilitate the review process.
Specific Comments
Existing Environment Section—Recommend that a section be added under
Existing Environment" to describe the existing fish and wildlife resources
that occur in the Jackson Hole area and downstream on the Snake River.
-123-
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July 11, 1977
Page three
PaRe II - 32—The statement should indicate whether exfiltration—as well
as infiltration—is currently a problem and perhaps a source of some of
the current pollution of ground water; this would have significance in
the assessment of the no-action alternative.
Page II - 58—The statement should indicate whether all interceptors and
pipelines are to be so constructed as to reduce infiltration and exfiltration
to insignificant amounts. This should also be clarified on pages III-5,
IV-3, and V-6.
Thank you for the opportunity to review this statement. Please let us
know if we can provide further assistance.
Sincerely,
JOHN E.RAYBOURN ( /
Regional Enviromental Officer
-124-
-------
vvp . ir v r >r
Response to Comments by the United States Department of
the Interior, Office of the Secretary, Missouri Basin Region
1. The EPA has determined that it will not fund a wastewater
facility on the South Park Elk Feedground (see Summary
Sheet of Draft EIS).
2. The only aspect of the proposed alternative projects
identified in the draft EIS that impacts the Wild and
Scenic River designation is the discharge of effluent and
the discharge structure itself that enters the Snake River.
As stated in Section V of the draft, the secondary
treatment proposed, will, under normal low flow condi-
tions, meet the existing water quality standards estab-
lished for the Snake Riv,er. Based upon the known
standards, proposed design criteria, and the EPA's
recent National Eutrophication Survey, that indicated
that nonpoint pollution will continue to be the major
source of pollution in the Snake River, it does not
appear the water quality will limit river classification.
The design and construction of an aerated lagoon/rapid
infiltration system proposed in the final EIS meets
several objectives of EPA and the U. S. Forest Service
programs. The system eliminated the need for any outfall
line to the Snake River. In addition, the level of
treatment provided by the infiltration basins is considered
adequate to protect water quality and meet applicable
standards.
The EPA plans to issue separate grants to finalize the
facility plan and design the outfall to the Snake
once the city and county decide upon a site. The outfall
designer will be required to work with the Forest Service
in developing a design harmonious with the expected
classification (scenic or recreational). While we
recognize that under the guidelines of the Wild and '
Scenic River Act instream structures are discouraged,
ther§ are really very few environmentally-sound and
cost-effective solutions to the Jackson wastewater
disposal problems. Flat Creek and the Snake River are
the only reasonable and technically sound discharge
waters. Discharge to Flat Creek would eventually
require further treatment to insure the protection of
its water quality.
3. A detailed description of the summer recreational use
of the South Park Elk Feedground campground and the
surrounding lands is available in the State of Wyoming
report titled Land Transfer to the Town of Jackson,
Appendix 1 of the Draft EIS. There are no other
public or open recreational lands in South Park,
therefore, recreation loss of the other alternatives
is minimal. It is unlikely, given the stringent water
quality and aesthetic standards the new facility will
be required to meet, that any degradation to the river
will occur that will entail the loss of recreational
opportunities.
-125-
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4. The EPA has decided that it will not fund the Elk
Feedground site. The monitoring requirement for any
site selected will be set by the Wyoming Department
of Environmental Quality prior to the beginning of
operation.
5. These are discussed starting on pages III-4 and III-5.
All cost estimates of pipelines and subsurface structures
include contingencies for dewatering and sealing.
6. The alternative construction sites and potential develop-
able lands are all on private land. No direct impacts on
Grand Teton National Park are anticipated.
7. See attached letter from Mr. George M. Zeimens, Associate
State Archeologist.
8. The subsection under Natural Communities, pages 11-40
through 11-44, in Section II - Existing Environment,
contains a summary of the fish and wildlife of the
region. This information was supplied by the Wyoming
Department of Game and Fish and, according to department
personnel in Jackson and Cheyenne, is based on the most
recent available data.
9. It is unlikely that exfiltration is ever a problem in
the South Park region due to the area's extremely high
groundwater.
10. The pipeline problems that have occurred in Jackson in
the past were a result of improper construction inspec-
tion. Modern construction methods and the inspection
requirements that the EPA now requires should insure
proper construction. Mechanical or permanently sealed
(adhesive sealed), pipe joints would have to be used in
all high water areas to insure minimal infiltration.
-126-
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THE STATE £?.&,
'OF WYOMING
ED HERSCHLER
GOVERNOR
COMMISSION
OFFICERS
ALBERT PILCH
PRESIDENT
1800 Morse Lee
Evanston 82930
JACK D OSMOND.
VICE PRESIDENT
P O Box 216
Thayne 83127
DUANE REDMAN
TREASURER
Dubois 82513
MEMBERS
REGNALD BAFFORD
P O Box 625
Lutk 82225
FLOYD BARTLING
P O Box 172
Douglas 82633
LYLE BENTZEN
1001 Pioneer Road
Sheridan 82801
MRS ROBERT FRISBY
2007 Newton Avenue
Cody 82414
MARVIN HARSHMAN
1507 West Spruce
Rawlins 82301
BILL NATION
2221 Van Lennen Avenue
Cheyenne 82001
Wyoming Stecbeaticn ^cmmi^ion
604 EAST 25TH STREET CHEYENNE. WYOMING 82002
October 6, 1976
PAUL H WESTEDT
Director
777-7695
Mr. Edwin T. Cryer
J. M. Montgomery, Consulting Engineers, Inc.
1301 Vista Avenue
Boise, Idaho 83705
Dear Mr. Cryer:
Concerning the proposed wastewater treatment facility for
Jackson, Wyoming, there are no known archeological sites on
the lands involved. However, since there are a number of known
sites in the general area, and since the lands involved have never
been subjected to an archeological study, we strongly recommend
that a field study be initiated before construction begins.
You can arrange for such a study through my office or by
contacting any qualified archeologist. If I can be of any
assistance with this project do not hesitate to ask.
cerely,
George M. Zeimens,
Associate State Archeologist
Department of Anthropology
University of Wyoming 82070
GMZ/mr
Telephone: 766-6334
JAY.LS M. MONTGOMERY
CONSULTING ENGINEERS, INC.
-127-
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Response to the Comments by the Wyoming Recreation Commission
1. The field survey you have recommended will be arranged
during the Spring of 1979.
-128-
-------
i Interior
J. David Love
D. S. Geol. Survey
Box
Jackson, Wyoming 63001
July 2?, 1977
TIr. .'es Vilson
'-C.P.A. Regional Office
ie60 Lincoln 3t.
Denver, Colo. 80295
'.tear J"r. ''ilson:
This letter concerns the eitin'- of the Jackson, 'yorin^, t'l.'niciTinl ne /a^e
treatnent olant. I have toured the various sites nropos^d by th2 to"H, in
connany with ^rvc.z 'iztz, ten en~ireer, "'oh Lablo Tie, whor. ;tu Icii v, prd other
concerned citizen:-.. 'e also .'ent to tin Vilson Canyon li'i.e that I recently
proomed for consideration. As you "nay recall, this site was not m the s rmy
flo'-d plain, as ell the others are, and is downwind fron a] 1 dcvelo^r,->->t.
I an so:nsv/hat -•"a'niliar vith the rrei, hrvir- nren?red an^ ouhlished ci" go] otic
quadra :le and environs, irtal "aps here (~ee '.'."J. '"eolr^ic?! "uvvey ""os I-7;9-^>
E, C, D, j}, and P, which you can ~et fro"1 the Survey's "ap '"istri",,iJ"ion o""."icr
in Denver). I.a~> 759-A chows the '-e^lo'-y of all the lites and nresents a crosr
section near the '"ilson Canyon site, "his site haT the folio-i"' r.dvant"~es
over the others:
1. ./ater inflov into the system (currently a -ia,ior rro^len) would not recur
because the pipeline would be above t^e '.Titer table.
2. -he leach fi^ld could c-.tend alon~ ~he TIob"c".: fault crushed rich zone.
3. °he entire system 1 /ould be v/ell abovi the -at^r t^'-'lc.
'4. The sy^ten '-'o^ld be It n-dn ] (the rrevailm~ • and is the soul^we'-t)
froT. all nre-ent development.
5. Outflow (i" any) cou?.d be pined into "l^t Oree'c at a olacc —here the
water l3~rel and ch~ ~"L
involve any •-riches.
Disac"anta~c.,r:
1. Affluent (if any is to be involved) frm the ~o"th Tarl: lovclop-'en» Tea
would have to be prnpeil uphill 100-200 feet.
Other considerations:
1. L jaka' e into t.ie water table. An ol-i -nil at the "'ilson 0a~,"nr si-e show
• the 'pter table to be at leant 75 feet ¦ elow the outface.
2. Aesthetics. The installation would not be consoicuour as Ion" a«? i: is
entrenched.
3. Interference v/ith pre ent develon'-.ent: T'cne.
4. Lubrication of Mobaclc fault pl'ne. -friucnt wruld r.ot be v_n"er cresE"re
(as for enr."2ple, in contrast vrith •'.'ater in reservoirs) so I doubt thet
there v/ould be any significant effect.
5. Contamination of v/atcr "iable o" mrir-s. * The^e a^e no sprm-T i~ -he are
and the wat ;r tabl • at a h me sits devel^rwcnt hp If a r-.ile n~i>thwest ir
at about 300 feet de^th. I doubt t'^at o-.y contariination wo"!1! o:r-" here
or to the scuth alon7 ".he 2nalce r?iver but to be rrure, tracer Ayen or" Id"
be put into an e:"Tjeri~';ntal well at the -it"; and i-. -'at-.r ct the he°a of
7iloon Canyon (Lhe lower canyon is dry) •
United States Department of the
GEOLOGICAL SURVEY
-129-
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.7ilson (p. 2)
Suggestions:
1. Cable tool about si" 150-foot holes alonr and acroT the 'lobae1: '^ult
zone where it chooser, the bottom of /ilson Ta^-'on to n<2t w^ter t^ble
data, width of crushed rock zone, and permeability of the none.
2. Put tracer dye in these hole-: to nee if v/ater encountered c-ner^es at thf*
surface ?ny;;here. It :n?y .lot.
3. Design a leich systei th^t could most eTi^iently be heDt f_-o*i nluT:ipr
up. Surely California can provide s've prpctical e—3~n?roe fron ni^il^r
situations.
In conclusion, I 'ope you will n because
the town nee Is all the constructive input t'-it it nan .»e«. I reithor fever nor
disapprove of any particular site. '-They should all b3 evaluated l-nsroona1 ly
from a lon^-ran^e standpoint, and on the basis of cold hird ec^no^ics.
Sincerely yours,
-130-
-------
Response to Comments by the United States Department of
the Interior Geological Survey
While Mr. Love's recommendation may have merit as a method
of disposing of treated effluent, the unknowns are of such
a magnitude as to make it a somewhat impractical consideration
for Jackson. Due to the town's existing problems, and the
need to make the necessary improvements to their system as
soon as possible, the resolution of research and environ-
mental problems in pursuing this proposal would delay the
implementation of a final system even longer.
The Wilson Canyon site proposed by Mr. Love would require
the pumping of all wastewater generated in the town and
South Park. It may also be necessary to inject the
effluent into the fault zone, if the permeability of the
surface and subsurface material will not accept the waste-
water in sufficient quantity. In addition, a primary
treatment plant would have to proceed any leach field
disposal system. Solids and grit, which are common*
constituents of municipal wastewater, could render the
proposed leach field inoperative in a short period.
Based upon the pumping requirements, cost of primary
treatment and sludge disposal, and the unknown reliability
factors inherent in an experimental system such as the
one proposed, Jackson with its limited financial capabili-
ties and no standby system, would be better off to pursue
a more traditional approach to its wastewater problem.
The proposed system would have several advantages if the
discharge requirements to the Snake River were strengthened
and it was necessary to provide advance treatment or seek
another disposal point. It may be more cost effective, if
this was required at a later date, to pump treated secon-
dary effluent back up to the Wilson Canyon site rather than
provide advanced treatment. The USGS may, as a special
project, want to look into the feasibility of this proposal
and conduct the proposed testing as a special federal
research project.
-131-
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S$S7T£/
WYOMING
EXECUTIVE DEPARTMENT
CHEYENNE
CD MfnSCMLFB
govibnob
June 30, 1977
Mr. John A. Green
Regional Administrator
U.S. Environmental
Protection Agency
region VIII
1860 Lincoln Street
Denver, Colorado 80203
".ear Mr. Green:
Subject: Jackson Wastewater Treatment System
Draft Impact Statement
In compliance with the National Environmental Policy
Act of 1969, Office of Management and Budget Circular A-95 (revised),
and the Wyoming State Review Procedure, the State of Wyoming
has completed its review of the above referenced statement.
Please note the attached comments.
Thank you for providing an opportunity to review this
statement. We are looking forward to receiving notification of
the progress of this project.
EH/trb
Attachments
-132-
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THE
tLyOF WYOMING
ED HERSCHLER
governor
tSbefiaktment of Snvi'ioii'mental Quality
AIR QUALITY DIVISION
HATHAWAY BUILDING
CHEYENNE. WYOMING 82002
TELEPHONE 777-7391
MEMORANDUM
TO:
Robert E. Sundin
Director
Dept. of Environmental Quality
FROM:
Woody Russell tcZ'
Air Quality Engineer
Air Quality Division
SUBJECT:
Town of Jackson Wastewater Treatment System
DATE:
June 22, 1977
The expansion and improvement of the existing wastewater treatment plant or the
construction and operation of a new one will have little, if any, impact on the
ambient air quality, except during the period of construction.
The possibility of secondary impacts exists if one of the South Park sites were
chosen. As stated in the E.I.S., the remote location of a treatment plant in the
South Park area will open that area to development. Such development could cause
an increase in emissions of particulates, oxides of nitrogen and carbon monoxide.
Baseline ambient air quality data other than particulates is unavailable and the
impact of the wastewater treatment plant and resulting development cannot be
ascertained.
-133-
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THE STATE
OF WYOMING
JUN 2 7 W?
ED HERSCHLE
GOVERNOR
^SbefiCLltment oj! §oz^i^cnm,enlal Quality
fy{'ate\ Quality ^ivibion
HATHAWAY BUILDING
CHEYENNE, WYOMING 82002
TELEPHONE 307 777-7781
MEMORANDUM
JUNE 24, 1377
TO: Robert E. Sundin, Director
FROM: Don Armstrong, Environmental EnglneerJ^^—"
SUBJECT: Draft, Environmental Impact Statement, Jackson
Wastewater Treatment System
The subject statement has been reviewed and the following comments
are offered:
1. The statement adequately addresses the water quality impacts of
the proposed action with the following exception: propound standards for
the Snake River include a no degradation policy of the river. The impact
of the proposed standards on the proposed action should have been discussed.
2. Page V - 32 - Alternative 6, states "once the Town of Jackson has
exercised its priority in terms of E.P.A. funding to upgrade the existing
plant', it is unlikely that additional Federal funding assistance will
become Immediately available to construct a new facility." This statement
is incorrect and should be further clarified. It is presumable that if the
existing Jackson plant was upgraded with solids handling and chlorination,
sufficient time"4would be afforded to properly evaluate the Wild 6 Scenic
River impact and the proposed standards changed without eliminating the
possibility of Federal funding.
CC: File
DA:jcf
-134-
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Response to Comments by the State of Wyoming Department of
Environmental Quality, Water Quality Division
1. If, as Mr. Armstrong proposes, an enforced nondegradation
policy were adopted for the Snake River, then the town
would have two options: either to increase its level
or treatment, or seek an alternate disposal site.
Since a literal interpretation of "no degradation" would
require the effluent to be of equal or better quality
than the water in the river, a very high level of
treatment would be required. The background levels of
contamination from nonpoint sources are relatively low
in the stretch of the Snake adjacent to the Town of
Jackson. Realistically, a no degradation standard
would require a treatment plant that could provide
nutrient removal, ammonia removal, de-chlorination,
trace organic removal and complete solids and BOD
reduction. In theory, a plant similar to that at
Lake Tahoe (probably the most advanced in the country)
would be necessary. Quite simply, a facility of this
type is presently beyond the financial and operational
capabilities of the town. If such a system were re-
quired, a complete federal funding would be necessary,
and for a number of years a federal operation and
maintenance grant would be needed to ensure proper
operation. Without the assistance of a federal
research grant and operational assistance, a plant of
that type envisioned would not be within the realm of
possibility for a community the size of Jackson.
The other alternative of discharging secondary effluent
to an alternative source has limited applicability in
the Jackson area. Geophysical and geohydraulic charac-
teristics of the region limit the potential for land
disposal (see response to letter by USGS). Flat Creek
is the only alternative surface water to which treated
effluent could be discharged. As shown on pages V-2,
V-3, and V-4, this discharge at design flow would
severely degrade the water quality of Flat Creek.
While no data is available, on the assimilative capa-
city of Flat Creek, we would have to question whether
the Snake River would be degraded by an effluent-
loaded Flat Creek discharging into it below the Elk
Feedground.
Since the EPA has, based upon several studies of the
Snake River, decided at this time to fund only secon-
dary treatment for Jackson, the proposed "nondegrada-
tion policy" would require a substantial realignment
of the federal and local approach to wastewater manage-
ment. Because of the economic and social impacts the
proposed change in standards would have, it would
necessitate careful analysis of its water quality
benefits against probable adverse affects. It is
-135-
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questionable that within the practical capabilities of
the community 'if the proposed "nondegradation policy
would be compatible with the continued growth of the
Jackson area. In other, words, total "nondegradation"
of the Snake River may not be possible if Jackson is to
follow the growth projection presently proposed. While
the above statement points out unfortunate but basic
flows in our pattern of civilization, it is a fact that
must be dealt with in a practical manner.
2. EPA has stated that once funding were obtained to upgrade
the facility, additional funding would not be immediately
available to the Town of Jackson to construct a new facility.
How soon Jackson could have restablished its position on
the priority list after such a decision is debatable, but
the needs of other Wyoming communities would undoubtedly
be considered in any decision by EPA to fund such a facility
for the Town.
-136-
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COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT - JACKSON WASTEWATER
TREATMENT SYSTEM - JACKSON, WVOMING
PAGE 1-8 - COMMENT
Option A of Options available to Jackson seems inconsistent with the
statement on the summary sheet that EPA has decided not to fund this
option. How does updating the design capacity make this more acceptable.
Livingston employment forecast is 5 to 7.5 percent over the next 15
years. Is this as stated or should it be per year. If it is over the
next 15 years how do you justify a population increase of 6% per year.
A growth rate of 6% per annum, which doubles population every twelve
years, is extremely high and must be justified by some type of data.
The State Planning Coordinators office has projected that population
will increase in Teton County from 6,983 in 1977 to 7,368 in 1985, a
7/10 of faZ increase per year. Also according to the Bureau of the Census,
only 55% of the county population has resided in Jackson during 1970 to
11-54-55
1975.
Uuyom i
"DePARTivveOT of C
'?LAV3lOl»OU "DfcU£L0P»r>6UT
-137-
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Response to the Wyoming Department of Economic Planning and
Development
1. This decision was based upon the results of the Draft EIS
and, as such, is the EPA's response to information pre-
sented. The Elk Feedground site will not be funded
under the Construction Grants program.
2. The sentence in question should read: employment
forecast of 5.0-7.5 percent annual increase in
This figure was justified by Mr. Livingston on the
basis of historic trends. The reader is referred to
pages 43-45 of Teton County Growth and Development
Alternatives, 1976, available through the Teton County
Planning Office for a complete discussion of employment
projection criteria.
3. Within the last five years, the population of Teton
County has increased at an annual rate of 4.7 percent.
Given the obvious building boom in the Jackson area,
the 0.70 percent annual increase cited by the State
Planning Coordinator appears unrealistically low. While
a 6 percent growth rate may seem excessive when approached
from a traditional planning standpoint, facility designers
must size critical municipal facilities for the maximum
growth that can be reasonably expected in order to avoid
costly interim expansions. Bonding capacity and financial
resources are normally planned on the basis of expected
capital commitment. If a wastewater plant requires
expansion prior to the retirement of existing debts,
municipal bonds necessary to finance that expansion may
be difficult to sell.
A 6 percent annual population increase may be somewhat
high given the limited employment opportunities in
the area. But, until a thorough economic baseline study
is undertaken, a straight-line historic projection pre-
sents a conservative approach for facility sizing. The
6 percent annual population growth rate was also used to
obtain the treatment plant capacity for 1995.
-138-
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THE STATE
OF WYOMING
J UN 8 1977
ED HERSCHLER
GOVERNOR
COMMISSION
OFFICERS
JACK D OSMOND
PRESIDENT
P O Boa 216
Thsrro 83127
REGNALD BAFFORD
VICE PRESIDENT
p O Boa 625
Lutk 62225
MRS ROBERT FRISBY
TREASURER
2007 Nrwlon Avenue
Cody 82414
MEMBERS
FLOYD BARTLING
P O Boh 172
Douglas 82633
LYLE BENTZEN
1001 Pionerr Road
Sheridan 82801
MARVIN HARSHMAN
1507 Weil Spruce
Rawtmt 82301
ALBERT PILCH
1800 Uocu Lie
Evantion 82930
DUANE REDMAN
DubotS 82513
E LAWSON SCHWOPE
900 fovtr Avenue
Cherennc 82001
0lecteation ^foommibbion
604 EAST 25TH STREET
CHEYENNE, WYOMING 82002
June 8, 1977
PAUL H WESTEDT
Director
777 7695
77-125D
Mr. Dick Hartman
Governor's Planning Office
2320 Capitol Avenue
Cheyenne, WY 82002
Dear Mr. Hartman:
Reference is to State Identifier No. 77-125D, Jackson
Wastewater Treatment System, Town of Jackson, Wyoming—
a D.E.I.S. by the U. S. Environmental Protection Agency.
This proposed wastewater treatment system, whatever
alternative is finally adopted, does not pose a great
threat to the cultural environment. But it does, in
most alternatives, necessitate trenching which extends
over considerable linear distance. The Statement ack-
nowledges that discussions with the State Historic
Preservation Officer (SHPO) and the State Archeologist
have stressed that evidence of prehistoric cultures in
the general area could be significant.
While the Statement agrees that an archeologic reconnais-
sance should precede any projected ground disturbance, it
rejects the need to have an archeologist present at actual
trenching unless the reconnaissance indicates heavy pre-
historic activity. However, most of the subject area has
been exposed to ground disturbance for upwards of a century
so that remaining evidence of prehistoric cultures could
be limited. Trenching may discover one or more scientifi-
cally important sites which reveal little or no evidence
-139-
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Mr. Dick Hartman
June 8, 1977
Page 2
on the surface. Some arrangement needs be made through
the State Archeologist to have all trenching monitored
by someone capable of recognizing cultural evidence.
Sincerely,
Paul H. Westedt, Director and
Wyoming State
Historic Preservation Officer
Ned Frost, Chief
Historical Division
PHW/NMF/mlr
cc: George Zeimens
Associate State Archeologist
Department of Anthropology
University of Wyoming
Laramie, WY 82071
By:
-140-
-------
Response to Comments by Wyoming Recreation Commission
1. EPA intends to require that Town of, Jackson obtain professional
archaeological services to conduct an archaeological survey
prior to construction of the proposed wastewater facilities.
The -construction contract will require the contractor to
cease trenching activities if any apparent artifacts are •
discovered. The City Engineer will be required to enforce
this provision of the contract. However, EPA does not
believe the presen-t information of the extent of prehistoric
activity would warrent the expense of a full time archaeologist
on the construction site. Should the preconstruction survey
delineate certain areas as possible prehistoric or cultural
evidence, an archaeologist will be hired to supervise construc-
tion activities for the remaining portions of the project,
as determined to be necessary by the State Archaeologist.
-141-
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THE STATE OF WYOMING
tone* t
i^9 <2s//ndkant/ Sfiaiwi
i
STATE CAPITOL BUILDING
CHEYENNE. WYOMING 82002
June 1, 1977
PLEASE ADDRESB REPLY
TO THE COMMISSIONER
Regional Administrator, Region 8
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Dear Sir:
Reference EPA-908/5-77-002 Draft EIS Jackson Wastewater Treatment System
Town of Jackson, Wyoming, we wish to remind you that this office is
responsible for the administration of the State land in the considered
Boyles Hill Alternative Sites A2 and A3. Please keep us informed as the
final site is, determined.
We do not concur with the woodland acreage figure of 1,175 in Table 8
on Page 11-46. The State Forester is charged by Wyoming Statute to collect
data relative to forest conditions in Wyoming and his records indicate
16,499 acres of forest land in private ownership in Teton County, Wyo-
ming.
Thank you for the opportunity to comment.
Very truly yours
Bryce E. Lundell
Asst State Forester
BEL/cs
-142-
-------
Response to Comments by the Wyoming Commissioner of Public
Land and Farm Loans
Figures for land use on private lands were taken from the
Master Plan for Teton County, 1970. Acreages were compiled
by the Teton County Soil and Water Conservation District,
Jackson, Wyoming.
The apparent discrepancy in the "woodland" category as
originally presented in Table 8 of the draft is attributed
to the fact that much of the forested land area in Wyoming
is also used for grazing. A, significant amount of this land
was probably placed in the "agriculture" category.
Table 8 has been revised to correct the discrepancy.
Approximately 16,499 acres, or 21.9 percent of the private
lands in Teton County are shown as woodland.
-143-
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P.O. Box 2355
Jackson, Wyoming 83001
July 6, 1977
Mr. John A. Green, Regional Administrator
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
Dear Mr. Green:
I wish to present my personal comments in regard to the
location of the Jackson Sewage Treatment Plant at the South Park
Road site.
From the very beginning of the project, the elected officials
from the Town of Jackson have expressed their desire to see the
treatment plant constructed at the southernmost end of South
Park. There are many good reasons for holding this position, as a
southern site would service the largest acreage of developable land,
allow all wastewater to flow by gravity to the plant, and remove
the existing treatment facility from Jackson's natural path of
expansion.
At the same time, it is well recognized that the southernmost site
would have several undesireable features. A much longer and consequent-
ly more costly sewer system would be required, T-he pressure for
development would be increased in a county which already experiences
a relatively high rate of growth. Furthermore, the South Park
location by accomodating scattered single family home development,
would conflict with the goals of the proposed comprehensive land use
plan to limit high density residential development to lands adjacent
to existing urban areas.
However, I feel that many of the issues vitally important to
ithe future of Jackson and Teton County concerning the South Park
Road site are often overlooked or misrepresented. By setting the
precedent of providing wastewater treatment facilities throughout
South Park, Jackson or Teton County would be committed to providing
additional services — water, police protection, schools, road
maintenance, etc. — for new urban areas at some time in the future.
The services cost money and the local taxpayer would pay the greatest
share. Also, total capital and maintenance costs would be greater
than the projected cost estimates indicate as a treatment facility
located in South Park could accomodate a much larger population than
the other alternatives evaluated in the Environmental Impact State-
ment and would accordingly have many of its structures designed larger.
144
-------
Mr. John A. Green
July 6, 1977
Page 2
Again, the taxpayer, in an area where low taxes and minimum public
services have been the rule, would pay the extra costs. In addition,
the population wnich the South Park sewage treatment plant could
promote, would as it has in the case of other developing areas of
the country, change existing rural character of Teton County which many
of the residents prize so highly, increase the potential for crime
in new urban areas which many people have come here to escape, and
detract from the scenic beauty that has attracted residents and visitors
alike to the valley from the very beginning.
I simply wish to ask the Town Council and decision making
officials to weigh both the present and future impacts of a South
Park Road site extremely carefully and realize that the ultimate
decision will play an important role in determining what happens to
Jackson and Teton County in the coming years.
Very sincerely yours,
Robert T. Ablondi
145
-------
Response to the Comments by Mr.
Robert Ablondi
EPA agrees that undesirable features that would be expected
to accompany rapid development are negative effects of the pro-
posed interceptor and plant location. The adopted Teton County
Comprehensive Plan reduces this impact by requiring well planned
developments. Even without the long interceptor line, .Sotith Park
would develop albeit at a slower rate. The plant size did not
change however as a result of this southernmost location. EPA
determined that the long-term historical rate of 6% per year
would be used for plant sizing. Thus the costs of the proposed
system did not increase by virtue of this southern location. Of
course, the opportunity to develop South Park which will be en-
hanced by the new interceptor will likely mean an earlier than
expected need to expand the facility. The draft NPDES permit
requires the City to begin new planning at 80% capacity. New
facilities will be the financial responsibility of the Town of
Jackson.
146
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STATE OF WYO MING
wsgsa •"""
<-Y-^ <;•'<¦ * ^ •; >:;'.s-V\ ?&.»&$&¦'»i?
MARY F.MOORE
StSyp.O. Box 1727
'v.
County Commiwiontit:
WILLIAM H.ASHLEY
Chairman
J. MAX MAY
JOLYNN COONCE
County Clerk
MARGARETFEUZ
Treasurer
EDNA E.JONES
Assessor
BARBARAOAKLEY JACKSON, WYOMING 83001
Clerk of Court
STEVEN W. ROGERS
Sheriff
DONALD TERRY ROGERS
County Attorney
JOHN C. MOYER
Road Supervisor
July 6, 1977
Mr. John A. Green, Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
* " ' ; ' V'v • 'xjl) , k -
I wish to offer my comments on the Environmental Impact
Statement on the proposed wastewater treatment plant for the
Town of Jackson, Wyoming.
Our staff has reviewed the EIS and finds that it was well pre-
pared and is in accordance with our proposed 208 Areawide Waste
Treatment Management Plan. I personally attended the public
meetings and the hearing and found that they were effectively
conducted.
•
The staff of the 208 Planning Agency has had a very cooperative
relationship with Mr. Wes Wilson of EPA and Mr. Ed Cryer of James
M,. Montgomery Engineers, Inc. We provided some of the necessary
data and found that our comments made to them were well received.
These gentlemen should be commended for their efforts.
Thank you for letting me take a few moments of your time to
comments on the EIS.
Sincerely
Eugene P. Zeizel, Ph.D.
Project Director
208 Planning Agency
EPZ/jeb
- 147 -
-------
A STATEMENT BY THE TETON COUNTY SCHOOL DISTRICT RELATIVE TO THE ALTERNATIVES SUGGESTED
IN THE IMPACT STATEMENT OF THE JACKSON WASTEWATER TREATMENT SYSTEM.
In as much as the County School District has a newly acquired 25 year lease on 40 acres
of property immedaltely adjacent to the existing wastewater facility, the school district
does have a vested interest in the future plans for the Jackson Wastewater System.
1 Undoubtly alternatives A-5, a stabilization pond near South Park Road.and Alternative
A-7, no action,have the greatest potential for impact upon the school system.
A-5 as quoted from the study, "would open a larger amount of land to be serviced by
gravity flow", this means new home construction, which means new familic . which means
children am students. We can plan for that eventuality.
A-7 would provide an incompatible circumstance, relative to quote from the study,
"do nothing further to improve the condition their wastewater system, reduce odor problems
and the water quality degradation that is presently occuring. We cannot plan proper
school site development if that is the choice.
Teton County School District No. 1
box 568, jackson, Wyoming 83001
June 28, 197?
SUPERIKTEKDERT 7)
HIGH SCHOOL 73
JR. HIGH SCHOOL 7).
E LEKEMTARY SCHOOLS;
Alt* J8J
Jackson . . . ,7J3
K«11y 733
Mo r 5*3
Wilton 733
i
V
148
-------
/ V\V 11 / /
National Wildlife Federation
1412 16TH ST, NVV., WASHINGTON, DC 20036
Phone 202—797-6800
June 10, 1977
Mr. John A. Green
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80 29 5
RE: Draft Environmental Impact System, Jackson Wastewater
Treatment System, Town of Jackson, Wyoming (EPA-908/
Dear Mr. Green:
The National Wildlife Federation applauds the EPA's decision
not to fund the above-referenced project at the proposed
location, the South Park Elk Feedground. We concur completely
with your determination that the environmental impacts,
(particularly the land use impacts) of this alternative are
not acceptable.
We recommend alternative A-3, a Stabilization Pond at Boyle's
Hill, as the most environmentally and economically sound
solution to Jackson's" water pollution problem.
In light of the rapid population growth in this area, we also
strongly recommend the selection of a ten-year design life for
whatever project alternative is chosen.
Thank you for this opportunity to comment on this project.
Qi nno-rol \r
5-77-002)
Thomas K. Bick
201 Project
Resources Defense
TKB:kmb
149
-------
Response to Comments by the National Wildlife Federation
EPA has decided on the selection of a 15-year design life since
the cost analysis indicated no advantage to a shorter one. It
should also be noted that EPA used a relatively conservative
annual growth rate of 6% in the development of the facilities
plan, rather than the Town's 10-12% estimate which was based
on the most recent population increases experienced during the
last 18 months. EPA determined this growth rate could not be
sustained.during the 15-year design life, and based plant
capacity on the long-term (1965-1976) historical growth rate
in Jackson.
150
-------
l ite Wilderness Society ~
7/8/77
Telephone (307) 635-3416
Mr. Wes Weston
EPA -- Region VIII
i860 Lincoln St.
Denver, Colorado 80203
Deir Wesi
I have a few comments to make concerning the proposed wastewater treatment
plant in Jackson Hole, Wyoming.
First of all, I support your decision to reject the proposal that would
locate a plant in the South Park Elk Winter Feed Ground.
Secondly, the protection of the integrity of the Snake River is of great
importance to The Wilderness Society. Any decision on your part must not
compromise the natural river values of the Snake.
At this time, I must support Alt. #1, construction of a new facility at
the present site. I feel that such a move would prevent disruption of
wild and scenic river values of the Snake» there will be discharge into
Flat Creek, but your report statesthat such a discharge will not cause
ill-effects on the fishery or public health. Furthermore, Alt.#l would
prevent disruptive land use patterns in South Park. South Park is a very
sensitive scenic area at this time, and is an important component of
the proposed National Scenic Preserve for Jackson Hole.
I'm sorry that I was unable to attend the hearing in Jackson. I hope that
these comments are helpful to you.
Sincerely,
Bart Koehler
"In II /> llf I'rrtfn uii-m nf »/)¦¦ \\ urltl. " 7 hiirruu
151
-------
Response to Comments by the Wilderness Society
The aerated lagoon/rapid infiltration system alternative at
the Lower Bench site does not involve an outfall line to the
Snake River, and thereby does not conflict with the management
ofjectives and guidelines of the Wild and Scenic River Act.
The rate and number of hook-ups to the central wastewater
treatment system in Lower South Park will be determined by the
Town of Jackson and Teton County prior to the system becoming
fully operational in 1980.
152
-------
ilflJlo X ugnxCi'
Skyline Ranch 7
Jackson, Wyoming, 83001
Mr, John A. Green
Regional Administrator
U. S. Environmental Protection Agency
Region VIII
i860 Lincoln Street
Denver, Colorado, 80203
Rly name is Hans Buehler, and my address is as indicated above.
I ara a orivate citizen. I attended the Public Hearing on the
above r.atter on June 28,1977, at the Teton County Courthouse.
While I did not read a prepared statement, I did ask questions
and present opinions. These will be noted in the records of the
recorder present. -+-Mp
I find the Draft EIS quite detailed, and it is a i difficult
to ..ort out all the extraneous information and get to tne heart
of the matter. I feel, thct after considerable study, I have
been able to do this, and have come up with several concerns that
have not been fully answered or considered in this Draft EIS,
The first concernjdeals with PageI-2 and relates to tne matter of
infiltration and inflow to the existing sewer system. I was noted
that EPA had determined it was cost effective to correct approx-
imately 600,000 gpd of the peak infiltration, which represents
75,o of the infiltration and inflow, I would like to look a£ this
problem a little more in depth, because I note on Page III-3,
Table 13» Population and Flow Estimates some further information
dealing with this subject in determining the maximum flow for t e
design criteria for a proposed plant.
If one uses you data that a resident uses 120gpc, and a non-resident
50gpc, one can calculate all the flows in terms of Residents.
Consider the data for the year 1990, one can conclude that the
12900 non-residents, in terms of flow are equivalent to_5426 residents.
The so-called non-correctible infiltration is equivalent to 1753
residents, _nd the expected new infiltration is equivalent to
1002 residents. Thus the proposed plant flow is equivalent to
17781 residents. The combination of the infiltrations represents
a flow equivalent to 2755 residents, or 15.48% of the total
equivalent residents to be served by the neiv plant. However, this
is not really the picture, since tne equivalent residents are reliy
only the true residents, 9600, and tne 5426 equivalent residents
represented by the non-resident flow. Thus the infiltration is
iz.yy/o Of the people caused flow. If one considers tnat the non
residents really hve nothing to do v.'itn the inflow, tnen the present
i.'flow, and tne projected inflow represents 28.70>o of tne flow of
t:ie residents. This would see^ to indicate an e::trenely high
rate of poor sewer connections, or poorly constructed mains, or
bacily fitting man hole covers. I t further indicates tnat a plant
is bei:._. built at least 15.48% above required capacity jus t to
-153-
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Page 2
handle this inflow. Plese look at Par,e IV-11 under trie 1990
column, and eliminate tnose items th^t are not necessarilly volume
related in terws of caoital costs. Under this alternative, I be-
lieve the following items woul have to be done regardless <5f the
size of the plant:
By-pass and Abandon Coinmunitor S19000
Renovate Sever Pumps 71000
Conversion of Aeration tanks etc. 58000
Electrical 129000
Landscaping 19000
8 296000
Thus $2,117,000 - 296000 = Sij821,000 as capital cost which
is size related. Considering the excess capacity required due
to the inflow, 15*48?u represents some $282,000, This represents
10.7 % of the total cost of the project of 82,625,000. Nov; turn
to Page IV-19, and considerin - the present worth (1990) of A-l
@ S6,508,000, the 10.7Ja represents a value of £699,000. It is
logical to assume that the 03
-------
ilization pond. The first 2 cells would be partial mix systems
providing enough aeration to stabilize the organic load in the
is known about this system, how can EPA accept such a proposal
as an alternative. At the meetim a representative from the
facility engineer indicated that t,he system would be a total aerated
system. Even they do not know what they are proposing. Later
irt the dialos» it states "if operated properly it should meet tne
30iiig/l BOD standard, but it may require additional treatment to
consistently meet tne 30mg/l SS» I question whetner an identical
system is installed, has been operating and meeting ttne above
stanards in a climate such -s is encountered in Jackson, and where
about of the flow is due to non residents, and thus hignly variable.
La700Jis are not good systems where we have large changes in t^rougn-
put, and tnis is especially true in the summer. They just cannot
handle such swinj,s in throughput as a 1.62 pjak to maximum. This
ruenns trie retention tirae well be feduced lor that period by 63-6%.
There has never been, to ray knowledge, a lagoon system that did not
give give up odor" r.ost of the time, and at times was really foul
due to the anerobic digestion process giving off methane gas which
.caused the top layers of organic matter to be breeched permitting
the gas and the H2S odors to escape. The releasing of "the gas
from the anerobic area causes belchinj of not only the gas but the
solids from tnis area, thus mixing the non stabilized organic solids
froc; the depths witn tne stabilized blanket, causing a stinking
mess. Tnis particular action is mos prevalent in the warm months.
This is also the time when most tourists visit this area to partake
of our pristine environment. With a lagoon system our area will be
a "stinking mess", and we v/ill be driving away the very people
we want to come to this area, Tne Tourist. At the hearing, it was
indicated that the odors would be evident for only 7 mile around
the plant. X have lived in Southern California for some 8-2- years
and have travelled the Pomona freeway (Calif. 60) iaant times heading
east past the Ontario, Calif, sewage disposal plant. The odors
stretch for seceral miles from this location. This is also tuE
for the Huntington Beech planfl located oust north of the east end
of the Huntington Beech State Park.
We have mild inversions here, but also have prevailing southwest-
erly winds whica will send tne odors northerly to the City of
Jackson, so the tourists will be able to take full benefit of this
swell.
Inave had som 20 years experience with lagoons (stabilization)
ponds working for a paper producing company in tthe mid west. I a
acquainted with upsets, flow variation, odor, paint discoloration,
fish kills, claimed animal kills, etc., etc. Lagoons are no for
Jackson.
In this particular internationally known area , it is mandated tact
-------
Pace k
tnat all possible be done to protect the environment in every
respect. This leaves no alternative but to install a tried and true
Mecnanical Secondary System. Certainly the cost is more, but
on a flow basis, . 65^.^ is the result of the tourists, and 1.15
mgd is the result of t e residents. Tourism's share is 36% of the
total. Y/hy should they no pay their share. Last night I received
you sheet indicating the cost per resident for the various Alt-
ernative, however there was not indication how tne calculations
>vcre made. It would seem that the cost of treating sewage could
be related to the usage of water. Since Jackson provides the water
from wells to the residents, tnis can be metered and through calcul-
ations a sewer charge determined. In this way, restaurants, motels
and such that cater to the to irist could bebilled for the sewer
costs and pass it on to those using their facilities. Anotner,
and possibly a simpler method v/oul be for the city to have a room
tax for all .v.otels,. and a s^all city tax for restaurants who are
on the seser system. A city tax is no an unco.nmon t:iin in t e
U.S. The result would be the proper allocation of costs to the
user. This now seems to be the governmental method of doing t.iings
a s evidenced by EPA in requiring industry to pay their fair share
of the capital and operating costs to treat tneir specific waste,
COD,SS, Flow, Peak Flow, etc. Why is tn. same requirement not fair
for tnose iv.io use the sewer system of Jackson.
I a-preciate tne opportunity to write this letter, and express
my t ;ou ,hts and opinions on this vital environmental problem
of tne area of Jackson Hole. While I recognize I do not live in
Jackson proper, it is evident tnat in thp future years septic
tanks and leech fields will be a tning of the past, and all will
nave to attach to a city or county seiva ,e system. Thus I feel J
will become involved, and tnus tne abo,ve comments snould be
considered as one concerned with the future of this area. I
suggest the EPA review tne Alternatives, and eliminate all tne
present lagoon alternatives, and in their place substitute new
alternatives involving, and encompassing Mecnanical Secondary
Treatment. This type of Alternative will be compatible with the
Comprehensive Plan now being developed, and will provide , and
assure t.;e highest quality wate water to either the Snake River or
Flat Creek, and retain the pristine environment of Jackson Hole
for tnose who live here, and for tne more than 3»000,000 visitors
who cone to see our Grand Teton National Park and Jackson.
cc: Mr. Ralph Gill
Mayor,
Jackson, Wyoming
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Response to the Comments of Mr. Hans Buehler
1. The infiltration allowances were calculated on two
separate basis. The first is the existing infiltration
which will not, according to the EPA funded Infiltration/
Inflow Analysis, be corrected by the sewer rehabilitation
work being conducted this summer. This 0.21 mgd peak
infiltration will remain constant through the design
period according to our assumption. The second I/I
figure is realy based on area served, not population.
The accepted I/I allowance for new sewer construction
has been approximately 300 gallon per acre service per
peak day. We estimated approximately 380 new acres
would be put in development by 1990 and calculated
out the 0.12 mgd expected peak infiltration. It appears
Mr. Buehler has misinterpreted our analysis, and we
hope this clarifies the figures presented. The 0.33 mg
of peak infiltration expected by 1990 is a figure which
is conservative. Jackson has, in the past, suffered
from poor sewer installation, but with the assistance
of a full time city engineer and the use of reliable
construction inspection, it should be possible to keep
new infiltration at a minimum. Unfortunately, it is
not cost effective to remove all the existing infiltra-
tion as presented in the EPA I/I analysis. Much of this
came from old house laterals and clandestine storm water
and runoff discharges into the system.
2. Facilities of the type proposed can work in cold climates.
Stabilization ponds are still the most common form of
treatment facilities for smaller communities. While
systems vary as to design and effectiveness, the major
problems result from high spring loading and improper
operating and maintenance procedures. It's necessary
to keep in mind that the proposed facility will be
mechanically aerated (at least partially), and capable
of handling peak organic loading if properly designed.
The higher summer loading rates could cause odor and
effluent quality problems unless the system is designed
to handle the peak day design flow. Retention times
and loading criteria are normally calculated from the
maximum day expected flow that could occur at the end
of the design period (1990) and still provide a final
effluent of the required quality.
3. While the "stinking mess," Mr. Buehler refers to, is
somewhat extreme, even a properly operated stabilization
pond will have odor problems. The degree of these
problems depend upon the organic loading rates, the
climatic (temperature, rainfall) conditions and the
design and operation of the system. In the Jackson
area, spring is the time when the greatest odor
problems will be encountered if the facility is inade-
quately sized to handle peak summer flow.
-157-
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4. Stabilization ponds used to treat paper mill wastes
have problems similar to those used in domestic systems.
The major problems come from inadequate sizing and the
buildup of excess amounts of septic sludge on the bottom.
The odor and paint discoloration problems cited for pulp
mill waste ponds is somewhat unique to that industry and
arise from the chemicals used in the cellulose digestion
process.
5. The revenue and financial plan included in the draft EIS,
and made available at the public hearing, presented a
detailed explanation of an equitable service charge
program for each alternative being considered. Under
the EPA guidelines, each user in the system must pay
its fair share of the capital and 0 & M cost based
upon total contribution {flow and loading). As detailed
in the plan, tourist-based businesses (i.e., motels,
restaurants, etc.) will be required to assume the
financial responsibility for their share of the system.
The reader is referred to the Preliminary Financing and
Revenue Program for Jackson Wastewater Treatment System
for a detailed discussion of use charges.
-158-
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July 1, 1977
James H. Gilbert
P. O. Box 2505
South Park
Jackson, Wyoming 8 30 01
Mr. John A. Green, Regional Administrator
U. S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 802 95
Dear Mr. Green:
As a homeowner in South Park, I wish to offer the follow-
ing comments relating to EPA - 908/5-77-002 Summary Draft
Environmental Impact Statement, Jackson Waste Water Treatment
System, Town of Jackson, Wyoming:
1). I question whether in the financial analysis of com-
parative costs of A1 through A5, the study has in-
cluded the cost of three separate outfall lines per
plant for Alternates A2 through A5.
2). Inasmuch as the river is less constricted as one pro-
ceeds upstream from A5 to A2, the adverse environmen-
tal impact both visual and odor in the river bed will
increase from A5 to A4 and onto A2. A2 outfall sys-
tem will have the most detrimental impact both visual
and odor.
£
,2 ' 3). I suggest the cost of three pipeline outfall systems will
be incrementally greater as one proceeds from A5 to A2.
4). Regardless of the constructive intent of the design
engineers, the odor pollution of the environment with
lagoons will be significantly greater than a mechan-
ical sewage disposal system.
t
5). With both the extremes of temperature and water table
the lagoon system will inevitably result in dramatic
air pollution. The wind-carried odor will affect all
within a one-mile radius of the plant.
6). A tertiary plant would have the least odor impact on
the environment. The less effective secondary plant
is compromise enough in its odor impact on the environ-
ment. The environmental quality of Jackson Hole in-
cluding South Park is world reknown, and at the same
time so fragile. Although a tertiary plant would be
-159-
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Mr. John A. Green, Regional Administrator
July 1/ 1977
Page 2
the best solution, a secondary plant is compromise
enough.
7). To consider building a new facility at Boyles Hill
(A2) located as it is at the north end of South Park
would be a less than logical decision. This would
not stop development in South Park, b"ut it would
dictate septic systems throughout South Park, prob-
ably one or more pumping stations in the future,
probably small private sewer plant systems, and e-
ventually construction of a sewage plant at A5.
Therefore, I recommend:
1). As first priority the construction of a secondary
plant at A5.
2). As a second priority the completion of original
design plus any changes necessary to make this plant
at A1 efficient. At the same time the acquisition
of land today in the A5 area for the plant which
will be required in the future.
Very truly yours,
James H. Gilbert
CC: Mr. Ralph Gill
Mr. William Ashley
-160-
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Response to Comments by Mr. James H. Gilbert
1. The cost of an outfall for each alternative (A-2 - A-5)
was calculated as indicated on Tables 17, 18, 19, 20, 21
2. Based upon the physiography of the river, the deepest
reliable channel is near the proposed outfall for A-5
along the Department of Game and Fish's diked area.
3. The estimated cost for the Alternative outfall is as
follows:
including engineering administration, contingencies, and
escalation.
4. A stabilization pond will generate some odors, but it
would be impossible to predict just how far the wind
could carry these on a given day.
and 22.
A-2
A-3
A-4
A-5
$760,000
760,000
869,000
512,000
-161-
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- -rrv-K \v-su, >
Byron Jenkins
Box 597
Jackson, Wyoming 83001 > /
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-162-
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-163-
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Response to Comments by Byron Jenkins
1. The approval of the Flat Creek interceptor route and the
Lower Bench treatment facility site meets the objective
of providing a long term'solution to Jackson's wastewater
treatment problems. Out-of-city hook-up priorities and
annual rates will be determined by the Town of Jackson
and Teton County prior to the plant becoming fully operational.
Groundwater monitoring requirements identified in the final
EIS will be imposed to ensure that groundwater quality at
the Lower Bench site is not being degraded.
-164-
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
W-°ftT8/%-79-ooiB
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Final Environmental Impact Statement
Jackson Wastewater Treatment System
Town of Jackson, Wyoming
S. REPORT DATE
February 12. 1979
6. PERFORMING ORGANIZATION CODE
8W-EE
7. AUTHOR(S)
Ed Cryer, James M. Montgomery Engrs.
Weston W. Wilson, EPA
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
J .M. Montgomery Engineers
1301 vistd Ave.
Boise, Idaho 83705 (202) 345-5865
10. PROGRAM ELEMENT NO.
11. CO^tRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln St.
Denver. Colorado 80295 (303) 837-4831
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING agency code
15. SUPPLEMENTARY NOTES
Draft Environmental Impact Statement dated May 1, 1977 EPA 908/5-77-002
Summary Final Environmental Impact Statement dated February 12, 1979 EPA 908/5-79-001A
16 ABSTRACT
This 1s a final environmental Impact statement (EIS) for proposed construction of
additional wastewater treatment facilities at Jackson Hole, within Teton County,
Wyoming. The U.S. Environmental Protection Agency (EPA), Region VIII, Denver, under
the authority of Section 201 of the Federal WAter Pollution Control Act Amendments
of 1972, 1s authorized to grant 75 percent matching funds for construction costs of
designated wastewater treatment facilities. Sewage discharges as a result of area
growth and development together with non-point source runoff have degraded the water
quality of Flat Creek. Therefor, additional sewage treatment facilities are needed
to meet water quality goals.
The recommended action 1s to construct aerated lagoons followed by rapid infiltration
basins 4 miles downstream of the existing plant. The new facility will enhance
development 1n the undeveloped South Park area. Ground water monitoring will be
requlred.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Sewage Disposal. Financing
Sewage Irrigation
Rapid Infiltration Basins
Water Pollution
Infiltration/percolation
Regional Planning
Environmental Impact Statement
Jackson Hole Scenic
Area
Snake River Wild and
Scenic River Study
18 DISTRIBUTION STATEMENT
Release Unlimited
19 SECURITY CLASS (TJtts Report)
21. NO. OF PAGES
187
20 SECURITY CLASS (This page)
22. PRICE
EPA Form 2220-1 (R«v. 4-77) previous edition is obsolete
165
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