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RUUES AND REGULATIONS
stages of the environmental impact
:.tat«ment process to expedite review of
the statement. Statements oil projects
affecting properties Included la or eligi-
ble foe Inclusion in the National. Register
should b« sent directly to the Advisory
Council for review. AO. statements In-
volving historic, architectural, archea-
logical, or cultural resourcas, whether or
not Included In or eligible for Inclusion
in the National Register, should he sub-
mitted to the Department of Interior
for review.
J- 801k} Definition*.
As used tn these procedures:
iai "Nattonal Historic Preservation
Act" means Public Law 89-865,. approved
October 15, 19OT, an "Act to estab-
lish a program for the preservation of
additional htstorlc properties throughout
the ffatlcm and far other purposes," 80
Stat. 91S, IS U S,C. 470, as amended, 84
Stat. 204 (197B) and 87 Stat. 138 (1973)
hereinafter referred to as "the Act."
»
Inclusion tn the National ftaaUtar tJiui
be conclusive for the purposes of Uiew.
procedures.
lb) Determination of effect. For each
property Included in or eligible for in-
clusion in the National Register that is
located within the area of the undertak-
ing's potential environmental impact, the
Agency Official, In consultation with the
State Historic Preservation Officer, shall
apply the Criteria of Effect, set forth in
Section 80Q.8, to determine whether the
undertaking has an effect upon the prop-
erty. Upon applying the Criteria anc
finding no effect, the undertaking ma)
proceed. The Agency Official shall keep
adequate documentation of a determina-
tion of no effect.
(c)	Effect established. Upon flndini
that the undertaking will have any el
feet upon a property Included in or e!i
gible for Inclusion In the National Regis
ter, the Agency Official, In consultation
with.the State Historic Preservation Offi
cer, shall apply the Criteria of Advers
Effect, set forth in §800.9, to determin
whether the effect of the undertaking i
adverse.
(d)	Finding of no adverse effect. Upon
finding the effect not to be adverse, the
Agency Official shall forward adequaw
documentation of the determination, in
eluding evidence of the views of tbr
State Historic Preservation Officer, to
the Executive Director for review. Un
less the Executive Director notes an ob
jectlon to the determination within 45
days after receipt of adequate documen-
tation, the Agency Official may proceed
with the undertaking.
(e)	Finding of adverse effect. Upov
finding" the effect to be adverse or upon
notification that the Executive Director
does not accept a determination of no
adverse effect, the Agency Official shall
(1) Request, in writing, the comments oi
the Advisory Council; (2) notify the
State Historic Preservation Officer of this
request; (3) prepare a preliminary case
report; and (4) proceed with the consul-
tation process set forth in section 800.5.
(f)	Preliminary, case report. Upon re-
questing the comments of the Advisory
Council, the Agency Official shall provide
the Executive Director and the State His-
toric Preservation Officer with a pre-
liminary case report, containing all
relevant Information concerning the
undertaking. The Agency Official shall
obtain such, information and material
from any applicant, grantee, or other
beneflciary involved in the undertaking
as may be required for the proper eval-
uation of the undertaking, its effects, and
alternate courses of action.
§ 800.5 Camnlbrtwn prorww.
(a) Response to request far coMvunts.
Upon receipt of a request for Advisory
Council comments pucauaat ta Section
800.4(e), the Executive Director shall ac-
FEDERAL REGISTER, VOL 39, NO. IS—FRIDAY, JANUARY 25, 1974

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3368
knowledge the request and shall Initiate
the consultation process.
(b> On-site inspection* At the request
of the Agency Official, the State Historic
Preservation Officer, or the Executive Di-
rector, the Agency Official shall conduct
an on-site Inspection with the Executive
Director, the State Historic Preservation
Officer and such other representatives of
national. State, or local units of govern-
ment and public and private organisa-
tions that the consulting parties deem
appropriate.
(c> Public information meeting. At the
request of the Agency Official. the State
Historic Preservation Officer, or the Ex-
ecutive Director, the Executive Director
shall conduct a meeting open to the pub-
lic, where representatives of national,
Btate, or local units of government, rep-
resentatives of public or private organi-
sations, and interested citizens can re-
ceive information and express their views
on the undertaking. Its efTects on his-
toric and cultural properties, and alter-
nate courses of action. The Agency Of-
ficial shall provide adequate facilities for
the meeting and shall afford appropriate
notice to the public in advance of the
meeting.
(d)	Consideration of alternatives.
Upon review of the pending case and
subsequent to any on-site Inspection and
any public Information meeting, the Ex-
ecutive Director shall consult with the
Agency Official and State Historic Pres-
ervation Officer to determine whether
there Is a feasible and prudent alterna-
tive to avoid or satisfactorily mitigate
any adverse effect.
(e)	Avoidance of adverse effect. If the
Agency Official, the State Historic Prea-
ervation Officer, and the Executive Di-
rector select and unanimously agree upon
a feasible and prudent alternative to
avoid the adverse effect of the undertak-
ing. they shall execute a Memorandum
of Agreement acknowledging avoidance
of adverse effect. This document shall be
forwarded to the Chairman for review
pursuant to Section 800.6(a).
(t) Mitigation of adverse effect. If the
consulting parties are unable to unani-
mously agree upon a feasible and prudent
alternative to avoid any adverse effect,
the Executive Director shall consult with
the Agency Official and the State His-
toric Preservation Officer to determine
whether there is a feasible and prudent
alternative to satisfactorily mitigate the
adverse effect of the undertaking. Upon
finding and unanimously agreeing to such
an alternative, they shall execute a
Memorandum ot Agreement acknowledg-
ing satisfactory mitigation of adverse ef-
fect. This document shall be forwarded
to the Chairman for review pursuant to
Section 800.0(a).
(g) Memorandum of Agreement. It
shall be the responsibility of the Execu-
tive Director to prepare each Memoran-
dum of Agreement required under these
procedures. In preparation of such a
document the Executive Director may
request the Agency Official to prepare a
proposal for Inclusion in the Memoran-
dum detailing actions to be taken to
avoid or mitigate the adverse effect.
RULES AND REGULATIONS
(h) Failure to avoid or mitigate ad-
verge effect. Upon the failure of consult-
ing parties to find and unanimously agree
upon a feasible and prudent alternative
to avoid or satisfactorily mitigate the ad-
verse effect, the Executive Director shall
request the Chairman to schedule the
undertaking for consideration at the next
Council meeting and notify the Agency
Official of the request. Upon notification
of the request, the Agency Official shall
delay further processing of the undertak-
ing until the Council has transmitted its
comments or the Chairman has given
notice that the undertaking will not be
considered at a Council meeting.
§ 800.6 Council procedures.
(a) Review of Memorandum of Agree-
ment. Upon receipt of a Memorandum of
Agreement acknowledging avoidance of
adverse effect or satisfactory mitigation
of adverse effect, the Chairman shall in-
stitute a 30-day review period. Unless
the Chairman shall notify the Agency
Official that the matter has been placed
on the agenda for consideration at a
Council meeting, the memorandum shall
become final: (1) Upon the expiration
of the 30-day review period with no ac-
tion taken; or (2) when signed by the
Chairman. Memoranda duly executed In
accordance with these procedures shall
constitute the comments of the Advisory
Council. Notice of executed Memoranda
of Agreement shall be published in the
Federal Rboistsr monthly.
(b) Response to request for considera-
tion at Council meeting. Upon receipt of
a request from the Executive Director for
consideration of the proposed undertak-
ing at a Council meeting, the Chairman
shall determine whether or not the un-
dertaking will be considered and notify
the Agency Official of his decision. To
assist the Chairman In this determina-
tion, the Agency Official and the State
Historic Preservation Officer shall pro-
vide such reports and Information as
may be required. If the Chairman de-
cides against consideration at a Council
meeting, he will submit a written sum?
mary of the undertaking and his decision
to each member of the Council. If any
member of the Council notes an objec-
tion to the decision within IS days of
the Chairman's decision, the undertak-
ing will be scheduled for consideration
at a Council meeting. If the Council
members have no objection, the Chair-
man shall notify the Agency Official at
the end of the 15-day period that the
undertaking may proceed.
(c> Decision to consider the undertak-
ing. Upon determination that the Council
will consider an undertaking, the Chair-
man shall: (1) Schedule the matter for
consideration at a regular meeting no
less than 80 days from the date the re-
quest was received, or In exceptional
cases, schedule the matter for considera-
tion In an unassembled or special meet-
ing; (2) notify the Agency Official and
the State Historic Preservation Officer of
the date on which comments will be con-
sidered; and (3) authorize the Executive
Director to prepare a case report
(d) Content of the case report. For
79
purposes of arriving at comments, the
Advisory Council prescribes that certain
reports be made available to it and ac-
cepts reports and statements from other
interested parties. Specific informational
requirements are enumerated below.
Generally, the requirements represent an
explication of elaboration of principle*
contained in the Criteria of Effect and In
the Criteria of Adverse Effect. The
Council notes, however, that the Act
recognizes historical and cultural re-
sources should be preserved "as a living
part of our community life and develop-
ment." Consequently, in arriving at final
comments, the Council considers those
elements in an undertaking that have
relevance beyond historical and cultural
concerns. To assist It In weighing the
public interest, the Council welcomes in-
formation not only bearing upon physi-
cal. sensory, or esthetic effects but also
information concerning economic, so-
cial, and other benefits or detriments
that will result from the undertaking.
(e) Elements of the case report. The
report on which the Council relies for
comment shall consist of:
(1) A report from the Executive Di-
rector to include a verification of the
legal and historical status of the prop-
erty; an assessment of the historical,
architectural, archeologlcal, or cultural
significance of the property; a statement
indicating the special value of features
to be most affected by the undertaking;
an evaluation of the total effect of the
undertaking upon the property; a critical
review of any known feasible and pru-
dent alternatives and recommendations
to remove or mitigate the adverse effect;
(2> A report from the Agency Official
requesting comment to include a general
discussion and chronology of the pro-
posed undertaking; when appropriate, an
account of the steps taken to comply
with section 102(2) (A) of the National
Environmental Policy Act of 1069 (83
Stat. 852,42 U.8.C. 4321): an evaluation
of the effect of the undertaking upon
the property, with particular reference to
the Impact on the historic, architectural,
archeologlcal and cultural values; stepe
taken or proposed by the agency to take
into account, avoid, or mitigate adverse
effects of the undertaking; a thorough
discussion of alternate courses of action;
and. if applicable and available, a copy
of the draft environmental statement
prepared in compliance with section 103
<2) (C) of the National Environmental
Policy Act of 1989;
(3)	A report from any other Federal
agency having under consideration an
undertaking that will concurrently or
ultimately affect the property, Including
a general description and chronology of
that undertaking and discussion of the
relation between that undertaking and
the undertaking being considered by the
Council;
(4)	A report from the State Historic
Preservation Officer to Include an assess-
ment of the significance of the property;
an identification of features of special
value; an evaluation of the effect of the
undertaking upon the property and Its
specific components: an evaluation of
KOiRAl «GISTM. vol. 39. NO. H-FRIDAY. JANUARY 25. 1974

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IULES AND REGULATIONS

known alternate courses of action; a dis-
cussion of present or proposed participa-
tion of SUte and local agencies or orga-
niMtWu in preserving or anlsttng In
preserving the property; an Indication of
the support or opposition of units of gov-
ernment and public and private agencies
and organisations within the State; and
the recommendations of his office;
(5)	A report by any applicant or po-
tential recipient when the Council con-
siders comments upon an application for
a contract, grant, subsidy, loan, or other
form of funding assistance, or an appli-
cation for a Federal lease, permit, license,
certificate, or other entitlement for use.
Arrangements lor the submission and
presentation of reports by applicants or
potential recipients shall be made
through the Agency Official having Juris-
diction in the matter; and
(6)	Other pertinent reports, state-
ments, correspondence, transcripts, min-
utes, and documents received by the
Council from any and all parties, public
or private. Reports submitted pursuant
to this section should be received by the
Council at least two weeks prior to a
Council meeting.
(t) Coordination of case reports and
statements. In considerations involving
more than one Federal department,
either directly or Indirectly, the Agency
Official requesting comment shall act as
a coordinator In arranging for a full as-
sessment and discussion of all interde-
partmental facets of the problem and
prepare a record of such coordination to
be made available to the Council. At the
request of the Council, the State Historic
Preservation Officer shall notify appro-
priate governmental units and public and
private organizations within the State of
the pending consideration of the under-
taking by the Council, and coordinate the
presentation of written statements to the
Council.
(g)	Council meetings. The Council does
not hold formal hearings to consider
comments under these procedures. Two
weeks notice shall be given, by publica-
tion in the Federal Register, of all meet-
ings Involving Council review of Federal
undertakings in accordance with these
procedures. Reports and statements will
be presented to the Council In open ses-
sion in accordance with a prearranged
agenda. Regular meetings of the Coun-
cil generally occur on the first Wednes-
day and Thursday of February, May, Au-
gust and November.
(h)	Oral statements to the Council. A
schedule shall provide for oral state-
ments from the Executive Director; the
referring Agency Official presently or
potentially involved; the applicant or
potential recipient, when appropriate;
the State Historic Preservation Officer;
and representatives of national, State, or
local units of government and public and
private organizations. Parties wishing to
make oral remarks shall submit written
statements of position in advance to the
Executive Director.
(1) Comments by the Council. The
comments of the Council, Issued after
consideration of an undertaking at a
Council meeting, shall take the form of
a three-part statement, including an
Introduction, findings, and a conclusion.
The statement shall include notice to the
Agency Official of the report required
under section SOO.61J) of these proce-
dures Comments shall be made to the
head of the Federal Agency requesting
comment or having responsibility for the
undertaking. Immediately thereafter, the
comments of the Council will be for-
warded to the President and the Con-
gress as a special report under authority
of section 202(b) of the Act and pub-
lished as soon as possible In the Federal
Register. Comment shall be available to
the public upon receipt of the comments
by the head of the Federal agency.
(j) Report of agency action in response
to Council comments. When a final deci-
sion on the undertaking is reached by the
Federal Agency, the Agency Official shall
submit a written report to the Council
containing a description of actions taken
by the Federal Agency subsequent to the
Council's comments; a description of ac-
tions taken by other parties pursuant to
the actions of the Federal Agency; and
the ultimate effect of such actions on
the property involved. The Council may
request supplementary reports if the na-
ture of the undertaking requires them.
ik) Records of the Council. The records
of the Council shall consist of a record
of the proceedings at each meeting, the
case report prepared by the Executive
Director, and all other reports, state-
ments, transcripts, correspondence; and
documents received.
(1) Continuing review jurisdiction.
When the Council has commented upon
an undertaking pursuant to Section 800.6
such as a comprehensive or area-wide
plan that by Its nature requires subse-
quent action by the Federal Agency, the
Council will consider its comments or
approval to extend only to the undertak-
ing as reviewed. The Agency Official shall
ensure that subsequent action related to
the undertaking is submitted to the
Council for review in accordance with
S 800.4(e) of these procedures when that
action Is found to have an adverse effect
on a property included in or eligible for
Inclusion in Uie National Register;
§ 800,7 Other powers of the Council.
(a)	Comment or report upon non-Fed-
eral undertaking. The Council will ex-
ercise the broader advisory powers, vested
by section 202(a) (1) of the Act, to recom-
mend measures concerning a non-Federal
undertaking that will adversely affect a
property included in or eligible for inclu-
sion in the National Register: (1) upon
request from the President of the United
States, the President of the U.S. 8enate,
or the Speaker of the House of Repre-
sentatives, or (2) when agreed upon by
a majority vote of the members of the
Council.
(b)	Comment or report upon Federal
undertaking in special circumstances.
The Council will exercise its authority to
comment to Federal agencies in certain
special situations even though written
notice that an undertaking will have an
80
effect has not been received. For example,
the Council may choose to comment In
situations where an objection is made to
a Federal agency finding of "no effect
§ 800.8 Cxilrrla of .-HV.-t.
A Federal, federally MMiated, or (<•>(
eiully licensed undertaking *lmll 1* con
sldcied to have an effect on n Nntlonu
Register property or property eligible fot
inclusion in the National Register (dis-
tricts, sites, buildings, structures, and
objects, including their settings) when
any condition of the undertaking causes
or may cause any change, beneficial or
adverse, in the quality of the historical,
architectural, archeological, or cultural
character that qualifies the property
under the National Register Criteria.
§ 800.9 Criteria of adverse effect.
Generally, adverse eifects occur under
conditions which Include but are not
limited to:
(a)	Destruction or alteration of all or
part of a property;
(b)	Isolation from or alteration of it
surrounding environment;
(c)	Introduction of visual, audible, o:
atmospheric elements that are out o!
character with the property or alter it
setting;
(d)	Transfer or sale of a federally
owned property without adequate condi
tions or restrictions regarding preserva-
tion. maintenance, or use; and
(e)	Neglect of a property resulting in
its deterioration or destruction.
§ 800.10 INutional Register criteria.
(a)	"National Register Criteria
means the following criteria established
by the Secretary of the Interior for use
in evaluating and determining the eligi-
bility of properties for listing in the Na-
tional Register: The quality of signifi-
cance in American history, architecture,
archeology, and culture is present in dis-
tricts, sites, buildings, structures, and
objects of State and local Importance
that possess Integrity of location, design,
setting, materials, workmanship, feeling
and association and:
(1)	That are associated with events
that have made a significant contribu-
tion to the broad patterns of our history;
or
(2)	That are associated with the lives
of persons significant in our past; or
(3)	That embody the distinctive char-
acteristics of a type, period, or method of
construction, or that represent the work
of a master, or that possess high artistic
values, or that represent a significant
and distinguishable entity whose com-
ponents may lack individual distinction;
or
(4)	That have yielded, or may be
likely to yield, information Important in
prehistory or history.
(b)	Criteria considerations. Ordi-
narily cemeteries, birthplaces, or graves
of historical figures, properties owned
by religious institutions or used for re-
ligious purposes, structures that have
been moved from their original locations,
reconstructed historic buildings, prop-
erties primarily commemorative in na-
FIDERAL REGISTER, VOl. 39, NO. It—FRIDAY, JANUARr 25, 1974

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3370
RULfS AMD RICUIATIONS
tare, and properties mat have achieved
tigntflcance within, the past 54 y«n
¦hall not be ceRiaMaved «h|IWi far ttw
National Register. Bovnw. aw* prop-
erties will quality If Uifty at* Integral
parts of districts that do mtt the cri-
teria « if U*y faD wttMn th« following
(1) A raOtloue property deriving pri-
mary significance from arehtteetural or
artistic distinction or bittoHoal Impor-
tance;
(1) A building or atructure removed
from Ita orldnai location bat which is
the surviving structure moat Importantly
¦rFoolsted with a his to He person or
•vent;
(3) A birthplace or grave of a histori-
cal figure of outstanding importance U
there la m appropriate alte or budding
dlreotly aaaooiatad with hi* productive
lUe:
(41 A oeraetery which derives lta pri-
mary ilgnificaace from graves of peraons
of transcendent Importance, from age,
from distinctive design featuraa, or from
association with historic events;
(5) A reconstructed building when ac-
curately executed to a suitable environ-
ment and presented In a dignified man-
ner aa part of a restoration master pirns,
and when no other buttdlag or structure
with the aame association haa aurvlv«d;
(Q) A property primarily oommamo-
rative In Intent if deelgn, an tradition,
or nymbollo value hag Invested It with
lta own hlatorloa] algnlfloaace: or
<¦?> A property achieving algnlflcance
within the paat BO years If it Is of excep-
tional Importance.
int DOC.74-10M jflad i-24-7«;g:« un)
81
FEDERAL REGISTER, VOl. 39, NO. 18—fRIDAY, JANUARY 21, 1974

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Response to Comments by Advisory Council on Historic Preservation
1. Dae to the EPA's decision on the Salmon Creek projects, as presented
in the Preface to this document, no further detailed investigation of
the historic or archeological properties of the area are to be considered.
That area of the Salmon Creek project that can be included under the
proposed Lemon Creek Interceptor project will be studied for historic
preservation. When the area from Salmon Creek to Norway Point is
resubmitted for development of wastewater facilities, the cultural
and historic aspects of the region will need to be evaluated.
82

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United States Department of Agriculture
FOKEST SERVICE
P. 0. Box 1628, Juneau, Alaska 99802
8400
December 2, 1975
r
Mr. Richard R. Thiel, Chief
Environmental Inpact Section M/S 443
Environmental Protection Agency
1200 Sixth Avenue
(Seattle, Washington 98101
Dear Mr. Thiel:
Following are our cements on the Draft Environmental Statement for
the Salmon Creek interceptor, Local Irrprovement District (LID) No.
4, City and Borough of Juneau, Alaska EPA Contract No. 68-01-2385.
1.	The statement speaks continuously to the various aspects
(Avalanche, Unstable soil, Steep Terrain, Dam Failure Hazard, etc.)
that will minimize additional development yet identifies the main
need for the proposed sewer system is due to anticipated development.
2.	The draft statement does not shew if a cost/benefit analysis
has been done for the overall project. This is needed for the
alternatives as well. It is difficult to effectively examine the
economic values of the project with what is presented.
3.	Generally accepted sewage flow is 75 gallons per capita per
day. The report uses 135 gallons. This is an 80 percent factor.
The use of 135 gallons nay have been justified in the Juneau proper
area where water is allowed to flow during the winter to prevent
freeze-up, but should not be vised for LID 4. The blanketing of the
entire area with figures for one area does not lend itself to sound
reasoning.
4.	The draft statement indicates- that about the only area of the
LID that has much developable area is adjacent to Salmon Creek. It
also identifies the hazard potential of the Salmon Creek Reservoir.
Current recognition and national concern for this type of hazard
potential would seem to minimize any development in this location.
5.	The use of 10 inch gravity lines will require introducing
additional water into the lines to maintain a velocity that will
keep the solids moving. This is another added cost both in construction
and maintenance that could be avoided by proper design and construction.
RECEIVED
17C:> 1975
CO * . —
83
•*00-" (1/M)

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6. The peaking factor of 2.5 times used in tbs report does not
Q seem to apply in LID 4 where there probably never will be storm sewers
or runoff included in the system.
Generally the Draft Statement is well written and adequately describes
the proposal. This agency has no objection to the proposed action.
We appreciate the opportunity to review and comment on the Draft
Statement.
Sincerely,
84

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Response to Comments by United States Department of Agriculture,
Forest Service
1.	While the area has significant geologic, seismic and avalanche hazards,
the comprehensive plans developed and adopted by the City and Borough
of Juneau, have essentially designated the entire project area for
residential, commercial and industrial development (see Figure 8).
Unless these plans are modified, it would appear that the additional
development should be anticipated within the project area.
2.	A cost/benefit analysis has not been developed for project alternatives
because the acceptable alternatives, as presented, achieve relatively
the same benefits at the same cost. A "cost-effectiveness" condition
must be performed by grantees, in accordance with Appendix A to
the EPA's construction grant regulations, 40 CFR, part 35.
3.	The 135 gpd figure was used in the engineering report on which the
proposed project was based. We realized that this was higher than
normally accepted as a basis for design, but felt that until further
engineering studies are developed, this figure should be presented.
The procedure of allowing water to flow to prevent winter pipe freeze-
up is utilized extensively in LID #4 according to the City and Borough's
engineer for this project. Until contrary evidence is presented, we
must assume this habit to predominate throughout the area.
4.	See response to 1.
5.	The line sizes referred to within the EIS draft are those given in the
City and Borough of Juneau's preliminary engineering report (1971).
Low flow velocities and long retention times may create several
problems in operating and maintaining a gravity sewer, but it was
realized that additional engineering would be necessary before the
project would be approved for further action. Due to the EPA's
decision as presented in the Preface of this document, a complete
reevaluation of the design criteria developed for the 1971 report will
be required. At such time, consideration should be given to such items
as scouring velocity, line retention, and wet-well holding capacities,
as discussed on page 46 of the draft EIS.
6.	A peaking factor of 2. 5 was utilized in the City and Borough of Juneau's
preliminary engineering report. The 2. 5 figure for the current and
projected population, and the flows expected within the area is low by
most accepted standards and would be assumed as the minimal peaking
factor. EPA's decision, as presented in the Preface, will require a
reevaluation of all design criteria.
85

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PYiaYT Cn c5 /ft\ n 6\ (? [f /?
\ •	¦ rj | i -J / Ln j (ill \\ | a\ jl\\	JAYS. MJMNMty f0MEMM
vV J Ln.: .. Lj [:l J LruJijLni^ iJuj'n\
OFFICE OF THE GOVERNOR
state niter omtonuHT m wuum men u-Hjmu mn
mm w-3512
November 28, 1975
Mr. Clifford V. Smith, Jr. PH.D.,P.E.
Regional Supervisor
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 96101
Subject: Salmon Creek Interceptor
State I.D. No. 75100607
Dear Mr. Smith:
The Alaska State Clearinghouse has completed review on the subject project.
The following agencies were invited to review and comment:
State of Alaska
Department of Community & Regional Affairs
Office of Planning & Research
Department of Environmental Conservation
Department of Fish & Game (Juneau)
Department of Highways
Department of Law
Department of Natural Resources
Division of Parks
Department of Public Works
Department of Commerce & Economic Development
Two of the above agencies responded and their comments are attached.
The Clearinghouse finds this project to be consistent with State long-range
planning goals and objectives. Therefore, this letter will satisfy the
review requirements of the Office of Management and Budget Circular A-95.
Sincerely,
Rayn^d W. Estess
State-Federal Coordinator
Attachment
RECEIVED
DEC 3 1975
86

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MEMORANDUM
to: Raymond Estess
State-Federal Coordinator
Division of Policy Development
and Planning
Office of the Governor
from: James W. Brooks, Commissioner
Department of Fish and Game
BY:
State of Alaska
DATE:
FILE NO:
TELEPHONE NO:
SUBJECT:
Richard Reed
Regional Habitat Protection Supervisor
Juneau
>' ¦¦. £»
y ^
November 5, 1975 f\\ *
J I j
/
*
'•" y «
;
** *•-
"'r' —
Salmon Creek Interceptor *
State I.D. No. 75100607
Wo have reviewed the Draft Environmental Impact Statement on the Salmon Creek
Sewer Interceptor and feel it is generally well written. There is one point
which we feel was not adequately covered, that was exactly how the sewer line
| was going to cross Salmon Creek. In our discussions with the consultants,
they indicated the line would be suspended from the old Glacier Highway bridge.
This point, however, was not discussed in the statement and we feel it should
have been. The remaining fish and wildlife aspects were quite clearly discussed
I With regards to the alternatives, the Department of Fish and Game supports
alternative 2, the proposed project (the establishment of a Local Improvement
District).
We appreciate the time and effort expended by the consultants to obtain our
comments during preparation of this document.
87

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Response to Comments by Alaska Department of Fish and Game
1.	An apparent misunderstanding took place during our initial contact
with Mr. Reed. It was our understanding the ADFG had reviewed
the initial project report and tentatively approved the feasibility of
utilizing a buried pipeline crossing of Salmon Creek providing the
necessary precautions were taken and the in-stream work proceeded
during a noncritical period of the year. Because of the EPA stand
on funding the proposed project (see Preface), a complete reevaluation
of the Salmon Creek Crossing will be necessary. This will allow ADFG
to comment on any proposed activities impacting on Salmon Creek and
aid in the formulation of the new project.
2.	Refer to EPA*a decision on the project and their alternatives as
presented in the Preface to this report.
88

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02-0011
STATE
of ALASKA
A/mmumr

i»
NOV g 1975
^ (Raymond W. Estes
State and Federal Coordinator
Division of Policy and Planning
Office of the Governor
THRU
mental Health Section
slon of Public Health
FROM: Joseph W. Cladouhos
Regional Sanitarian
Environmental Health'Section
Lnvi ronTt-nt'il Health Section
Division of Public Health
date . November 5, 1975
subject! Draft Environmental Impact
Statement
Salmon Creek Interceptor
City and Borough of Juneau
The subject draft statement has been reviewed by (Mrs.) Kit E. Ballentine,
Juneau Borough Sanitarian, and myself. It 1s our opinion that Implementation
of LID No. 4 presents the best alternative to wastewater disposal, particularly
in the areas adjacent to the Twin Lakes Impoundments.
The septic systems of the three occupied lakeside lots are built 1n an area In-
dicated by soils maps as having very severe soils conditions for construction
of waste water disposal systems. One resident has resorted to a holding tank
because of continued leach field failures. Soil maps of the area indicate ex-
tremely limiting sols conditions for sewage disposal systems throughout the
area from Salmon Creek north to Vanderbllt Hill. Eleven septic or raw outfalls
emptying to the lake were Identified In this area. Some residents have reported
extraordinary success with drain fields, reportedly never having replaced their
drain fields or pumped their septic tanks 1n over ten years operation. In addi-
tion, because of the extreme slope encountered 1n some lots, septic tank efflu-
ent (although percolated through leach fields or sand filters) will ultimately
reach the Twin Lakes.
There appear to be two misconceptions 1n the draft statement:
1. Although Individual on-lot water and sewage disposal systems north of
Salmon Creek is a less than desirable alternative, it is not considered In
the draft statement. Page 45 states, "Since ADEC will not approve Individ-
ual waste treatment systems in the LID area..." It should be noted that
ADEC has not prohibited new construction or installation of on-lot sewage
systems in this area, but has required any new Installations to meet depart-
r	ment Wastewater Disposal Regulations. This includes the stipulation of a
'	100 foot horizontal separation between a drain field and any body of water
i.e. the Twin Lakes. Adequate separation of a potable water supply and '
wastewater disposal system 1s not considered to be a problem since only
five residences use ground water supplies. Other residences are served by
community or individual surface water supplies; all are a minimum of 100
feet uphill from septic tanks or drain fields.
I Both ADEC and ADH & SS (Environmental Health Section) would discourage any
% large residential or developments until sewer is available.
89

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Raymond Estes
- 2 -
November 5, 1975
2. Page A-6 of the subject document incorrectly states the relationship between
ADEC and the Juneau Borough Sanitarian regarding approval of building permits.
Individual on-lot sewage disposal systems are not routinely received by ADEC.
The Borough Sanitarian reviews all applications to ascertain compliance with
ADEC Wastewater Disposal regulations. ADEC is not contacted regarding indi-
vidual systems except when assistance 1s required by t£ft Borough Sanitarian.
ADEC does review all community and public sewage disposal systems.
According to an agreement between the Highway Department and the Borough dated
October 22, 1971, all conforming outfalls extended to low tide elevation would be
extended through the highway embankment. However, local residents north of Salmon
Creek reported that they were never informed of this agreement and given an oppor-
tunity to bring their system into compliance, 1n order that the outfall line could
be extended through the highway embankment. The general sentiment of area resi-
dents 1s 1n support of public sewer to service the area.
This office recommends Implementation of the proposed LID No. 4 as the best alter-
native for sewage disposal 1n the Salmon Creek area.
cc: Kit E. Ballentine, Borough Sanitarian

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Response to Comments by Environmental Health Section, Division of Public
Health
1.	Revised as indicated -- see page 44.
2.	Please refer to EPA's decision on this project as stated in the Preface
to this statement.
3.	Revised as directed -- see page A-6
4.	Please refer to EPA's decisions on this project as stated in the Preface
to this statement.
91

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THE CITY AND BOROUGH OF JUNEAU
CAPITAL OF ALASKA
155 SOUTH SEWARD ST. JUNEAU, ALASKA 99801
date:	November 21, 197 5
FILE NO.
subject-. Draft Environmental Impact
Statement on the Juneau-Salmon
Creek Interceptor
RECEIVED
Mr. Richard R. Thiel, Chief
Fnvironmental Impact Section M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
NOV 2 4 IS75
cpv f~i<7
The City and Borough of Juneau Assembly, at their regular
meeting of November 20, 1975, formally directed the following
response be sent to the Environmental Protection Agency regarding
the abovementioned subject matter.
Our detailed analysis of the Draft EIS prompts the following
specific comments:
In the first section entitled "Important Considerations and
Issues," p 3 - Alaska Capital Move, third sentence, the word
will should be changed to the word could.
On the same page under "State Priority for Federal Waste
Collection and Treatment Grants," we are of the opinion that this
needs further explanation. Specifically, what contributed to the
revised priority rating by the State and why did EPA not require
a full-fledged EIS in the first place when the original Salmon
Creek Interceptor application had a high priority and could have
been placed under construction some time ago.
Also, on the same page under "Public and Private Benefits,
Including Growth Pattern," in the first sentence, the word unlikely
is used. Does this mean that ADEC personnel would probably not
approve individual waste treatment systems in the project area on
the basis of ADEC regulation, or rather will the decision be based
on a departmental policy decision. This should be carefully ex-
plained since "policy vs. regulation" can have two entirely
different meanings.
92

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Mr. Richard R. Thiel
November 21, 1975
Page 2
"Secondary Impacts" on p 4, first sentence regarding Twin
Lakes being involved as a secondary impact in our judgment should
be changed to Primary Impact. The completion of this major recrea-
tion area costing hundreds of thousands of dollars is a significant
primary impact to the sewer interceptor project.
On p 5, third paragraph, the term "sunk cost" is utilized.
We don't think this term has been adequately explained especially
the $350,000 expenditure associated with the "sunk cost." Why is
this now a noneligible cost with respect to the overall project?
Also on p 5 and on numerous other pages throughout the report
the word Borough is used and should be changed to City and Borough.
This is a unified City and Borough project, not a City of Juneau
or Borough project.
On p 6, the first paragraph, in our judgment, needs further
clarification. On what basis was the priority list changed? Since
this is a part of the Introduction-Background, how has this changed
the overall priority position and how has this change contributed
to the present difficult situation?
On p 8, "Proposed Project Cost and Financing," the estimated
cost of the project is probably too low as compared to 197 5 dollars
On p 15, last paragraph, first sentence, the word grown
should be changed to the word grow.
In the second paragraph under Public and Quasi-Public, p 24
the statement was made "this is seldom if ever done." This wording
is in the first sentence. In our opinion, this is not a correct
statement. In fact, it is quite misleading since the City and
Borough has, on many occasions, imposed land use controls for environ
mental purposes on land development. This is normally accomplished
through the Conditional Use Procedure in the Zoning Ordinance. jn
addition, quite often, we request technical input from Fish and Gam
and ADEC on potentially sensitive environmental matters that may Ke6
associated with a particular development.
On p 28, the last paragraph, specifically the last sentence
"No permits, including for the expressway project, are known to *
exist within the project area." This statement was quite surprise
to us because we can remember Corps permits being processed in con?®
junction with the Orme Transfer development, Triplette Constructio
Company property, and possibly KJNO expansion, all within the	n
project boundary.
Under General Observations, p 30, second paragraph, the
authors again would like the reader to believe that the City and
Borough is not exercising land use control authority which includes
93

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Mr. Richard R. Thiel
November 21, 1975
Page 3
environmental protection. As we stated previously, this is not
true. Many developers throughout the area have had their projects
approved through the Conditional Use Procedure in which environ-
mental protection devices were incorporated into the development.
On p 33, second paragraph, first and second lines under
State, it is the Alaska Department of Environmental Conservation
not Quality.
Finally, it appears the report reaches the conclusion that the
proposed LID No. 4 is the most valid alternate of those considered.
As of now, we are not sure this is still the case. For example,
on the basis of total cost, individual lot owner costs, low ADEC
funding priority, and continued delays associated with the comple-
tion of the Twin Lakes Project it may be necessary to reconsider
the viability of this alternate.
Moreover, of all the alternatives suggested in the report,
the proposed "Twin Lakes Area^ to Mendenhall Plant and Individual
Systems for 5 Years and Juneau Treatment" appears to have many
advantages and involves generally beneficial effects. However,
there may be other combinations such as "Twin Lakes Area to the
Mendenhall Plant and Individual Systems for 10-15 Years" which
may also be feasible.
It is with this in mind that we respectfully request that the
Environmental Protection Agency grant a ninety-day extension to the
official review period in order that the City and Borough be given
the opportunity to explore additional information on a more suitable
alternate.
At the present time we are carefully analyzing the fiscal
impact of a number of alternates outlined in the Draft EIS. We
are conducting this study with the technical assistance from the
Alaska Department of Environmental Conservation and the U. S.
Environmental Protection Agency.
Once again, please grant us the ninety-day extension.
Thank you.
Art Hartenberger
Director of Planning
and Zoning
AH/kh
94

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Response to Comments by the City and Borough of Juneau, Alaska
1.	Revised as requested -- see page 3.
2.	The Salmon Creek Interceptor was about the last project within funding
reach on the 1974 State Priority List. The following year, the priority
list was developed with minor modifications to the priority criteria
and the project ranks lower on the list and out of funding reach. Although
the project was at one time within the funding zone, we have never
received a priority certification from ADEC, so that a grant offer could
be made. However, had the project been certified by ADEC, it is
doubtful that the project would at that time have passed public benefit
tests.
3.	Please refer to the letter written by Joseph W. Cladouhos, Regional
Sanitarian, for an explanation of what action can be taken by ADEC in
regard to regulations affecting approval of new individual wastewater
disposal systems.
4.	By accepted definition, completion of the Twin Lake Project is a
"Secondary Impact" in regard to the proposed wastewater facilities.
5.	The segments of sewers on which construction was initiated during
April 1973, as part of high construction, is not eligible for grants
assistance because projects eligible for reimbursement under Section
206 of PL 92-500 must have been initiated before July 1, 1974, and
construction regulations do not allow grant assistance for construction
unless a grant award precedes initiation of construction.
6.	Revised as indicated where appropriate.
7.	See comments given in Item No. 2.
8.	The figures used are those developed in 1973 Application for Federal
Assistance and would need to be updated if the proposed project would
have been approved. (See Preface for EPA1 s decision on grant funding. )
9.	Revised as requested -- see page 15.
10. It was our impression after extensive conversations with both state and
local officials that land use controls were seldom imposed solely for
environmental purposes. We have revised the referenced passage to
stress this single use aspect, but because of the lack of any substantial
examples to the contrary, feel that the statement must stand as corrected
95

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11.	See Army Corps of Engineers letter and subsequent revisions on page 28.
12.	As stated in response No. 10, what we are indicating is that according
to our conversations with state and local officials, environmental con-
siderations are rarely the sole justification for denying a permit appli-
cation, or imposing prohibitive land use stipulations on potential projects.
If this conclusion is fallacious, it is because none of the individuals
interviewed expressed a differing opinion.
13.	Revised as indicated -- see page 33.
14.	The EIS does not attempt to develop a prejudicial attitude for or against
any of the proposed alternatives. Facts and judgments are presented
based on a careful analysis of the problem and merits surrounding each
potential alternative. This allows the adequate evaluation of each by
the individuals involved in decision-making processes which affect the
final implementation.
Because of the EPA's judgment (see Preface) not to fund the project as
proposed, it will be necessary to completely reevaluate the LID No. 4
wastewater project. The reader is asked to refer to the enclosed
letter of December 2, 1975, in regard to the Agency's response to the
City and Borough of Juneau requesting for an extension to review and
evaluate additional suitable alternatives.
96

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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
1300 SIXTH AVENUE
SEATTLE, WASHINGTON HtOI
December 2, 1975
% PRC**5*
BBTSM/S 443

fiEBEt™
	 J
i*j
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-2-
I sincerely hope this meets with your approval. If you have
any questions concerning the remaining steps of our Environmental
Impact Statement process, please call me at (206) 442-4011. Thank
you again for your comments.
Sincerely,
Richard R. Thiel, P.E.
Chief, Environmental Impact Section
98
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Box 295
Juneau, Alaska 99802
Nov. 25, 1975
U. S. Environmental Protection Agency
Region X
Attn: Mr, Richard Thiel
1200 6th Ave.
Seattle, Wash. 98101
Gentlemen:	Re: Salmon Creek Interceptor
L.l.D. No. 4, City and
Borough of Juneau, Ak.
EPA Contract No. 68-01-2385
I have reviewed the environmental impact statement covering
the above proposed project. It is urged that you reject the
entire project for the time being for the following reasons:
There are not sufficient families in the area at the present
time to warrant the project and its excessive cost. The
individual assessments for some of the families would be
prohibitive and these people would probably have to sell their
property.
Even though some of the sewers in the area are in violation of
state and federal laws, these property owners could be required
to install individual treatment systems - not septic tanks -
but aeration sewage treatment systems, some of which medtthe
standards of the Public Health Service and other governmental
agencies.
Knowing that some developers will push for the project now, it
is then asked that you consider Alternative 7.a. The steep
terrain south of Salmon Creek will prevent much future develop-
ment and the residents of this area should not have to pay the
excessive costs simply because some people plan to develop
Salmon Creek and the area north sometime in the future.
Sincerely,	r ->
• i'i t'll
Mrs. Patricia Lane
RECEIVED
CEC 11975
£0 *
99
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Response to Mrs. Patricia Lane
1. The reader is asked to refer to the Preface to the document for the
EPA1 s response to the questions raised by Mrs. Lane.
100
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Juneau, Alaska
Nov. 26, 1975
U.S. Snvironrmntal Prot ction A-ioncy
1200 Sixth Avanue
Seattla, Washington. 98101
Attention M/S 43
D?ar 3irs:
Aft ?r looking ov -r the propos id Draft ""Jr.viro. /nontal Stat j a tvt
I wi-.h to mako the following staton-nts r j ^ardi-.v^ this roport.
The statovmt spiaks continuously to tho various asnjcts
(avalanche, umta bio soil, stoep terrain, dam. failure hazard, otc.)
that will min i/'.iz- additional dovelopM ;nt v~t id .'»itif i*s tho aain
ii3'id Cor oho ropcv.-d	tho sow;r interceptor in due to
anticisat d 1 :v; op'n.nt.
Th: draft stat. >m-vt doors -;ot show if a co t/b ivofit analysis
has b:;~ inno for V< overall r>roj -ct. Thi.i n_od:;'d for tho ALtornativas
is well. It is difficult to of foe liv sly v:aj,i.n tho ocono-nical
val-ios of nroj^ct v'.th what is nrotod.
+.
f ,
The -ocal sh.-r of 15-» ^00. 13 i^0 /. It war, brought o.it at
th •> 'SPA ¦•.ooti.i^ "ov. 11,1975, that t'ia local .-.hare would :o over
pl»?0\3~!3. 'Vith thfis® nav cost figures, this pro,j ct will not be
economically foa^iblo for the fow famili-a livin;; in this corridor.
My own S«w :r A -sm .it was ov^r S 11,3^2,97 which inciudod th« ZOi
overrun.—On property that wa=s tax^d for $10,000 in 1973. This amounts
to a Sewer Assovmont of over ll3^t aven with ths Borough's sharing
tha costs by th« Twin Lakos project, th-? asse:s:nvvt will cost mo ovsr
30 = of the uroporty evaluation. It was brought out at th« :5PA Hosting
that thi Alaska 13.tutos allow 25 » of tho as-:s^M^nt val ;<* for projects
of this nature.
Iquostion tha actual flow volumes for the aystorn a3 showo in
Draft Stato i -nt ao realistic. I believe the flow rat-os shown aro
fro-- data coll :ct >d for tho City of Juneau's sy-.ts:a. Go -s-rally tho accoptod
flow is 75 allono por ca ita osr day. Th': roport us s 135 jallon3.
This is an 30% factor. G-.narally a 25' factor is us >d. The blanketing
Df th- o-tiro arsa with figuros do not lend ltsslf to sound r:asonint;,
isp-cially whero tha majority of th» hom:>s aro on individual wolls
'or t'-oir vat>r 3urwly.
received
DfC 2I97S
101
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2.
The 'is* of 10" gravity lins will require introducing
water into th '> Unas to maintain a velocity to keep the solid#
moving. This is another added cost both in construction and
maintenance that could be avoided by proper design. The Peaking
Factor 2,5 times ua?d in the report do«s not seem to apply to
LID4. There probably never will be storm sewers or run-off
included in the system.
The Draft Statement indicates that about the only area of th# LID
that has much developable area Is adjacent to Salmon Cr-ek and
environas. It also identifiei the hazard potential of th? Salmon
Crsek Res rvoir. Current roco^flitiovi a nd national concern for
this typo of Hazard Pots^tial sould	to mi nimize any dsvslopment
i:" this location.
T v: Draft -It - vj i. ^-t make# mention of six homes that run
3*wr diachar^'iS into the T"in Lakes arsa. Th® min. requirements ha# always
b -*n for a s^sntic tank and drain fislcila, I think that ev«ry one
should be ^.ade to comn'.y, It may be a good idea to t-?st the
lakes and find out how much pollution thore is.
The Idea of alternatives is a. ?ood ona and I think we need to
investigate alter-ative ?& further.
I have to object to th« formation of thin LTD mainly for the cost
of the wojnct in relation to th'-s "special benefits" th3 iraprovom'ints
"ill off*r.
I'm ¦JHc',.o»i-j ray previous corr^spondenc^o the '.P.A. about
this matter. And a report on chlorination on	effl/j-its i
sea water for your information. This will bear t» out on statement*
I'v3 -nads in thn past about the secondary requir«n«nt is ok for fresh
water, but is not apolicable to salt water. Numerous Research Papers
and Publications indicate that wastewater paranotors used to control
dischar^s to streams riv«rs and lakes ar# not significant or applicable
for discharges to a Marine Environment. However these critsria are still
baiiv, usjd to define secondary treatment for coastal waters. There is
also th i add ;d energy requirement for secondary traatient.
I hops this Kill explain ay concerns, and socio--icoiioraic factors
cone :rr.i'Ojj this project.
Si*c«r«ly,
Gaory-'i Danmr
P. 0. Box 123
Juneau, Alaska 99832
lo". ir' s
102
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Response to Mr. George Danner
The reader is asked to refer to the EPA's decision regarding funding of the
proposed project as presented in the Preface. Since the proposed project
is not to receive federal assistance, a complete review and reevaluation
of the LID No. 4 wastewater problem will be required.
1.	Refer to response to USFS letter, Item 1.
2.	Refer to response to USFS letter, Item 2.
3.	Refer to EPA's decision in Preface.
4.	Refer to response to USFS letter, Item 3.
5.	Refer to response to USFS letter, Item 5.
6.	Refer to response to USFS letter, Item 4.
7.	The problems associated with septic tank and raw sewage discharges
in the immediate vicinity of Twin Lakes will need to be evaluated in
light of the EPA's decision not to fund the proposed project. It is the
general opinion of ADEC and local public health officials that these
may create a serious health problem if the lakes were further developed
as a recreational amenity. An enforcement decision or further consid-
eration for providing immediate public wastewater facilities or upgrading
individual systems will be developed through the City and Borough of
Juneau and ADEC.
Studies of the water quality of Twin Lakes are being considered (re
discussion with Kit Ballantine, Juneau Sanitarian June 17, 1975, page
A-3), and would be necessary before any further action within the
subject area.
8.	Due to the decision on the part of EPA not to fund the proposed project
additional evaluation will be necessary on the entire wastewater problem
within LID No. 4.
9.	EPA does not get involved in the distribution of the local share of sewer
construction costs nor costs of construction which are ineligible for
grants participation. However, it must be demonstrated that the cost-
effective alternative is selected in abating the pollution problems.
103
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tOAT*^ f J-., ,w ^
\$% % 8*
J
11 i Gen®1^* , \ c\^°
61
UNIVERSAL CHLORINATION must
be reevaluated in light of recent
events.
The carcinogen question alone
makes tnis revaluation necessary.
Chlorination has sometimes been
mistakenly viewed as the universally
accepted method of disinfection,
used for many years in the treatment
of water and wastewater effluents.
Thus, after issuance of the National
Environmental Policy Act of 1969,
and subsequent environmental legis-
lation, chloiination was often seen by
legislators as the most effective
means of disease transmission con-
trol, not only with respect to drinking
water, but all other water uses, (con-
tact sports, for example) —in short, as
a panacea for the country's water pol-
lution ills. These legislators, and other
individuals with similar views, were
apparency unaware of the reason lor
the long history of chlorine u&e in this
country.
It is a point of fact that up until tne
late 19th century, disease was
thought to be spread by odors. Con-
sequently, the control of odors war;
though! to prevent the spread of dis-
ease. Hence, long before its lull ger-
Dr. Genctelli is a prof<' .sor at Rnkicrs
Uijiv., Ni.'W Hruu-iwicK. N J and jjriisiiiont,
fciv.'ironmoni:!! Assossmi i.t C'Viwil. In;.
Mr. Lul-etkin i'. c'lir-: cujinc-cr, l' i; . olo,
arid though the need loi i; war not
shr wn rtisinfoctio" was mr.ndat.'d for
nil treatment on <"• year round oas In
fact, the definition of secon 'ary
104
treatment (Sec. 133.102, 38 redeu;.
Register 22298, 8/17/73), included
disinfection to 200 fecal coliforrn/100
ml (geometric mean for 30 conse-
cut've days), and the EPA's inter
pretation of "disinfection" was
"chlorination." There was nothing ¦-
the regulations concerning the noeu
for chlorination, the type of waters
being discharged into, or any othei
discretionary items.
Even though expensive and un-
necessary in the majority of cases,
large-scale chlorination would pro-
vide a satisfactory means of treating
wastewaters if, in tact, in its present
use, it would indeed disinfect and
cause no harmful side effects. Un-
fortunately, this is not the case.
Recent testing and concern about
some of the carcinogens appearing
in drinking water has resulted in the
scientific community reappraising the
wisdom of indiscriminate use of
chlorine as a disinfectant. It was dis-
covered that, in addition to the partial
disinfection of wastewater effluent,
chlorination can result in secondar y
toxic effects on other biota within re-
ceiving waters, as well as in the for-
mation of chlorinated hydrocarbons
which could prove carcinogenic to
man.
What are the adverse effects?
To explain the secondary toxic
effects that chlorine may have on an
environmental system, a com-
prehensive review of percent liter-
ature was undertaken. Within the iit-
erature appeared extensive descrip-
tions of the toxic effects of chlorine
residuals and chlorinated com-
pounds. The effects of chlorinating
wastewaters were found to range-
from aesthetic problems of taste and
odor, through toxic effects to fish and
aquatic vegetation, to potential toxic
effects to man.
Taste and odor problems occurring
in water may be due to chlorinated
phenolic compounds which can also
change the flavor of fish flesh
Eisenhauer in the Journal of the
WPCF in 1961 proposed that chlori-
nation of wastes containing phenol
produces monochlorophunols, iu-
chlorophenols, and ehloio-su'o-
slituted aliphatic acids. His work in-
dicated that chlorophenols appealed
whether pure phenol and hypochlorite
or a stripped refinery waste con-
taining phenol and hypochoiili. v."-ts
used. He also found that a dichlcr>
substituted aliphatic acid was pro
duced in increasing amounts H.d
showed no sign of being destroyed ,')i
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increasing concentrations of avail-
able chlorine; (up to 5,000 tny ¦'i) used
on a refinery wusio explaining 78
ii'.a'/! of phenolic waste
D.L Shumway of Oregon State
Univ. studied the effect of secondary
municipal wastewater treatment plant
effluent on the impairment of the
flavor of fish flesh He found that
chlorinated effluents (20% by volume)
increased the extent of an "off' flavor
in fish
After analysis of the findings of
these studies, a number of generali-
zations can be made. For one, chlori-
nation of wastewaters has the poten-
tial to produce chlorine residuals and
chlounated compounds with varying
toxic effects. In addition, chlorine
itself is a powerful oxidizing agent,
and, as such, is toxic to bacteria. It
can also exist in water as free avail-
able chlorine in the form of hypo-
chlorous acid, hypochlorite ion,
arid/or combined available chlorine in
the form of chlormines or other
chloro derivatives. Chloramines,
formed from the combination of
chlorine and nitrogen compounds, are
also toxic. Their disinfecting action,
however, is recognized as much less
ef'octive tlrii: free cMonne, although
it persists foi a longer period of time.
In the past, fiee available chlorine
was seldom found in treated waste-
waters and treatment plant
effluents—this because chlorine was
usually tidcied in amounts less than
the total chlorine demand required to
form free available chlorine. With
recent EPA rulings on residuals, this
may no longer be true.
Residual defines toxicity
The toxicity of chlorinated waste-
water effluents with respect to aquatic
life depends not only on the amount of
chlorine added, but .;n the conci-
liation of residual chlorine remaining
and on (he relative amounts, of free
chlorine and chloiommes piusont.
Doudorofi and K.u/ in Sewage and
Industrial V.'ustcs and f.'orkens in
Wnier and Waste Treatment Journal
stated Km! the toxicity of free chlorine
is appai'-ntly of the same orner as
fhal of chloro?nines, and any measure
of rcsiuiia! cliloniK! is generally ade-
quate to define chlorine toxicity.
In ci Matty by V L. f;nci;yinl\ rrtd F.I.
Maiku.-. ihr actual concentrations of
chlorine les-duals discharged to re-
ceiving waleis at SO wastewater
treatment plants in central Illinois
were sun/eyed. The lulal chlorine io-
s'dmls of Ihr. effluents ne:n tiie
twenty ..t.¦ p.!'int.. Linger J im vi''i.e
fe :n o : ¦? ;.pm !n ;> 1 / ppm
The typo and severity o' the toxic
effects of ch'oiine residuals, such ns
those on fish and photosynthesis, can
vary depending upor> the concen-
tration of chlorine residuals. In a
study reported in Nature by Hiatt,
Naughion. and Matthews of marine
fish (Kahlia sandriconsis) in sea
water, it was found that as chlorine
concentration increased, so did the
severity of effect. Irritant activity in-
cluded excitation, body shaking, and
violent swimming.
In a study by J.W.T Dandy of biook
trout at a chlorine concentration of
0.35 ppm, irritant activity after several
minutes became very intense. The
fish swam repeatedly to the ceiling of
the chamber, and a "coughing" reflex
was continually observed along with
an increased ventilation rate. Eventu-
ally, fish movement slowed and
become soasniodic; the fish tended to
lose equilibrium, and, after a time,
turned over. Death followed with fish
mouth and tji'Is gaping widely, the
spine arched and the fish covered lib-
erally with mucous. These symptoms
of death were also observed in fish
exposed to a 0.08 ppm chlorine re-
sidual.
Chlorination of power plant effluent,
as described in a study in Science by
Hamilton, Flemer, Keefe, and
Mihuisky, showed a reduced rate of
photosynthesis and active chlorophyll
concentration from 60% to 90%. The
location of the study was a power
plant at Chalk Point on the Pataxent
River, Md., near commercially pro-
ductive oyster beds. Computations by
the authors indicated that primary
pioduction was reduced by 6.6% in
the affected area of the river.
Strongest data yet
Perhaps the strongest data to sub-
stantiate the toxicity of chlorinated
wastewaters is the expensive study by
Esvelt, Kaufman and Selleck {Journal
of the WPCF) on the ioxicity of munic-
ipal wastewaters entering San Fran-
cisco Bay and surrounding areas. Fol-
lowing chlorination, significant in-
creases in toxicity were observed. In
their study, Esvelt et al. used (ho so-
called toxicity units. (T.U -- defined as
the recipjroc.il of the 96 hour TL. 50%).
and studied the toxicity of thru-?
different sewage treatment plant
effluents before and after chtorin.-.
tion. The data indicated that toxicity
effects of municipal wastewatc
treatment plant effluents are sub-
stantially increased by chlorination for
either primary, activated studge, or
lime precipitation treated Waste-
waters. One of the conclusions of ttv,
study was that: "based on meas-
urements using the golden shiner, the
toxicity was increased about 1 T.U.
for each 0.2 mg/1 of nmperometric
chlorine residual in the fish tanks,
which correspond to about 1 T.U. in-
crease for each 0.5 mg/l of residual
maintained ahead of the contact
chamber." Chlorination of sewaqo
treatment plant effluents appears us
markedly increase toxicity of fish in
the receiving waters.
Chlorinated wastewaters from
treatment plants can affect the diver-
sity of the fish community as well as
produce acute and chronic toxic
effects. Use of a fish diversity index to
evaluate chlorine effects on receiving
waters can indicate not only th-
number of fish species reduced from
the area, but the reduction in the di-
versity range of species for sport
fishing. In a study by Tsai, chiorirmtpci
effluents from 156 secondary sav^g*--
treatment plants in Virginia, fv,fc.v.
land, and Pennsylvania were studi-xl
for water quality parameters. Tote'
chlorine appeared to be a major cau-
sative factor in reducing fish commu-
nities in surface waters located belov*
the chlorinated effluent outfalls. One
recommendation by Tsai to protoc'.
the fish community was to take ste$'«.
to insure that sewage effluent outta!!
mixing areas did not contain meve
than 0.1 ppm total chlorine—this so
as to ensure no more than a 50% in-
duction in species diversity.
Although chlorinated wastewaUf
effluents can lead to taste and odtv
problems and the pioduction of to-tc.
effects on fish life the potential cl>t,
cinogenic effect of chlorinated or-
ganic compounds on man has nU-«»
been recently highlighted. In an
cle by Onqei th and
associates oi the
We must-take a rationa/ approach to
effluent disinfection in tight of recent
developments, these auttocs say.
105
-------
California Department of Public
Health, it was indicated that a major
source of concern was the? potential
long term effects (e.g. chronic, car-
cinogenic, rnuluyunic, or teratogenic)
from piolonged ingestion of organic
residues originating in domestic
sewage. The most definitive work,
with respect to isolating and identify-
ing these individual compounds in
municipal sewage effluents, was per-
formed by A A. Rosen and as-
sociates. Reporting in Water Re-
search, Rosen delected 77 com-
pounds in the primary effluent and 38
compounds in the secondary effluent
of a wastewater treatment plant using
high-resolution an ion-exchange
chromatography. Of the compounds,
13 in the primary effluent were iden-
tified. The extent to which these com-
pounds were toxic to man is a subject
which is presently being studied. In
addition, the identification of these
organic compounds in wastewaters
and the evaluation of their potential
carcinogenic effects from the chlori-
nation process is a topic of intense
investigation.
Contact time is factor
In a study by Robert L. Jolley, it was
pointed ou! that although residual
chlorine is biotoxic, it does not include
stable chlorine-containing organic
compounds that may have been pro-
duced during the chloririation
process. It was also pointed out that
assessment, in terms of biohazards,
cumulative effects, and the socio-
economics of tha total ecological
impact of chlorination of waters, re-
quired qualitative and quantitative in-
formation concerning the formation of
these compounds. The study con-
cluded that the formation of the
chlorinated organic compounds was a
function ol the quantity of chlorine
used in the dosage and the reaction
time (eg. contact time). It also con-
cluded that about 1.0°o of the chlorine
dosage went into chlorinated organic
compound;: a typical secondaiy
effluent. The average molecular
weight of Iho chlorinated organic
compounds was estimated a.\ approx-
imately i 75; thus, about five tons of
chlorine-containing oinanic com-
pound? veie released foi each 100
tons of chlorine used lor disinfection.
The same ratio held tor primary and
secondary effluent. The greater
amount ol chlorinated otganics in the
primary effluent occurred as a result
of the yicvt er dose ol cMoiirto
.needed.
Recently, the I PA iour.d am jII con-
centiT.t'ons oi su .peaed caiic-r-cau-
sing agents in ;!iu diini iny w: -yrs in
/.'¦>. !	11 , i '¦ \"r ¦ i, t; i MrvK i • h: h -,
Cincinnati and New Orleans. In the
view of Gordon C. Robeck, director ol
the EPA laboiatoiies in Cincinnati,
the problem of cancer-causing agents
may exist in every water system that
includes industrial wastes and
sewage.- According to EPA spokes-
man Marlin Fitzwalter, It appears
many of them (carcinogenic mate-
rials) are getting there as a result of
the chlorination process." The two
EPA spokesmen indicated that car-
cinogenic materials may bo formed
through the chlorination of waste-
waters.
Is there a need?
It has long been recognized that
sea water does not contain large
numbers of bacteria, and that bac-
teria that enter sea water, either from
land drainage and/or sewer outfalls,
die off quickly due to an antagonistic
action present. Waksman and Hutch-
kiss suggest in the Journal of Bac-
teriology that the paucity of bacteria
in sea water may be the result of one
or more interrelated physio-chemical
and biological factors such as: a) ad-
sorption and sedimentation; b) de-
structive action of sunlight; c) lack of
nutrients; d) toxic substances; e)
presence of bacteriophages and pre-
dators; f) the competitive and an-
tagonistic effects of other micro-
organisms. The study observed the
destructive effect of sea water on bac-
teria within a 23-hour period as well
as the almost total kill effect after 72
hours. Similarly, C.E. Zoboll, using
sewage bacteria, found that at 75%
sea water bacterial counts were re-
duced by 39% from the original figure
in two hours. Carpenter, Sutter and
Weinberg observed that sea water
has considerable disinfecting proper-
ties on fresh sewage organisms. In
their experiments, reported in Amer-
ican Journal of Public Health, an
average of 80% ot the organisms died
in 30 minutes.
The Massachusetts Department of
Public Health and A.P. Weston and
G.P. Edwards reported that sewage-
sea water mixtures showed a rapid
decrease in bacterial counts with no
coliforins surviving beyond lour days.
An examination of Santa Monica
benches by the California Department
of Public Health showed marked col-
iform reductions in samples of con-
taminated sea water held for 2A
hours. B.H. Ketchuin and associates
found tnal coliloim baotma quickly
dirappearod from sea water ai ° rale
mom rapid tk.a could be cicccKJiited
lor by dilution or sedun- nt ¦ ion.
Woods Hole Lafjoialotie;;, i:i a \!utly
on liio baclencidal aciicn ot sea
106
water, indicated 99% total reductions
of conforms. The conclusion was that
sea water was an important factor in
decreasing coliform counts.
Among the stated purposes ot
sewage plant effluent chlorination
are: the prevention of the spread of
disease; the protection of public water
supplies, bathing beaches, and rec-
reational waters used for boating or
water contact sports; and the preven-
tion of contamination of shellfish
growing areas. Although the practice
of adding numerous applications of
chlorine in sewerage systems is
utilized for odor control and grease
removal, by far the greatest use ir,
wastewater collection and treatment
is the attempted disinfection of treat-
ment plant effluents to effect a proper
kill of pathogenic organisms that may
be present in the treated sewage
effluent. In spite of this extensive
usage, there are indications that
chlorination does not effectively ac-
complish disinfection.
An outbreak of an epidemic of in-
fectuous hepatitis in Delhi, India in
1955, resulting in the infection of
30,000 to 50,000 people, occurred as
a result of contamination of a munici-
pal water supply—a supply which had
undergone complete treatment, in-
cluding chlorination. Bacteriological
counts, which were satisfactory for
drinking water standards, did not pro-
vide an adequate index to viral den-
sity. Although the coliform indices
were acceptable, pathogenic viruses
were present in concentrations
sufficient to cause disease. Similar
outbreaks of infectuous hepatitis
from contaminated shellfish in the
New York-New Jersey area from
shellfish beds located downstream of
chlorinated sewage treatment plant
effluents have also been docu-
mented.
Adsorption removes viruses
AppaieiitlVj t:lle mechanisfluter-Jiei;
moval of viruses is not chlorination,
but rather adsorption. Kelly reported
in the Jou
-------
of 1 unit above pH 7 more than
'doubles the contact time required tor
virus inactivation, He suggested that
in order lor chlorination to be elective
as a viricidal process, secondary
effluents should be treated by coagu-
lation and filtration to zero turbidity.
This was based on studies that in-
dicated a 95% kill efficiency in alum
treated effluents.
Pathogens that are indicated by col-
iform levels should be less resistant
to chlorine than coliform bacteria.
Thus, a suitable coliform count may
indicate public health protection for
these particular pathogens. However,
worms, cysts and spore forming bac-
teria, and viruses which are more
resistant to chlorine are not indicated
by the coliform test. The implication is
that chlorinated discharges with ac-
ceptable coliform counts do not
necessarily provide protection
against a pathogen such as E. His-
tolytica. Furthermore, residual levels
of chlorine or contact times required
for effluent disposal based on
chlorine bacterial counts can be in-
adequate.
Wattie and Butterfield reported in
Public Health Reports a required
combined residual of 0.6 mg/l and
contact time of one hour to effect a kill
of E. Typhosa at pH 7. Mycobac-
terium Tuberculosis found in sewage
primarily from sanatoria required two
mg/l combined residual and at least
30 minutes contact time to effect de-
struction. E. Histolytica, responsible
for amoebic dysentery, required an
8.0 mg/l combined residual at six
flours contact time to effect kills. Both
o1 the contact times and residuals re-
quired indicate levels above and con-
tact times beyond present require-
ments for coliform bacteriological
kills. In addition, if consideration is
given to the fact that primary treated
sewage effluents frequently contain
particulate matter that can shield bac-
teria harboring within, it can be.easily
seen that the potential for pathogenic
organisms lo survive present chbri
nation practices is ever present. In
fact, K.G. Silvey and associates
stated in tfie Journal of the WPCF
that: "chlorination was not totally ef-
fective in destroying pathogenic Sal-
moneNae: these' organisms were iso-
lated as frequently during chlorination
as during periods of non-
chlorination." Another factor to con-
sider is the effect of chlorinated
effluents on the sea's natural ability to
kill pathogens.
Regrowth may bo significant
Chlorinated efliu'jnts hav« shown
ralos of regrowth of conforms in re-
ceiving waters by as much as one or
(Continued on page 50)
New plant cuts phosphates
Phosphate, BOD. and suspended
solids are greatly reduced in a ne,w
regional wastewater plant operated
by Lower Allen Township, near Har-
risburg, Penna.
The new wastewater treatment
facilities occupy 15 acres in Fairview
Township on the banks of Yellow
Breeches Creek, where the Town-
ship's original wastewater treatment
plant was built in 1957.
The Lower Allen Township in-
stallation is a regional set-up with
Upper Allen Township and the Slaie
Correctional Institution at Camp Hill
(White Hill) sharing in its cost and
participating in its use.
The original plant, providing pri-
mary treatment for an average flow
of one mgd. was due for expansion
in 1966 when the Department of En-
vironmental Resources issued an
order requiring secondary treatment,
and, at a later date, phosphale re-
moval. Therefore, Lower Allen
Township directed its engineer,
Gannett Fleming Corddry and Car-
penter, Inc., to design a plant that
would meet the Slate's require-
ments.
Design work was completed in
1971 when a 60% federal con-
struction grant was awarded. Foun-
dation work began in 1972, Part of
the control building and one sludge
holding tank are all of the original fa-
cilities that remain in the new plant.
Wastewater coflected by an inter-
ceptor is delivered to the plant's
pumping station. After 10 hours of
settling, floccu^tion, skimming, bio-
logical and chemical treatment, the
treated wastewater flows to the
Susquehanna with its usefulness re-
stored. Practically all of the waste-
water solids, 80% of the phosphorus
content, and 85% of the BOD is re-
moved in the treatment process.
The pumping stations principal
function is to deliver wastewater
through a distribution chamber to the
plant's primary clarifiers at a design
capability of 7500 gpm.
The two circular primary clnriiiers,
each 6b feet across and holding
water to a depth of 12 feet, provide
both gravity and chemical treatment.
More than half of the solids settle
lo the bottom o: the claiifiors where
they are pumped lo llie plant's
sludge disposal system. Other solids
float to the surface to be skimmed
into a hopper and pumped to the
sludge disposal building.
Chemical treatment is introduced
in the primary clirifiers io remove
phosphors. Pebbiod limoted into
thu clarifiers by way of sU'-crn ar.d
107
mixers from a storage silo. Th® time
acts as a coagulating or flocculating
agent which, in a gentle paddling
action, collects the suspended
phosphates into particles large
enough to settle to the bottom.
Having had 35% of the BOD; 50%
of the suspended solids, and 80% of
the phosphorus content removed.
1he wastewater flows to the aeration
tanks for secondary treatment.
Four 90-foot by 45-fool aeration
tanks, each equipped with two 30 hp
aerators, further improve the quality
of the water by bacterial action.
Each tank's surface aerators, by
means of violent agitation, provide
the mixing and additional oxygen
which the bacteria must have in
order to thrive and consume the or-
ganic wastes contained in the
wastewater.
Further settling and clarification
occur in two final clarifiers, similar in
design to the primary clarifiers.
One of tho technological advan-
ces incorporated in the final clarifiers
is a vacuum syslem which supple-
ments the bottom rake in collocting
the solids that settle to the bottom.
The effluent from the final clarifiers is
practically free of solids.
The final treatment stage is chlori-
nation.
After the liquid treatment systems
have done their jobs and the treated
water, stripped of its impurities,
returns to the environment in a
useful state, the plant operators turn
their attention to an equally difficult
task; disposal of the sludges that
have been accumulated through the
treatment processes.
Described as the dry end" of the
plant, the Lower Allen Plant's sludge
disposal system incorporates an in-
tricate series of treatment steps jn
disposing of the sludges in a manrwsr
that will not impair the environment.
Solids collected in the primary and
final clarifiers are pumped to the
sUdgj disposal building for proc-
essing in a four step disposal
system. First, the sludge is dp.gri^ocj
by a cyclone process and pumped to
one of the two 40-foot diameter
sludge thickeners for dewateriny.
The thickened sludge is Uv>n
pumped to one ol two centrifuges
where it is furtho; dewotered. Tru>
centrate is returned to the primary
clarifier via the distribution cfoarnh«r.
The dewatered sludge is discharw^i
into the top of the slurfye incinerator
in the final sludge disposal procosn
Oil-fired flames at seven lovot.
me tum".co induce the tuns 
-------
(Continued 1rom page 49}
two logs within lour or five days after
chlorination. Thus, the regrowth phe-
nomena potentially available is sig-
nificant. Bacteriological investigations
performed on the Trinity River in
Texas concluded that beneficial het-
erotrophes were more susceptible to
chlorine than fecal or non-fecal col-
iforms, allowing regrowlh to occur £t
factors of throe and four times original
coltform levels due to the reduced
level of competitors and/or predators.
This observation has significant im-
plications when consideration is given
to the conclusion of Waksman and
Hutchkiss that predators and com-
petitive microorganisms play a sig-
nificant role in the bactericidal effect
of sea water on coliforms. Stryszak
further inferred that predators were
most important in the elimination of
enteric pathogens in sea water, and
that inactivation of predators in-
creased survival of Salmonella typh-
osa and Salmonella paratyphi.
Tests performed on sterile and un-
sterile sea waters indicated a direct
correlation between the size of the
native microbial population, and the
rate of virus inactivation. As the popu-
lation of native bacteria increased,
viral densities declined. Although it is
not known what the responsible an-
tagonists are, there is the direct im-
plication that antiviral enzymes, toxic
metabolites, or predation may be the
causative agents. Thus, chlorinated
effluents introduced in salt water en-
vironments can inhibit the natural
bacteria's capability to remove col-
iforms and pathogens in salt waters.
Therefore, it appears that the main-
tenance of a chlorine residual to meet
bacterial standards, on the one hand,
does not effectively remove disease
producing viruses from treated
wastewaters but, on the other hand, it
can reduce the capability of natural
sea water to destroy viruses through
the bactericidal effect of the chioiine
residual on native salt water bacteria.
The potential for reduced bacterici-
dal effect of salt waters is not sig-
nificant if it ij assumed that enteric
organisms have been effectively
killed by chlorination. However, the
Trinity River study indicated that
chlorination was not totally effective
in destroying pathogenic salmomil-
lae. These organisms were isolated
from chlorinated wastewater effluents
as well as iion r.tilorinatyd waste-
water effluonls in the receiving
waters.
Coliioi'rri is k'iJ'.ici first
Another extremely irrnoKant
aspect of chlorination, not usually
discussed, is the fact I hat chlorination
tends to kill coliform more rapidly than
the more resistant pathogens. As
understood by even the layman, col-
iform themselves are harmless and
testing for their presence is under-
taken merely to indicate the presence
or absence of sewage and the poten-
tial of harmful pathogenic organisms.
Thus, in the absence of fecal coliform
there should be no pathogens of en-
teric origin. Although this could be the
case without chlorination, it is less apt
to be so when chlorination is utilized.
Here is an example illustrating this
point.
To begin with, a shellfish area
tested for fecal coliform is found safe,
A primary sewage outlet is then con-
structed in the vicinity of the shell lish
area and fecal coliform are dis-
covered. The area is promptly de-
clared unsafe and "off limits." Next
the primary treatment plant is re-
quired to chlorinate to kili coliform—-a
process which kills many pathogens,
but does not accomplish dis-
infection—many pathogens and
viruses survive. Further meas-
urements of coliform at the suspect
shellfish area indicate satisfactory
counts, although some of the shellfish
in the area are contaminated. The
shellfish area is again declared safe
and a contaminated crop is har-
vested. Serious health problems
result. Thus, without disinfection,
chlorination effectively removes the
indicators which would normally func-
tion to warn the authorities that the
area is unsafe.
This example raises serious ques-
tions as to the advisability of wide
scale chlorination. A number of points
have also been raised which question
the extensive use of this process:
(1)	The natural ability of sea water
to kill pathogens;
(2)	The facl that chlorination does
not completely accomplish dis-
infection;
(3)	The danger of chlorinated or-
ganics being formed;
(4)	The illusion of safety that
chlorination gives the general public.
A number of questions must now be
asked. For one, if chlorination does
not effectively remove viruses from
primary treated effluents, what health
benefit is gained by reducing the nat-
ural bacteria population with the
maintenance of residual chlorine
levels in effluents discharged to
saline receiving waters? In addition,
with consideration of the fact thrit
other industrialized nations r>f tiie
world do not chlorinate ttum s ' wtujo
effluents (e.g. England and Geri.uiny)
does indiscriminate o!!!ue:H ch'or.na-
tir>n aclvevo the stated b-'noJic^l ob-
jectives? In spite of the abovu unan-
swered questions, fecal coliform re-
quirements cf the Federal EPA have
essentially mandated the year-rouna
chlyrinalion of treated effluents in an
indiscriminate manner throughout the
USA.
With due consideration of these
points and questions, there are a
number of other factors that need to
be taken into account in any assess-
ment of the pros and cons of chlorina-
tion. A discussion of these factors
follows.
Energy is one consideration
The manufacture of chlorine re-
quires both chemicals and power. It
takes approximately 3,000 kilowatt-
hours of electricity to produce one ton
of chlorine by the electrolysis method
from brine. With the average family
using about 400 kw-hrs per month,
the power to manufacture three tons
of chlorine would just about supply
the annual electrical requirements for
two average families. Yet three tons
of chlorine is not a significant amount.
Jclley estimated that 100,000 tons o?
chlorine is used annually in the U.S.
for disinfection of wastewater. With
the EPA enforcing its policy of requir-
ing chlorination as part of itc definition
of secondary treatment, this annual
use is increasing.
In addition to the potential for in-
efficient use of electrical power in the
production of what may be excess
amounts of chlorine, there is the logis-
tical problem of moving large
amounts of chlorine to a particular
site. Whether by tank car, truck, oi
barge, fuel is required. If, as has been
theorized, the amount of chlorine ac-
tually required is in fact far iess than
the amount presently utilized, with a
significant decrease in the use of
chlorination, the transportation of this
excess amount would no longei
waste large amounts of fuel or sig-
nificantly contribute to air pollution.
Economics is yet another factor
warranting consideration. Chlorine
can cost anywhere from $160 per ton
to S300 per ton, depending on quan-
tities and types of chlorine to be used.
If excess amounts of chlorine are
indeed being used, this is an expense
that is not only unnecessary, but
wasteful.
Finally, in addition to all of the;
aforementioned points, a number of
comments made by the National
Waiei Commission would seem to
lend vvciqht to the view that the coun-
try's largo scale use of chlorination
needs to be ir examined. T
comments appear in the Com-
mission's booklet on water pollution
control emitted Now Direction? e
(Continued on pug*. 
\ !!•»!':/*?i n r»i circle 11 on «nnp2ry Gi»r»* f'.ir ffoti • ' 4
-------
Let's be sane about chlorination
(Continued from page 50)
U.S. Wator Policy, (pages 36 to 43):
"Operation of waste treatment
systems consumes scarce minerals
and energy. The chemicals usod in
waste treatment are themselves
products of a process which also
creates wastes. These chain effects
mean that a large expenditure of re-
sources to produce a small improve-
ment in water quality may turn out to
be counter-productive when total en-
vironmental consequences are con-
sidered ...
"Public expenditures for water pol-
lution abatement must compete for
limited tax moneys with social
demand for housing, education, med-
ical care, slum clearance, full em-
ployment, and price stability . . .
"The regulations should recognize
that streams have a self-purifying ca-
pacity which allows them to absorb
some kinds of discharges in reason-
able quantity without harm .. .
"Drinking water requires high
standards, navigation practically no
standards at all."
We must be selective
It should be emphasized that dis-
continuance of all attempted dis-
infection by chlorination is not being
advocated. There are, in fact, many
areas where the use of chlorine is not
only warranted, but, with present day
technology, absolutely necessary.
What should be thoroughly examined,
however, is the extensive, in-
discriminate use of chlorine as the
panacea for all water pollution Ills.
Only when all available data has been
analyzed, when the natural purifying
ability of a stream or ocean has been
evaluated, when consideration has
been given to the detrimental effects
of chlorine with its chlorinated organic
or hydrocarbons and its partial de-
struction of the natural purifying abil-
ity of the stream, when the use of the
receiving stream (i.e. bathing, drink-
ing source, fish propagation, etc.) and
the proximity of such use has been
taken into account, when the benefits
to b derived from chlorination far
outweigh the disadvantages, in short,
only when an environmental assess-
ment—formal or informal—has been
undertaken, can the decision be
made whether or not to use chlorina-
tion of sewage effluent discharge.
It is probable that reliable enteric
organism control through disinfection
lies with (he adequate disinfection of
potable water and not with waste-
water effluent disinfection. It has been
shown that chlorine can combine with
many wastewater constituents to form
compounds that are harmful to both
man and his environment. The poten-
tial carcinogenic effects of chlorinated
effluents have been considered
serious enough for the EPA to be
conducting confirmatory studies at
this time. There is no doubt that off-
flavor in fish, and taste and odor
effects in waters may result from the
discharge of these waters.
Saline wators, as indicated, have a
natural self-purifying effect on
pathogenic bacteria introduced from
sewage effluents. Chlorination of
such effluents has the potential of re-
ducing this effect by adversely affect-
ing competitive natural bacteria and
predators present in the saline
waters. This reduced bactericidal po-
tential of saline waters on sewage
effluent bacteria has added sig-
nificance when consideration is given
to standard chlorination practices that
fail to provide adequate residuals and
contact times to remove viruses and
some pathogenic organisms. Fur-
thermore, the failure to control
sources of enteric organisms trans-
mitted through direct discharges, sur-
face runoff, or storm water overflows
while requiring the chlorination of
treated effluent to the same receiving
waters does not appear to begin to
approach the objective of enteric or-
ganism control for the public health.
Primary treated effluents are more
difficult to disinfect than secondary or
tertiary effluents which require higher
chlorine dosages because of particu-
lates and high chlorine demands of
organics present in the effluent. The
resultant effect is the potential for in-
creased chlorine toxicity to fish and
photosynthetic aquatic vegetation
and the potential for the formation of
greater numbers of chlorinated or-
ganic compounds. An evaluation of
the potential risks as opposed to the
potential gains with regard to public
health and safety and environmental
impact must be conducted prior to
any direction which would promote
indiscriminate chlorine practices.
Conclusions can be drawn
Certain conclusions can now be
drawn based upon the material and
literature cited, as to the general
impact of chlorinating effluent prior to
its discharge to brackish and salt
waters.
1) Chlorination of a treated
effluent, as currently practiced,
109
cannot provide for complete dis-
infection at all times.
2)	Chlorinated effluent has the po-
tential of reducing the natural bac-
tericidal effect of brackish and salt
waters.
3)	Sea water into which chlori-
nated effluent has been introduced
may be less effective against other
sources of pathogens, (bird drop-
pings, surface runoff, direct dis-
charge, etc.), leading to increased
counts within these waters.
4)	Chlorinated wastewater has the
potential of forming toxic and off-
flavor producing compounds which
could adversely affect the en-
vironment and prove carcinogenic to
man.
Based upon these findings and
other multiple factors and consid-
erations previously discussod, the fol-
lowing general recommendations art
made:
1)	The decision to chlorinate
wastewaters should be made on a
case by case basis after studying the
benefits to be gained as opposed to
the potential detrimental effects to be
produced.
2)	Overall environmental consid-
erations such as discharges of un-
treated wastewaters, surface runoff,
storm water overflows and the dis-
charge from marine vessels should
be evaluated before mandating year-
round chlorination to any one known
source.
3)	While no conclusive evidence
exists which relates contact water
sports in polluted waters to disease,
public confidence in wastewater
treatment systems is necessary for
continued public support. Therefore,
it is recommended that chloriruffion
be considered only during the normal
bathing season, until public education
regarding this matter is completed
4)	When discharging to saline pr
brackish wafers, it is recommended
that parameters other than coliform
density be used in formulating dis-
charge requirements to protect the
public health. These considerations
should include dilution effects, travel
time of discharge waters to locations
where water contact sports might be
occurring, the presence and occur*
rence of other discharges which may
be detrimental tr- the public health, as
well as the benefit gain to the'in-
tended or present use of the receiving
waters as opposed to the discharge
requirement's potential health
environmental risks to man. q q
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THE CITY AND BOROUGH OF JUNEAU
CAPITAL OF ALASKA
155 SOUTH SEWARD ST. JUNEAU, ALASKA 99801
DATE:
SUBJECT:
FILE NO.
May 15, 1973
LID #4
George Danner
P. 0. Box 125
Juneau, Alaska 99801
RECEIVED
DEC 2 1975
EPA-EIS
Dear Mr. Danner:
This acknowledges your letter of May 11, 1973, with your
prior letter of February 26, 1973 attached. You have asked for
a status report on LID #4.
This local improvement district was approved by the Assembly
by ordinance on May 3, 1973, along with another ordinance which
reduces substantially the individual assessments by providing a
general fund payment of $335,000 on account of the Twin Lakes
project. This effectively reduces the amount to be borne by local
assessments from $560,000 to a maximum of $335,000.
Work is proceeding on the design of LID #4 improvements,
and certain of the work which had to go forward in conjunction
with the State Highway project has been authorized. The remaining
work is scheduled for completion in two annual phases, but
commencement of it must be preceded by grant approval. The concept
of this job is fully consistent with the regional plan for water
pollution control, which has been approved by EPA. The alternatives
mentioned in your letter have been considered and rejected as less
satisfactory or less practical than the design selected.
As»to your specific assessment, the LID procedure allows for
review of final figures after the work is done, so you may wish
to seek an adjustment at that time if you believe it is warranted.
City-Borough Manager
RLU:pw
cc: City-Borough Engineer
110
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George Danner, Jr.
P. 0. Box 123
Juneau, Alaska 99801
February 26, 1973
Mr. Ron Usher, Manager
Juneau City & Borough
155 South Seward Street
Juneau, Alaska 99801
Dear Mr. Usher:
In regard to the notice of hearing for L.I.D. No. 4, that appeared
in the Southeast Alaska Empire, February 20, 1973, and my notice
received for a public hearing and cost estimates to property owners.
I feel that I must object to this proposal as presented; it is not
equitable to me and the utility of my land at Norway Point. I believe
a reasonable and conservative approach should be by some method of a
cost benefit ratio. My property with single dwelling will certainly
not be benefited by said improvements to the tune of $9,362.97. This
ordinance further provides a cushion of 20% which could, and no doubt
will, bring the amount to $11,234.55. This is more than the appraised
value of land. Furthermore, your prospectus does not give all the facts
for total probable cost to the property owners such as hook-up charges,
service charges, L.I.D. taxes, and increased property taxes. In addition,
my sewage will not run up hill! I will need additional lift pump and
related accessories to complete the hook-up. Therefore, this assessment
will be a small part of the total costs for this proposal.
I can't see why an individual home owner has to pay such an exorbitant
assessment as proposed for a sewage treatment plant, that for 4-6 months
of the year will still be pouring some raw sewage into Gastineau Channel.
This is not the intent of the Environmental Act I am sure. Furthermore,
my septic tank is operating efficiently with the effluent discharging
into low water, not raw sewage!
In essence, your approach places the entire burden of paying for the
facilities upon the present landowners. It bears no relationship to
actual land or potential use, nor does it reflect any variation in
facility use. Thus, the lot upon which an apartment house may be built
111
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2
would be assessed at no greater share than a similarly located
residence. Similarly, the commercial lot would pay no greater
charge no matter what its use. However, from the standpoint of
increased property value alone, resulting from the availability
of central sewer facilities, the apartment house lot and commercial
lot will have benefited much more than a residence lot.
An additional disadvantage to this approach is the fact that the
assessment cost will be reflected in the asking price for the property
upon sale. In some cases this reflection might actually result in
reducing the value of the property to the present owner. The added
assessment liability compared to the value of the land for development
purposes will be unrecoverable upon sale.
Some of my land has no particular value now, or in the future, for any
development, due to topography and location. The new freeway fronting
on my beach precludes any further development; in addition to loosing
an intangible asset that of having had waterfront property; two 29,000
volt powerlines crossing the property, one being a direct 100' R.O.W.
for the A. J. powerline, and another secondary line above the glacier
highway.
Therefore, there is a need to make some adjustment, at least for purposes
of an economic analyses. This particular property was never intended for
development, having had it for the past 20 years and built my home there
in 1954. We liked the freedom of the country and this mode of living
where we have "elbow room" space to raise our animals and chickens and
not be a nuisance to our neighbors.
As you know, the area from Norway Point to the commercial area at Salmon
Creek due to its topography and avalanche areas, will always be a narrow
corridor. By its location, restricted by the new freeway on one side and
limited to a useful depth of substantially less than 200 ft. above the
highway.
The present population density is above .7 people per acre in this corridor
with a projected population density by 1990 of, say 2.5 people per acre.
It is normally considered that when population densities reach 5.0 people
per acre it will become financially feasible to support a sewer syetem.
Another thought, if the commercial development at Salmon Creek around the
powerhouse and Morris Point proceeds as proposed, a sales tax would provide
additional revenues for purposes of financing some portion of this sewer
system cost.
112
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3
Getting back to my assessment, I'm wondering how your people
arrived at 7-1-043-LXO-000-1820 of 49,863 sq. ft. and 7-1-
G41-LXO-000-1820 of 3^,992 sq. ft. for a total of 86,855 sq. ft.
These figures taken from the Glacier Highway to a depth of 180 feet I
My figures are as follows:
Computer area for U.S.S. 1820 » 113,839 sq. ft. Consisting of
57,148 sq. ft. between Glacier Highway existing R.O.W. and the
westerly meanderline along the beach; 15,199 sq. ft. within
Glacier Highway existing r/w; 41,492 sq. ft., above the highway.
Computer area for ATS 724 ¦ 11,148 sq. ft.
U.S.S. 1820	57,148 sq. ft.
ATS	724	11,148 sq. ft.
68,296 sq. ft. total
- 881 Freeway take
67,415 sq. ft. remaining
This does not include the 100' R.O.W. for the A. J. powerline
reserved into the U. S. Government (Forest Service).
The project as proposed and the assessments now scheduled are
totally unacceptable. I would be glad to meet with you at any
time to seek a reasonable solution to the problems I, and many
others, face as a result of this proposed project.
Enclosed is a plot plan of U. S. S. 1820 for your information.
Sincerely,
GEORGE DANNER, JR.
Enclosure
cc: Andy Boyd, City Engineer
P.S. I maan raisin* our children in a country environment tool
in addition to tho animals.
113
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May 11, 1973
Mr. Ron Usher, Manager
Juneau City and Borough
155 South Seward Street
Juneau, Alaska 99801
Dear Mr. Usher:
In regard to your May 3, 1973, Borough meeting, I would like to point
out some of the inequities of LID 4 and 5 on the agenda of Page 2 of
that meeting. The local share of LID 5 was $1,181,000 and LID 4 was
$560,000. In prorating this against people of both LID's, it will
amount to say, 6,000 people of LID 5 or about $195.00 per person;
while LID 4 will amount to say 300 people or $1,870.00 per person will
be paying for the initial system.
This seems unreasonable for residential property, especially benefited
for rural living. It is the big land developers in the area who will
be especially benefited by this system and still have lake frontage
with the proposed Twin Lakes.
Some of my land has no particular value now, or in the foreseeable
future. This is due to its topography and location. An effort should
be made to determine land which could be considered undevelopable.
This can only be determined by an appraisal of lets in question.
There is a need to make adjustments for such land and for purposes
of project analysis as I stated in my letter of February 26, 1973.
I truly believe that the human environment has not been truly taken
Into consideration.
1 want you to understand I am not against a sewer line. However, as
a taxpayer I objected to the original concept which would force me
to leave since I was planning to retire in a few years. After being
born and raised in Juneau, this would be a difficult decision to
make.
114
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Your proposal of having some area-wide funding is appreciated and a
step in the right direction, hov?ever, it is still excessive for a
single family unit. I believe the Engineering Department should
have considered alternates to present to the property owners in the
LID prior to going ahead with their design.
I wish to compliment your staff on an excellent presentation of the
Lemon Creek Development Plan on the night of May 3, 1973. Using this
talent, I believe it would be appropriate to approach the EPA
alternates that would be more acceptable to the property owners of
the LID. The use of the gravel ponds mentioned by Mr. Hartenburger
appears to offer a new and acceptable approach. This would facilitate
sewage flow from the Salmon Creek area and Twin Lakes to a Lemon
Creek sewage lagoon.
I have been disturbed that alternates were not part of the public
involvement sessions. This places the public in an awkward position
of either being for the project or against it. Even since the original
R&M Plans were submitted to EPA and accepted, the situation has changed
enough to warrent further consideration of alternates. In addition to
new developments and proposed comprehensive development in the Lemon
Creek area; a major portion of the flats had been classified as
wetlands when the original application was presented. This may be
enough to warrent reconsideration by your staff and EPA.
You no doubt know that the majority of the people feel virtually
unanimous that the financing proposal is unacceptable. The property
owners did not have an opportunity for involvement into this LID
prior to the start of the design as required.
I would be glad to meet with you and arrive at an equitable and
reasonable solution of this problem I face as a result of this
project. I would also appreciate an acknowledgement of this letter
and my letter of February 26, 1973, with a brief, current status report
on LID 4.
Sincerely,
GEORGE .pMttR
P. 0. Box 123
Juneau, Alaska 99801
cc: Andy Boyd
115
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April .2, 1973
The Honorable Joseph A. McLean
Mayor of the City and Borough
of Juneau
155 South Seward Street
Juneau, Alaska 99301
Dear Mayor Mclean:
I went on record as opposing the formation of LID A (Vanderbilt Hill to town)
because I felt that:
1.	A sewer system was not necessary for an area of such low density
(75 families in a 4^ mile stretch) nor could it function properly under such
a light load.
2.	The procedures used for "voting" on the proposed LID by property
owners in the area can best be described as "kangaroo" and bore no resemblance
to traditional democratic procedures.
However, assuming that the project is approved, than I think that the proposed
method of financing it should be cast aside as clearly unfair and probably
illegal. I propose the following:
1.	Every property owner in the proposed LID should bear a share of the
cost of the line since all properties stand to benefit. Presently, only
properties located within 180 feet of the line (with a few notable exceptions)
are assessed. This is clearly unfair, if not illegal.
2.	Since one of the rationales for the line is to protect the Twin
Lakes area, and since this recreational area will benefit all borough resi-
dents, the borough should pick up an appropriate share of the cost.
3.	There should not be a depreciation charge made to	the property owners
In addition to a charge for the original cost of the line.	This would ataount
to charging twice for the line. If I pay cash for a car I	certainly shouldn't
have to cake monthly payments as well.
4.	The payments for the cost of the line should be spread out over the
life of the bonds issued and interest shou3.d be charged at the same rate as
the bonds (Government, in other words, should not make a profit on its con-
constituents). Anyone who desires to pay in advance should be charged only the
present value of his projected payments (i.e., he should be given a discount).
5.	Monthly operating charges should be calculated to meet direct
operating costs (exclusive of depreciation) only.
116
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honorable Joseph A. McLean
-2-
April 2, 1973
ink that these suggestions are fair and appropriate. I urge your careful
ideration of them before you make a final decision on this proposal.
regards,
lerick P. Boetsch
jerty owner in LID k
Borough Assembly
Juneau Enpire
117
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Kouce h i>o.\ hjco
May 8, 1973
Dr. Ma:; Brewer, Commissioner
Alaska Department of Environmental Conservation
Pouch 0
Juneau, Alaska 99801
Dear Dr. Brewer:
I have the following specific comments delating to revision of
18 AAC 70.000.
Section 18 AAC 70.080 Minimum Treatment;
The proposed change to require conventional "secondary" treatment for
all domestic sewage obviates rational engineering design for sewage
treatment in the coastal waters of Alaska.
Several research papers and publications indicate that wastewater
parameters used to control discharges to streams, rivers, and lakes
are not significant or applicable for discharges to a marine environ-
ment. However, these criteria are still being used to define secondary
treatment for coastal waters. Some of t.he major parameters of concern
are:
Dissolved Qxvgen
Oxygen depletion in open coastal waters due to disposal of municipal
effluents is of minor concern.	The National Academy of Sciences-
National Academy of Engineering reports that there are no significant
oxygen problems resulting from waste discharges to open coastal waters.
The California State Water Resources Board publication — and the
proceedings from the Coastal Zone Pollution Management Symposium _
arrive at the same conclusion. Conventional waste treatment systems
primarily developed to satisfy critical oxygen situations in confined
receiving waters are not applicable for a problem that literally does
not exist when discharging to unconfined coastal waters.
Settleable Solids and Sediment Characteristics
Various studies over the last 10 years have investigated the.benthic
distribution of sewage solids in the vicinity of outfalls. — In most
cases it has been difficult to determine the extent of any sludge
deposits because of the dispersion of the solids by currents and mixing
The Allan Hancock Foundation Study —' stated "there is no observational
evidence that static beds of material continuously accumulate despite
many years of operation of various marine outfalls along this coast".
A study of outfall areas in California at Point Loma, Palos Verde, and
Santa Barbara by the Institute of Marine Resources (Lajolla) found no
substantial accumulation of sediments that could be attributed to
discharged waste material. —
118
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Here again the concern with these effects has been based on experience
with waste discharges into lakes, streams, and other confined waters
where accumulations of sludge-have posed real problems. In the open
ocean environment, the relatively high turbulence due to tides, wind
and wave action, together with abundant quantities of o>cygen result
in rapid dispersal and oxidation of wastewater solids.
Floatables, Oil, and Grease:
Control of floatables should be considered; a problem of major importance
in marine waste disposal. This was pointed out by H. F, Ludwig — in
1942 during the East Bay Cities Sewage Disposal Survey of San Francisco
Bay. Despite this, no standard method is yet available for the quanti-
tative determination of sewage constituents that will float after dis-
charge into the receiving water. Some progress has been made in
attempting to quantify floatables and the recent ocean disposal system
designed for Rio de Janeiro in Brazil has been tailored to recognize
the significance of floatables as a key parameter.
Bacteria
Enteric bacteria can pose a public health hazard if not well dispersed
in coastal waters. This hazard is reduced however, because coliform
bacteria do not survive well in seawater. The die-off results from
a combination of factors, including salinity, sunlight, agglomeration,
and sedimentation. The die-oft rate is usually expressed in terms of
a T90 value which is the time required for 907. of the bacteria to die.
T90 values determined by field experiment normally are found to be in
the range of one to six hours. 2J
Metals
Metals may enter coastal waters from a variety of sources; the major
sources are waste discharges, surface runoff, aerial fallout (including
rainfall and advective transport by the coastal currents). Estimates
of the annual inputs of several metals to the coastal waters of
Southern California were made recently by the Southern California
Coastal Water Research Project.— These are shown in Table 1
Table 1. Total Annual Input to the Southern California Bight (metric
tons per year).
	Source	Mercury	Lead	Cadmium
Municipal wastewaters	3.2	180	30
Storm runoff	1.6	10	4
Direct rainfall	8	1,000	1
Advective transport	600	6,000	2,000
119
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3
These estimates, although admittedly crude, do raise serious questions
concerning the feasibility of controlling tine input of metals by
controlling wastewater discharges.
General
The proposed secondary treatment requirement seems to override the
State's water quality criteria (18 AAC 70.020), for disposal to coastal
waters. Primary treatment will, in most co&stal locations, meet the
existing and proposed water quality criteria. The additional con-
struction and operation costs associated with secondary treatment are
therefore unwarranted to meet environmental or public health hazards
in the coastal waters of Alaska.
According to Robert Dean of the Ultimate Disposal Research Program, EPA:
Disposal to the ocean takes advantage of the huge dilutions
available and is often the best method, considering ail alternatives.
For example, sodium chloride, calcium chloride, and magnesium
sulfate brines will be undetectable against the natural background
of these salts in the ocean - even hydrochloric acid can safely
be diluted in the ocean - whereas, since these substances are
water soluble and cannot practicably be converted into solid
precipitates, their disposal on the land or into fresh waters
is highly objectionable.
Between the obvious perils of mercury and the obvious safety
of sodium chloride, there is a vast range of substances whose
candidacy for disposal in the ocean is not so clear-cut. General
organic wastes that settle to the bottom, including garbage, will
be decomposed by marine bacteria. Iron salts will form ferric
hydroxide minerals, which are already present in ocean sediments
along with many other minerals. The key to safe disposal of
such substances is control of quantity. Certain nutrients, both
organic and inorganic may be beneficial in increasing the
harvestable crop from the ocean, and in colder waters thermal
wastes may also be useful.
While there has been very little work on the effects of sludge and
spoil dumping at sea, sewer outfalls have been carefully investigated
and these studies point to the rather surprising conclusion that
such outfalls, if properly designed, do not constitute serious threats
to the environment. The large Hyperio Plant in Los Angeles has had
a sewer sludge pipeline outfall in operation for 20 years and has
apparently done remarkably little damage to the marine environment.
120
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A
It would be shortsighted then to make a secondary requirement for the
coastal zone equal to requirements for othetf waters. David Smith.says
that the following are "compatible" wastes for ocean disposal. —
1.	Unpolluted dredge spoil
2.	Construction debris (including drilling wastes)
3.	Organic municipal refuse
4.	Incineration ash
5.	Cannery wastes
6.	Sewage treatment plant effluents
His conclusions are, of course, premised on the basis that these
wastes do not contain highly toxic substances.
Obviously a great deal of research and development is in order before
the practice of marine waste disposal can become scientifically
based. One urgent step is for a project for quantification of aquatic
ecological values - to put numbers, no matter how crude, on the relative
value of the various types of receiving waters (streams, rivers, lakes,
estuaries, oceans) so that the engineer will have some guidelines for
designing waste disposal systems with minimum adverse effects on the
overall regional ecology.
The current proposal however, appears to shortcut essential investigation
and research and to establish the answers by legislative or regulatory
fiat. In most cases this will result either in uneconomical utilization
of our resources or, for any given level of expenditure, in less than
maximal protection of our environmental resources. It certainly is
not cost effective.
I suggest that your revision to 18 AAC 70.080 include secondary
effluent requirements as they relate to the receiving waters involved.
Suggested requirements may include the following: (Please note that
numerical values shown are arbitrary and are only to show the intent of
my proposal)
Receiving Waters
General Secondary Treatment
Effluent Parameters	
Ocean water
(1) 307, BOD removal
(Define by relation of
percent fresh water and
percent tidal flushing
exchange)
(2)	307. Solids removal
(3)	95% Floatables removal
(4)	PH between 6.5 and 8.5
(5) Initial dilution of 50: 1 prior
to any contact with beach or
commercial shell fish areas.
(6) Etc.---for temperature, color,
nutrients, toxicity, pesticides
metals, odors, radionuclides.
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5
Receiving Waters
			- II. ¦ 1
General Secondary Treatment
Effsluent Parameters
Estuaries
(Define by relation of
percent fresh water and
percent tidal flushing
exchange)
(1)	65% BOD removal
(2)	65% Solids removal
(3)	95% Floatables removal
(4)	P** between 6.5 and 8.5
(5)	Iriitial dilution of 50 : 1 prior
to contact with beach areas.
(6)	Etc.--- for temperature, color,
nutrients, toxicity, pesticides,
metals, odors, radionuclides.
Glacial lakes and rivers
(Define by amount of suspended
sediment and/or turbidity
of natural water)
(1)	65% BOD removal
3C a'
(2)	-fr-S'/r Solids removal
(3)	95% Floatables removal
(4)	between 6.5 and 8.5.
(5)	Initial dilution of 50: 1 within
100 feet of outfall
(6)	Etc.	for temperature, color,
nutrients, toxicity, pesticides,
metals, odors, radionuclides.
Non-glacial lakes and rivers
(Define as natural "fresh
water" lakes and streams)
(1)	95% BOD removal
(2)	95% Solids removal
(3)	95% Floatables removal
(4)	between 7.0 and 8.0
(5)	Initial dilution of 50: 1 within
100 feet of outfall.
(6)	Etc.	 for temperature, color,
nutrients, toxicity, pesticides,
metals, odors, radionuclides.
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The environment is a dynamic living system. Changes in its charac-
teristics are inevitable. In many cases, socio-political considerations
may veil make such changes necessary. The real problem is not to
attempt to cvoid changes but to devise ways in which these changes
can be controlled and managed. If marine (or any other) resources are
Important enough to warrant the massive expenditures presently
comtemplated for their protection, they are sufficiently important
to Justify the expense and effort necessary to ensure that these
expenditures will achieve the desired results. I believe the proper
classification of secondary treatment as related to the receiving
waters would be an important step towards a rational solution to
proper wastewater treatment.
LES PAUL	/
Civil Engineer^ P.E.
Route 4, Box 4528
Juneau, Alaska 99801
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7
References;
If City of Los Angeles, Department of Public Works, Bureau of
Sanitation. "Environmental Effects of Liquid Wastewater Discharge
Upon Santa Monica Bay." Los Angeles, California (March 1971)
2/ K. K, Turekian Cited in Feldman, M. H., "Trace Material in Wastes
Disposed to Coastal Waters: Fates, Mechanisms, and Ecological
Guidance and Control." FW'QA Pacific Northwest Water Laboratory
Working Paper No. 78, Corvallis, Oregon (1970)
3j National Academy of Sciences - National Academy of Engineering,
"Waste Management Concepts for the Coastal Zone." Washington,
D. C. (1970)
4/ "Concepts in Open Coastal Disposal of Municipal Wastewater"
California State Water Resources Board, 1416 9th St., Sacramento,
California 95814, October 5, 1971.
j>/ Proceedings - Coastal Zone Pollution Management Symposium -
Edited by Billy Edge Clemsoti University - Charleston* South
Carolina - February 21-22, 1972.
6/ Allan Hancock Foundation, "An Oceanographic and Biological
Survey of the Southern California Mainland Shelf", California
State Water Quality Control Board, Publication No, 27, Sacramento
(1965)
7/ California State Water Quality Control Board, "An Investigation
of the Effects of Discharged Wastes on Kelp", Institute of Marine
Resources, Publication No. 26, Sacramento (1964)
8/ Ludwig, H. F., "Suggested Procedure for Determination of Grease",
Proceedings, American Society of Civil Engineers.
9/ Smith, D. D. and Brown, R. P., "Deep-sea Disposal of Liquid and
Solid Wastes", Industrial Water Engineering, PP. 20-24, September
(1970)
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Juneau, Alaska 99601
P. 0. Box 123
May 14, 1973
Mr. Hurlon Ray
Environmental Protection Agency
1200 6th Avenue
Seattle, Washington
Dear Mr. Ray:
Enclosed are letters I have written to the Borough regarding LID 4.
For your infornation, I still think a cev/er line 4 1/2 nilea Ion?, for
$2,101,000 is excessive and other alternate.^ should be considered in view
of the new developments at Lenon Creek. Ilsther than rim the sewer to
the rock dump, it rcny be advantageous to consider a treatment plant at
Lemon Creek rather than going from there to the plant in the Valley.
Hoping this may be considered or at least looked into, I ara,
Yours truly.
GEORGE DAI JEER
P?0. Box 123
Juneau, Alaska 99801
125
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Juneau, Alaska 99801
P. 0. Box 123
June 6, 1973
Mr. Robert S. Surd, Director
Enviornmental Protection Agency, Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Attn: M/S 421
Dear Mr. Burd:
It was by accident that T came across your memo of May 25, 1973, in regards to
a negative statement is all that ds required in support of the construction
project No. C-020032 for the City and Borough of Juneau.
This has been a very controversial issue since the start. The proccedures for
"voting" on the proposed LlD's by property owners can best be described as
"Kangaroo" and bore no resernbalance to traditional Democratic procedures. These
sewer projects have been "ram:;>ed" down our throats by the City and Borough Assembly.
This news memo about the negative declaration has not been released to the
interested public by the Borough and to the news media and appears to be a coverup
to keep the concerned public unaware what is going on until after the two week
period for comments has passed.
They have not followed any of the guide lines and rules for reporting and seeking
oui" and involve the interested public both at the preliminary stage and during
development of the project. No measures were taken to facilitate rather than
inhibit public understanding of and contributing to resolve the matter. No
adequate information had been provided and enough time allowed for public under-
standing and response given prior to March 22, 1973, when the project already
had been advertised for bids. I could go cn to great lengths on other irregularities
but I am sure you are aware of them.
I live in LID No. 4 and have discussed our objection about my environmental concern
on this project and the Borough officials are trying to convince us that our only
concern is the assessments. I certainly object to the inequities built into the
assessment method of financing for the utility of my land. This original
assessment of almost $12,000 for residential property, especially benefitted for
rural living, while the Baranoff Hotel will pay an assessment of about $5,600.
Forty-niine percent of the people of LID 4 sent in protest letters and petitions
against the proposal as unacceptable... After all, "The Human Environment is the
Aggregate of all External conditions and Influences Apparent Esthetics, Social,
Economic, Historical, ETC" that affect the life of a human. Taken from your
own "Guide Lines". Assessment affect human environment for individuals.
I want you to understand I am not against a sewer line, however, I object to the
manner in which this matter was handled by the Borough from its inception.
126
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2
I read the Environmental Assessment proposal to Mr. Raymond Estess, State
Coordinator, Juneau, Alaska, dated April 26, 1973, a copy you will have by now.
This is different than the one presented at the public hearing March 22, 1973,
Again, there are a lot of loop-holes and half-truths and should require
further review before further action is taken as a sev,*er line for an area of
such low density (75 families a <> 1/2 mile stretch) costing $2,161,000
seems excessive except for certain land speculators, who will benefit by this plan
Extensive development in the Lemon Creek area than had been anticipated, may
warrant a review of Alternate No. 2.
The Borough has contributed $335,000 as area wide contribution to help the
people in the area to "ease" the inequities in the original plan. However, I
still feel that they are too high. I want to pay my fair share and no more than
other property owners of the rural areas of the Borough.
I hope this letter and copies of previous letter*I have sent you will explain
some of the problems we are having in regards to LID 4 and 5 and the lack of
public involvement prior to final design and lack of communication with the
Borough officials on this project from the start.
Sincerely,
GEORGE BANNER JR.
P. 0. Box 123
Juneau, Alaska 99801
127
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
-------
George Danner
P. 0. Box 123
Ouneau, Alaska 99801
October 24, 1973
Mr. Robert S. Burd, Director
Environmental Protection Agency - Region 10
1200 Sixth Avenue
Seattle, Wash. 98101
Dear Mr. Burd:
I am enclosing an article that appeared in The Alaska Empire, dated
October 4, 1973; and I strongly take exception to the implication
that the stumbling blocks of the Salmon Creek project as being "straw
issues" and the environmental complaints in "Fussing about their
assessments".
I live at Norway Point; a narrow corridor area to mile 2.5 that due
to the potential geophysical hazard classification given the area
by an investigation prepared by the Alaska Geological Consultants of
Anchorage for the Borough in 1972, the construction of the new
Glacier Highway further restricts extensive development on this
section of the sewer project.
I feel further study is needed to this proposed LID 4. As presented,
it is not equatible to property owners like me. I want to pay a
fair share of the costs; but to have a low density area zoned primarily
one and two family units, (approximately 75 families, except for a
potential land developer at Salmon Creek) having to pay for the ultimate
development, and this is what our assessment will pay, I think this is a
very unfair assessment. There should be some method whereby as new users
or developers come on the line, their assessments could be set aside and
credited to an account that would lower the cost or assessment of the
people that paid for the project initially.
129
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2
Even though the assembly agreed to bear half of the costs of the
project due to the fresh water lake recreation area, th cost cf the.
system by the few property owners to be specially berrl d by said
improvement, in comparison with the other service are^vis out of reason.
I believe the costs must be based on the actual load put on the system
and every property owner on the LID should bear a share of the cost of
the line since all properties stand to benefit.
We, here in Juneau, are in an unfortunate situation where our local
management does not seem to be concerned about the wishes of the us
taxpayers.
There are many concerns indicating that the human environment was noit
considered and that the local improvement assessment is not part of
an environment impact statement.
The Policy and Procedure memorandum transmittal 90-1, of the Federal!
Highway Administration, September 7, 1972 - Environmental Impact and
Related Statement, paragraph 3(f) defines human environments as"The
Aggregate of all external conditions and influences (aesthetic,
ecological, biological, cultural, social, economic, historical, etc.)
that affect the life of a human".
For further references on the matter, I've written the following letters
regarding the sewer projects as follows:
1.	Telegram dated May 5, 1973, concerning specific environmental
concerns.
2.	Letter to Mr. Hurron Ray dated May 14, 1973, enclosing letters
I've written the Borough regarding LID 4.
3.	Letter to Mr. Robart Burd dated Juno 6, 1973, regarding the
manner in which the Borough handled the situation.
4.	Letter to Mr. Roy Ellerman about the second environmental
impact appraisal, and my comments on statements made in this report.
Therefore I will not comment further on this subject except to state that
the Borough is still adai/ierit on their stand on this matter and have made
no attempt to communicate in regards to the environmental assessment of
the SI anion Creek s ewer. There are several factors that need further study,
such as the potential hazards of the 23,000 volt power transmission lines
that will be running across these fresh water lakes.
130
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3
I question whether there will be adequate flow of water for this
70 acres of recreation waterway. The small streams flowing into the
lake are all short drainage streams that during the dry summer months
create very little flow, and with the limitation of water that can be
diverted from Salmon Creek could further restrict the flow needed to
create the water needed to maintain the flow necessary circulation. The
Borough officials feel that the the local utility (The Alaska Electric
Light and Power Company) will abandon the lower power house; therefore,
this water can be diverted into Salmon Creek for the necessary water
supply. However, the officials of the A.E.L.&P. Company have no intention
of abandoning this source of hydroelectric power for some time.
I think this project deserves further scrutiny by you before any further
action is undertaken. If you are in the Juneau area, we would like to
discuss this matter with you.
Sincerely,
George Danncr
cc: Senator Ted Stevens
131
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
mi
PRO^
1 200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
NOV 8 1973
REPIY TO
AT1N Of :
M/S 429
Mr. George Danner
Post Office Box 123
Juneau, Alaska 99801
Dear Mr. Danner:
Your letter was read with great interest and points up essentially
two issues; assessments for the LID 4 and the environmental impact of
the Salmon Creek project. The Environmental Protection Agency has re-
sponsibilities on the environmental aspects of the projects it funds
and on separate user charge systems to assure adequate operation and
maintenance and replacement of the sewerage works, but has no responsi-
bility on LID assessments.
This office has not received a complete application nor environmental
assessment statement for the Salmon Creek project. Your concerns of the
impact the construction of interceptor sewers and lift stations may have
on the environment should be addressed to the City and Borough of Juneau
for consideration since they are now writing the environmental assessment
statement. Although the planning and the design may be virtually complete,
the project is not under construction and changes can be made. We are
therefore taking the liberty of forwarding a copy of your letter to the
City and Borough of Juneau. Public input to Federally funded projects is
in keeping with the spirit of the National Environmental Policy Act.
An environmental review, which will include the environmental assessment
statement from the City and Borough, will be made of the project and if sig-
nificant environmental impacts are indicated, or significant public objections
are raised, an environmental impact statement will be written on the Salmon
Creek Project.
Sincerely
Cfef Robert S. Burd
v*"" Director
Air & Water Programs Division
cc: City & Borough of Juneau
Alaska Opns. Office
ADEC
132
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M/S 429
November 16, 1974
Juneau, Alaska 99802
Mr. Robert S. Burd
Director - Air and Water
Region X
1200 Sixth Avenue
Seattle, Washington
Dear Mr. Burd:
I've written to Mr. Hurl on Ray of your office about L.I.D. 4,
with my back-up material, on May 14, 1973. Since then I've
received your letter of intent, regarding the environmental
impact statement that should be prepared.
As I stated before, the area from the Juneau City Limits to
Salmon Creek is a corridor type of Development, and always
will remain as such, because of the topography and the steep-
ness of the terrain. This area has been classified as a
geophical hazard area by the Borough. The only area left for
development is the area at Salmon Creek and the area around
the Fresh Water Lake.
Another inequity of LID4; the local share of the amount. In
prorating this amount against the people in the LID's, it will
amount to say 6000 people in LID5 or about $195.00 per person:
While LID4 will amount, say 300 people or $1,870.00 per person,
in other words, our prorata rate will exceed the cost of the
other system.
It is normally considered that when population densities Reach
5.0 persons per acre it becomes financially feasible to support
a sewer system. Even with the population projection of this
area for 1980, will fall short of this density. (Realistically,
then the largest amount would be 1.87.)
It appears then that a reasonable and conservative approach to
cost benefit and repayment analysis is to re7ate the needs and
values to year 1990.
The Boroughs proposed of repayment construction was solely by
assessment against the privately owned property in the area,
that is 200 feet from the Glacier Highway.
In essence, this approach places the entire burdon of paying
for the facilities upon the present land owners. It bears no
relationship to actual land use or potential use, nor does it
reflect any variation in facility use. Thus, the lot upon
which an appartment house my be built would be accessed no
greater shart than a similarly located residence lot.
133
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2
An additional disadvantage to this approach is the fact that
the assessment cost will necessary be reflected in the asking
price from the property upon sale. In some cases, this reflec-
tion might actually result in reducing the value of the property
to the present owner.
The added assessment liability compared to the value of the
land for development purposes would in some cases be entirely
out of proportion and unrecoverable upon sale.
I've attempted to present some additional facts to you regarding
this matter, and I know that it is a little more that the matter
of only "assessment". But I believe that the "Human Environment"
is involved here.
Very Truly Yours,
/
P. 0. Box 123
Juneau, Alaska 99802
134
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Rt. 4, Box 4973
Juneau, Alaska 99803
Not. lkt 1975
RECEIVED
EPA
1200 Sixth Ave*	Attention: M/S M*3	'*0V 1 8 1975
Seattle, Wash* 98101
CP ^ b r-»r*
This la in regard to the public hearing held by EPA in Juneau, Alaska
on November 11, 1975 regarding ffm propose*construction of an inter-
ceptor sewer line from Vanderbilt Hill to Norway.Point. After consider^
able study of the matter with regard to needs, environmental impact,
and social and economic costs , some facts seem most significant to me.
They are:
1.	There is only a small number of dwellings/ and/or families
along that short stretch of road. (About 75)
2,	*ith inflation, plus ever mounting construction costs, the
probable cost to each individual family could conceivably be from
16,000 to 110,000—-and this is a conservative estimate. Quite a fen
of those families are composed of people who either are retired or
about to retire* This places a terrific burden upontfche few who must
bear the coBts. The costs are way out of line *¦
3* Because of the topography and terrain* (little land for build-
ing a/c the close proximity of 6*lt water on one side and mountains on
the other,) there is little likel^ihood of the population becoming much
greater there* The area around Salmon Creek is the only area which is
likely to grow much. The owner of a sizable chunk of land there, js a
developer of sorts, and has, from time to time, prop£tf&/a number of
different possible uses of his land; for example, a mobile home park.
Conceivably, the sewer line would be to his financial advantage, while
at the same time, it would work a terrific hardship on many of the other
property owners. Indeed, there are some families and retired people
who woufcd be forced to sell their homes and perhg*#'even leave Alaska
as an all too probable effect of the high assessments*
There are otherfar more economical alternatives to avoid pollution such
as:
1* Requiring adequate septic tanks, or*here necessary, home treat-
ment plants for each home, with the exception of any developer who
might choose to have numerous dwellings such as mobile homes, apart-
ments, condominiums, etc., in which the density of population per acre
might be high. In such cases,	o*	p^nntp should h-
borne by developer* All too often, these high priced sewers are pushed
end urged by self-seeking schemers upon an unsuspecting public who
wind up footing the kill, while the developer pockets the profits* Often
too, these schemers manage to pose as benefactors to the community!! *
Environmental impact twStudieB rttfiet consider not only the natural envir«
onment, but also the humans »s jpart of that environment and the social and
economicjbonsequences»<^tf-inc«r®^ y°ur8t ^
135	^^<7
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Response to Mary E. Ross
The reader is asked to refer to EPA's decision regarding funding of the
proposed project as presented in the Preface to the EIS. Since the project
as conceived is not to receive federal assistance, a complete review and
reevaluation of the wastewater problem within LID No. 4 will be necessary.
Both the environmental and socio-economic consideration of any proposed
alternatives will be carefully evaluated prior to committing any federal
funds.
136
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TO: Richard R. Thiel
Environmental Impact Section	RECEIVED
Environmental Protection Agency
1200 Sixth Ave.	NOV 2 6 1975
Seattle, Washington 98101
CP'-, rri'
In reference to the Impact Statement and hearing on the Juneau-Salrton
creek Sewer Interceptor I would like to have the following included in
the final Impact Statement.
1. Graph on page 45: SociO-Econcmic section .
A.	Total cost is completely out of line with other sewer projects in
this area , as far as cost to benefit ratio, very few people are
to be served by this system and the proposed cost is too high.
B.	Individual cost: since the entire project appears to be necessary
for the twin lakes project it does not appear reasonable to force
private individual to pay for a public area such as this.
Method of assessment is wrong, undeveloped property and large lots
are billed ( assessed ) the same as developed land. This method
assumes that undeveloped land derives seme benefit frcm the systan.
Which is not true. This was discussed with the Borough at the
time but they would not change the method.
C. Development: Since the Capitol move the possibility of large
developmet is not practical. even if the sewer were installed.
2. Graph on page 45 Recreation vise and facilities
I personnaly doubt that there will be any great recreation use of
the Twin Lakes area. Since Juneau has already lot of water related
activies. And this will just be one more small item .
3.	The possibility of running the sewer frcm the Hospital to the north of
airport palant and increasing the size of the LID would appear the
most acceptable solution. including more area would cut the overall
cost, a different method of assessment should also be explored one that
is based on the single family dwelling principle rather than the gq
foot, and also calling the system a collector thus incleasing the "federal
funding .
4.	The cost factor for this project is extremely high under the present
method of assessment, the entire project is for public recreation,
and caused by the highway and the twin lakes plan and should not cause
a finical hardship on the people owning property in the area, especially
property that is not developed and may not be developed due the the
capitol move .
Stanley A. Beadle
RR 5 Box 5199-12
Juneau, Alaska
137
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Response to Stanley A. Beadle
Mr. Beadle's letter is concerned primarily with the impacts the proposed
project would have on the individual property owners within LID No, 4.
Because of the EPA's decision not to provide federal assistance {see Preface),
this proposal is no longer viable. The wastewater problems within the study
area will require a complete reevaluation in terms of engineering feasibility,
environmental impacts and socio-economic affects. At such time, a study
of alternative financing methods would be provided in order to arrive at an
equitable solution for funding any approved alternative.
138
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RECEIVED
DEC 3 1975
EPA-EIS

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Response to Vivian Lovaas
1.	Refer to the response to the City and Borough of Juneau, Item 8.
2.	Due to the EPA's decision not to fund the proposed project, a complete
engineering reevaluation of the wastewater problem in LID No. 4 will
be required. The proposed system was conceptually designed to service
the projected population of the entire area based on existing land use
planning. In any system with a small initial population, but a projected
one which is significantly larger, maintenance problems of the type
suggested can occur. These problems are difficult to correct until a
larger population is realized, but can be reduced by the application of
sound engineering and operational procedures.
3.	We note that the majority of your comments under No. 3 were responded
to at the EPA's public hearing on November 11, 1975. You do mention,
however, a number of actions that occurred in the Salmon Creek in
1973. Please realize that EPA's EIS is a result of an application for
grant funds from the City and Borough of Juneau to construct the Salmon
Creek Interceptor. The projects you refer to were not EPA actions
and, therefore, did not require an EPA EIS.
4.	While the actual cost to an individual property owner in LID No. 4 is
higher than that assessed residents of other LID's for similar services,
the basis for this assessment is similar. The problem arises due to
the high capital costs created by the length of the proposed line and the
relatively few residents with large land holdings. In any system of this
type, the costs must be borne by someone. If additional local, state or
federal funds cannot be secured, the additional revenues must be pro-
vided by the local residents on an equitable basis. The decision on
what constitutes an equitable basis must be developed on a local level.
5.	The development of the new Glacier Expressway and Twin Lakes project
has created some serious wastewater problems, which could develop
into public health as well as environmental hazards. The correction
of these problems (i.e., raw sewage outfall into Twin Lakes) should be
accomplished prior to the onset of ahy serious implications. Individual
financial burdens are a major consideration, but the hazards posed by
the situations that have been created in LID No. 4 are not going to be
resolved simply by alleviating those in other areas. They must be
addressed, and when possible, positive solutions implemented. The
cost of these solutions will need to be borne, in part, by the local
residents.
151
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REFERENCES
Alaska, State of, Department of Highways; n.d. ; Gastineau Channel
Crossing, Including Douglas Highway Between Lawson & Kowee Creeks,
Final Environmental Impact Statement.
	, Department of Health and Welfare, Division of Public
Health; June 1964; Sanitary Facilities for the Greater Juneau Borough.
	, Department of Health and Welfare, Division of Public Health;
May 28, 1969; Correspondence to Project Area Homeowners re Survey
Along Glacier Highway from Norway Point to Vanderbilt Hill, to Determine
the Number and Location of Unapproved Domestic Sewage Outfalls.
	, Office of the Governor, Division of Planning and Research;
July 1973; Bibliography of Community Planning.
	, Department of Environmental Conservation; March 10, 1975;
Correspondence to City and Borough of Juneau re Refusal of Permit to
Temporarily Fill Twin Lakes.
	, Department of Health and Social Services, Divison of Public
Health; June 9, 1975; Correspondence to Planning Department, City-
Borough of Juneau re Current State of Salmon Creek Wastewater Problem.
Boeing Computer Services, Inc., and Naramore Bain Brady and Johanson;
1974; Alaska State Capital Relocation Study.
California State Water Resource Control Board; 1963; Water Quality
Criteria.
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References, continued
9. Daniel, Mann, Johnson, and Mendenhall; October 1972; Geophysical
Hazards Investigation for the City and Borough of Juneau, Summary Report.
10.		; October 1972; Geophysical Hazards Investigation for the City
and Borough of Juneau, Technical Supplement.
11.	Hill and Ingman Consulting Engineers; 1967; Engineering Report on a
Comprehensive Plan for Sewage Collection Treatment and Disposal,
City of Juneau, Alaska.
12.	Hill, Clair A. , and Associates, Consulting Engineers; January 29, 1971;
Letter Report on Juneau Sewerage Project.
13.	Homan Associates; February 1974; Capital City Economic Base Study.
14.		; February 1974; State and Federal Employment in Juneau,
December 1974 (A Supplement to the Economic Base Study).
15.	Juneau, City and Borough of; n. d. ; Improvements to Juneau Municipal
Airport, Phase II, Negative Impact Statement.
16.		, Planning and Zoning Department; December 1966; A Com-
prehensive Plan for the Development of the Greater Juneau Borough
(Area Outside the Two Cities).
17.
	; 1972; Title 49: Planning and Zoning, Code of the City and
Borough of Juneau, Alaska.
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References, continued
18.	Juneau, City and Borough of, Planning Department, and Fred Utevsky and
Associates; May 1972; Juneau Area Housing Study.
19.		March 22, 1973; Verbatim Transcript Environmental
Hearing Salmon Creek Sewer.
20.		; April 19, 1973; Ordinance of the City and Borough of Juneau,
Alaska.
21.		; November 6, 1973; Correspondence to Environmental Pro-
tection Agency re the Environmental Assessment for the Salmon Creek
Sewer.
22	.	February 20, 1975; Correspondence to Alaska Department
of Environmental Conservation re Request for Permit to Fill Twin Lakes.
23.		, Planning Department; March 7, 1975; Correspondence to
Planning Commission re Report on Joe Henri Conditional Use Application.
24.	R&M Engineering and Geological Consultants; 1971; Engineering Report,
Sewage Collection and Treatment, Norway Point to Mendenhall Valley,
Juneau, Alaska.
25.	U.S. Geological Survey; 1969; Hydrologic Data of Juneau Borough, Alaska.
26. 	, 1971; Water Resources of the City and Borough of Juneau,
Alaska.
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References, continued
27.	U.S. Geological Survey (G.O. Balding); 1974; Hydrologic Investigations
of Salmon Creek Reservoir and Drainage Basin Near Juneau, Alaska.
28.	U.S. Corps of Engineers, Alaska District; May 1969; Special Flood
Hazard Information Report, Salmon Creek, Juneau, Alaska.
29.		; November 1972; Esoro Petroleum Products Transfer Fac-
ility and Access Channel.
30.	U.S. Environmental Protection Agency; June 8, 1973; Negative Declaration
and the Environmental Impact Appraisal on the Juneau-Douglas Interceptor
Sewers and Treatment Plant System.
31.		; July 1974; Manual for Preparation of Environmental Impact
Statements for Wastewater Treatment Works, Facilities Plans, and 208
Areawide Waste Treatment Management Plans.
32.		; February 1975; Authorization to Discharge Under the National
Pollutant Discharge Elimination System.
33.		; April 14, 1975; Environmental Protection Agency Prep-
aration of Environmental Impact Statements,
34.	U.S. Soil Conservation Service; 1974; Soils of the Juneau Area,
35.	Wyller-Killewich-Van Doren and Hazard, Engineers-Architects; May i
1969; Comprehensive Report for the Alaska State Housing Authority:
Water-Supply, Treatment and Distribution, Sewage-Collection and Treat-
ment, in the Greater Juneau Borough, Alaska.
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APPENDIX A
The following is a summary of discussions between
the consultant, James M. Montgomery, Consulting
Engineers, Inc., and various individuals concerned with
the project. It was sent for review and comment to the
individuals listed, and reflects the comments returned.
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APPENDIX A
SUMMARY" OF FIELD DISCUSSIONS
SALMON CREEK INTERCEPTOR EIS
Field Review with John Trube, Juneau Engineering Department, 6/16/75
Viewed project area from Vanderbilt Hill to Norway Point, and portions
of Lemon Creek area and Juneau waste treatment plant (under construction).
Viewed one raw sewage outfall within project area discharging into pro-
posed (and BOR-approved) recreation lake (a total of six such outfalls exist).
Discussed LID approach and method of assessment.
General Meeting, 6/16/75
In attendance: Ron Eckhardt, Juneau City and Borough Engineer; Ron
Hansen, Alaska Department of Environmental Conservation; John Trube,
Engineer, City and Borough of Juneau Engineering Department; Glenn Johns,
Federal Highway Administration; Richard Shadduck, City and Borough of
Juneau Engineering Department; Richard Marriott, Alaska Fish and Game
Department; Randy Wooley, City and Borough of Juneau Engineering
Department.
The Twin Lakes recreation project increased the interest in a sewer
interceptor for the area.
The 1971 regional collection and treatment plan (stated to be EPA-approved
as an "interim" plan) included two plants (Mendenhall area and south of Juneau)
and the Salmon Creek interceptor (northernmost extension of Juneau plant
interceptor).
Original Twin Lakes plan included a self-propagating fishery in one lake
and recreation in the other, but eventually ended up with both as recreation
(and connected) with a put and take fishery.
A 1972 contract was let for the portions of the interceptor under the new
highway.
Five project financing approaches were considered, including square foot
basis which was eventually chosen as the most equitable. The period of pub-
lic challenge to the method of assessment has ceased, since such challenge
must be during the first hearing. Not all developable land considered in the
assessment (basically a 180-foot strip on both sides of the old highway).
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Due to the high cost, the City of Juneau reduced the assessment from
$. 11 /sq. ft. to $. 06/sq. ft. through direct contributions (also retained the
option of increasing the assessments by 20% due to contingencies).
Joseph Henri (a local lawyer/developer) is proposing to run a 4-inch line
from a treatment plant at his proposed 126-unit trailer court to the hospital
outfall, rather than the alternative of constructing a portion of the interceptor
(since this would be a nonreimbursable cost for the EPA and consequently
the Borough).
The regional collection and treatment plan was approved by the Borough,
the state and the EPA.
It has been suggested that the hospital add a nursing home, an alcoholic
rehabilitation center and a children's school for the handicapped. The official
status of these "proposals" is not known.
Potable water contamination has not been reported, probably due to most
if not all of the wells being uphill from the waste disposal areas.
Depth of the proposed Twin Lakes averages 5 to 6 feet, with a maximum
of from 25 to 30 feet.
A developable plateau sits above some portions of the project area in the
timber (much of it excluded from the LID).
EPA funding possible only to Salmon Creek (doesn't include the Twin
Lakes portion).
Gastineau Channel not considered by the Fish and Game Department to be
a major fishery area. ADFG was originally pressured (still some pressure)
by the "Territorial Sportsmen" to utilize the Twin Lakes area as a coho
rearing site (not deemed feasible). Present plans are to stock with rainbow
or possibly landlocked coho on a put and take basis.
John Trube mentioned that one possible Indian-related site may exist in
the vicinity of the existing Children's Home. No one at the meeting had seen
this documented, but John had heard such rumors. The A-J Flume was also
mentioned as a potential historical area.
Primary citizens mentioned are: Vivian Lovaas, George Danner and Tom
Accord.
Other impact statements in the area include the Juneau-Douglas Bridge,
the airport (assessment only), the ski area on Douglas Island, the Tesoro
tank farm and the pulp mill.
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Some concern has been expressed concerning sedimentation of the recreation
lake.
Photographic Flight, 6/16/75
Ed Cryer and Tom Davis chartered a half-hour flight along the project
for photographic and field reconnaissance purposes.
Discussions with Clay Allred, Juneau Planning Department, 6/16/75
Two visits with Allred were made: one on the afternoon of June 16 and
one on the morning of June 17, to finalize discussions and pick up materials.
Allred noted that he thought the zone had been changed to accommodate
Henri's trailer court development.
Ordinances including sections on mobile homes, zoning, subdivision,
etc., were obtained.
Three maps that are not reproducible show the planning (two maps) and
zoning (one map) for the project area. These were photographed on Ekta-
chrome since no copies are available.
Allred felt that the capital move would occur, but that the move would be
8 to 10 years away.
Discussions with Kit Ballantine, Juneau Sanitarian, 6/17/75
(Also Alaska Department of Health and Social Services Employee)
Furnished with a copy of the 1969 inventory of septic and raw sewage out-
falls in the Twin Lakes area (total of 14). Color photographs of these outfalls
also examined.
No reported water problems in the area. Essentially, all water supplies
are individual systems.
Ballantine has recommended a field study to Hartenberger (Borough Plan-
ning Department), but a reply has not yet been received. Concern expressed
about an individual treatment plant for the trailer court, primarily due to
the operation and maintenance difficulties foreseen.
Definite feeling that a public health problem exists in the Twin Lakes area,
but without documentation.
A-3
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Discussions with Richard Freer, Deputy Commissioner,
Alaska Department of Administration, 6/17/75
Primary point discussed with Freer concerned the probability of even-
tual capital move. We were furnished copies of the initiative and the
summary Boeing Report.
Freer believes the capital move will occur, but not as rapidly as initia-
tive provides (according to initiative, move to be completed by 1980).
A Capital Site Selection Committee, as specified in the initiative, has
been appointed by the Governor, and will within 18 months select three alter-
native sites. The voters will then vote on their choice among these three
sites. A third vote will probably occur concerning the method of financing.
The Alaska Legislature passed a bill insuring up to 95% of the assessed
value as of January 1, 1976, to Juneau homeowners selling property after
that time. Also, bills were passed guaranteeing the bonding capacity of
Juneau (due to capital move) and a subsidy for low or fixed income people
assessed for a municipal project.
Approximately $700, 000 has gone to the Site Selection Committee in 1975
(Anchorage A&E firm selected by Committee).
Discussions with Ray Estes, A95 Coordinator for Governor's Office, 6/17/75
Provided with names of various reports.
A95 review of the regional plan now in state archives and difficult if not
impossible to obtain; however, Estes felt that this had been an inadequate
review as per present procedures, and a new A95 review should occur for
the interceptor line itself.
Field Review, 6/17/75
Ed Cryer and Tom Davis walked over much of the project area, includ-
ing the largest of the Twin Lakes, and photographed various aspects of the
project. Of particular note was the observance and photographing of two raw
sewage outfalls going into the larger of the Twin Lakes areas and the location
of four others. It was noted that much of the surface water now in the unfilled
Twin Lakes has a pronounced algae bloom, and the locations of the sewage
outfalls are made prominent by profuse growths of high grass. One outfall
was particularly prominent due to a collection of pink and blue toilet paper
at the end o£ the pipe.
A-4
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Discussions with Ron Bolton, Juneau Zoning Administrator, 6/18/75
The project area is zoned for commercial, industrial and residential
development.
A snow slide area exists near Norway Point and several other areas
within the LID.
The interceptor would facilitate development of the strip between Vander-
bilt Hill and Norway Point.
The primary constraint to the extent of development would be the steep
topography immediately behind the area zoned for development.
The soils in the area are subject to severe erosion when exposed to
development, and are "marginal to poor" for septic tanks.
Planning and Zoning Board approvals seldom if ever include special pro-
visions outside of the specific constraints within the ordinance. For example,
it would be very unusual for a 50-foot buffer strip along Salmon Creek or the
intertidal area, which might be desirable from a fishery standpoint, to be
included in the local approval. It is assumed that this is a state function, and
if necessary will be imposed either by the Fish and Game Department or the
Department of Environmental Conservation.
Correspondence and a copy of the comprehensive plan policies and other
relevant information were provided.
Discussions with Deena Henkins, Regional Supervisor,
Alaska Department of Environmental Conservation, 6/18/75
Provided with a map showing six homes which discharge raw sewage into
the proposed Twin Lakes area. Septic outfalls may also be a problem if they
still exist and were not extended under the highway. (This has been checked
on with the Highway Department, and they do still exist at Twin Lakes.)
The Department has a 100-foot setback requirement for septic tanks
along a water body. Septic tank/drainfields very difficult to fit due to slope
and area limitations. "To eliminate outfalls into Twin Lake, ADEC would
probably not enforce this setback for those existing homes which have out-
falls, provided the system is installed on the uphill side of the road. No
new systems would be allowed within 100' for new development. "
Maximum or saturation development as per the City/Borough Planning
and Zoning maps would be impossible with individual or septic systems due
to health and/or environmental problems.
A-5
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The Department's approval or disapproval of a wastewater system is
apparently quasi-formal. The first official notice by the applicant to the
Department generally occurs indirectly when the applicant applies for a
building permit from the Borough. One aspect of getting such a permit is
getting an approval from the Borough Sanitarian, who in this case works for
both the Borough and the Department of Health and Social Services. The
Sanitarian reviews such applications, sometimes in cooperation with the
Department of Health and Social Services (which also has important authority
related to health) and generally directly corresponds and approves or dis-
approves by letter to the applicant. The Department must review all public
wastewater facility plans, but is not normally contacted regarding individual
disposal systems.
The Department could disapprove a project {e. g., the proposed trailer
court) on the basis of general environmental effects (e. g. , eutrophication),
as well as direct health effects (but this might be difficult).
The Anchorage office of the Department is now requiring two alternate
leachfield sites in addition to the primary site. This would preclude develop-
ment in most of the LID on individual systems if applied by ADEC.
Mrs. Henkins was not aware of whether or not the Highway Department
actually extended the septic tank outfalls under the highway and into the
channel.
It was not felt that even if the maximum point allowance was given to the
project, due to a health hazard, that the project could significantly change its
federal funding priority position. State funds are not constrained by this
priority system.
The Alaska Department of Health and Social Services could post the Twin
Lakes against swimming, and seems to be definitely inclined to do so if the
raw sewage is not intercepted and removed.
A definite health hazard was felt to exist in the Twin Lakes area.
The Highway Department is proposing to fill the lake to test the adequacy
of the highway fill.
Discussions with Jim Nelson, Alaska Department of Highways, 6/18/75
Mr. Nelson stated that the City initiated the development of the Twin
Lakes projects; the Highway Department originally envisioned tidal struc-
tures in the area. The Twin Lakes project did prove cheaper. He supplied
a copy of the New Channel Crossing EIS and a set of as-builts showing the
location of those outfalls (from operating and approved septic systems) that
A-6
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were extended by the Department when the new expressway was installed.
Discussions with Rod Pegeus, Alaska Attorney General's Office, 6/18/75
Mr. Pegeus felt that the capital move would occur, but not as early as
provided for in the initiative.
It was also mentioned that the new highway proceeded without an environ-
mental impact statement or a Corps of Engineers permit. (See Corps of
Engineers letter dated 18 November 1 975. )
Discussions with Gary Balding, U.S. Geological Survey, 6/18/75
Three reports were picked up from Mr. Balding concerning the hydrology
of the Juneau area (including Salmon Creek). Mr. Balding felt that this was
essentially all of the relevant hydrologic information for the area.
Discussions with U.S. Army Corps of Engineers, 6/18/75
Inquiry was made concerning the availability of the Tesoro Petroleum
Products Transfer Facility and Access Channel Environmental Impact State-
ment. This EIS could not be found in the Juneau office (later provided by Mr.
Rick Reed, Alaska Fish and Game Department).
Discussions with Mr. Rick Reed, Habitat Supervisor,
Alaska Fish and Game Department, 6/19/75
Probably no significant impact on wildlife, since the highway and residen-
tial-commercial development has already severely impacted the area. Hunting
is closed a half-mile from the highway. Referred to Dave Johnson, Area
Game Biologist. Primary species would probably be deer, black bear, vari-
ous smaller mammals, grouse, and some waterfowl.
Outlet of Salmon Creek was one of the better waterfowl and shorebird areas,
since it does not freeze as much as other areas.
Twin Lakes might draw waterfowl, but it is doubtful. In any case, minor
species of little value to ADFG would be involved.
Salmon Creek is one of the better road system streams around Juneau,
and includes Dolly Varden and coho, chum and pink salmon (coho probably
small populations; chum 200-250; pink 500-2000). Salmon Creek is closed
during spawning, from July through September. Total anadramous fishery
A-7
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length is approximately . 20 mile (stopped by falls).
The ADFG commented on the trailer park (comments obtained). Primarily
concerned with sedimentation and consequently a 50-foot buffer strip has been
proposed, which Henri said he could incorporate, possibly also with an inter-
ception-sedimentation ditch filled with gravel.
ADFG has no direct authority to impose regulations such as buffer strips
in anticipation of a problem, but can suggest to the developer and then take
action if sedimentation occurs (for this reason most developers comply). This
type of provision is not usually imposed in local planning and zoning approvals,
even though such is often recommended by the ADFG.
Hospital wells were drilled near Salmon Creek.
Salmon Creek freezes up less than other creeks due to warm water releases
from the lower reservoir levels.
Primary forest type is spruce-hemlock rain forests, with alder where
disturbances have occurred.
The Gastineau Channel fishery is very limited north of the Juneau-Douglas
Bridge, with most of the fishing occurring south of that bridge (which is out
of the project area). The channel is, however, very important as a migration
route for salmon, trout and char.
Some sedimentation would probably occur with full residential development,
as allowed by City/Borough zoning.
The Corps of Engineers flood plain report on Salmon Creek was mentioned.
The intermediate regional flood would result in a depth of water of 23 feet
just upstream from the highway bridge, with a depth of 25 feet 600 feet up-
stream from the bridge. The Corps stated that a 50-foot wide floodway would
be adequate. With dam failure (no probability determined) a 12-foot wall of
water over the bridge for three minutes could be anticipated.
Reed stated that the Department would probably support the sewer inter-
ceptor as desirable for getting rid of the raw sewage going into the Twin Lakes
area.
May and June (nonspawning season) would be the best construction period
from the standpoint of the Fish and Game Department.
Discussions with Mr. Ron Davis, Project Area Resident, 6/19/75
Most people in the LID were thought to support the interceptor. Problem
A-8
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is with method of assessment that hits some fixed or low income people
relatively hard.
Discussions with Dave Johnson, Regional Biologist,
Alaska Fish and Game Department, 6/20/75
Had a very brief discussion. He felt that the proposal to provide waste-
water services to the Salmon Creek area could only have beneficial impacts.
No hard copy reports exist as to the habitat or wildlife (except Salmon Creek)
within the area. Since the area is closed to hunting, and for all practical
matters fishing, the Department has little active interest in the area (except
again for Salmon Creek).
Discussions with Mr. George Danner, Area Resident
With Major Property Holdings, 6/20/75
Mr. Danner's only objection to the project at this point is the high cost to
the property owners and the method of assessment. He owns deep lots on both
sides of the old highway, and is being doubly assessed even though he feels that
power line accesses (three), a 50-foot setback and steep slopes preclude addi-
tional development. His original assessment was over $12,000; this has been
reduced by a factor of 6/11 with a 20% possible contingency for inflation and
government land within the LID.
Mr. Danner feels that the LID was rushed through without proper involve-
ment of the residents, and that the majority of the people living within the
area are against the project (49 to 51% objected at a second hearing; 23% filed
objections with the EPA). He is on a septic tank and has had his outfall ex-
tended by the Highway Department. Related that much of the land on the
upper side of the old highway is undevelopable in his area (near Norway Point)
because vegetation is needed as an avalanche buffer.
A-9
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APPENDIX B
Alaska Law
Title 18. Environmental Conservation
Chapter 70
Title 18. Environmental Conservation
Chapter 72
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Register If, October llfl
TtTLE II. ENVIRONMENTAL CONSERVATION	II AAC 70.011
CHAPTER TO. WATER QUALITY STANDARDS IIAAC 70.021
SECTION
Oil.	Wiur Quality Slindirdi
020.	Establishment of Water I)m Classification! and Criteria
020.	Procedure tor Determining Water Quality Criteria
040.	Natural Conditions
Oil-	Classification of Slate Watera
4; am I/2I/T1. Regis! or 9«;
aa 10/22/T1, Register 44).
AUTHORITY: AS 41.03.010
AS 44.02.020 (10) (A)
AS 40.01.tnf
AS 4l.tt.0M
10 AAC T0.no. ESTABLISHMENT OF WATER USE CLASSIFICATIONS
AND CRITERIA, (a) There are established seven water uae classifications
whfeh are designated by the letters "A* through "G", inclusive. The water
uae claasiftcations are aa follows:
(1) Class A. Water supply, drinking, culinary, and bod pro-
ceasing without tha need for treatment other than simple disinfection and
simple removal of naturally present impurities.
/
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Register 47. October 1171
ENVIRONMENTAL CONSERVATION	II AAC 70.020
(2) Clsss B. Watar supply, drinking, culinary, and food pro-
cessing with the need for treatment equal to coagulation, sedimentation,
filtration, disinfection, and any other treatment processes necessary to
remove naturally present impurities.
(S) Class C. Water contact recreation.
(4)	Class D. Growth and propagation of fish and other aquatic
life, including waterfowl and furbearers.
(5)	Class E. Shellfish growth and propagation, including
natural and commercial growing areas.
(6)	Class F. Agricultural water supply, including irrigstion.
stock watering, and truck farming.
(T) Class C. Industrial water supply (other than food processing).
(b) The water quality criteria applicable to each water use clsssi-
ficstion are aa foUowa.
2.
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Regietar 41. Odctxr ltT)
ENVIRONMENTAL CONSERVATION	It AAC 70.02*
Notes:
1. OrganlaM of Dm colifona group ahal) be Mtninid by Moat
Probable Number or equivalent membrane Hilar technique.
1. Wherever cited in lhaaa atandarda. th« National Shellfish Sanita-
tion Program. Manual of Operations ¦ Part 1^. means Sanitation
of Sheilneh Growing Areaa. IMS revision,~C.S. Department
of Haalth . Education and Welfare. Public Health Service Publication
No. S3. Part 1. obtainable from Uta Superintendent of Documents,
U.S. Covernroant Printing Office. Waahington. 20402
(Priea 45 canta). or in any regional office of the Department
of Environmental Conservation. and whicia ia on file in the office
of the lieutenant governor.
1. Induced variation of pH conditiona naturally outaide thia range
may not exceed Q.t pH unit and the pK Chang* ahal] be only
in the direction of Ihie range. pH conditions naturally within
thia range ahall be maintained within 0.S pH unit of the natural
PH-
4.	Wherever cited in theae atandarda. USPHS Drinking Water Stan-
dards mean the Public Health Service Drinking Water Standarda.
1962 revision. U.S. Department of Health. Education and Walfara.
Public Health Sarvica Publication No. fS(. obtainable from the
Superintendent of Documenta. U.S. Government Printing Office.
Washington D. C. 10402 (Price 30 cents) or from any regional
office of the Department of Environmental Conaervation, and
which ia on file in the office of the lieutenant governor.
5.	Wherever cited in theae atandarda. National Bureau of Standarda
Handbook M means the handbook entitled "Maximum Term^aaible
Body Burdena and Maximum Permissible Concentrations of Radio-
nuclides in Air and Water for Occupational Exposure" .U.S.
Department of Commerce. National Bureau of Standarda Handbook
SI, June 5. 195*. obtainable from the Superintendent of DocujfttnUt
U.S. Government Printing Office. Washington. D. C. 20402. or
in any regional office of the Department of Environmental Conaer-
vation, and which ia on fUe in the office of J he lieutenant governor.
C. Wherever cited in these standards, Radiation Protection Guides moans
the guidelines recommended by the former Federal Radiation Council and
publiahed in the May H, 1H0 Federal Ragiater, and published in tha
September >6. ltd Federal Register, obtainable from any Regional Office
of the Department of Environmental Conservation end whUh era on file
in the office of tha lieutenant governor.
(c) The analytical procedures used ss methods of snalyaic to deter-
mine the quality of waters shall be in accordance with the 13th edition of
Standard Methods for the Examination of Water and Wastewater, publiahed
by the Weter Pollution Control Federation, the American Water Worka Aaeo-
ciation and the American Public Health Aaaociatlon. (publication titties:
American Public Health Aeaociatkm. 1740 Broadway, New York, New York
10011), or in accordance with other standarda mutually approved by the
s
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Register 47. October 1911
ENVIRONMENTAL CONSERVATION	II AAC 70.020
II AAC 70.050
department end the U.S. Environmental Protection Agency. On effect before
7/2I/S9; an 5/24/70, Register 34; an 1/21/71, Register Hi am 10/22/72,
Register 44; an 8/12/73. Register 47).
AUTHORITY: AS 4C.03.020 (10) (A)
AS 46.03.070
AS 46.03.010
II AAC 70.030. PROCEDURE FOR DETERMINING WATER QUALITY
CRITERIA. In determining the appropriate water quality criteria for any
waters or portion of waters, the department shall adhere to the following
procedure:
(1)	if waters have more than one classification. the moat stringent
water quelity criterion of all the classifications shall apply; and
(2)	if a tributary water either receives a sewage waste discharge
or Industrial waste discharge, or has s lower classification than the con-
fluence water, and the tributary water affects the quality of the confluence
water. the most stringent water quality criteria applicable to either the
tributary water or the confluence water shall spply to the tributsry water;
and
(3)	waste discharge permits will define a mixing zone outside
of which violations of the criteria will be determined. The mixing tone
will be limited to a volume of the receiving water that will
(A) not interfere with biological communities or populations
of important apecies to a degree which is damaging to the ecosystem,
and
(fi) not diminish other beneficial uses disproportionately.
In effect before 7/21/59. am S/24/70. Register 34; am 1/21/71.
Register 39; am 10/22/72. Register 44; am 8/12/73; Register 47).
AUTHORITY: AS 46.03.020 (10) (A)
AS 46.03 070
AS 46.03.010
II AAC 70.040. NATURAL CONDITIONS. Waters may have natural
characteristic* which would place them outside the criteria established by
thia chapter. The criteria established in this chapter apply to man-made
alterations to the waters of the state. (In effect before 7/21/51; an
S/24/70. Register 34; am »/ll/71. Register 31; am 10/22/72. Register 44).
AUTHORITY: AS 46.03.020 (10 (A)
AS 46.03.070
AS 46.03.030
18 AAC 70.050. CLASSIFICATION OF STATE WATERS, (a) Waters of
the stata that have been classified after public hearing, and their designated
classes according to the Watar Quality Standards are aa follows:
(1) Ship Creek - near Anchorage, Alaska - from the Ship Creek
diversion structure at river mile 11.5 to the confluence with the Knik Arm
of Cook Inlet - Classes B. C. D. 6 G.
U
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Rigliur 41. October »TS
ENVIROMMEICTAI, CONSERVATION	It AAC 7D.0i»
II AAC TO.OH
(I) Chena River - near Fairbanks, Atuki - from Oil confluence
of the Chena River and Chena Slouch to tha confluence of the Chena River
and Tanana Rivar - CIumi ClD.
(1) All other marine and estusrine waters - Claaaes C, D. E t G,
(4) Tha ground watara of tha data - Claacaa A, B, F, ifi,
(b) The other frttli waters of tha state arc generally in tbakr ori-
ginal and natural condition* and aa such arc considered suitable to aerve
all classifications established in sec. 20 of thia chapter and arc ao classi-
fied. until reclassified. (In effect before 7/2B/S9; am 5/34/70, Regis!ar
34; am 1/31/71, Regiatar 19; am 1D/2I/T1. Register 44; am V1V72.
bfiM«r<7).
AUTHORITY: AS 46.U.020 (10) (A)
AS 46.03.070
AS I6.0J.0V0
It AAC 10.060. PERMITS. Repealed 10/22/72. (In effael before
7/lf/St; am S/21/70, Register 34; am 10/22/72. Regiatar «}.
It AAC 70.070. TABLE - WATER QUALITY CRITERIA FOR WATERS OF
THE STATE OF ALASKA. Conaolidatad into aac. 20 .
AUTHORITY: AS 46.01.020 (10) (A)
AS 46.01.070
AS 46.01.010
AS 4t.Bl.T10
If AAC 70.011. CERTIFICATE OF REASONABLE ASSURANCE. The
department may issue certification that there is a reasonable assurance,
•a determined by the department, that a proposed activity will comply
with the requirements of section 401 of the Federal Water Pollution Control
Act Amendments of 1072, 16 Stat. 116. (Eff. 13/16/70, Register It; am
10/22/72, Register 44; am 'A2/", Register 47).
AUTHORITY: AS 46.03.020 (1)
AS 46.03.020 (10) (A)
7
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Register 47. October 1971
ENVIRONMENTAL CONSERVATION	II AAC 70.01!
II AAC 10.OH
II AAC 70.082. PUBLIC NOTICE OF APPLICATION, (a) When
certification pursuant to «ec. II of thu chapter hit been requested, the
department shall cause to be published ¦ public notice a! the application.
The public notice shall invite interested parties to submit to the department
comments regarding the proposed certification. Such comments shall
be received by the department until 30 days after the publication of the
public notice provided for in this section. The public notice may be
issued jointly with the federal permitting agency.
(b)	The public notice of application shall contain the name and
address of the applicant, the activity sought to be certified as in compliance
with the water quality standards, the location of the affected waters, and
the location and type of discharge.
(c)	The public notice of application shall be published at least
once in a newspaper having general circulation within the borough in
which the proposed activity will take place; however, if the proposed
activity will take place in the unorganized borough, or if there is no newe-
Daper of general circulation within the borough, then the newspaper
shall be one of general circulation within the judicial district in which
the proposed activity will take place. (Eff. 12/18/70. Register 36; am
10/22/72, Register 44; am 8/12/73. Register 47).
AUTHORITY; AS 46.03.020 (9)
AS 46.01.020 (10) (A)
18 AAC 70.083. PUBLIC HEARING. In addition to the notice of
application provision of this chapter, the department may hold public
hearings on certtttcttian applications (Eff. 12/16/70, Register 3t. am
10/22/72. Register 44).
AUTHORITY; AS 46.03.020 (9)
AS 46.03.020 (10) (A)
18 AAC 70.084. NOTICE OF PUBLIC HEARING, (a) If a public
hearing is to be held, the department shall cause to be published a nwiee
t>[ public hearing in the manner set forth in sac. 82 (c) of this chapter.
The notice shall contain the time and place of the public hearing, a summary
of the certification application and U1 other information specified in sec. 82
of this chapter. The department may combine the notice of application
provided for in sec. <2 of this chapter with the notice of public hearing
provided for in this section.
(b) If a public hearing on the application for certification is to be
held, it shell be held no aooner than 30 days after publication of the notice
of public hearing. At the hearing, the department may receive comments
from the public and other individuals, entities, or governmental agencies
involved, together with comments from the applicant. Such comments
may be filed with the department in writing at or before the time of the
hearing, and reasonable oral comments shall be permitted.
9
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Register 47. October 1873
ENVIRONMENTAL CONSERVATIONS It AAC 70.014
II AAC 70.100
(c) Nothing in thU chapter «h*U prevent the consideration of more
than one application at any public hearing when proper public notice has
been given. (EtT. 12/14/70, Register 36. an 10/22/71, Register 44).
AUTHORITY: AS 46.OS.020 (9)
AS 4S.03.020 (10) (A)
II AAC 70.MS. ACTION UPON APPLICATION. The department may
take action upon an application for certification any time after a 30 day
period has elapsed from the date of publication of the notice provided for
in sec. (2 of this chapter. However, if a public hearing ii held as provided
in sec. 13 of this chapter, the department may act upon the application
any time after the public hearing. (EtT. 12/16/70. Register 31; ajn
10/22/72. Register 44).
AUTHORITY: AS 46.03.020 (9)
AS 46.03.020 (10) (A)
II AAC 70.080. IMPLEMENTATION AND ENFORCEMENT PLAN. The
plan for implementing and enforcing sec. 10 of this chapter shall be baaed
upon achieving the minimum levels of treatment specified in that section at
the time o( construction for new discharges and as soon as possible but
not later than July 1977 for existing discharges, and the plan shall eonsitt
of the following elements:
(1)	waste discharge permits issued by the department and those
federal permits issued within the state and certified by the state pursuant
to sec. >1 of this chapter;
(2)	the Water Pollution Control Program Plan of the department;
and
(3)	plans developed by the department while implementing
the "continuing planning process" required by sec. 303 (e) of the Federal
Water Pollution Control Act Amendments of 1972, IS Stat. lit. (Ell. 1/21/71,
Register 39; am I/1Z/73, Register 47).
AUTHORITY: AS 41.03.020 (10) (A)
AS 40.03.U0
AS 4S.03.070
II AAC 70.100. PENALTIES. A person who violates any provision of
this chapter Is punishable by the appropriate penalties contained in AS 46.03.7S0
and AS 4S.03.790. These penalties include the possibility of a punishment
by fine of not more than 125,000 or by imprisonment lor not more than one
year or both. (EtT. 10/21/71, Register 44; am S/12/73 • Register 47).
AUTHORITY: AS 46.03.020 (10) (A)
AS 46.03.710
AS 4S.03.7C0
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Register 47, October 197 J
ENVIRONMENTAL CONSERVATION	II AAC TO. 110
II AAC 70.110. DEFINITIONS. Unless the context Indicate* other-
wise. in this chapter
(1) "commissioner" meant the commissioner of the Department of
Environmental Conservation.
(J) "contact recreation" means any form of recreation involving
deliberate or accidental contact with water, including but not limited to
swimming, water skiing, fishing, and commercial and recreational boating.
(3)	"department" means the Department of Environmental Conser-
vation.
(4)	"dredge spoil and Till" means unpolluted solid material
including but not limited to sand. silt, clay and rock which may be placed
in the waters of the state, provided that it it placed in the water in •
manner such that it does not interfere with any designated water use.
(5)	"ground water" means water in the tone of saturation, which
is the zone below the water table in which all interstices are filled with
water.
(6)	"primary treatment" means the method of removal of settleable,
suspended and floatable solids from water by the application of mechanical
forces or gravitational forces, or both and may include processes such as
sedimentation, flotation, screening. centrifugal action, vacuum filtration,
dissolved air Dotation, and others designated to remove settleable, suspended
and floatable solids.
(7)	"secondary treatment" means that method of removal of
dissolved and colloidal materials that in their unaltered state, as found
in water, are not amenable to separation through the application of mechani-
cal forces or gravitational forces or both. Secondary treatment may include
processes such as bio-absorption, biological oxidation, wet combustion,
other chemical reactions, and adsorption on surface-active media, change
of phase, or other processes that result in the removal of colloidal and
dissolved solids front waters.
(I) "sheen" means an iridescent appearance on the surface of
the water.
(•) "sludge" means a combination of solids and liquids including
but not limited to an aggregate of oil or oil and matter of any other kind
having a combined specific gravity equivalent to or greater than that of
water. Sludge do«s not mean dredge spoil and fill.
iO
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Register IT. October ltTI
ENVIRONMENTAL CONSERVATION	1* AAC TO.110
(10) "water*" means lmV*>. bay a, sound*. ponds. impounding
reservoirs. springs. walla. riv»r». atreama, creek*. estuaries, marahes.
inlet a, straita, psssagea, canals, the Pacific Ocean, Gulf of Alaaka.
Bering Sea and Arctic Ocean, in I he territorial limits of th« atata. and
all other bodies fit surface or underground water, natural or artificial,
publfc or private • inland or coastal, freah or salt, which arc wholly .or
partially In or bordering upon the *tata or under tit* jurisdiction of the
Male, tain	Kegiaier Mi •» Wit HI, Register 3k; «a
10/22/72, Register 44; am S/12/75. Register 47).
AUTHORITY: AS 41.01.020 (10) (A)
AS 40.03.070
AS 40.03.0*0
M
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Register 4". October 1971
TITLt 18. ENVIRONMENTAL CONSERVATION II AAC 72.010
CHAPTER 12. WASTEWATER DISPOSAL
SECTION
010.
020.
030.
040.
0S0.
060.
070.
M0.
0S0.
100.
Surface Wastewater Discharge Prohibited
Subsurface Wastewater Discharge Prohibited
Pretreatment
Sludge Dispoaal
Connection* Prohibited to Overloaded Facilities
Plan Review
Operational Reports
Emergency Notification
Penalties
Definitions
18 AAC 72.010. SURFACE WASTEWATER DISCHARGE PROHIBITED,
(a) No person may discharge. cause the discbarge, permit or allow the dis-
charge of sewage, industrial liquid waste, or wastewater to turface water* or the
surface of the land without the minimum required treatment prescribed in
It AAC 70.080. The department may require further treatment for discharge
or, where neceesary, prohibit Ch« discharge of treated wastewater to sensi-
tive receiving environments.
(b)	No person nay discharge, cause the discharge, permit or allow
the discharge of sewage, industrial liquid waste, wastewater, or other wast«
in any manner which result* in violation of the Water Quality Standards found
in ch. 7o of this title.
(c)	No person may deposit, cause the deposit, permit or allow the
deposit of garbage, refuse, solid wsste, excrement, or animal carcasses to
watera of the atate or to land nearby such waters so thst such matter or leachate
there from may enter the surface waters at the state.
(d)	No person may discharge, cause the discharge, permit or allow
the discharge of septic tank or package plant effluent to the surface of the land.
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Register 4T. Octobw ltTt
TITLE M. ENVIRONMENTAL CONSERVATION II AAC 72.010
II AAC 71.021
AS 41.AS.020 (10) (E)
AS 41.03.050
AS 44.01.070
AS 4C.03.710
AS 4C.O3.CO0 (a)
AS 46.03.110 (a)
II AAC 72.020. SUBSURFACE WASTEWATER DISCHARGE PROHIBITED,
(a) No person nay discharge sewage or Industrial liquid waate into Uia
ground by wall, crevice, ainkhole, gravel pit or depression, or any othar
opening, whether natural or man-made, without written approval Iron the
department. except
(1)	septic tank or package plant effluent through an appro-
priate aoll absorption system or equivalent, and;
(2)	material from or for production of petroleum products
reinjected or injected into the ground.
(b)	No parson may construct, inatall, or use a septic tank, package
plant, or aoll abaorpttan system without written approval from the depart-
ment If a community sewerage ay stem ia available within 200 feat.
(c)	No person may construct or Install a septic tank, package plant,
or soil absorption system in such a manner that a water supply la in danger
of becoming contaminated. Unless the dapartmant requirea further aepara-
tian becauee of poor soil conditions. the minimum separation
(1)	betwaen a septic tank, package plant, or aoil absorption
system and community water supply well shall b« 200 feet, measured hori-
son tally, regardless at property Unas or ownership, and;
(2)	between a septic tank, package plant, or soil absorption
system and private water supply well shall be 100 feat. measured horizon-
tally , regardless of property Unas or ownerahip.
(d)	No peraon may construct or inatall a septic tank and aoil abaorp-
tion system or privy within 100 feat, measured horizontally, of any natural
or man-made lake, river. stream. alough. or coaatal water of the state.
The department may require further aeparations if necessary to protect
aenaitivc receiving environmenta.
(a) No person may construct, place. or inatall a septic tank or eawer
line in ths ground, either directly above, directly below, or within ten
teat, measured horizontally, of a water supply pipe. If aewer lines snd
water supply pipes must cross, the sawer lines shall be constructed of cast
Iron, ductile iron, or equivalent with watertight joints for ten feel on both
sides of the wster supply pipes.
(ft No person may construct or install a septic tank for an individual
year-round residential dwelling unit with a liquid capaeity of leas than
1,000 gallons.
(g) No parson may oonstruct or install a sewer line with a diameter
of less than eight inches without prior written approval from the depart in ent.
13
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Register 41. October IN)
TITLE IB. ENVIRONMENTAL CONSERVATION II AAC 7Z.C20
It AAC 72.040
(h)	No person may construct, Install, maintain, or opcrau • septic
tank or toll absorption system In permanently frosen (round.
(i)	No person may construct or Install a ceaapool.
0) No peraon may construct, InaUll, permit, allow, or uae a septic
tank or package plant with soil absorption ayatem in soils not suitable for
effective absorption.
(1) The vertical separation from the lowest part ot the discharge
pipe for the aoil absorption system to the water tablt, as measured during
the Hsaon of the year with maximum water table elevation, shall be (our
feel or greater.
(1) The vertical separation between the lowest part of the
discharge pipe for the sail absorption system and the surrounding bedrock
or ether impermeable atrats thai! be six feet or greater.
(3)	The dimensions of the sol] absorption lyetam shall be aised
based upon characteristics of that soil in which il is to be used and according
to techniques approved by the department.
(4)	The department may require that soil tests and borings
be submitted and certified by a disinterested registered professional engineer
or geologist.

AS 46.03.100 (•)
AS 46.03.710
IB AAC 72.040. SLUDGE DISPOSAL, (a) No parson may deposit,
cauae the deposit, permit or allow the depoeit of sludge trora septic tasks,
holding tanks, ceispqpls, privies, sewage tree an em works, water treatment
works, industrial or commercial facilities, or sludges from other wastee to
the waters or land without a waste disposal permit.
(b) The department may require that sewerage system* or treatment
worke be designed or opersted to sccept and treat sludges.
(Eft. 8/10/73, Rag. 47)
14
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Register 47, October 1071
TITLE II. ENVIRONMENTAL CONSERVATION IS AAC 72.040
U AAC 72.0(0
AUTHORITY:	AS 4C.0S.020 (10)(A)
AS 44.OS.020 (10XD)
AS 46.OS. 100 (a)
AS 46.03.710
IS AAC 72.050. CONNECTIONS PROHIBITED TO OVERLOADED FACIL-
TIES. No person may connect to or permit any connection or additional
discharge to a aewerage ayatem or treatment work* which the department
haa stated in writing are overloaded or would be inadequate to accept and
treat the additional load.
an. 1/10/79, Reg. 47)
AUTHORITY:	AS 46.03.020 (10)(A)
AS 46.03.020 (10) (D)
AS 46.03.050
AS 46.03.710
IS AAC 72.060. PLAN REVIEW, (a) No person may construct, alter,
or modify a aewerage ayatem or treatment works or any part thereof until
detailed engineering report*, plana, and apeclfieationa are submitted to the
department and approved by the department in writing. The department
may waive thie requirement for aewage treatment and diapoaal on individual
residential or recreational lota.
(b)	The engineering reports, plana, and specification a hall be
prepared, signed, and sealed by a diaintereatad professional civil engineer
registered in the State of Alaaka.
(c)	The department may require that the designa for sewerage systems
and treatment works in remote area* have a history of successful operation
tn comparable environmental aituations. Sewerage systems or treatment
worka also must be deeigned to successfully operate under the oonditiona
of seaeonal Croat or perennial froat encountered in the areea where the
construction is proposed.
(d)	if on-site water supply or eewage disposal ia propoeed for
public or private property subdivision or development. the required sub-
mission of plana for eewage disposal and treatment shall contain but not
be limited to the following information:
(1)	location of representative test sites for water sources within
the proposed subdivision or development and, if well* ere propoeed, the
yield and drawdown after two hour a of pumping at rated capacity,
(2)	representative chemical and bacteriological testing of
water sources to assure that drinking wster quality standarda are satisfied:
(3)	potential locetions of any future community water or sewer-
ege systems and an approximate timetable for their development;
(4)	representative soil testing, logs, and borings in the area
during the wet and dry sassons to insure that so Lie are suitable for on-site
sewsge disposal and to determine the eree required for soil absorpticn ay stems:
IS~
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Register 47. October >973
TITLE 1(. ENVIRONMENTAL CONSERVATION IS AAC 72.060
11 AAC 72.0(0
(5)	location of existing water sources. on-site disposal systems,
sewerage systems. treatment works, and bodies of water within 600 feet
of the proposed subdivision or development;
(6)	a typical lot diagram showing the location of on-site water
sources and sewage disposal systems In relationship to water sources a no
sewage dispoaal systems on adjacent lots, including showing the area of
influence of aewage disposal systems, including both initial and replacement
¦oil abaorption «ysterna;
(7)	a statement concerning responsibility for operation and
maintenance of water supply or aewage disposal facilities la the proposed
subdivision or development.
(e) The department may adopt guidelines for design by wt-jch engi-
neering reports, plans, and specifications are to be approved.
(Eff. 8/10/73. Reg. 47 <
AUTHORITY:	AS 46.03.0t0
A£ 46.03.720
lb AAC 71.070. OPERATIONAL REPORTS The department may
require that person* who own or operate a wastewater treatment works
submit routine operational reporta on forma supplied by the department
(Eff. * '10/73> Reg. 47)
ai thoritv	as 4i.oi.-c:J >; The written report shall contain but net be United to
(!) times and dates of the event:
(2) a detailed description of the ewent. including quantities
of sewage involved;
lb
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Register 47. October III)
TITLE 11. ENVIRONMENTAL CONSERVATION II AAC 72.CIO
II AAC 72.100
(3)	detail* of any damage to rocetring waters;
(4)	action* taken to correct the causes of the event.
(Eff. 1/10/73. Reg. 47)
AUTHORITY:	AS 46.03.020 (10)(A)
AS 46.03.020 (10) (D)
AS 46.03.710
IS AAC 72.090. PENALTIES. A per*on who violate* any previa ion
of this chapter i* punishable by the appropriate penal tie* contained in
AS 46.OS.760 (a) and AS 46.03.790. The** pensltles include th* possibility
of* maximum punishment by flne of not more than $25,000 or by imprfson-
ment for not more than one year or both.
(Eff. 8/10/73. Reg. 47)
AUTHORITY:	AS 46.03.760 (a)
AS 46.03.790
18 AAC 72.100- DEFINITIONS. Unless I he canter) indicates otherwise,
in thia chapter
<1> "cesspool" means a subeurface pit which receive* untreated
sewage;
(23 "commieiiorer" meana th* commissioner of environmental
conservation;
(3)	"community sewerage system" mean* any system, whether
publicly or privately owned, serving two or more individual dwellinge
or buaineas establishment*, for the collection and disposal of sewage or
indurtrial liquid waste, to a point of treatment works;
(4)	"community water supply system" means a source of water
and a distribution system, including treatment work*, whether publicly
or privately owned, serving the public or two or more individual dwelling unite:
(5)	"department" meana the Alaaka Department of Environmental
Conservation:
(6)	"equalized" meana the dampening of daily Quctuationa
of Bow of sewage, industrial liquid wsste. or other wsstewster so as to
distribute surges over a period of time.
(7)	"holding tank" meana a vesael (or the temporary itoregt
of aewage or excrement. such as found on boats, mobile homes, and caapera;
(8)	"laachite" meana water that ha* percolated through solid
waste and contain* diaaolved or suspended portions from th* solid waste;
(9)	"other wsstss" meana garbage, refuse, dscsyed wood,
sawdust, shsving*, bark, trimmings from logging operations, sand, lime
cinders, sshes. offal, oil, greaae, tar. dyestuffs. acids, chemicals, and
n
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Register 47 . October 1973
TITLE 18. ENVIRONMENTAL CONSERVATION 11 AAC 72.100
other tubitances not sewage or industrial waste which may ctuu or tend
to cause pollution of the water* of the state;
(10)	"package plant" mean* aerobic treatment system. holding
tank, or any other treatment works which receives or treats sewage;
(11)	"person" means tny individual, public or private corpora-
tion. political subdivision, government agency, municipality, industry,
copartnership, association, firm, trust, or any other entity whatsoever;
(12)	"privy" means a structure which receives excrement,
usually not walerborne;
(13)	"private water supply well" means a treU serving a single
dwelling unit or business;
(14)	"residential" means land divided into two or more units
or lots, for the purpose, whether immediate or future, of sale or of develop-
ment of housing including mobile home parks; or that land which has been
zoned for any residential uae by a governmental xbning agency;
(15)	"sensitive receiving environment" means fresh waters
supporting anidromout fisheries, fresh or saline waters used for drinking
or food processing. waters susceptible to cultural eutrophication. streams
with low or intermittent flow, tundra, or land which results in exposure
of wastewater to the public;
(16)	"septic tank" means a settling tank in which sol it! ana scum
materials may be removed from sewage.
(17)	"sewer" means a pipe or enclosed conduit which carries
sewage, industrial liquid waste, or other wastewater, but not including
that plumbing that conveys wastewster from the building to a community
sewerage systen; or point of on-site disposal;
(18)	"sewage" means that water-carried human or animal wastes
from residences, buildings, industrial establishments, or other places
together with ground wster infiltration ana surface wster as may be present;
the mixture of sewage with industrial liquid waste or other waste is "sewage"
(19)	"sewerage system' means pipelines or conduits, pumping
stations, and force mains, and all olner appurtenant constructions, devices,
and appliances used for conducting sewage, industrial liquid wastes, or
oiner waste to a point of ullimau disposal.
(20)	"sludge" means accumulate solids separated from sewage,
industrial liquid wastes, oil. tar. dyestuffs, acids, chemicals, and.other
similar substances;
>21) "soil absorption system" means » subsurface system,
including lateral perforated discharge pipes, gravel trenches, crushed rock,
that uses soil for the percolation of septic tana effluents, treated sewage, or
wastewater, such as a filtering field, leacnir.g fielc . seepage bed. or seepage
pit, but not including cesspools;
(22) "treatment works" means a plant, oevice. structure.
w
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Register 47. October 1973
TITLE 18. ENVIRONMENTAL CONSERVATION ISAAC 71.100
disposal outfall, lagoon, pumping station. Incinerator, area devoted to
sanitary Landfill*, or othsr worka installed for the purpose of treating,
neutralizing, stabilizing, or disposing of sewage, industrial liquid wast*,
or other waste. and sludges resulting therefrom;
(2J) "wastewater" means sewage, waterborne industrial waste.
laundry liquid efQuent, shower or sink water, or other wastes which are
waterborne.
(24) "waters" includes lakes, bays, sounds, ponds, impound-
ing reservoirs, spring*, creeks, estuaries, marshes, Inlets, straits, passages,
canals, the Pacific Ocean, Gulf of Alaska, Bering Sea. and Arctic Ocean.
In the territorial limits of the sute, and all other bodies of surface or under-
ground water, natural or artificial, public or private, inland or coastal,
fresh or salt. which are wholly or parttally in or bordering the state or under
the Jurisdiction of the state.
(Eff. 8/10/71. Reg. 47)
AUTHORITY:	AS 46.03.020 (10) (A)
AS 46.03.020 <10>CD)
AS 46.03.900

i:GPO 696-67 3
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