United States Region 10
Environmental Protection 1200 Sixth Avenue
Agency Seattle WA 98101
Water February 1979 EPA-10-QR-MULT-City of Portland-WWTW-79
Environmental Final
Impact Statement
Sewage Sludge
Disposal for the
City of Portland
Oregon
-------
FINAL ENVIRONMENTAL IMPACT STATEMENT
SEWAGE SLUDGE DISPOSAL
FOR THE
CITY OF PORTLAND, OREGON
Prepared by
U.S. Environmental Protection Agency
Region X
Seattle, WA 98101
With Technical Assistance from
Jones & Stokes Associates, Inc.
2321 P Street
Sacramento, CA 95816
In Association With
Culp, Wesner and Culp
and
Gruen Gruen & Associates
Official:
Regional Administrator
JAN 1919
Date
-------
PREFACE
On June 23, 1978 the Environmental Protection Agency (EPA) re-
leased a Draft Environmental Impact Statement (EIS) for a proposed
sewage sludge reuse program for the City of Portland, Oregon. Under
provisions contained in the Clean Water Act of 1978 (Public Law 92-217),
EPA is authorized to provide 75 percent of the funds necessary to plan,
design and implement such a program.
The Draft EIS, which evaluates the direct and indirect environ-
mental impacts of a number of feasible reuse alternatives was submitted
to Federal, State and local agencies as well as interested citizens for
a 45-day review period. In addition, EPA conducted a number of public
workshops and two public hearings to receive oral testimony on the
Draft EIS. Comment letters received during the review period and a
summary of comments received at the public hearings are included in
this document on pages 241-314.
As a result of our evaluation of each of the alternatives, EPA
elected to provide 75 percent grant funding for either of two cost
and environmentally equivalent alternatives—Alternative A-l (land
application of liquid sludge in eastern Oregon) or C-l (sludge drying
for production of a fertilizer aid). After a review of the City's
Facilities Plan, EPA's EIS, and other supporting documents the City
selected Alternative A-l as the long-term method of handling sludge
generated at the City's Columbia Boulevard wastewater treatment plant.
The salient factors considered by the City in selection of Alterna-
tive A-l are contained in "Exhibit A" of the City of Portland Ordi-
nance Number 146547 (Appendix I).
During the review period on the Draft EIS significant comments
were received from the Oregon Department of Fish and Wildlife resulting
in changes to Alternative A-l. Department comments stated that the
two proposed barge offloading sites located in Morrow County, Oregon
are extensively used by wildlife and use of these sites could cause
significant impact. Because of these impacts, EPA has ruled out the
use of Three- and Six-Mile Canyons for offloading facilities. A new
site located north of Castle, Oregon has been selected for the facili-
ties.
In addition, as a result of comments received from the Oregon
State Historic Preservation Office (SHPO) (page 254) and as a result
of an archaeological survey conducted by Oregon State University (OSU)
(Appendix E), EPA has determined that additional survey work will be
required. While the OSU study consisted of a survey of the offloading
facilities and proposed pipeline route, no survey has yet been conducted
-------
for the proposed disposal site. Therefore EPA will require an archae-
ological survey of the new identified offloading facility north of
Castle, Oregon and the proposed disposal site. This requirement will
be a part of the Step 2 (Design) grant offered to the City of Portland
and will read as follows:
The grantee shall be responsible for
conducting the activities necessary to
identify cultural properties in the primary
impact area of the project, to evaluate the
effect of the project on the cultural properties,
and to avoid or mitigate adverse effects
on the cultural properties. These activities
shall proceed as project design proceeds and
as approved by EPA and the State Historic
Preservation Officer. The grantee understands
that such activities may include project
relocation, archaeological salvage, or
other appropriate measures. These activities
shall be completed prior to the award of a
subsequent Step 3 grant for the project.
Another significant comment was received from the U.S. Department of
the Interior regarding the need for a groundwater monitoring program.
To insure that this potential impact is fully evaluated EPA will
also include as a condition to the City's Step 2 grant the requirement
of a groundwater survey of the disposal area. The condition will read
as follows:
The grantee shall be required to conduct a
groundwater survey of the sludge disposal area.
Upon completion, the survey will be submitted
to the Oregon Department of Environmental
Quality (DEQ) for review. The grantee understands
that DEQ may require the preparation of a detailed
groundwater monitoring program and contingency
plan for the disposal site. This plan, if required,
will be completed and approved by DEQ prior to the
award of Step 3 grant funds for the project.
EPA releases this Final EIS for a public review period of 30-days.
At the conclusion of the review period, EPA will consider all comments
received prior to a final determination regarding the award of construc-
tion grant funds to the City for implementation of Alternative A-l. We
would like to thank all of the agencies and interested citizens who have
taken the time to provide us with their comments.
ii
-------
TABLE OF CONTENTS
Page
SUMMARY 1
INTRODUCTION 9
Purpose and Objectives 9
Background of Past Events 10
Project Objectives and Environmental Goals
and Constraints 10
Important Issues and Considerations: Phase II 11
ENVIRONMENTAL SETTING 13
Project Planning Area 13
Topography 17
Climate 20
Geology 21
Soils 22
Surface Water Quantity/Quality 24
Groundwater Quantity/Quality 26
Flood Hazards 28
Aesthetic Values 31
Air Quality 32
Vegetation 32
Fisheries Resources 35
Wildlife Resources 36
Land Use 37
Present and Projected Populations 44
Laws, Rules, Policies and Institutional Practices 46
ALTERNATIVE SLUDGE HANDLING SYSTEMS 53
Introduction 53
Constraints 54
Existing Oregon Programs for Land Application
of Sewage Sludge 56
Description of Alternatives 57
ANALYSIS OF THE ENVIRONMENTAL IMPACTS OF THE ALTERNATIVES 103
Introduction 103
Short-Term Impacts 103
Long-Term Impacts - Sludge Processing 103
Long-Term Impacts - Sludge Conveyance 108
Long-Term Impacts - Sludge Disposal 126
Mitigation Measures 157
Overall Suitability of Land for the
Application of Sludge 162
111
-------
Page
UNAVOIDABLE ADVERSE IMPACTS 167
LOCAL SHORT-TERM USES OP THE ENVIRONMENT VS. MAINTENANCE
AND ENHANCEMENT OP LONG-TERM PRODUCTIVITY 169
IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS
OF RESOURCES 171
UNRESOLVED ISSUES 173
BIBLIOGRAPHY 175
References 175
Personal Communications 180
APPENDICES
A - U. S. Environmental Protection Agency Technical
Bulletin, Municipal Sludge Management 183
B - Biotic Resources 193
C - Morrow County Population Projections
Based on ECOAC Scenarios 200
D - Emission Rates 204
E - Archeological Survey 207
F - Detailed Cost Analysis of Alternatives A-l,
C-l, D-l, D-2 and No-Action 210
G - Energy Analysis for Alternatives A-l, C-l,
D-l and D-2 225
H - Letter of Interest — Boeing Agri-
Industrial Company 231
I - City of Portland Ordinance No. 146547 233
COMMENTS AND RESPONSES TO THE DRAFT EIS 241
1V
-------
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Page
23
27
29
30
34
45
47
50
62
62
69
70
83
94
97
104
106
115
118
119
120
LIST OF TABLES
Properties of Common Soils Occurring on Land
Currently Utilized or Proposed for Application
of Sewage Sludge
Representative Groundwater Quality of Test
Wells Located at Active Sludge Disposal Sites
Quality of Groundwater from Two Wells in the
Vicinity of Morrow County Disposal Site
Chemical Analyses of Groundwater from the
Clackamas-Marion County Site
Acreages of Major Plant Communities and Other
Land Uses in the Study Area, 1970
Portland Service District 1975 Population and
Projections of Population for the Year 2000
Present and Projected Populations, Morrow County
and City of Boardman
Maximum Cumulative Sludge Metal Application Limits
Average Wastewater Characteristics, 1976
Measured and Computed Sludge Quantities for 1976
Projected Sludge Quantities for 2000
Planning Area Waste Flow and Sludge Volume
Forecasts
Estimated Total Annual Costs - All Alternatives
Specialty Soil Amendment and Fertilizer Uses
and Users
Summary of Conclusions Marketing Analysis
Table Omitted
Table Omitted
Short-Term Impacts - Portland Sludge Disposal
Estimated Chemical Requirements for B.E.S.T.
Process
Average Daily Traffic Volumes on Existing
Sludge Conveyance Routes, 1975
Projected Emissions from Barging Sewage Sludge
to Morrow County
Projected Emissions from Barging Sewage Sludge
to North Willamette Valley
Projected Emissions from Trucking Sludge from
the Columbia Boulevard STP to the North
Willamette Valley
v
-------
Table
Page
24 Heavy Metal Characteristics of Sludge from
Columbia Boulevard Plant 132
25 Maximum Metal Addition (pounds per acre and Kg/Ha)
with a Soil Cation Exchange Capacity (CEC)
(meq/lOOg) 134
26 Projected Life, Sludge Loading/Acre and Acreage
Requirements for Sludge Application in Morrow
County 136
27 Projected Life, Sludge Loading/Acre and Acreage
Requirements for Sludge Application in the
North Willamette Valley 141
28 Crop Suitability for Sludge Application 153
29 Yearly Sewage Sludge Applications Required to
Provide a Constant Level of Available
Nitrogen 155
30 Local Share Annual Costs - Year 1990 158
31 Comments Received on Draft Environmental
Impact Statement 24 2
32 Public Hearing Testimony 243
VI
-------
LIST OF FIGURES
Figure • Page
A Columbia Boulevard Plant, Proposed Barge Dock
and Rivergate Sludge Disposal Sites 3
B Sludge Application Sites, Dock Sites and Pipe-
line Routes - Alternative A 4
1 Portland Sludge Disposal Project Area 14
2 Columbia Boulevard Plant, Proposed Barge Dock
and Rivergate Sludge Disposal Sites 15
3 Proposed Sludge Application Sites - Alternative A 16
4 North Willamette Valley - Sludge Disposal Study
Area - Alternative D 18
5 Existing Land Use - Morrow County Sludge Appli-
cation Sites - Alternative A 40
6 General Land Use - Clackamas and Marion Counties 43
7 City of Portland Service Area 59
8 Past and Estimated Future Sludge Production, 67
1975-2000 67
9 Feasible Sludge Processes 75
10 Schematic Diagram for Alternative A-l 86
11 Schematic Diagram for Alternative C-l 89
12 Schematic Diagram for Carver-Greenfield Process
Alternative 92
13 Schematic Diagram for Alternatives D-l and D-2 99
14 Schematic Diagram for the No-Action Alternative 102
15 Sludge Conveyance Routes (Alternatives A and D)
on the Columbia and Willamette Rivers 110
16 Existing and Proposed Sludge Truck Routes H4
17 Area Considered for Construction of Barge
Unloading Dock, Willamette River - Alternative D 122
18 Projected Acreage Requirements for Sludge Appli-
cation Based on Projected Sludge Volumes for
Years 1978 and 2000 137
19 Projected Years of Life of Sludge Application
Areas in Morrow and Clackamas/Marion Counties 139
vii
-------
SUMMARY
FINAL ENVIRONMENTAL STATEMENT — SLUDGE DISPOSAL FOR
THE CITY OF PORTLAND
Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
1. Type of Statement: Draft ( )
2. Type of Action: Administrative ( X
3. Description of Action:
The objective of this project is to provide an institu-
tionally and environmentally acceptable sludge disposal or
reuse program for the City of Portland's Columbia Boulevard
Wastewater Treatment Plant. This Final Environmental Impact
Statement identifies alternatives for providing the city with
a means of sludge disposal while at the same time achieving
a beneficial reuse of the sludge.
The city is presently disposing of its primary and
waste-activated sludge under an interim program of spraying
on unoccupied lands in the Rivergate Industrial District and
settling and storage in a sludge holding lagoon adjacent to
the treatment plant. The Columbia Boulevard STP produces
approximately 45 dry tons of sludge per day. The Tryon Creek
and Kellogg (CCSD No. 1) wastewater treatment plants presently
contribute sludge to the Columbia Boulevard plant or dispose
of the sludge on the Rivergate area. Future development of the
industrial district, filling of the sludge holding lagoons and
filling of the St. Johns landfill make it necessary for the city
to establish a long-term (20 years) means of sludge disposal.
The city is presently increasing their capacity to anaerobically
treat sludge and refurbishing the storage lagoons near the
plant.
4. The Preferred Alternative:
The U. S. Environmental Protection Agency (EPA) elected
to provide 75 percent grant funding for either of two cost
and environmentally equivalent alternatives - Alternative A-l
(land application of liquid sludge in eastern Oregon) or
Final ( x )
) Legislative ( )
1
-------
C-l (sludge drying for production of a fertilizer aid) - as
selected by the City of Portland. On September 27, 1978,
the Portland City Council chose Alternative A-l as a long-
term method of sludge disposal. Factors considered by the
city in selection of this alternative are contained in
"Exhibit A" of the City of Portland Ordinance No. 146547
(Appendix I). Alternative A-l, which would involve barging
sludge on the Columbia River to eastern Oregon, was re-
commended for implementation because of the relative simplicity
and proven reliability of sludge pumping, barge transportation
and land application systems.
Alternative A-l, as described in subsequent chapters,
provides for the transportation of liquid digested sludge by
barge up the Columbia River to Morrow County, where the
sludge would be incorporated into the soil. Sludge treatment
would be by anaerobic digestion for primary sludge and separate
anaerobic digestion followed by lagooning for secondary
sludge. Digested sludge would be pumped to a barge-loading
facility on the Oregon Slough (Figure A) and then barged to
Morrow County. At the Morrow County off-loading site, sludge
would be pumped from the barge to a small lagoon and from
there to a number of potential agricultural sites for soil
incorporation (Figure B). Of the potential agricultural
sites identified, the site preferred by the City of Portland
is site "C" on Boeing Agri-Industrial property, southwest
of the City of Boardman (Figure B).
Major impacts associated with barging liquid sludge to
Morrow County (Alternative A) involve potential sludge spill
hazard in the Columbia River (particularly in the Oregon Slough
area), consumption of fuel, land form and soil alterations and
natural vegetation and wildlife changes. In Morrow County
liquid sludge will be stored in sludge lagoons prior to appli-
cation on nearby agricultural lands. Methods of sludge
application will be designed to minimize any problems associated
with heavy metal loading, odors, vectors, and groundwater or
surface water contamination. Large areas of irrigated and
nonirrigated agricultural lands appear readily available in
the Morrow County area. When spread on the land, liquid
sludge will be a beneficial soil conditioner and light
fertilizer (approximately 4 percent nitrogen). Samples of
sludge analyzed during 1977 indicate zinc to be present in
moderate quantities (2,400 ppm) and to be the heavy metal
dictating the long-term sludge loading per acre and the
expected life of the disposal sites.
Provision Mb" of the City of Portland Ordinance No. 146547
directs the city engineer to negotiate for purchase of pre-
ferred agricultural sites in Morrow County for sludge disposal.
This provision, however, also provides the city with the
2
-------
PROPOSED BARGE
LOADING FACILITY
ACTIVE tPAST^^
'SLUDGE DISPOSAL/$)
SITES _ i
INDUSTRIAL
RIVERGATE
DISTRICT
BY BEE
.LAKE
PHSUHE
WMTCWATCN
OUTFALL
SMITH
LAKE
TUl ANOLC LAKE
«LUtXC LA80QW
ST. JOHNS
LANDFILL
ST. JOHNS
BRIDGE
*'V£R
. . ; COLUMBIA
COLUMBIA BOULEVARD
SEWAGE TREATMENT
PLANT
SCALE IN MILES
FIGURE A
COLUMBIA BOULEVARD PLANT,
& RIVERGATE SLUDOE
3
-------
CITY OF BOA ROM AN
f
S ALTERNATE I
£D l3_fOSAL_AREA_J
PROPOSED DOCK SITE
6 PIPELINE ROUTE
(CASTLE AREA)
EXISTING PORT
OF MORROW DOCK
REJECTED DOCK
SITES e
PIPELINE ROUTES
SABRE
V. S NAVY
BOMBING RANGE
FARMS
BOEING AGRI-INDUSTRIAL SITE BOUNDARY
approx. scale
IN MILES
FIGURE B
PROPOSED SLUDGE APPLICATION
SITES, DOCK SITES 6.
PIPELINE ROUTES
-------
option to accept bids from private concerns for independent
sludge transportation and disposal at other locations in the
Columbia River basin.
The Oregon Department of Fish and Wildlife expressed
opposition to use of proposed off-loading sites and pipeline
routes at Threemile and Sixmile Canyons due to extensive
wildlife use of these areas (Figure B). A new area, north of
Castel, Oregon, was suggested for sludge off-loading and
pumping. Figure B shows a potential off-loading site and
pipeline route in the Castle area, which would convey sludge
to Site C on Boeing property. Due to concerns of the
Department of Fish and Wildlife, EPA has ruled out use of
Three- and Six-Mile Canyons and concurs with the Department
as to the acceptability of a route to be located in the
Castle area.
Vegetation within the proposed Castle off-loading site
and pipeline route is typical of the area, consisting of
native shrub-steppe vegetation, such as big sagebrush and
rabbitbrush. The understory is composed of sparse native and
introduced grasses and weedy species. Wildlife species
associated with this plant community are listed in Appendix B.
Elevations rise from approximately 200 feet at the
Columbia River to 550 feet at Site C. Finely textured
soils are shallow over basalt bedrock. Basalt outcrops
are evident at numerous locations.
Because of the sparse nature of vegetation at the off-
loading site and pumping route, impacts on vegetation and
associated wildlife would be relatively minor. To minimize
adverse impacts on fish resources at the proposed off-loading
site, The Department of Fish and Wildlife has suggested that
alternative design features of the basin be evaluated at an
early stage in the design phase.
Conditions required by EPA as part of the Step II grant
to the City of Portland will include 1) a groundwater survey
of those areas proposed for sludge application. Upon comple-
tion, the survey shall be submitted to the Oregon Department
of Environmental Quality for a determination of whether or
not groundwater monitoring will be required and 2) a detailed
archeological and historical survey of all on- and off-loading
sites, pipeline routes and sludge application sites chosen by
the City of Portland.
5. Additional Alternatives Considered:
Additional alternatives evaluated in this EIS are
Alternatives C-l (sludge drying for production of a fertilizer
aid) and D-l (land application of liquid sludge in the
5
-------
Willamette Valley). The No Action Alternative (continued
use of Rivergate property and the Triangle Lake Sludge
Lagoon for sludge disposal) is also evaluated. More detailed
descriptions of these alternatives and their environmental
impacts are presented in the Chapters on ALTERNATIVE SLUDGE
HANDLING SYSTEMS and the ANALYSIS OF THE ENVIRONMENTAL IMPACTS
OF THE ALTERNATIVES.
6. Unresolved Issues:
During the course of report preparation, it became clear
that there are several key issues relative to the Portland
sewage sludge disposal project. These issues are identified
in the INTRODUCTION to this Draft EIS and are futher discussed
throughout the report. The resolutions to several of the issues
are regulatory or institutional problems that must await further
governmental action.
o Review of heavy metal constituents of Portland
sludge indicates moderate concentrations of zinc
(2,408 mg/kg). Zinc concentrations are sufficiently
high to reduce the projected life of application
sites when sludge is applied at rates greater than
4.6 tons/acre, and to significantly increase the area
of land needed to the year 2000. Three apparent
options are available to deal with this loading:
1) additional source control of those industries con-
tributing heavily to the metal loading, 2) utiliza-
tion of larger amounts of land if sludge is used for
agricultural purposes, and 3) disposal of sludge on a
smaller area with no beneficial use and the possible
long-term degradation of such land.
o Preliminary review of test well monitoring results
at the Rivergate industrial area indicates possible
high amounts of zinc in the groundwater. No predisposal
background data exist with which to compare the moni-
toring results. The acceptability of continued use of
Rivergate as a disposal area should receive additional
review and evaluation in reference to the monitoring
data.
o The use of Boeing agri-industry land or the U.S.
Naval property in Boardman strictly for disposal
of sludge (rather than for beneficial agricultural
reuse) may be unacceptable to landowners and lessees
in Morrow County.
6
-------
FEDERAL AGENCIES
U. S. Department of Agriculture
U. S. Department of Defense
U. S. Department of Interior
U. S. Department of Health, Education and Welfare
U. S. Department of Housing and Urban Development
U. S. Department of Transportation
Federal Energy Offi ce
National Marine Fisheries Service
Advisory Council on Historic Preservation
MEMBERS OF CONGRESS
Mark 0. Hatfield
U. S. Senate
Robert W. Packwood
U. S. Senate
A1 Ullman
U. S. House of Representatives
Les Aucoin
U. S. House of Representatives
Robert Duncan
U. S. House of Representatives
STATE AGENCIES
Robert W. Straub - Governor of Oregon
Jack Sumner - State Representative District 55
Oregon State Clearinghouse
Department of Environmental Quality
LOCAL AGENCIES & INTERESTED GROUPS
Columbia Region Association of Governments
Clackamas County Board of Commissioners
Clackamas County Department of Planning & Development
Clackamas County Health Department
Clackamas County Public Works Solid Waste Division
City of Oregon City
City of Oregon City Library
City of Oregon City Planning Department
Morrow County Department of Planning & Development
Morrow County Board of Commissioners
Morrow County Health Department
7
-------
City of Boardman
City of Boardman Planning Commission
Multnomah County Board of Commissioners
Multnomah County Department of Planning & Development
Multnomah County Health Department
Oak Lodge Sanitary District
City of Portland
City of Portland Library
City of Portland Planning Department
Resource Conservation Company
Lee Engineering Enterprises
Cloudburst Research
Arthur Forsyth Co.
Boeing Agri-Ind. Co.
Western Farm Service, Inc. - Wheatland Division
Boardman Mobil Home
Lo-Ko Inc.
Wagon Trail Farm
Dehydro-Tech Corporation
League of Women Voters
National Wildlife Federation
1000 Friends of Oregon
Northwest Environmental Defense Center
OSPIRG
Oregon Environmental Council
Micheal B. Mathews - U.S.A.
Rupert Kennedy - Port of Morrow
INDIVIDUALS
Bill Culham
George D. Ward
Ronald Black
7. The Above Listed State, Federal and Local Agencies, as well as Other
Interested Groups, were Invited to Comment on the Environmental impact
Statement.
8
-------
INTRODUCTION
Purpose and Objectives
The National Environmental Policy Act of 1969 (NEPA)
requires that agencies of the federal government prepare
a detailed Environmental Impact Statement (EIS) on proposals
for projects that may significantly affect the quality of the
human environment. NEPA requires that agencies (in this case
the Environmental Protection Agency [EPA]) include in their
decision-making process all environmental aspects of proposed
actions, the environmental impacts of the proposed project
and its alternatives, and a discussion of ways to avoid or
minimize adverse effects. The EIS is to be a "full disclosure"
document and must follow specific regulations of the EPA
as contained in 4 0 CFR, part 6, as published in the Federal
Register/ Volume 40, Number 72, April 14, 1975.
Because the City of Portland sewage sludge disposal
project can be 75 percent funded by the EPA, as part of the
Construction Grants Program authorized by the Federal Water
Pollution Control Act Amendments of 1972 (PL 92-500), it
requires NEPA action. After reviewing the facilities plan
and environmental assessment submitted in September 1976
and March 1977 by the City of Portland, the EPA determined
that the proposed project be separated into two phases --
Phase I - sludge processing (treatment) and Phase II - sludge
handling and disposal. Pursuant to EPA regulations for NEPA
actions a Negative Declaration was prepared for the Phase I
project; however, EPA determined that an environmental impact
statement was required for grant funding of Phase II.
Data for this EIS were compiled from numerous existing
regional and local studies pertaining to Multnomah, Clackamas,
Marion and Morrow Counties and the City of Portland. Field
reconnaissance, literature review, personal contacts with
involved agencies and individuals, and a marketing study all
provided the data needed for this report. A listing of
references and personal contacts appears in the bibliography.
The EIS process encourages public input into the decision-
making process. A series of public information meetings were
held March 1, 2 and 3, 1978, on the sludge disposal project
and the EIS to both enlighten the public and to encourage
comment on the project's impact. This EIS is prepared in
draft form and shall be widely circulated for public comment.
Announcement of an EPA public hearing on the project will
9
-------
be made in the local press. The hearing is held to solicit
public response to the Draft EIS. After the 45-day public
comment period on the Draft EIS had elapsed, a grant fundable
project will be described in the Final EIS. At the end of
a 30-day comment period on the Final EIS, the EPA Regional
Administrator will announce his decision concerning a grant
award for the City of Portland.
Background of Past Events
Prior to 1968 the City of Portland's Columbia Boulevard
sewage treatment plant operated as a primary treatment
facility with a treatment capacity of 60 million gallons per
day (mgd). In 1968 and again in 1972 the facility was
expanded to a present capacity of 100 mgd secondary treatment.
Prior to 1968 digested sludge was pumped to a series of
lagoons for additional stabilization and storage. Solids
were ultimately disposed of on drying beds located where the
secondary facilities now exist.
With the addition of the secondary facilities plant
sludge is treated by two methods — anaerobic digestion for
the stabilization of primary sludge and heat treatment/
vacuum filtration for stabilization and dewatering of waste-
activated sludge. Sludge is disposed of by a combination of
three methods — application of sludge to vacant industrial
properties in Portland's Rivergate district, storage in the
existing sludge lagoon (Triangle Lake) adjacent to the sewage
treatment plant, and disposal in the City's St. Johns sanitary
landfill, although the landfill site has not been used since.
These disposal options have limited capacities.
In March 1977 the City's Department of Public Works
prepared a report entitled Alternative Methods for the
Disposal of Sewage Solids in which the need for additional
sludge disposal capacity was discussed and alternative methods
of disposal were evaluated.
On the basis of that document, the EPA and the Oregon
Department of Environmental Quality approved a step 2, grant
application (project design) for the construction of additional
digesters and refurbishment of the existing sludge lagoons
(Phase I). It was determined that the work proposed for
Phase I would be necessary regardless of the method of
conveyance and disposal ultimately chosen for Phase II.
Project Objectives and Environmental Goals and Constraints
An important element of any project is its objectives.
Well-defined objectives are essential to establishing a
rationale for a project and later providing guideposts to
determine if identified alternatives are justifiable or viable.
10
-------
The conveyance and disposal of sewage sludge from the
Portland Columbia Boulevard sewage treatment plant is deemed
a necessity because nearby storage and disposal space is
lacking and because of institutional requirements — that is,
to meet EPA and DEQ regulations for wastewater solids disposal.
The following project and environmental objectives appear
relevant:
Project Objective
o To provide an institutionally acceptable sewage sludge
disposal program for the citizens of Portland.
Environmental Objectives
o To minimize the adverse environmental effects of
sludge treatment, transport and disposal.
o To minimize the social-economic costs of sludge
treatment, transport and disposal.
o To provide for the beneficial reuse of sewage sludge.
Important Issues and Considerations: Phase II
Prior to and during the course of preparing this EIS,
a number of key issues were identified that warranted
discussion and, if possible, resolution.
The issues are identified below and are described and
evaluated in the ENVIRONMENTAL SETTING and ENVIRONMENTAL
IMPACT chapters of this report. Those issues that remain
generally unresolved in this EIS will be discussed further
in the Chapter entitled ISSUES TO BE RESOLVED. Of particular
importance to this project are:
o The interaction of the City of Portland's project with
overall regional sludge disposal planning and the
areawide 208 (CRAG) study.
o Impacts associated with the land application of
digested sludge in rural areas - i.e., the North
Willamette Valley, Morrow County, Oregon.
o Impacts to public lands, scenic areas, wildlife, etc.,
resulting from land conversion, haul roads and
application equipment.
o Effects of sludge containing heavy metals and other
potential toxicants and pathogens on land, water
and agricultural resources.
11
-------
Impacts of a liquid sludge spill in the Columbia or
Willamette Rivers, or on land transportation corridors.
Marketability of sterile dry sludge.
Capital and operation/maintenance costs of the
alternatives.
Energy budget.
Secondary environmental and societal changes.
Possible conflicts between DEQ and EPA guidelines
and the proposed project.
12
-------
ENVIRONMENTAL SETTING
Project Planning Area
The planning area under consideration for processing
conveyance and disposal of sewage sludge extends from the
City of Portland east along the Columbia River Gorge to
northcentral Oregon in Gilliam, Morrow and Sherman Counties,
and south along the Willamette River into Clackamas, Marion,
Multnomah, Polk, Washington and Yamhill Counties (Figure 1).
The Columbia Boulevard sewage treatment plant is located
in Multnomah County in the vicinity of the Rivergate Industrial
District, which is presently used for sludge disposal. Treated
sewage sludge could be transported to numerous places within
the planning area for disposal. Because of the dispersed
nature of the project alternatives, the potential project is
segmented in the description of the ENVIRONMENTAL SETTING
into three parts: Portland, North Willamette Valley, and
northcentral Oregon including the Columbia River. Each
segment is described in general and in site-specific details
responding to informational needs for evaluating sludge
processing, conveyance and disposal operations.
The sites currently used for sludge disposal are in
Portland. The no-action alternative for sludge disposal
would continue present practices with disposal in Triangle
Lake, the Multnomah County landfill and vacant industrial
acreage in the Rivergate Industrial District north of
Portland (Figure 2). The additional sites proposed for land
disposal are located in Clackamas, Marion, Morrow and Multnomah
Counties.
In Alternative A (land application for soil improvement
in northcentral Oregon), digested sludge would be pumped
through a pipeline running parallel to the Union Pacific
railroad tracks or trucked from Columbia Boulevard STP and
Triangle Lake to a barge loading facility on Oregon Slough
(Figure 2). Sludge would then be barged upstream on the
Columbia River to a dock unloading facility located in
northern Morrow County at either Threemile or Sixmile Canyon
west of the City of Boardman, or at the existing Port of
Morrow docking facility east of the City of Boardman.
Sludge would be conveyed by pipeline from the docks to
storage and land application sites either on land controlled
by Boeing, Sabre Farms or the U. S. Navy (Figure 3).
13
-------
FIGURE I
PORTLAND SLUDGE DISPOSAL
PROJECT STUDY
AREA
-------
PROPOSED BARGE
LOADING FACILITY
ACTIVE kPAST5*-^
SLUDGE DISPOSAL^
iSITES ! i
INDUSTRIAL
RIVER6ATE
DISTRICT
SMITH
LAKE
POTENTIAL FUTURE^
SLUDGE DISPOSAL/fJ?
SITES /(f
TRIANGLE LAKE
SLUDGE LAGOON
ST. JOHNS
LANDFILL
ST. JOHNS
BRIDGE
#/VER.
SCALE IN MILES
FIGURE 2
COLUMBIA BOULEVARD PLANT, PROPOSED
& RIVERGATE SLUDGE DISPOSAL 5
(NO-ACTION ALTERNATIVE)
BARGE DOCK
COLUMBIA BOULEVARD
SEWAGE TREATMENT
PLANT
.COLUMBIA.
| PRESSURE
WASTEWATER
OUTFALL
-------
s*
lM
0^
PROPOSED DOCK
SITES 6
PIPELINE ROUTES
£3
fliy £&¦'..
-T e0 Nauru
l'°w Boordman
Flight Strip
pr**TfnI ^
p\p«*ln
71
SITE VC
1,809 ACRES
SITE'
1,983 ACRES I
A
acres]
ALTERNATE I
. _>&12l??02.Alv.A5A-J
(T»
APPROX. SCALE
IN MILES
3,208 ACRES
BOEING A8RI - INDUS TRIAL SITE BOUNDARY
EXISTING PORT
OF MORROW DOCK
CITY OF BOAROMAN
U. S. NAVY
BOMBING RANGE
SABRE
FARMS
.J
FIGURE 3
PROPOSED SLUDGE
APPLICATION SITES
ALTERNATIVE 'A'
-------
Under Alternative D (land application for soil improvement
in the northern Willamette Valley) sludge would be applied
to an undetermined acreage of agricultural land within an
area of approximately 470 square miles east and south of
Oregon City in Clackamas and Marion Counties (Figure 4).
One hundred square miles of this study area highlighted in
Figure 4 was designated by CRAG as a potential sludge
application area for sewage treatment plants in Clackamas
County. The remaining 370 square miles was chosen by CRAG
as a potential application site for sludge from Portland's
Columbia Boulevard sewage treatment plant. Sludge would
either be trucked to the North Willamette Valley area or
barged from the proposed loading facility on Oregon Slough
to an unloading facility on the Willamette River between
Oregon City and Canby.
Dry solids produced in Alternative C are amenable to
disposal within the total area. The marketing study activity
should identify the viability of disposal options for B.E.S.T.
or Carver-Greenfield process sludge. These options could
include commercial nurseries, farms, recreation areas and
home use in and near Portland or be extended into the Willamette
Valley or northcentral Oregon.
The organizational format for the present and future
environmental setting components relating to the above
alternatives is general to site-specific for the Portland
area, northcentral Oregon and North Willamette Valley.
Topography
Portland
Portland lies at the confluence of the Willamette
and Columbia Rivers (Figure 1). Much of the industrial-
commercial area of the city lies on alluvial lands while
the main residential-business districts are on upland and
adjacent hill terrain. The wastewater treatment facilities
and existing sludge disposal areas are in the historical
floodplain.
The Rivergate Industrial area is a broad flat peninsula
lying between the Willamette River on the southwest and the
Oregon Slough and Columbia River to the north. Several lakes
and sloughs occur on the peninsula including Columbia and
Mud Sloughs and Smith, Bybee and Ramsey Lakes. Elevations
range between 10 and 30 feet above mean sea level.
17
-------
.LIMIT OF CRAG
>>208 STUDY AREA
LIMIT OF CRAG
208 STUDY AREA
-------
Northcentral Oregon
The northcentral Oregon portion of the study area lies
in the Deschutes-Umatilla plateau, which is bounded by the
Columbia River to the north, the Ochoco and Blue mountains
to the south and east respectively, and the Cascade Range
to the west.
The plateau region slopes gently to the northwest toward
the Columbia River. The land is generally smooth and rolling
with elevations ranging from 150 feet at the Columbia River
to 2,000 feet farther inland. Drainage patterns are characterized
by steep swales and narrow canyons with abrupt sides.
Tentative disposal sites in northern Morrow County lie
south of the Columbia River in gently sloping topography
(Figure 3). The Willow Creek drainage is located approxi-
mately 1/2 mile west of Site A. Threemile Canyon lies between
Site A and B rising from an elevation of 250 feet at the
Columbia River to 4 50 feet. Sixmile Canyon is located between
Site B and C and rises from the river to an elevation of
approximately 550 feet at Site C.
Topography of the U. S. Navy Bombing Range and Sabre
Farms is similar to that of the Boeing property. Progressing
from north to south on the Bombing Range, the terrain changes
from gentle undulations to steeply sloping hills. Elevations
range from 400 feet to 950 feet. Juniper and Well Springs
Canyons extend through the site from south to north. Sabre
Farms is dominated by gently sloping terrain. Finley Buttes
and Sand Hollow lie on the southern border of the property.
Elevations range between 600 and 900 feet.
North Willamette Valley
The Clackamas-Marion County site is characterized by
areas of rolling topography and low hills interspersed with
relatively level valley bottoms. West of the Molalla River,
the valley is gently rolling to level with elevations ranging
between 80 and 200 feet above MSL. East and north of the
Molalla River the terrain consists of gently rolling terraces
at elevations between 200 and 4 50 feet above MSL with moderate
to steeply sloping foothills to elevations exceeding 1,500
feet above MSL. Numerous intermittent and ephemeral drainage-
ways dissect the site.
19
-------
Climate
Northcentral Area
The climate of northcentral Oregon is temperate and
semiarid, being characterized by low annual precipitation,
low winter temperatures and high summer temperatures.
Strong winds, generally from the west and southwest, may
occur at any time of the year, causing drifting snows in
winter, soil movement and accelerated evaporation in other
seasons (U. S. Department of Agriculture, 1961 and 1962).
Annual data on climatic conditions in the area can be obtained
from the U. S. Department of Commerce.
Climate of the northern Morrow County sites is typical
of the region. The site is characterized by a relatively
mild average annual temperature of 53.3°F. Temperature
extremes average approximately 103°F in July and range from
5°F to 18°F in January. There are an average of 181 days
between the first fall and last spring freeze, with freezing
temperatures occurring sporadically from October to April
(U. S. Department of Commerce, 1974-76).
Total annual precipitation averages 7 to 8 inches with
72 percent occurring from November to April. Extreme
amounts of precipitation can occur in the site area. A
one-day rainfall total exceeding 2 inches and a monthly
maximum snowfall of 31 inches were recorded at Arlington,
which is 15 miles west of the site. The evapotranspiration
rate averages somewhat less than 30 inches in most years.
Winds commonly from the southwest average 9 mph in the
site area with gusts ranging up to 40 mph (Portland General
Electric Company, 1973).
North Willamette Valley Area
The north Willamette Valley has a temperate maritime
climate with dry, moderately warm summers and wet, mild
winters. Varying topography of the valley produces con-
siderable variation in climate. Prevailing winds are from
the west and northwest during the summer months and from the
south and southwest during the winter storm period. Wind
velocities are generally moderate, although strong gusty
winds occasionally accompany winter storms.
Climate at the potential Multnomah, Clackamas and Marion
Counties sludge disposal sites is similar and typical of the
Willamette Valley, with mild temperatures and moderate
precipitation prevailing.
20
-------
Both sites are characterized by a mild average annual
temperature of approximately 53.8°P. Temperature extremes
for the Rivergate Industrial site vary from a high of 95°F
in July to lows ranging from 15°F to 25°F in January. The
number of days between the first fall and last spring freeze
average 258/ with freezing temperatures occurring irregularly
between November and March. Temperature extremes for the
North Willamette Valley sites average 96°F in July and range
from 12 to 23°F in January. There is an average of 224 days
between the first fall and last spring freeze, with freezing
temperatures occurring sporadically between October and April.
The average annual snowfall in the Portland area is about
5 inches (U.S.D.A., 1962 and 1963). Total annual precipita-
tion averages approximately 40 inches and over for both sites,
with 88 percent occurring between October and May.
Prevailing winds are generally from the northwest in
summer and south in winter for both sites. Occasional wind-
storms from the Columbia River Gorge occur year-round.
Except in localized areas, wind speeds for both sites are
generally light with an average annual wind speed of 7.7
mph (Multnomah County Planning Commission, 1977).
Geology
The Rivergate Industrial District in Portland is underlain
by Miocene Columbia River Basalt. The Troutdale formation
of middle Pliocene age covers the basalt down to 1,500 feet.
This formation consists of beds of micaceous and guartzose
sandstone and siltstone and tuffaceous siltstone, sandstone
and conglomerate. Overlying the Troutdale formation is
an alluvial formation of Pleistocene age consisting of
unconsolidated sand, gravel, silt, clay and pyroclastic
debris. More detailed information on the geology of this
area can be found in U. S. Department of Agriculture (1963).
Disposal sites in northern Morrow County are underlain
by Columbia River Basalt. Resting over the basalt are coarse-
textured Plio-Pleistocene glacial deposits. These deposits
consist of clean sand and fine gravel with some large boulders
and local silt lenses. Columbia River Basalt is exposed at
various locations. Hogenson (1964) gives more detailed
geologic information for this region.
The Clackamas-Marion County site is underlain by Eocene
sedimentary and volcanic rocks. Resting over Eocene rocks
north of the Oregon City area is Columbia River Basalt.
Miocene basaltic breccia, tuffs and flows rest over Eocene
rocks south of Oregon City and are exposed on the southeastern
21
-------
edge of the site. Lying over Columbia River Basalt and
Miocene tuffs and flows over much of the site is the Trout-
dale formation. Boring lavas overlie the Troutdale and cap
many hills in the northern portion of the site. Alluvial
deposits known as Willamette silts overlie the Troutdale
formation throughout much of the site. More detailed
information on the geology of this region can be found in
U. S. Department of Agriculture (1962 and 1963).
Soils
Soils of the Rivergate Industrial District site are
derived from recent alluvial sands and gravels. The most
common soil series is the Pilchuck urban complex comprised
mainly of Pilchuck sand derived from dredge spoil material.
Slopes range from 0 to 3 percent. All land application
sites in the Rivergate Industrial areas occur on this soil
type. Triangle Lake is situated on soils of the Sauvie-
Rafton urban complex. Soils range from siltv clay loam to
silt loam with slopes of 0 to 3 percent. Table 1 describes
the properties of these soils in greater detail. Additional
information can be found in U. S. Department of Agriculture
(1963) .
A variety of soils derived from transported materials
occur on the Morrow County Sites A through C. Table 1
lists properties of the most common soils (U. S. Department
of Agriculture, 1961 and 1962).
Soils of Site A belong primarily to the Prosser and
Taunton series. These soil textures consist of silty loam
and fine sandy loam, with slopes ranging from 0 to 12 percent,
although slopes commonly do not exceed 5 percent. Koehler
loamy fine sand with slopes between 2 and 5 percent also
occurs on Site A in a limited area.
The major soil series of Site B are comprised of Prosser
and Taunton, with slopes ranging from 0 to 20 percent. A
large acreage component of Site B is a Prosser-Rock outcrop
complex with shallow soils, scattered exposed basalt, and
slopes up to 20 percent. A variety of additional soil types
occur on Site B. These are Quincy loamy fine sand, Koehler
loamy fine sand, and Warden very fine sandy loam. Slopes
range from 5 to 20 percent. Average cation exchange capacity
is 11 meq/lOOg.
Common soils of Site C are Quincy and Koehler loamy fine
sand with slopes from 2 to 20 percent, although slopes do
not typically exceed 5 percent. Other soils occurring in
limited areas include Prosser silt loam, Hezel loamy fine
sand and dune land. Slopes are usually less than 5 percent.
The average cation exchange capacity is 13 meq/lOOg for
Prosser and Hezel soils and is estimated to be less than
5 meq/lOOg for dune land.
22
-------
Table 1
PROPERTIES OF COMMON SOILS OCCURRING ON LAND CURRENTLY
UTILIZED OR PROPOSED FOR APPLICATION OF SEWAGE SLUDGE
Soil
Series
Study Area
location
Texture
Profile
Depth Fran
Surface
(in.)
PH
Organic
Matter
Slope Content
<%) (*)
Cation
Bcchange
Capacity Conductivity
(nea/lOOo) (nmhos/cn)
Depth to
High Wats:
Table
(ft.)
DejJth to
Hardpaix/
Bedrock
(in.)
Permeability
Rjnoff
Erosion Hazard
Water Wind
Floodix
Pros9er
Morrow County
Silt Loam
Silt Loam
0-4
4-29
6.6-7.3
6.6-7.3
0-20
(.5-1.0)1
(15-16)
<1.0
>6.0
20-40
Moderate
Slow to
Median
Moderate
Swere
None
Taunton
Morrow County
Fine Sandy Loam
Fine Sandy Loan
v. Fins Sandy Loam
0-5
5-15
15-22
6.6-9.0
6.6-9.0
6.6-9.0
0-12
(.5-1.0)
(12-15)
<1.0
>6.0
20-40
Moderately
Rapid
Slow to
tedium
Slight
Severe
None
Jtoehler
tbrrcw County
Loany Fine Sand
Loamy Fine Sand
0-3
3-24
7.4-8.4
7.4-8.4
0-12
(<.5)
(8-10)
<1.0
>6.0
20-40
Rapid
Slow
Slight
Severe
None
Quincy
Morrow County
Loamy Fine Sand
Loamy Fine Sand
0-6
6-61
6.6-8.4
6.6-8.4
2-20
<¦5
8-9
<1.0
>6.0
>60
Rapid
Slow
Slight
Severe
None
Pilchuc*
Multnaaah County Sand, Loany Sand
Sand, Loamy Sand
0-12
12-60
6.1-7.3
6.1-7.3
0-3
<.5
(<10)
>6.0
>60
Very Sapid
Slow"
High
Moderate
Note
Sauvie
Multncmah Oounty Silty Clay Loam
Silty day Loan
Sandy to Silt Lotm
0-15
15-39
39-60
5.5-6.5
5.5-6.5
6.0-6.5
0-3
2-4
(30-40)
-
>6.0
>60
Moderately
Slow
Slow
Slight
Slight
Nore
Raftn
Miltnonah County Silt Loan
Silt Kan
Silty Clay boat
0-9
9-40
40-60
5.6-6.0
5.6-6.5
5.6-6.5
0-3
1-3
(20-25)
-
0.0-1.0
>60
Moderate
Slow
Slight
Slight
None
Jary
Clmicanns Oounty Silty Clay loan
Silty Clay
Clary
0-6
6-16
16-60
4.5-6.0
4.5-6.0
4.5-6.0
2-12
5-e
22-30
-
>6.0
>60
Moderately
Slow
Slow to
Medium
Moderate
Moderate
None
Aloha
Silt Loan
Silt Loan
0-8
8-46
46-65
5.6-6.0
5.6-6.0
5.6-6.0
0-8
2-3
15-20
-
1.0-2.0
>60
Moderately
Slow
Slow
Slight
Slight
None
Modbim
Marion Oounty
Silt Loaa
Clay Loaa
Silt I»
0-17
17-32
32-68
5.6-6.5
5.6-6.5
5.6-6.5
0-20
3-6
15-25
-
2.0-3.0
>60
Moderate
Slow to
Rapid
Slight
Slight
None
1 Parentheses indicate estimation
2 No data available
Source: 0. S. Department of Agriculture (1972 and 1976)I A. Floss, pars, w, (1978)
-------
Numerous soil series also occur on Sabre Farms property.
The most common soils are Quincy loamy fine sand, Royal fine
sandy loam, Sagehill fine sandy loam and Irrigon fine sandy
loam. Slopes range from 2 to 5 percent. Additional soils
of limited distribution include Gravden gravelly loam, Warden
very fine sandy loam, Ellum fine sandy loam, Burbanks loamy
fine sand, and Taunton fine sandy loam. Slopes range from
0 to 20 percent.
A variety of soil series occur on the U. S. Navy Bombing
Range. The two most common series are Quincy and Koehler
loamy fine sand with slopes ranging from 2 to 5 percent.
Other soil series on the range include Royal loamy fine sand
and silt loam, Sagehill fine sandy loam, Warden very fine
sandy loam and sandy loam, and Hezel loamy fine sand. Slopes
range from 2 to 20 percent. Active dunes occur throughout
the property with greatest concentrations occurring along
the northern and southeastern boundaries.
A great variety of soil associations and series derived
from alluvial and loess deposits occur on the Clackamas-Marion
County site. The Jory series is the most widespread type.
It is silty clay loam and silty loam in texture and ranges
from 0 to 12 percent in slope. The Aloha silt loam series
with slopes of 0 to 8 percent is common west of the Molalla
River in Clackamas County. In Marion County the Woodburn-
Amity-Willamette association consisting of silt loam over
silty clay loam on slopes ranging from 0 to 12 percent is
most common. Table 1 describes properties of some of the
above soil series in greater detail. Less common soil
associations on the site are McBee-Chehalis-Cloquato, Wapato-
Cove, Latourell, Briedwell, Woodburn-Willamette, Bornstedt,
Concord-Clackamas-Amity, Concord-Dayton-Amity, Jory-Saum,
Estacada, and Honeygrove-Apt-McCully. Overall slopes may
range from 0 to 50 percent. Cation exchange capacity averages
24 meq/lOOg. More general and specific information on soils
of this region can be found in U. S. Department of Agriculture
(1962 and 1963) and U. S. D. A. Soil Conservation Service (1972).
Surface Water Quantity/Quality
Surface water resources of the Rivergate Industrial
District are the Columbia River, Willamette River, Oregon
and Columbia Sloughs and Smith and Bybee Lakes. Water
temperatures and average daily flows for the Columbia and
Willamette Rivers in this area are similar to those reported
for the river at Portland (U. S. Geological Survey, 1975).
Average daily flows in Oregon Slough are influenced by both
the Columbia River and by tidal action. Average flows in
Oregon Slough range from about 10 to 17 percent of the
Columbia River flow (Stevens, Thompson and Runyan, Inc., 1973)
or from 20,100 to 34,170 cfs (Stevens, Thompson and Runyan, Inc.
1973). Flows as low as 4,600 cfs could occur in Oregon Slough.
24
-------
Water quality of Oregon Slough is similar to that of the
Columbia River. Biochemical oxygen demand (BOD) ranges
between 1.0 and 2.8 mg/1 (STR, Inc., 1973).
Major surface water resources in northcentral Oregon are
the Columbia, Deschutes, John Day, and Umatilla Rivers.
Other intermittent streams of importance include Willow, Butter
and Rock Creeks.
Surface water resources of the northern Morrow County
sites are limited to the Columbia River. Threemile and Sixmile
Canyons on the Boeing property and Juniper Canyon, Well
Springs Canyon and Sand Hollow to the east are ephemeral
drainages, conveying surface waters only during and shortly
after periods of heavy precipitation.
At Sixmile Canyon, the Columbia River has a drainage
area of approximately 219,000 square miles. The average
daily discharge at this point is approximately 186,000 cfs.
The 10-year low flow of the Columbia River in the vicinity
of Sixmile Canyon is approximately 47,000 cfs (Portland
General Electric Company, 1973).
Columbia River water generally complies with Oregon
Department of Environmental Quality water quality standards
for dissolved oxygen, turbidity, pH, temperature, coliform
bacteria, and certain chemical ions (Oregon Department of
Environmental Quality, 1975). Water temperatures range
from 32°F in winter to above 70°F in summer. Seasonally
high turbidity from land runoff occurs annually.
Major surface water resources of the northern Willamette
Valley are the Columbia River and the Willamette River and
its major tributaries; the Yamhill, Tualatin, Pudding, Molalla
and Clackamas River (USGS, 1975 and 1977).
The entire Willamette River basin has a watershed of
approximately 11,500 square miles. The river between
Salem and Portland is comprised of three distinctive reaches.
These are the upstream reach between Salem and Newberg, which
is shallow and characterized by a meandering channel; the
Newberg pool from Newberg to Willamette Falls at Oregon City,
which is deep and slow-moving; and the tidal reach from
Willamette Falls to the river mouth, which is also deep and
slow-moving and affected by tides and backwater from the
Columbia River during spring and early summer (Rickert, et al., 1977).
Water temperatures in the river range from 32°F in winter
to 73°F in July and August. Average summer temperatures at
Newberg and Portland are 68°F and 71°F, respectively.
25
-------
The Willamette River meets most DEQ water quality standards
throughout the year (DEQ/ 1977). Dissolved oxygen levels
have fallen short of standards on several occasions. Coliform
bacteria concentrations, resulting primarily from diffuse
land sources and regrowth on certain organic industrial
effluents, commonly exceed DEQ standards. Temperature increases
resulting from solar heating during periods of low-flow are
common.
Major surface water resources of the Clackamas-Marion
County site are the Clackamas, Molalla and Pudding Rivers.
Numerous intermittent and ephemeral drainageways occur through-
out the site.
In the Clackamas River, all DEQ water quality standards
are met annually. Temperatures in the Molalla and Pudding
Rivers normally exceed standards during the summer months.
Coliform bacteria counts are often high in the Pudding River
from land runoff (Oregon Department of Environmental Quality, 1975).
Groundwater Quantity/Quality
Groundwater supplies of the Rivergate Industrial District
sites are derived from alluvial deposits of the Columbia and
Willamette River floodplains and lie at depths greater than
6 feet. Water quality information from 3 wells located
southeast of John Fulton Terminal Number 6 is given in Table 2.
These wells are located within an active sludge disposal
site.
In northcentral Oregon Columbia River Basalt, the most
productive and widespread aquifer, is at depths up to 700 feet
below the surface. Porosity of basalt, however, is low with
the percentage of space within lava flows available for
water storage averaging less than 1 to 3 percent (Bartholomew,
et al., 1973). Additional information on groundwater of this
region can be found in Hogenson (1964) and Robison (1971).
Groundwater from basalt aquifers in the region is suitable
for most uses. In general, the water^varies from soft to
moderately hard, has a moderate mineral content, and does not
contain significant amounts of objectionable constituents.
The main groundwater body underlying possible disposal
sites in northern Morrow County is confined within Columbia
River Basalt at a depth of roughly 200 feet. Limited amounts
of groundwater are also present in glacial sediments overlying
the basalt at depths between 30 to 16 0 feet and in alluvial
deposits of all canyons (Hogenson, 1964).
26
-------
Table 2
REPRESENTATIVE GROUNDWATER QUALITY OF TEST WELLS LOCATED
AT ACTIVE SLUDGE DISPOSAL SITES (November 12, 1975)
Well
Number
Temperature
°C
PH
Alkalinity
mg/1 CaCO^
Total
Coliform/
100 ml
Fecal
Coliform/
100 ml
Cd
Cr
mg/1
Cu Ni
Pb
Zn
102
13.0
7.2
250
<10
<4
<.04
<.13
<.04 <.13
<•5
45
103
13.5
7.1
670
<10
<4
<.04
<.13
<.04 <.13
<.5
62
104
13.5
7.1
390
<10
<4
<.04
<.13
<•04 <.13
<.5
25
to
SOURCE: City of Portland, Bureau of Waste Water Treatment
-------
Significant recharge to groundwater in glacial or
alluvial deposits occurs primarily from percolation of
irrigation water. Very little recharge reaches these deposits
from precipitation. Recharge to basalt aquifers underlying
the sites is very limited.
One active well with a static water level approximately
250 feet below the ground surface occurs on Sabre Farms
property (Fritz, pers. comm.). Several springs which feed
into Juniper and Well Springs Canyons occur on the southern
boundary of the U. S. Navy Bombing Range.
Groundwater in the site area is moderately hard, has a
predominance of calcium sodium bicarbonate, an average pH
of 8.0 and an odor of hydrogen sulfide. Table 3 gives water
quality information for five test wells in the vicinity of
the site areas. No active wells occur on Sites A through C
on the Boeing property or the U. S. Navy site.
The most productive groundwater bodies underlying the
Clackamas-Marion County site are alluvial gravels under the
Willamette River floodplain and Columbia River Basalt under-
lying rolling terrace and foothill areas. Groundwater from
alluvial aquifers west of the Molalla River is normally
perched in many soil types from 0.5 to 3.0 feet below the
surface between November and May. Groundwater derived from
basalt aquifers lies at depths greater than 6 feet below the
soil surface during the entire year. A random sample of 28
wells located within the site area drilled after 1970 had
an average static water level of 77 feet below the ground
surface with a range of 2 to 312 feet (Oregon Water Resources
Department, Well Water Reports). According to Hampton (1972)
the average depth to the water table within the site area
south of Aurora and Mulino is 30 feet.
The quality of groundwater within the foothills and
valleys of the site is typical of the Willamette Valley
with soft to moderate hardness and low concentrations of
chloride, sulfate and nitrate. Iron content can be excessively
high in some areas. Table 4 gives information on chemical
quality of groundwater from 7 wells within the site area
taken from Hampton (1972).
Flood Hazards
The Rivergate Industrial District sites are subjected
to flooding hazards primarily from the Columbia River in
June during the peak runoff from snowmelt upstream. The U. S.
Army Corps of Engineers 100-year flood elevation on Columbia
Slough is estimated to be 28 feet above mean sea level
(City of Portland, 1977). Management of upstream impoundments
on the Columbia River substantially reduces the possibility
of major floods in this area.
28
-------
Table 3
QUALITY OF GROUNDWATER FROM TWO WELLS
IN THE VICINITY OF MORROW COUNTY DISPOSAL SITE
3N 23E-25bc
7 56
5-09-67
-
61
3.0
0.6
106
15
213
0.4
53
2.0
347
10
14
501
8.4
6N 24E-22»cc
86
5-09-67
62
50
30
20
64
4.5
258
50
26
0.8
372
158
2.2
588
8.0
3N/26E-5cbd
830
5-11-67
74
78
9.0
2.9
57
12
176
0.2
20
1.5
268
34
4.2
344
8.1
3N/26E-10cca
<94
5-11-67
74
79
9.4
3.1
56
10
168
2.0
20
1.6
264
36
4.0
329
8.0
3«/26E-10dcc
4
5-11-67
64
55
40
11
25
46
143
48
26
0.4
280
145
0.9
416
7.5
a
b
Ttownship/Range - Section
Frcm Robison (1971)
-------
Table 4
CHEMICAL ANALYSES OF GROUNDWATER FROM THE CLACKAMAS-MARION COUNTY SITE
Location
Depth of
Water-
bearing
zone(s)
(feet)
Sate of
Collec-
tion
Temper-
ature
Milligrams per liter
Dissolved
solids
Hardness
U>
O
*
x
s
3E S « 0
— 3 C *>
0 «
§• AC
• MO
« « &
«C 4* o U
O 0 -H 4
(A Cb CO O
U
9
V
•H
U
0
£
h
C 0
O-H
•uo
9
? WO
T3 OOO
-r*
0) Q
8) >4J
a o «
T4SR1K
126-129
6- 6-62
13 55
42
2.2
31
10
7.6
2.5
164
0
1.2
2.8
0.1
0.2
1.5
0.00
180
—
120
T4SR1E
285-293
6-11-62
14 57
48
.50
20
9.0
25
2.4
166
0
.0
6.5
.0
.2
1.2
.02
195
193
87
T4SR2E
115-122
6-11-62
13 55
25
1.2
4.0
3.0
5.1
.4
40
0
.0
2.0
.0
.1
.01
.03
61
62
22
T4SR3E
113
6- 6-62
12 54
29
.01
7.0
3.5
4.0
.4
47
0
.8
1.0
.0
.9
.05
.00
70
-
32
T5SR1E
325-340
7-26-62
16 60
43
1.1
30
7.5
33
4.0
130
0
5.2
50
.3
.0
.11
.11
238
-
106
T5SR1E
436-438
2-14-57
- -
12
.01
2, 310
.0
1,410
3.2
13
0
18
6,190
.0
-
-
-
9,950
-
5,760
T5SR2E
105-138
6- 6-62
11 52
43
.30
11
6.4
8.1
.8
83
0
1.6
2.2
.3
.1
. 24
.00
115
-
54
4
c
2
«
o
c
o
SB
0
0
0
0
0
5,750
0
Source: Hampton (1972)
-------
Sites A through C in northern Morrow County are subjected
primarily to rapid runoff caused by cloudburst storms in
late spring and early summer. Flash floods have occurred
in the past in Sixmile Canyon (Norton, pers. comm.). The
probably maximum flood in the Columbia River as computed by
the U. S. Army Corps of Engineers (1969) would reach an
elevation of 268 feet in the John Day Pool at the Dalles Dam
and have a regulated peak flow of 820,000 cfs.
The traditional flood season in the northern Willamette
Valley is from November to April with more than two-thirds
of recorded floods occurring from December to February. Flash
floods in the Willamette River and its tributaries have been
the most common type in the past, occurring approximately
every 4 to 5 years. Small streams can flood several times
a year (USDA, 1963). Control structures on the Willamette
River and several tributaries have reduced potential flood
hazards.
Streams of the valley containing flood hazard reaches
are the Tualatin, Pudding, Molalla, Yamhill, Clackamas and
Willamette Rivers (Battelle, 1973). The Willamette River and
its tributaries below Oregon City are also affected by the
Columbia River at flood stage in early June.
Flooding in the Clackamas-Marion County site could
potentially occur in the Molalla, Pudding and Clackamas
Rivers drainages.
Aesthetic Values
The vast semiarid country of northcentral Oregon is bounded
by the John Day Pool of the Columbia River to the north and
by the Blue Mountain range far to the south. Parts of the
gently rolling hills of native sagebrush have been converted
to grain land which provides the major visual diversity in
the region. Perennial streams typically flow through deeply
scoured canyons lined with rocky bluffs, of which the Columbia
River in Sherman and Gilliam Counties is a good example.
Pockets of riparian vegetation in these drainageways provide
islands of native greenery in a predominately arid environment.
The northern Willamette Valley is bounded by the Coast Range
to the west and Cascades to the east and encompasses the major
metropolitan areas of Portland and Salem. The riverine habitat
of the Columbia and Willamette Rivers and their tributaries,
surrounded by rolling hills and valleys interspersed with agri-
cultural land and native vegetation, provide a diverse scenic
environment. Mount Hood to the east and Mount St. Helens to
the north are the major visual attractions in the Portland area.
31
-------
Air Quality
Air quality in the Portland Rivergate Industrial area and
Clackamas County is generally representative of the Portland
area. Relatively light average winds in the basin, particularly
during September and October, result in a high potential for
air stagnation and thus air pollution problems through low-
level temperature inversions. Suspended particulate matter,
carbon monoxide and photochemical oxidants derived primarily
from automobile and industrial sources are the pollutants of
main concern. Specific areas of the basin wherein air quality
standards are exceeded vary in noncompliance with wind speed
and direction.
Northcentral Oregon lies within the Department of Environ-
mental Quality (DEQ) central and eastern air quality control
regions. Air quality within the northern portion of these
control regions is generally acceptable, with few pollutants
exceeding air quality standards set by the DEQ. Of the
pollutants monitored suspended particulate matter exceeded
DEQ air standards 3 days in the Pendleton area in 1976.
Naturally entrained dust was the primary cause of standards
violations (Department of Environmental Quality, 1976) .
Vegetation
Common plant species of the Rivergate Industrial site
along Oregon Slough and surrounding Smith and Bybee Lakes
are riparian dominants such as black cottonwood, Oregon ash
and willows. Dominant understory species include blackberry,
snowberry and reed-canary grass. Common forbs are cocklebur
and teasel. Approximately 2 acres of riparian vegetation
occurs on the proposed barge loading facility site. The
remainder of the vegetation is dominated by weedy composites
and grasses. Common plant species occurring on the proposed
pipeline route are Oregon ash, blackberry, teasel and weedy
grasses and forbs.
Current and proposed disposal sites at the Rivergate
area are characterized by sparse stands of weedy, annual
grasses and forbs, perennial grasses and willow shrubs.
Northcentral and northeastern Oregon lie within an
extensive, arid shrub-grass community known as steppe and
shrub-steppe. Less common plant communities include riparian,
marsh and conifer forest habitat. Limited riparian, wet
meadow and marsh habitat occur in drainageways of inter-
mittent and perennial streams. Forest vegetation is generally
confined to mountain slopes of the Blue and Ochoco Mountains.
32
-------
Large areas of the steppe community have been altered
through cultivation of wheat, potatoes and similar crops
or by grazing of sheep and cattle. Heavy grazing has
resulted in elimination of many native bunchgrasses and has
allowed an invasion of the alien grass and forb species.
Acreages of steppe, shrub-steppe and other habitat types
occurring in Gilliam, Morrow and Sherman Counties are shown
in Table 5. Additional information can be found in Franklin
and Dyrness (1973).
Common plant species of the northern Morrow County site
are native shrub-steppe vegetation and introduced agricultural
species. Site A, on the Boeing property, is dominated by
agricultural species of grasses, alfalfa, wheat and introduced
weedy species. Sites B and C as well as the pipeline routes
up Threemile Canyon and Sixmile Canyon are characterized
primarily by native shrub species such as big sagebrush and
rabbitbrush. Common grasses are the perennials, needle-and-
thread grass and Sandberg bluegrass and the annuals, cheatgrass
and slender fescue. Dominant weedy species include Russian
thistle and filaree. The proposed dock unloading facilities
at the bases of Threemile and Sixmile Canyons are generally
rocky-gravelly surfaces supporting sparse vegetation.
The dominant plant community of the U. S. Navy Bombing
Range is native shrub-steppe vegetation. The target area of
the bombing range, because it has been relatively undisturbed,
contains many examples of native grasses and forbs which are
fast disappearing elsewhere. Sabre Farms is dominated by
introduced agricultural species such as potatoes, wheat,
alfalfa and grasses.
Major plant communities occurring in the northern
Willamette Valley are oak woodland, conifer forest, grassland
and riparian habitat. Much of the valley has been subjected
to extensive human influences in the form of cities, farm-
land and other developments. Wherever natural vegetation
remains, it has been altered by human uses such as grazing
and logging.
Acreages of major plant communities in the northern
Willamette Valley for Clackamas, Marion, Multnomah, Polk,
Washington and Yamhill Counties are shown in Table 5.
See Franklin and Dyrness (1973) for additional information.
Native vegetation of the Clackamas-Marion County site
is typical of the Willamette Valley region. The dominant
native plant communities of the site are coniferous forests,
characterized by Douglas fir and bigleaf maple and riparian
stands of black cottonwood, Oregon ash, and willow species.
A large proportion of the site is characterized by agricultural
crops such as hay, fruits, nuts, vegetables, berries and
grains. Introduced weedy species of grasses and forbs are
common throughout the rural-agricultural and residential
areas of the site.
-------
Table 5
ACREAGES OF MAJOR PLANT COMMUNITIES AND
OTHER LAND USES IN THE STUDY AREA, 1970
Habitat Type
Acreage
North Willamette Valley Northcentral/Eastern Oregon
% of
% of
total
total
Riparian-Marsh
41,506
1.15
5,169
.26
Grassland
290
.01
706,335
27.01
Shrub-Steppe
-
-
741,922
28.37
Oak Woodland
66,814
1.86
-
-
Conifer Forest
2,210,611
61.40
228,890
8.75
Agricultural
1,060,513
29.46
931,384
35.62
Urban-Industrial
204,013
5.67
1,153
.04
Other
16,364
.45
119
.01
TOTAL
3,600,111
100.0
2,614,972
100.0
SOURCE: Oregon State Department of Fish and Wildlife, unpublished
preliminary data
34
-------
The proposed dock unloading facility between Oregon City
and Canby is characterized by riparian species of willow,
black Cottonwood, Oregon ash, blackberry and conifers, e.g.,
Douglas fir.
Rare and Endangered Plant Species
Several rare and endangered plant species are known to
occur in northcentral Oregon and the northern Willamette
Valley (Siddall, pers. comm.). Most species are commonly
found along roadways, fence rows and in remnants of undisturbed
native plant communities. Land utilized for agricultural
purposes, either cropland or grazing land, typically supports
few, if any, native species because of the persistent dis-
turbance to soils and vegetation. The potential for existence
of additional species presently uncataloged or new sites of
cataloged species is high for undisturbed habitats in both
regions.
Fisheries Resources
A total of 45 or more species of fish inhabit the
Columbia and Willamette Rivers. Appendix B lists those
species commonly present. Nine anadromous species utilize
both river systems. Those species of major importance as
commercial and recreational resources upstream of Portland,
are chinook and coho salmon, steelhead, American shad, smelt
and white sturgeon. Salmonid species utilize the main stems
of the Willamette and Columbia Rivers primarily for upstream
migrations to spawning sites in tributary streams, for the
rearing of juvenile fish and for the downstream migration of
juveniles (smelts) to the ocean. Fall chinook salmon, winter
steelhead and chum are known to spawn occasionally in the
main stems of both rivers. American shad and smelt utilize
the main channels of the Willamette and Columbia Rivers for
spawning. Appendix B gives general life history information
for anadromous species of the region.
Many species of game and nongame fishes are residents
in the Columbia and Willamette Rivers. For most species
spawning and rearing of juveniles occurs mainly in backwaters
or tributaries of both rivers. Species that utilize the main
channel and connecting sloughs for spawning include channel
catfish, smallmouth bass, walleye and white sturgeon.
Rare, Endangered or Threatened Species
No rare, endangered or threatened species of fish are
known to occur within the Columbia or Willamette River systems.
35
-------
Wildlife Resources
Few areas of undisturbed native vegetation occur in the
Rivergate Industrial District. Riparian and wetland habitat
of Smith and Bybee Lakes probably support the greatest diversity
of wildlife species in the peninsular area. Remnants of
riparian habitat on the barge loading facility site and pipe-
line route are commonly inhabited by nesting bird species
such as the bewick's wren, rufous-sided towhee and song
sparrow and wintering species such as the dark-eyed junco.
Mammals such as the striped skunk and raccoon probably occur
in limited numbers. Reptiles, e.g., the red-spotted garter
snake, and amphibians, e.g., the Pacific treefrog, may also
occur here in moist depressions.
Little wildlife usage was noted on sites of sewage disposal
because of the general lack of vegetation and cover.
The shrub-steppe community of northcentral Oregon supports
relatively few wildlife species due to unfavorable climatic
conditions and the resulting low diversity and productivity
of vegetation. Irrigated agricultural land has replaced
native vegetation in many areas thereby increasing habitat
diversity and to some degree wildlife habitat opportunities.
Additional wildlife species normally not found in shrub-
steppe habitat occur here, particularly where agricultural
land lies in close proximity to the Columbia River. Common
wildlife species and their preferred habitat types of north-
central Oregon are given in Appendix B.
Field inspection of Sites A through C on the Boeing
property in northern Morrow County took place in January 1978
when few representative wildlife species were observed.
Additional information on species common to the study area
can be found in the Portland General Electric study (1973)
which was conducted in similar habitat approximately 7 miles
to the south.
An island located at the mouth of Threemile Canyon is
utilized by Caspian terns and ring-billed gulls for nesting.
An estimated 3,000 gulls and 300 terns nested on this island
in 1977 (Ward, pers. comm.). This general area is also used
in winter by waterfowl for feeding and loafing.
The northern Willamette Valley, because of its greater
diversity of plant communities, supports a wider variety of
wildlife species than northcentral Oregon. All plant
communities of the valley - conifer forests, oak woodland,
riparian forests, grassland and agricultural land - provide
habitat for many species. Some species may be restricted to
one habitat type while other more adaptable species may
utilize several habitat types. Common wildlife species and
their preferred habitat types in the northern Willamette
Valley are given in Appendix B.
36
-------
Wildlife of the Clackamas and Marion County sites is
typical of the region. Those native and introduced species
associated with native conifer and riparian stands or agricultural
land are most common (see Appendix B). Dominant domestic
mammals are cattle, sheep and horses.
Rare/ Endangered and Threatened Species and Species of
Special Interest
Six rare, endangered or threatened wildlife species and
9 species of special interest occur within the study area,
encompassing northcentral and northeastern Oregon and the
northern Willamette Valley. Appendix B lists rare, endangered
or threatened species and species of special interest,
respectively, and their probable distribution within the
study area.
No nesting or wintering habitat designated as critical
for rare, endangered or threatened species occurs on any
sites in Morrow, Multnomah and Clackamas Counties.
Several species of special interest are known or likely
to nest within site areas. These include the burrowing owl
and long-billed curlew in northern Morrow County. The U. S.
Fish and Wildlife Service is currently conducting a long-
billed curlew nesting study in eastern Oregon. The U. S.
Navy Bombing Range is a major study site. The Washington
ground squirrel, which is uncommon in the Columbia plateau
region, also occurs on the Navy Bombing Range. The great
blue heron, which nests in large colonies, known as rookeries,
is found at several locations on the Columbia, Willamette
and Clackamas Rivers (Battelle, 1973) . One rookery designated
as a significant natural area by the Nature Conservancy
(197 6) is located on the Clackamas River on the northern
boundary of the Clackamas-Marion County site.
Land Use
Portland Rivergate District
Present Land Use. Most land in the Rivergate Industrial
Distract is zoned for industrial use. Industries such as
Oregon Steel Mills and Collier Carbon and Chemical Corporation
are located in Terminal Number 1 on the Willamette River.
John Fulton Terminal Number 6 is located on Oregon Slough.
Stauffer Chemical Company lies east of the proposed barge
loading facility. Smith and Bybee Lakes and Kelley Point
Park are the major recreational - open space areas on Port
of Portland property. The St. Johns Sanitary Landfill,
which serves most of Multnomah County, is located in the
southern portion of the Rivergate Industrial District. The
landfill is estimated to reach fill capacity about 1980
(Multnomah County Planning Commission, 1977).
37
-------
All sites currently utilized or proposed for sludge
disposal or transportation are zoned industrial. Disposal
sites currently used or proposed for use lie on Port of
Portland property. The proposed barge loading facility
site is located on private property. The proposed pipeline
route runs parallel to the Union Pacific-Burlington Northern
Railroad right-of-way and across private industrial land.
The barge loading facility site and acreage proposed for
sludge disposal are currently idle.
Major routes into the disposal site area are North Columbia
Boulevard and North Portland Road leading to Port of Portland
Terminal Number 6 and North Rivergate Boulevard and North
Lombard Street to Terminals Number 1 through 5. Access to
the proposed barge loading facility is via Suttle Road.
Proposed Land Use. Port of Portland land currently
utilized or proposed for sludge disposal is planned primarily
for industrial use by the Port or will be leased or sold to
private industries. Some recreational and commercial develop-
ment in the vicinity of Smith and Bybee Lakes and Columbia
Slough is planned by the Port (Jonasson, pers. comm.).
Northcentral Oregon
Present Land Use. The primary use of land in northcentral
Oregon is agricultural. In 1974 over 2,326/000 acres (89 percent)
of land in Gilliam/ Morrow and Sherman Counties were in farms
and ranches. Average farm or ranch size ranged from 2,400 to
4,400 acres (U. S. Department of Commerce, 1977).
Over 1,000,000 acres are plowed for cropland in this
region. The most important crop is dry-farmed wheat. Other
crops of importance are potatoes and hay (Morrow County) and
other grains. The annual market value of all crops in 1974
was in excess of $67,000,000 (U. S. Department of Commerce, 1977).
Approximately 1,270,000 acres of the region are utilized
as rangeland for grazing cattle and sheep. The market value
of livestock and their products was over $11,000,000 in 1974
(U. S. Department of Commerce, 1977).
The remaining land of the region is dominated by urban
and industrial uses. Major rural centers are Heppner and
Boardman in Morrow County, Arlington and Condon in Gilliam
County and Moro in Sherman County. Industrial developments
occur primarily along the Columbia River. The major industry
is food processing.
38
-------
Recreational-open space land occurs primarily in the
southeast corner of Morrow County in the Umatilla National
Forest, east of Boardman in Umatilla National Wildlife Refuge,
Dyer Wayside and J. S. Burres State Park in Gilliam County.
Major routes of transportation of the region are Inter-
state 80 North connecting the Portland metropolitan area to
northcentral and northeastern Oregon, U. S. Highway 97 in
Sherman County, State Highway 19 in Gilliam County, and
State Highway 74 in Morrow County.
Proposed sludge application Sites A, B, and C in northern
Morrow County lie within a 100,000-acre agricultural-industrial
park owned by the State of Oregon and leased to the Boeing Agri-
Industrial Company (Figure 5). Approximately 10 miles southeast
of the site, Portland General Electric Company is constructing
a coal-burning power plant and filling the 5,000-acre
Carty Reservoir. Bordering Boeing Company land on the west
is the U. S. Navy Weapons System Training Facility. The
southern end of this facility is utilized for practice in
approach and deployment of simulated weapons, while the
northern portion is currently leased for pasture.
Sites A and B, which are zoned agricultural by the county,
are part of a 34,800-acre farm subleased by Sim-Tag Farms
primarily for the production of potatoes. Potatoes are
currently grown in rotation with wheat on approximately
22,800 acres. The use of sewage sludge for growing root
crops (i.e., potatoes) is unacceptable according to DEQ
guidelines. Less important crops are alfalfa and pasture
grasses. Approximately 4,000 acres of alfalfa are grown
in rotation with wheat. Grasses for livestock grazing are
grown on 655 acres on a 3- to 4-year rotational basis with
alfalfa and wheat. Remaining acreage is utilized as rangeland,
feedlots, storage warehouses, or is idle (Martin, pers. comm.).
Water supplies for irrigation are drawn from the Willow
Creek arm of the Columbia River. Crops are irrigated by
elevated circular irrigation systems.
Virtually all of Site A is under agricultural use.
Crops currently grown are primarily alfalfa and pasture grasses
with approximately 3 50 acres of wheat.
Approximately 130 acres on Site B are currently utilized
for growing alfalfa. The remainder of the site is characterized
by native vegetation on undulating shallow rocky soil unsuitable
for agricultural use. Cattle and sheep grazing occurs on
this land.
Site C is dominated by native shrub-steppe vegetation
and is part of a 15,000-acre sublease for grazing cattle and
sheep in winter and spring. This site is also zoned agricultural
by the county.
39
-------
—I'••••/>
APPROX. SCALE
IN MILES
CITY OF BOARDMAN
U. S. NAVY
BOMBING RANGE
FIGURE 5
EXISTING LAND USE
MORROW COUNTY SLUDGE
APPLICATION SITES
ALTERNATIVE 'A'
-------
Land in Threemile and Sixmile Canyon lies, for the most
part, on Boeing Company property and is utilized for grazing
of cattle and sheep south of I-80N. Canyon land north of
I-80N is idle. The base of Threemile Canyon south of I-80N
is U. S. Army Corps of Engineers property. The railroad spur
line for the Portland General Electric Company coal-burning
power plant extends across Sixmile Canyon in Section 30.
Routes of access to Sites A, B and C are Threemile Canyon
Road between Sites A and B and Tower Road east of Site C.
The U. S. Navy Bombing Range (46,720 acres) is currently
used by Navy aircraft for practice in approach and deployment
of simulated weapons. A large portion of the training facility
is also leased for grazing. At the present time there are no
definite plans for any change in use of the bombing range
(Rappel, pers. comm.).
Sabre Farms property (16,000 acres) is currently utilized
for the production of wheat, potatoes, alfalfa and pasture
grasses for cattle. Wheat in rotation with potatoes is grown
on approximately 8,900 acres; alfalfa, spring wheat, and
grazing pasture is grown on 3,125, 1,37 5 and 5,000 acres,
respectively (Fritz, pers. comm.). Crops are irrigated
primarily with water from the Columbia River using pivoting
sprinkler systems.
Proposed Land Use. No plans exist for changes in land
use of Sites A and B under the Sim-Tag sublease. Site C,
which is currently under a grazing lease, is planned for
agricultural use in the near future because the soils are
highly suitable for crops such as potatoes and wheat
(Norton, pers. comm.).
It is anticipated that Sabre Farms will also continue
to maintain its present agriculturally-oriented land use.
North Willamette Valley
Present Land Use. Over 2,000,000 acres (61 percent) of
land in the northern Willamette Valley in Clackamas, Marion,
Multnomah, Polk, Washington and Yamhill Counties are forested.
Approximately one-half the forests in the region are owned
by the state or federal government, a portion of which is
available for recreational-open space use.
Approximately 1,000,000 acres (30 percent) of the region
are agricultural land. Average farm size in 1974 ranged from
7 2 to 195 acres (U. S. Department of Commerce, 1977). Seventy
percent of farm land in the valley is utilized for crop pro-
duction, of which wheat and hay are most common. The annual
market value of crops in the valley was over $155,000,000 in
-------
Present land use of the Clackamas-Marion County site
is predominantly timber production and open space to the
southeast and suburban-rural agricultural uses with land
holdings of 2 acres or greater over the remainder of the
site (Figure 6). Agricultural land in farms of 20 acres
or more extends across the northeast corner and southwest
half of the site. Average farm size in 1974 was 72 acres
in Clackamas County and 118 acres in Marion County (U. S.
Department of Commerce, 1977).
Small agricultural landholdings in suburban and some
rural-agricultural areas are used as grazing land for small
numbers of cattle, horses and sheep. Areas of more intensive
agricultural uses in Clackamas County produce mainly hay,
seed crops and grain. In Marion County, a variety of crops
are grown within the site area including vegetables, tree
fruits and nuts, berries, hops, grass, legume and sugar
beet seed, hay, grain and nursery stock. Some acreage is
also used for livestock and dairying.
Within Clackamas County approximately 20 percent of the
site, predominantly in the southeast corner is zoned for
timber growing and harvesting with a minimum lot size of 20
or 40 acres. Seventeen percent of the site lying south of
Canby is zoned for exclusive farm use with a minimum lot size
of 20 acres. Approximately 12 percent associated with rural
centers is zoned for general use (single-family dwelling,
commercial) with minimum lot sizes of 1 acre or less. Eight
percent is zoned rural-agricultural with lots ranging from
a 1- to 5-acre minimum. The remaining 43 percent of the site
within Clackamas County is currently unzoned (Clackamas
County Planning Department, 1978 zoning map).
The majority of land in Marion County within the site
is zoned for exclusive farm use. Within rural centers land is
zoned residential-agricultural with a minimum lot size between
6,000 square feet and 1 acre. Surrounding rural centers,
limited acreage is zoned for farm use with a minimum lot size
of 20 acres (Marion County Planning Department, pers. comm.).
Major routes of transportation into the site area are
Interstate 5, State Highway 99E, 211, 213 and 224.
Proposed Land Use. Land use trends on the Clackamas-
Marion County site most likely reflect overall county trends.
In Clackamas County the population has increased approximately
4 percent annually* resulting primarily in reductions of
agricultural land. Acreages of land in farms have decreased
from 210,000 acres in 1969 to approximately 174,300 acres in
1974, which represents a 17 percent decrease in 5 years
(Clackamas County Planning Department, 1974). In Marion County
42
-------
FIGURE 6
GENERAL LAND USE AREAS
CLACKAMAS & MARION COUNTY SITE
BORING
DAMASCUS
*
NAMON COUNTY
CLACKAMAS COUNTY
L_ EGEND-
SUBURBAN/RURAL CENTERS
URBAN -OREGON CITY
AGRICULTURAL - 20 ACRES
43
SUBURBAN - 5 ACRES
RURAL 5-20 ACRES
7/////\ FOREST -20 ACRES
SOURCE: CLACKAMAS COUNTY PLANNING DEPARTMENT, 1974
MID WILLAMETTE VALLEY COUNCIL OF GOVERNMENTS , 1972
-------
acreages of land in farms has also decreased in recent years.
In 1964 a total of 333,624 acres of county land was in farms.
In 1974 this total dropped to 295,285 (U. S. Department of
Commerce, 1977). This represents an annual decrease of 1.2
percent in agricultural land while county population increased
2.5 percent annually during the same period (Mid Willamette
Valley Council of Governments, 1972).
Present and Projected Populations
Present and projected populations of the study area
are important in two respects: 1) as the contributing
source of sewage sludge and 2) from the standpoint of pro-
ject impacts on residents.
City of Portland Service Area
According to the CRAG 208 Study (1977) the 1975 popula-
tion of the City of Portland service area is 450,595. This
estimated population includes the Columbia Boulevard STP
(CBSTP) and the Tryon Creek STP (which contributes sludge to
the CBSTP) (see Table 6). The City of Portland service area
encompasses an area larger than the official City of Portland
boundaries. Other areas included are the City of Lake Oswego,
portions of the City of Milwaukie and some unincorporated
portions of Multnomah, Clackamas and Washington Counties (City
of Portland, 1976).
The future (year 2000) population of the service district
is projected to be 505,471, a 12 percent increase during a
25-year period.
Morrow County
Morrow County is a sparsely populated county of approxi
mately 5,2 00 people located 160 miles east of the City of
Portland. Major communities in the county include Heppner
(the county seat), Boardman and Irrigon.
In recent years the county has been the focal point of
substantial population growth resulting primarily from
agricultural expansion and related economic activity.
Approximately 50,000 acres in northern Morrow County have
come under irrigation in the past few years.
Boardman has experienced substantial growth during the
past 5 years. The most recent estimate is 1,100 people in
1976 (Pacific Northwest Regional Commission, 1977), a
dramatic increase from the 1970 population of 190.
44
-------
Table 6
PORTLAND SERVICE DISTRICT 1975 POPULATIONS AND PROJECTIONS OF POPULATION FOR THE YEAR 2000
1975
2000
Columbia Boulevard STP
Total
Service
Area
Population1
404,986
Estimate of
Population
Actually
Sewered
263,241
Total
Service
Area
Population1
437,865
Projected
Population
Actually
Sewered*
380,943
Tryon Creek STP
45,609
34,663
67,606
58,817
450,595
297,904
505,471
439,760
1 Populations taken from Technical Supplement 8 of the CRAG Sludge Management Study.
These represent final population estimates and differ from the preliminary estimates
presented in the City of Portland's Alternative Methods for the Disposal of Sewage
Solids report (Table 1, page 16).
2 The estimates of the population actually sewered within the Portland Service District
are from Nunamaker (pers. comm.). A portion of the unsewered population contributes
sludge from septic tank pumpage.
-------
Table 7 depicts the present and projected growth of
Morrow County and Boardman based on several scenarios of
growth developed by the East Central Association of Counties
(ECOAC, 1977).
The City of Boardman is approximately 3 1/2 miles northeast
of the three possible sites for sewage disposal.
Clackamas County
The proposed North Willamette sludge application area
encompasses approximately 400 square miles. The nearest
major population centers are Oregon City with a 1975 popula-
tion of 12,460/ West Linn with a population of 8,800 and
Gladstone with a population of 8,120.
According to the CRAG 208 Study, the 1975 population of
the sludge application area was approximately 14,000. Popula-
tion projections for the year 2000 estimate a 110 percent
increase from the 1975 population to 29,4 00*
Laws, Rules, Policies and Institutional Practices
A checklist of governmental agencies and departments having
regulatory authority and/or planning responsibility affecting
the planning implementation and operation of a sludge disposal
project by the City of Portland follows.
U. S. Environmental Protection Agency
The Environmental Protection Agency (EPA) is charged with
administering the Federal Water Pollution Control Act (PL 92-500),
the Federal Clean Air Act and the Federal Safe Drinking Water
Act. Under terms in the Water Pollution Control Act, EPA was
required to prepare and enforce minimum water quality standards
for the nation. The 1972 amendments to this act established
the National Pollution Discharge Elimination System, which
allows EPA to require a permit for any discharge of waste
materials to a waterway.
46
-------
Table 7
PRESENT AND PROJECTED POPULATIONS - MORROW COUNTY AND CITY OF BOARDMAN
Scenario1
19702
19752
1976 3
19801*
20001*
Morrow County
A
4,470
5,190
-
7,290
10,590
B
-
-
-
9,910
11,590
C
-
-
-
-
13,300
Boardman
A
190
700
1,100
1,280
2,370
B
-
-
-
2,620
2,900
C
—
—
—
—
3, 410
1 Scenarios A-C established by East Central Oregon Association of Counties (ECOAC)-
See Appendix D for assumptions made by ECOAC in their population projections.
2 U. S. and Oregon census.
3 Population estimate from Pacific Northwest Regional Commission (1977).
* ECOAC projections.
-------
To comply with the 1972 Water Pollution Control Act
timetable, all treatment plants discharging to surface waters
were to meet the federal secondary treatment effluent require-
ments by July 1, 1977 (listed in Federal Register, Vol. 40,
No. 159, August 15, 1975 - see Table N-5). Portland is in
compliance with the secondary treatment requirement. By
July 1, 1983, all municipal treatment facilities must have
instituted "Best Practicable Waste Treatment Technology".
By July 1, 1985, municipal treatment facilities must have
reached a condition of no discharge of pollutants. In this
definition, complete elimination of discharge is not implied;
only elimination of discharge of pollutants, where a pollutant
is defined as anything that adversely affects the quality
of water necessary to support a beneficial use.
The act was recently amended (December 1977) and EPA
is in the process of preparing regulations.
Under Section 208 of the Federal Water Pollution Control
Act, EPA is also responsible for approving plans and programs
to control "non-point" source pollution. The state must
identify regions with "substantial water quality control
problems" and authorize a single organization to operate
"a continuing areawide waste treatment management planning
process". The Columbia Region Association of Governments
(CRAG) recently conducted an "Areawide Waste Treatment Manage-
ment Study" to satisfy the 2 08 planning requirements of the
Federal Water Pollution Control Act. This plan is presently
under review by EPA.
To achieve the goals of PL 92-500 EPA participates in
the funding (75 percent) of the Clean Water Grant program
which enables wastewater system improvement projects. This
funding system is operated jointly with the state; the
DEQ has been given responsibility in administration of the
program. This EIS is a required element in the application
for Clean Water Grant funds by the City of Portland.
In administering the Federal Clean Air Act, EPA has
established National Ambient Air Quality Standards. These
standards are designed to protect human health from the
effects of chronic air pollution. Any project that creates
local air pollution conditions in excess of NAAQS may have
federal funding withheld.
The Federal Safe Drinking Water Act of 1974 required EPA
to set standards for drinking water quality and to establish
guidelines for state regulation and enforcement of these stan-
dards. It also gave EPA the responsibility of protecting under-
round sources of drinking water. Protection will probably
e implemented by requiring permits for injection of wastes
48
-------
into usable aquifers and by prohibiting waste disposal operations
that will endanger the quality of drinking water sources.
National interim primary drinking water regulations were
recently released by EPA (Federal Register - Vol. 40, No. 248 -
Wednesday, December 24, 1975). Any option of land disposal
of wastewater or sludge adopted as part of this proposed
sludge disposal project will be analyzed by EPA for its
effects on local drinking water supplies.
In November 1977, the EPA issued a technical bulletin
concerned with the environmental factors associated with
municipal sludge management (42 CFR, No. 211, November 2,
1977). The bulletin addresses factors important to the
environmental acceptability of particular sludge management
options. Acceptable methods of sludge utilization and disposal
are presented, emphasizing the return of sludges to the
environment in an ecologically acceptable manner. These
sludge management guidelines are presented in Appendix A of
this EIS.
In the November 1977 technical bulletin the EPA stated
that the establishment of allowable levels for heavy metals
and other contaminants in sludges applied to the land
(specifically agricultural land) are planned to be developed
and published under the Solid Waste Disposal Act as amended
by the Resource Conservation and Recovery Act of 1976
(PL 94-580). Until such time , EPA considers the report
Application of Sewage Sludge to Cropland: Appraisal of
Potential Hazards of the Heavy Metals to Plant and Animals
prepared by the Council for Agricultural Science and Technology
(EPA 430/9-76-013; November 1976), to represent the most current
information available on the potential effects on agricultural
crops and animals by heavy metals in sewage sludges applied
to cropland. Table 8 illustrates current recommendations
for the agricultural land disposal of heavy metals contained
in sewage sludge.
Public Law 94-580 amending the Solid Waste Disposal Act
was passed in October 1976 giving EPA broad authority in the
regulation of solid waste disposal. Major emphasis is placed
on the design and operation of sanitary landfills; the law
also includes grants to states to develop solid waste
management plans, a federal ban on open dumping and resource
recovery encouragement. On May 12, 1977, the EPA Office
of Solid Waste produced a working draft of proposed regulations.
Sludge is identified as solid waste with the notation that
7.3 million tons are produced in the United States each year?
this represents a potential threat to public health.
49
-------
Table 8
MAXIMUM CUMULATIVE SLUDGE
METAL APPLICATION LIMITS
Soil cation exchange capacity
(milliequivalents per lOOg)
0-5 5-15 >15
Metal Amount of Metal (kilograms
per hectare)
Zinc
250
500
1,000
Copper
125
250
500
Nickel
50
100
200
Cadmium
5
10
20
Lead
500
1,000
2,000
Source: 42 CFR, No. 211; November 2, 1977
U.S.D.A./ October 1976
50
-------
The EPA Office of Solid Waste has been placed under the
jurisdiction of the Assistant Administrator for Water and
Hazardous Materials for coordination with the clean water
grant program of PL 92-500 to give a unified regulatory program
within EPA. EPA has identified two sludge management task
forces to (1) develop an overall agency strategy for municipal
sludge and (2) to prepare guidelines for land disposal of
sludge as required in Section 1008 of the Resource Conservation
and Recovery Act. The results of this latter task are expressed
as the technical bulletin on municipal sludge management
(42 CFR No. 211) as previously described.
On February 6, 1978, the EPA published Proposed Classi-
fication Criteria dealing with solid waste disposal facilities
(43 CFR No. 25, February 6, 1978). These proposed regulations
contain minimum criteria for determining which solid waste
land disposal facilities shall be classified as posing no
reasonable probability of adverse effects on health or the
environment. These proposed criteria are important in that
they relate also to municipal sewage sludge, specifically when
applied to land used for the production of food chain crops.
Criteria were proposed dealing with cadmium limitations in
crop production (43 CFR, No. 25, February 6, 1978).
U. S. Food and Drug Administration
The U. S. Food and Drug Administration (FDA) is responsible
for promulgating recommended acceptable levels of various
contaminants in human and animal foods.
The FDA recently responded to the EPA's draft technical
bulletin on municipal sludge management (41 CFR, No. 108;
June 3, 1976) by stating that the limitations for sludge usage
to protect the public health were not adequately addressed.
The FDA supports the cadmium and lead limitations shown in
Table 8 and further recommends that sludges containing
over 20 ppm (mg/kg) cadmium and/or 1,000 ppm (mg/kg) lead
not be used on agricultural land and crops.
U. S. Advisory Council on Historic Preservation
The Advisory Council is responsible for ensuring that ^
the procedures for protecting historic and cultural properties
are fulfilled under the National Historic Preservation Act
of 1966. The Council reviews federal, federally assisted
and federally licensed undertakings affecting cultural resources
(36 CFR Part 800).
51
-------
U. S. Army Corps of Engineers
The Corps of Engineers has jurisdiction over uses of
all navigable waterways in the United States. The construction
of any structure (i.e., barge loading and unloading docks)
will require Corps permit approval.
U. S. Coast Guard
The conveyance of sludge by barge will have to be in
conformance with U. S. Coast Guard regulations for the
commercial shipping of hazardous materials.
Oregon Department of Environmental Quality
In September 1977, the DEQ issued proposed regulations
and guidelines regarding the "handling, disposal and use of
municipal sludge relating to land application". These
regulations prescribe the manner in which sewage sludge
can be transported, disposed of or used beneficially for
agricultural purposes.
The DEQ regulates the disposal of sewage sludge through
NPDES and state permits. All disposal sites, sludge handling
and support facilities and disposal operations must be approved
by the Department.
52
-------
ALTERNATIVE SLUDGE HANDLING SYSTEMS
Introduction
The United States Environmental Protection Agency (EPA)
promulgated regulations outlining minimum requirements
comparing project alternatives in the preparation of an EIS
(Federal Register of April 14, 1975, CFR 40, Part 6). The
comparative evaluation should include an analysis of the
environmental impacts, commitments of resources, costs and
societal risks associated with each alternative. The reasons
why a proposed alternative management system is finally
selected must also be explained in detail. This section
contains a description of the alternatives considered for
this project and evaluations relative to cost and engi-
neering considerations.
This comparative evaluation and alternative selection
is accomplished by what the EPA has termed cost-effective-
ness analysis. The cost-effectiveness analysis is defined
by the EPA as:
"The waste treatment management system determined from
the analysis to have the lowest present vrorth and/or equivalent
annual value without overriding adverse nonmonetary costs and
to realize at least identical minimum benefits in terms of
applicable Federal, State and local standards for effluent
quality, water quality, water reuse and/or land and subsurface
disposal."
The cost-effectiveness analysis therefore incorporates the
total project costs, technical and environmental considera-
tions of the alternatives, ability to implement each alter-
native, public and agency comments on the project, and
miscellaneous considerations relative to specific project
constraints.
The Facility Plan for which this draft EIS has been
prepared is titled Alternative Methods for the Disposal of
Sewage Solids. It was developed by the Department of PuETic
Works of the City of Portland. A sludge management study
was originally developed for the City of Portland by Stevens,
Thompson and Runyan, Inc., Consulting Engineers, and was
published in 1972; the study recommended incineration of
the sludge followed by landfill of the resulting ash. This
recommendation evoked considerable public reaction and a
formal hearing was held where written and oral testimony
was received. Following the hearing the city made its
evaluation and prepared a Facility Plan on alternative sludge
management systems in accordance with EPA regulations. The
initial study was submitted for review on September 2. 197 6
and the final report became available on March 3, 1977.
53
-------
The existing sludge disposal sites were projected to be
at capacity by about 1980. The sludge management study was
undertaken to develop a long-term solution for the disposal
or reuse of an estimated 90 tons/day of sludge by the year
2000. The eventual solution should provide an economical,
reliable, socially acceptable and environmentally sound sludge
handling system compatible with both the existing treatment
processes at the city's main Columbia Boulevard treatment
plant and the recommendations of the Columbia Regional Asso-
ciation of Governments (CRAG) Areawide Waste Treatment
Management Study (208 Plan).
The Facility Plan and this draft EIS deal specifically
with the handling of the sludge to be generated at the Columbia
Boulevard plant. Detailed consideration is not given to the
wastewater collection systems nor the existing or proposed
treatment systems at the Columbia Boulevard plant. The
alternative sludge management systems evaluated include all
systems presented in the Facility Plan and additional alterna-
tives that appear to provide similar benefits to the city.
Constraints
In developing alternative sludge handling systems it
should be recognized that both regulatory and nonregulatory
constraints are imposed upon facility selection. The princi-
pal constraints influencing the development of alternatives
for the sludge handling and disposal system are:
0 PL 92-500 - Federal Water Pollution Control Act
Amendments of 1972.
0 EPA Cost-Effectiveness Analysis guidelines.
0 Oregon State Department of Environmental Quality
and the EPA National Pollutant Discharge Elimination
Systems (NPDES) Permit.
Federal Register, Vol. 42, No. 211, November 2, 1977.
0 EPA Municipal Sludge Management, Federal Register,
Vol. 42, No. 211, November 2, 1977T
0 Oregon State Department of Environmental Quality,
Handling, Disposal and Use of Sewage Sludge.
0 U. S. Environmental Protection Agency and Oregon
State DEQ, general regulations covering ocean dumping,
air pollution emissions and other process-related
standards.
54
-------
0 Non-regulatory constraints relating to considerations
of time of implementation, energy consumption,
operational reliability, existing facilities and
committed or ongoing facility construction.
Public Law 92-500, the Federal Water Pollution Control
Act Amendments of 1972, gives the EPA the responsibility for
establishing waste discharge criteria, both liquid and solid,
for all federally-funded wastewater treatment facilities.
The EPA Cost-Effectiveness Analysis Guidelines provide a
uniform method for computing the costs of wastewater treat-
ment alternatives. The term "cost-effectiveness analysis"
has already been defined as encompassing more than just the
dollar value of each candidate alternative. These guidelines
delineate the planning period over which the alternatives should
be evaluated, the elements of cost that should be included,
the interest rate that must be used, guidance on the service
life of various types of facilities, and the salvage value
that should be used for the proposed projects. They provide
a uniform and standardized procedure for comparing the cost
of the various project alternatives. Considering that the
guidelines do not permit the inclusion of speculative pro-
jections of inflation, changing interest rates, etc., the
comparative costs for each alternative do not represent the
actual "true" cost of a project over the planning period.
However, they do approximate the costs and present a uniform
method for comparing alternative systems within a project.
The Oregon State Department of Environmental Quality
and the EPA must issue an NPDES permit to ensure that the
proposed facilities achieve the desired standards for waste-
water discharge as well as sludge disposal. Therefore, the
NPDES permit establishes specific requirements for the dis-
posal of liquid and solid wastes, which greatly influence
methods of treatment and handling. In the formulation of
the project alternatives, only those that will meet the
NPDES permit requirements are considered feasible.
The federal and state guidelines for municipal sludge
management apply principally to the beneficial use or
disposal of sewage sludge on the land. The guidelines
present allowable loading rates for agricultural uses
including crop types. These guidelines place restrictions
on land application of sludge, limitations on public access
to the site, and amounts of surface runoff, infiltration to
groundwater and heavy metal concentrations. The guidelines
are therefore related principally to the beneficial use of
sludge and the protection of the environment and public health.
55
-------
The regulations governing the ocean discharge of sewage
solids, which were not enforced prior to 1971, basically
prohibit the use of the ocean as a disposal means. Ocean
disposal simply makes use of the large dilutional capacity
of the ocean to dispose of sewage sludge. Through the Marine
Protection, Research and Sanctuaries Act and the Water
Pollution Control Act Amendments of 1972, the EPA was
directed to promulgate regulations governing ocean discharge.
Based on these regulations, only those facilities that
currently operate an ocean dumping program can operate if
they meet regulatory criteria. The Oregon State DEQ and the
EPA both do not permit ocean dumping off the Oregon coast
line.
Other regulations cover air emission standards that parti-
cularly affect incinerations of sludge and other heat treat-
ment systems. Because of the stringent air quality standards
required by these regulations, heat treatment processes
consume greater amounts of fuel than previously.
The sludge management alternative ultimately selected
for Portland should also be compatible with the Columbia
Region Associations of Governments, Area-wide Waste Treatment
Management Plan. Any proposed sludge handling system that
is not compatible with the plan may require amendment of the
plan, which would be difficult, time-consuming and costly.
Alternatives chosen by the city conform to regional planning
expectations.
The nonregulatory constraints include the time for
implementation of a system and the direction taken for sludge
treatment, i.e., the Phase I project. Implementation and
operation of the system by about 1980 assumes importance when
it is considered that the existing disposal sites are projected
to be at capacity. The committed direction of sludge management
relates to existing or soon to be constructed treatment facilities
that exclude some potential sludge handling systems, or at
least lead to increased costs, that make a particular alterna-
tive not cost-effective.
Existing Oregon Programs for
Land Application of Sewage Sludge
Since 197 2, the City of Salem, Oregon, has applied
liquid sewage sludge to farm lands in the vicinity of the
Willow Lake STP. These agricultural applications started
informally but became a full-scale, regulated disposal
program in 1975.
56
-------
During 1976, the City of Salem spread over 8,250,000
gallons (approximately 1,400 dry tons) of BIOGRO onto
agricultural lands within a 7-mile radius of the sewage
treatment plant. In 1977 the amount of sludge applied
increased to over 22,500,000 gallons (approximately 3,755
dry tons). Annual application rates have approximated
12,000 gallons (2 dry tons) per acre.
Sludge application is dependent upon weather conditions
and the weight-supporting conditions of field soils. The
use of sludge spreaders with extra-large tires has reduced
problems of soil compaction when fields are moist. The
best time for sludge application has been when the fields
are driest. Sludge generated during the winter months is
stored in lagoons at the Willow Lake plant.
Chemical analyses of Willow Lake plant sludge indicate
that Salem sludge is relatively high in total nitrogen
(6.2 percent) and low in heavy metals; copper - 296 ppm;
nickel - 33 ppm; cadmium - 8 ppm; lead - 400 ppm; zinc - 1,300 ppm;
and chromium - 60 ppm. The high nitrogen value and low levels
of heavy metals make Salem sludge particularly attractive as
an agricultural fertilizer.
The agricultural lands on which the BIOGRO is spread
are approved for this purpose by the DEQ.
Several other small treatment plants have also applied
sludge to agricultural lands in the Willamette Valley. The
Oak Lodge STP and Oregon City STP report having favorable
results from land application (Norman, Abraham, pers. comm.;
Snyder, letter to G. Ward, February 1975). A description of
present land application systems in the Portland region is
presented in the CRAG Sludge Management Study, Technical
Supplement £, Appendix B.
Description of Alternatives
A total sludge handling system (treatment, conveyance,
storage and disposal) can be formed from a variety of
individual processes and therefore the final selection of a
system must be based on an economic and environmental
evaluation of the more viable systems. Selection of these
systems will be based upon a consideration of the existing
facilities at the Columbia Boulevard plant, the project sludge
quantities and the compatibility with the regional plan.
This chapter therefore identifies these considerations and
describes those alternatives considered and the reasons for
screening or eliminating certain of the alternative sludge
handling systems.
57
-------
The sludge disposal sites now used by the City of Portland
are projected to be at capacity by about 1980. Consequently,
the handling, treatment and subsequent disposal of these
solids represent an immediate problem to the City of Portland.
Portland's two wastewater treatment plants currently yield
approximately 65 tons of sludge per day and are projected
to yield 90 tons of sludge per day by the year 2000.
Existing City of Portland Treatment Facilities
The City of Portland currently owns and operates two
wastewater treatment plants which are projected to serve
approximately 136 square miles of residentially, commercially
and industrially zoned areas. These areas are located within
the City of Portland, the City of Lake Oswego and portions
of unincorporated areas in Multnomah and Clackamas Counties
as well as a small area of the City of Milwaukie. The larger,
Columbia Boulevard plant also handles septic and holding
tank pumpings from the surrounding tri-county area of Washing-
ton, Multnomah and Clackamas and unprocessed sludges from
the Tryon and Clackamas Counties , Kellogg Creek plants.
The two city plants process a combined average daily
wastewater flow of about 71.5 mgd in the summer and 106 mgd
during the winter months. The Columbia Boulevard plant is
located close to the Columbia River and about 2 miles west
of Interstate 5. The smaller Tryon Creek plant is located
adjacent to the Willamette River immediately north of Lake
Oswego, and within the corporate limits of the City of Lake
Oswego. Both plants and the potential service area for these
two plants are shown in Figure 7. The existing treatment
facilities are briefly described below.
Columbia Boulevard Wastewater Treatment Plant. The
Columbia Boulevard Wastewater Treatment Plant hasa design
capacity of 100 million gallons per day with a maximum
hydraulic flow capacity of 300 million gallons per day. The
plant provides secondary treatment. A description of the
wastewater treatment process can be found in the facilities
plan report.
The clear liquid overflow from final clarification
basins is disinfected by the addition of chlorine. The
disinfected final effluent then flows to the Columbia River
through an outfall sewer.
The solids from the treatment processes are treated
differently than the wastewater. The grit and screenings are
taken to the sanitary landfill. The primary sludge is
degritted and pumped to gravity sludge thickeners where the
58
-------
Figure 7
v//)
y,
L
I
5&-
L...
'CL XcVa m a|^(5ount y
'MILWAUKIE v^
.KELLOGG
OAK U3DGE
L GLADSTONE.
WEST LINN
A.
' y^WILLAMETTE
TRI- CITY
OREGON CITY
LEGEND
CITY OF PORTLAND
SERVICE AREA 59
FROM: City of Portland, 1976
CITY OF PORTLAND SERVICE AREA.
CITY OF PORTLAND BOUNDARY
COUNTY BOUNDARIES
Ak CITY OF PORTLAND SEWAGE TREATMENT PLANTS
/\ OTHER TREATMENT PLANTS
-------
water content of the sludge is reduced. Water overflowing the
sludge thickener is returned to the primary sedimentation
basins. Thickened sludge, 7 percent concentration, is
collected and pumped to four anaerobic digesters. These
digesters stabilize the sludge and at the same time reduce
its volume by approximately 40 percent. The methane produced
by anaerobic digestion is used to fire boilers that maintain
the digesters at a 95°F temperature as well as providing
supplemental fuel for boilers that heat buildings. The
stabilized or digested sludge is applied to Port of Portland
property near Terminal 6 (the Rivergate Industrial District
area), as a soil conditioner or is pumped to the Triangle Lake
sludge lagoon for storage. Excess liquid from the digestion
process, called supernatant, is returned to the primary sedi-
mentation basins.
Sludge from the secondary sedimentation basins is either
returned to the aeration basins or pumped to tanks (waste-
activated sludge) for further processing and disposal. This
waste sludge is thickened by centrifuges and as much as 40
percent is pumped to the anaerobic digesters for stabilization
with the primary sludge. The remaining waste-activated sludge
is aerobically digested, using two of the aeration basins,
and then pumped to the Triangle Lake sludge lagoon.
The city also has the option of combining thickened
primary and secondary sludges and heat-treating the mixture.
The treated sludge is dewatered by vacuum-filtration and
often heat treated before being transported to the city's
sanitary landfill.
The Columbia Boulevard plant processes approximately
19,000 gallons per day of undigested sludge from the Clackamas
County, Kellogg Creek plant and 17,000 gallons per day of
digested sludge from the city's smaller Tryon Creek plant.
These sludges are conveyed by tank truck to the Columbia
Boulevard plant.
Tryon Creek Wastewater Treatment Plant. The Tryon
Creek Wastewater Treatment Plant is being expanded from 5 to
8.3 million gallons per day. The plant provides secondary
treatment to the wastewater. Wastewater flows are conveyed
in two gravity sewers to the Tryon Creek plant from the City
of Lake Oswego and the southwest Portland area. After
treatment the chlorinated effluent is discharged to the
Willamette River.
The sludge collected from the primary sedimentation
basins is pumped through a degritting mechanism to gravity-
thickening basins. The thickened sludge withdrawn from the
bottom of the tank is pumped to the anaerobic digesters and
60
-------
the water overflowing the top of the basins is returned to
the primary clarifiers. As previously explained the methane
produced by the anaerobic digesters is used to maintain the
digesters at a constant 95°F. The digested, or stabilized
sludge, is hauled by truck to the Columbia Boulevard plant
or to the Rivergate Industrial District for incorporation
into the soil. The excess liquid (supernatant) from the
digesters is returned to the primary clarifiers.
Existing Sludge Disposal
The existing sludge handling systems at both the
Columbia Boulevard and Tryon Creek plants have been described.
Ultimate use and disposal practices for the sludges generated
at these plants have also been briefly identified. This
section, however, includes a more detailed analysis.
Current Sludge Production Quantities, The sludge pro-
duction from the two city-owned treatment plants is
reasonably predictable because it is directly related to
the characteristics of the raw influent wastewater. The
1975 average daily flow rates for these plants as well as
the historically averaged concentrations for the BOD and
suspended solids are given in Table 9. Using these;values
and assumptions about the removal efficiencies of the various
treatment processes, an estimate of the sludge quantities can
be computed. The computed values can then be checked easily
against the measured sludge production. The measured sludge
quantities for the two plants for the year 1976 are shown in
Table 10,together with the values computed from the influent
wastewater characteristics. The digestion process reduces
the quantity of sludge to be handled by approximately 40
percent, and therefore the amount of sludge produced for
disposal is about 60 percent of the values shown in Table 10.
The computed and measured sludge quantities in Table 10
show close agreement; therefore, the computational procedure
is considered suitable for projecting future sludge quantities.
Current Sludge Disposal Methods. Although the City of
Portland currently has available three methods for disposing
of sewage sludge, all three are considered temporary and are
collectively projected to serve the city only to about 1980.
Each of the three methods is discussed below.
Sludge Soil Stabilization. This method involves incor-
porating the stabilized sludge into the soil on vacant,
industrial lands in the Rivergate Industrial District. The
land is owned by the Port of Portland and is zoned for in-
dustrial development. This method has proven to be a
successful soil conditioning agent by binding the soils, which
then provide the necessary medium for ground cover growth
and thus the prevention of wind erosion. The availability
61
-------
Table 9
AVERAGE WASTEWATER CHARACTERISTICS, 1976
Columbia Boulevard Tryon Creek
Parameter Units Plant Plant
Flow mgd 76.1 4.6
BOD mg/1 166 175
SS mg/1 140 154
Table 10
MEASURED AND COMPUTED SLUDGE QUANTITIES FOR 1976
Sludge Type
Units
Screenings cu ft
Primary Sludge lbs/day
Secondary Sludge lbs/day
Total Primary
+ Secondary
Columbia Boulevard
Plant
Tryon Creek
Plant
Measured Computed Measured Computed
75
63,100
39,500
76
59,000
42,500
lbs/day 102,600 101,500
8,000
5
3,800
2,800
6,600
62
-------
of this area for continued sludge incorporation is directly
dependent upon the rate of industrial growth in the area.
At the time of the study immediate growth was projected, but
it apparently did not materialize. Since the initial pro-
jection revised projections show that the capacity of the
area may be reached between 1985 and 1988, based on slower
industrial development.
Sludge Lagooning. Under this disposal method most of
the digested, waste-activated sludge and part of the primary,
digested sludge is pumped to a sludge lagoon. This lagoon,
called Triangle Lake, is located immediately north of the
Columbia Boulevard plant, close to the Oregon Slough. The
detention time in the lagoon is sufficient to allow the
solids to settle to the bottom of the lagoon where they
undergo additional anaerobic digestion and slowly accumulate.
The liquid, or supernatant, then flows through three polishing
ponds where the BOD is reduced. The final effluent from
these ponds is heavily disinfected with chlorine and dis-
charged to the main outfall sewer for conveyance to the
Columbia River.
The sludge lagoon has been operational since 1970 and,
due to the accumulation of solids, is now nearing its
capacity. On the basis of existing practices, the lagoon
system is projected to be full prior to 1980 unless the
solids are removed and disposed of elsewhere. A potential
solution is to incorporate sludge from the lagoon into soils
at the Rivergate Industrial District area. Once emptied,
the lagoon will be upgraded and it may then be used again for
sludge storage.
Sanitary Landfilling. This third method of sludge
disposal permits sterilizing the sludge prior to dewatering
and hauling to the St. Johns sanitary landfill. The treat-
ment consists of subjecting the sludge to high temperatures
and high pressure, similar to a pressure cooker. The treated
sludge is then vacuum-filtered to achieve a solids content
of 3 0-35 percent and hauled by truck to the landfill. This
disposal method is not often used due to the high cost of
operating the heat treatment and dewatering equipment. Also,
St Johns is approaching its maximum capacity. On the basis
of historical quantities hauled to this particular landfill/
its projected useful volume will be reached by about 1980.
Regionalization and Sludge Quantity Projections
Regionalization Considerations. The regionalization of
wastewater treatment facilities has been widely promoted for
reasons of reduced cost and improved operations. The Water
Pollution Control Act Amendments of 1972 encouraged the
implementation of a regionalized system by requiring that at
63
-------
least one alternative provide a regional approach to the
project being studied. The objective of a regionalized
system therefore is to provide the most cost-effective method
for wastewater handling and treatment. However, the single
large facility approach toward regionalization is changing to
the point where the planning alone is done on a regional
basis with facility construction being divided into smaller
areas. The term "cost-effectiveness" has already been defined;
essentially it comprises three costs: monetary or dollar
costs, environmental costs, and social costs. Only the
monetary costs are considered; the others are considered later
in this report. Typically, environmental and social costs
are judgmental. The cost-effective alternative, therefore,
is that alternative judged to have the least overall social,
environmental and monetary cost.
Regionalization has many advantages, including economy
of scale in construction and annual operation and maintenance
costs, a larger base for the distribution of costs, one
operating authority for treatment facilities, treatment
process efficiency control, easier incorporation of new develop-
ment into the system, and the ability to plan for an area-
wide or total basin. The principal disadvantage of region-
alization is the loss of local autonomy wherein local govern-
ments or agencies frequently enter some kind of intergovern-
mental agreements in which local responsibilities are
extended beyond individual member control.
An areawide Waste Treatment Management Study has just
been completed by the Columbia Region Association of Govern-
ments (CRAG), which has studied numerous treatment alterna-
tives for the greater Portland Metropolitan area and outlying
communities. Regionalization was studied for four areas which
are separated by natural topography. These areas are generally
the service areas of the following wastewater treatment plants:
the Columbia Boulevard, Inverness, Gresham, Troutdale, Sandy
and Tryon Creek wastewater treatment plants; the Happy Valley,
Kellogg (CCSD No.l), Oak Lodge and Tri-City plants, and possibly
the Tryon Creek plant; the Unified Sewerage Agency treatment
system; and the Wilsonville and Canby wastewater treatment
plants.
On the basis of regionalization for sewage solids only
the Columbia and Kellogg regions have any bearing on this
study. The CRAG study concluded that if the Columbia Boulevard
plant were expanded within the 20-year planning period {to
reduce combined sewer overflows), only then would a regional
plant concept become attractive for the Columbia region, if
the issue of treating combined sewer overflows is not decided,
then regionalization around the Gresham plant is recommended
for Inverness and Troutdale with the Sandy plant remaining
64
-------
autonomous. Regionalization has not been chosen. The favored
method of sludge handling in all cases was by land application
of liquid stabilized sludge on private lands. Sludge from
the Columbia Boulevard plant is proposed to be barged to eastern
Oregon for soil incorporation. The sludge from the other
plants should be reused primarily on agricultural land in
eastern Multnomah County and/or northern Clackamas County.
The CRAG study recommendations for the Kellogg Region
would result in different handling of the wastewater and
sludge. The analysis in that study indicated no preference
nor significant advantage for consolidation of treatment plants.
The only recommendation is that flows greater than the
capacity of the Oak Lodge plant should be treated at the
Kellogg plant. However, in treating sludge from these plants,
a joint program of liquid sludge application to private lands
is recommended as being less costly and environmentally
beneficial. The CRAG study identifies the land having the
greatest potential for sludge application as being southeast
of Oregon City, although recognizing that other sites may
also be suitable. The current practice of dewatering a
nominal quantity of sludge on sand drying beds is also
encouraged to provide for community reuse of the sludge.
The City of Portland's Tryon Creek plant is located
within this region. Stabilized sludge from this plant is
currently handled together with the sludge from the Columbia
Boulevard plant, as already described, and the Facility Plan
shows a continuance of this practice. However, the CRAG
study analysis indicates that it may be more economical for
the Tryon Creek plant to treat and dispose of sludge
independently of the Columbia Boulevard plant. Two methods
are suggested: the first is to operate an independent land
application system in the area southwest of West Linn; the
second is to realize greater cost savings by cooperating with
the other Kellogg Region plants in an overall land applica-
tion operation. A final recommendation was delayed, pending
completion of the City of Portland's studies.
In summary, the CRAG study recommends that the Columbia
Boulevard plant operate an independent sludge management
system. While the study recommendations on sludge handling
from the Tryon Creek plant await the outcome of current City
of Portland studies.
Sludge Quantity Projections. Sludge quantity projections
have been made in the Facility Plan for the City of Portland
to the year 2000. The daily sludge production increase was
assumed to be linear in the intervening years. The CRAG
study has made some preliminary sludge projections for the
other treatment plants in their study area, with the exception
of the USA-Durham plant. Basically, the CRAG study assumed
that because the USA-Durham plant was new and appeared to
65
-------
have sufficient capacity throughout the planning period, the
plant and its service area would not be included in the study.
Additionally, sludge handling facilities at this plant include
incineration of dewatered sludge, resulting in a significantly
reduced quantity of ash to be landfilled. However, sludge
quantity projections for this and the other plants in the area
are reported to identify the potential volumes produced in
the area.
City of Portland Sludge Quantity Pro,j eotions. The City
of Portland, in its Facility Plan, has projected the
sludge quantity as 90 tons per day by the year 2000. This
amount is produced from both the Columbia Boulevard and
Tryon Creek plants and is based on a per capita contribution
of sludge with an allowance for industrial contributions. The
industrial allowance was estimated on what is termed a
"population equivalent" basis. This is the population that
would yield the same quantity of sludge that is contributed by
industries. The Facility Plan identifies several assumptions
upon which the projections were based, and these are repro-
duced here for clarity:
"a. Population and industrial/ccarmarcial contribution to
sludge production will increase in direct proportion to popula-
tion growth within the service area. The total 1975 service area
population, including non-sewered areas, is 459,500. Between
1975 and 2000 population is expected to increase about 13 percent
to approximately 522,000.
"b. Population contribution to sludge production will
increase in direct proportion to the increase in population
connected to the sewerage system. Currently, 66 percent or
302,684 residents of the total service area are connected. By
the year 2000 it is estimated that approximately 90 percent of
the service area, or 466,000 people, will be connected.
"c. Per capita contribution of sludge will increase in the
Tryon Creek Service Area because of more stringent effluent quality
standards for those treatment facilities discharging to the
Willamette River Basin.
"d. An increase in sludge production between 1975 and 2000
is expected to occur at a uniform rate (see Figure 8).
"e. Sludge production in the six areas indicated in Sec-
tion E, Intergovernmental Service Agreements, with the exception
of Clackamas County Service District No. 1, is included in the
sludge production figures through the study period. It is
anticipated that Clackamas County Service District No. 1 will
provide sludge disposal facilities at the Kellogg Creek Sewage
Treatment Plant. The sludge produced in this area is not in-
cluded in the final sludge production figures."
66
-------
Figure 8
PAST AND ESTIMATED FUTURE SLUDGE PRODUCTION
1975 - 2000
C.B.S.T.R SECONDARY TREATMENT ADDITION
2000
YEAR
From: City of Portland, 1976.
67
-------
The historical and projected sludge quantities were
graphically shown in Figure 8.
The projections presented here are again individually
developed by using the influent wastewater characteristics.
On the basis of the above assumptions, the strength and
solids content of the wastewater are assumed to remain
approximately constant with time, and only the wastewater
flow is changed. The CRAG study projects a nominal increase
in the per capita flow from 1975 to 2000. Table 11 shows the
projected sludge quantities using the wastewater character-
istics. Again, these values show close agreement with the
projections in the Facility Plan.
Sludge Projections From Surrounding Areas. The CRAG
study has developed projected sludge quantities for each of
the treatment plants in the study area, and these are
reproduced in Table 12. Also included in Table 12 are sludge
projections for the USA-Durham plant that were not included
in the CRAG study. These were obtained from the Unified
Sewerage Agency.
Relationship of the Tryon Creek, Clackamas County Service
District No. 1 (Kellogg Creek) and USA-Durham Facilities
to the Sludge Disposal Program
The Columbia Boulevard STP presently receives and handles
sludge from two small neighboring sewage treatment facilities:
Tryon Creek STP and the Kellogg Creek STP.
Tryon Creek STP. The Tryon Creek STP presently disposes
of approximately 555,000 gallons of anaerobically-digested
sludge per month at the Columbia Boulevard plant or at the
Rivergate industrial area. Because Tryon Creek is a part of
the City of Portland system, sludge generated at that plant
will be disposed of with that from the Columbia Boulevard
plant. The alternatives considered in the City of Portland's
facility plan included Tryon Creek as a sludge contributor.
The Portland study did not consider Tryon Creek disposing
of its sludge independently from Columbia Boulevard. However,
in the CRAG 208 study, an alternative was developed and
analyzed which considered Tryon Creek independently.
The CRAG alternative (42a) analyzed Tryon Creek applying
liquid sludge to privately owned agricultural lands in South
Clackamas County possibly in cooperation with Kellogg, Tri-
City and Oak Lodge. Land application of sludge for Tryon
would require approximately 8 00 acres. Preliminary analyses
by CRAG indicated that it would be more economical for Tryon
Creek to treat and dispose of sludge independent of the
Columbia Boulevard STP.
68
-------
Table 11
PROJECTED SLUDGE QUANTITIES FOR 2000*
Parameter
Columbia Boulevard
Plant
(tons/day) (1,000 lbs/day)
Tryon Creek
Plant
(tons/day) (1,000 lbs/day)
Primary sludge
47.5
95
3.7
7.4
Secondary sludge
34
68
2.7
5.3
Total
81.5
163
6.4
12.7
SOURCE: City of Portland, p. 46; CRAG population estimates.
* NOTE: These sludge quantities projections were determined by using CRAG
population projections, estimations of the sewered population, assumed
wastewater flow rates, average per capita flows, average concentration of
BOD and SS, and average removals each (65 percent) during sludge processing.
-------
Table 12
PLANNING AREA WASTE FLOW AND SLUDGE VOLUME FORECASTS
(CRAG 208 Areawide Study)
1975
1985
2000
i)
•*j
o
Planning .\rea
Columbia Boulevard0
Inverness
Greshart
Troutdale
Sandy
Happy Valley
Kellogg (CCSD No.
Oak Lodge S.D.
Tri-City
Tryon j
USA-Durham
VSfc-Rock Creek6
Hillsboro East
(Rock Creek)
Hillsboro west
USA-Forest Grove *
USA-Gaston*
USA-Banksf
USA-North Plains
Wilsonville
Canby
Holalla1
Estacada
Government Camp
Timber line Rim/Vtemme/
Zig Zag Village/
Rhododendron
Total
f ,h
Population Population
404.986
46,656
51,204
2,669
2,060
2,278
46,297
21,678
35,244
45,609
91,987
51,112
7,716
8,815
12,706
522
507
778
2,908
5,675
2,760
1,620
510
663
853,621
425,249
50,638
62,336
5,233
3,950
3,475
56,693
25,450
46,584
55,049
124,156
81,146
12,402
11,029
17,770
850
727
1,051
6,538
8,750
3,726
2,578
1,220
1,700
1,008,300
Sludge volume
Sludge Volume
(Ib/dsy)
(lb/da?)
CAS*
population
CAS*
TFb
„
437,865
90 tons
10,828
11,693
55,247
11,953
12,908
12,959
13,995
85,937
17,626
13,035
1,345
1,453
11,234
2,505
2.7CS
761
822
7,275
1,403
1.515
669
722
5.818
1,123
1,213
11,481
12,399
77,382
14,994
16,192
5,051
5*454
27,720
5,999
6,47?
9.016
9,750
66,549
12,913
13,945
10,610
11,450
67,606
13,028
14,C7:
24,600
155,545
31,
234
17,660
112,216
24,458
2,391
16,690
3,216
—
4,455
14,815
4,949
10,500
23,510
12,465
164
—
1,085
208
--
141
—
879
170
—
202
—
1,270.
245
—
1,723
1, B60
14,600*
2,ti25
3,:5i
1,686
1,821
13,000
2,505
2, ~-5
—
5,246
—
—
497
537
4,508
869
—
—
1,545
——
~ -
3,600
1,211,142
a
Conventional activated sludge process for secondary treatment (1,927 lb of sludge produced per million gallons at influent BOD * 20C ng/1 a
TSS - 200 ng/1).
b
Conventional activated sludge process followed by tertiary filtration (2,081 lb of sludge produced per million gallons at influent bod * 2;
mg/1 and TSS * 200 rog/1).
C Combined sludge production of Columbia Boulevard and Tryon Plants. Taken from Portland Sewage Sz'vida Disposal Studies (September 1976).
d
Includes Bock Creek Basin (Clackamas County).
e Sludge production based on information from predesign report. Chemical phosphorus removal for 5 months during summer.
CAS year-around with land application of wastewater effluents assumed during summer months (presently used at Hillsboro West and Forest Grc
¦q
Sludge production based on CRAG projected waste loadings instead of standard influent BOD and TSS values because of sutstantial industrial
^ Average daily sludge production based on CRAG projected waste loadings instead of standard influent BOD and TSS values. Substantial sunder
loadings because of food processors.
No sludge will require disposal from the proposed Nolalla plant.
-------
Kellogg Creek. Primary sludge and thickened secondary
sludge from the Kellogg Creek treatment plant are trucked to
the Columbia Boulevard STP for final processing and disposal.
Kellogg Creek and the City of Portland maintain an open-ended
contract for sludge processing; however, Clackamas County has
recently hired the firm of CH2M Hill to prepare a sludge dis-
posal study for the Kellogg Creek plant and proposed Tri-City
plant (Naef, pers. comm.). Kellogg Creek's sludge contribution
to the Columbia Boulevard plant is approximately 390,000 gallons
per month (CRAG, 1977).
The CRAG Sludge Management Study (1977) evaluated a
regional disposal concept by Kellogg Creek, Tri-City and Oak
Lodge. Eight alternatives were evaluated — five dealing
with land disposal in South Clackamas County, one evaluating
barging sludge to Morrow County, and the other two dealing
with landfill disposal and production of a marketable product.
It was determined that approximately 915 acres of land in
South Clackamas County would be needed for land application
assuming agency ownership of the land and that 2,100 acres
would be needed if sludge were spread on private lands.
The CRAG final-round analysis recommended the truck
transport of liquid-digested sludge to South Clackamas County
and spreading of sludge on privately owned farm lands
(Alternative 2a). The area recommended for sludge appli-
cation lies due north of the area evaluated in Alternative D
of this EIS (see Figure 4). Approximately 2,100 acres of
land would be needed to meet year 2000 projected needs (CRAG)
Technical Supplement 8, 1977).
Unified Sewerage Agency - Durham. At the time of the
preparation of the CRAG Sludge Management Study, it was
judged that the USA-Durham plant could be excluded from
analysis because the sludge facilities and plant capacities
through the 20-year study period (to the year 2000) were ade-
quate. Recent problems with sludge processing and incineration
components have caused the USA to begin a study to evaluate
future sludge handling and disposal for Durham (Naef, pers.
comm.). After the first-round analysis, two alternatives
appear best: 1) refitting the existing incinerators, and
2) land application of liquid digested sludge.
The Durham plant presently produces approximately 8.2
tons of sludge per day and by the year 2000 will be pro-
ducing an estimated 15.6 tons per day. Possible sludge
application areas to be evaluated include land northwest
of Durham in Washington County (south of Forest Grove and
Hillsboro) (Naef, pers. comm.). An evaluation of the south
Clackamas site (Kellogg region) is not anticipated.
An evaluation of the alternative of Durham trucking
sludge to the Columbia Boulevard plant for disposal is
also not anticipated (Naef, pers. comm.).
71
-------
Constraints on Alternative Sludge Disposal Practices
The Oregon State Department of Environmental Quality
has developed Proposed Regulations and Guidelines for Handling,
Disposal and Use of Municipal Sludge Relating to Land Applica-
tion (OAR Chapter 340, Division 4, Subdivision 2). The
principal restrictions in these regulations are listed below:
o Raw or non-digested sludge shall not be disposed of
on land surfaces, but with the prior approval of the
DEQ can be buried.
o Only heat-dried sludge can be used as a fertilizer
on truck crops and in public areas.
o Sludge application in fruit or nut orchards is not
permitted within 60 days of harvest.
In addition, environmental conditions may also limit
the applicability of an application process or create an
additional economic burden on the process. An example would
be the composting of sludge which requires a maximum moisture
content of about 50 to 60 percent. In the northwest area
this would require a protective cover at least during the
rainy season.
Finally, considering that the city operates and is
committed to expanding their solids handling system, any
processes proposed should be compatible with existing facilities.
The existing stabilization process is committed to anaerobic
digestion. Based on these conditions and the regulations
published by the DEQ and the EPA, the following general observa-
tions are made.
Among the solids disposal methods that can be considered
certain ones are eliminated because of agency regulations:
o Ocean dumping.
o Sludge lagooning (this can be used for temporary
but not permanent storage).
o Land application of raw sludge.
o Sanitary landfilling of raw sludge.
Some of the disposal systems considered are affected
by environmental conditions that constrain utility or
acceptability relative to the City of Portland;
o Air emission standards for thermal processing systems
are difficult and costly to meet, resulting in less
favorable consideration.
72
-------
o Composting operations require a relatively large
operating area, wet weather protection and should
be buffered from the public.
o Land application systems should be buffered from the
public, and require large land areas, which reduces
the number of available sites.
o Sand drying beds in the coastal climate may require
wet weather protection to permit sludge dewatering
and relatively large land areas for the city.
o Crop type regulations and time of application combine
to limit agricultural options for liquid sludge use
as a soil conditioner/fertilizer.
o Heat-treatment processes occasionally create an
odor nuisance for surrounding areas, are energy
intensive and subject to mechanical failure.
The choice of disposal systems is affected by existing
and in-process facilities:
o Sludge thickening processes, other than gravity and
flotation, are eliminated.
o Sludge stabilization by composting and lime treat-
ment is eliminated.
o Existing experience at the Columbia Boulevard plant
does not favor the sludge conditioning processes of
heat treatment because of odors and possible mechanical
failure.
o Existing commitments to anaerobic digestion makes
incineration nonviable.
Some disposal systems that can be considered are adversely
affected by economics and operational reliability:
o Mechanically complex systems, such as heat treatment
or mechanical sludge reduction processes are expen-
sive, require skilled operational personnel, consume
large amounts of fossil fuel and are subject to
mechanical failure.
o Sludge haul distances and the type of conveyance
generally dictate the suitability of a land applica-
tion system through an economic evaluation. The
farther from the source that suitable lands are for
sludge application, the more critical is the economic
evaluation.
73
-------
Based on these foregoing comments, the sludge process
diagram presented in Figure 9 can now be modified to eliminate
processes that need not be considered. In addition, those
processes that are of low viability, as described above, are
identified by cross-hatching in Figure 9.
Screening of Alternatives
This section presents a discussion of the sludge handling
alternatives considered in the Facility Plan and the rationale
for deleting many alternatives from additional consideration.
The Facility Plan includes a further refinement of recommended
alternatives by subdividing them into Phase I and Phase II.
This phasing concept is also explained and discussed in this
section.
Sludge Management System Phasing. The sludge management
systems considered for tne City of Portland can all be
divided into sludge treatment (at the plant) and sludge
conveyance and disposal or beneficial use. The treat-
ment consists of one or more combinations of the processes
presented in Figure 9. Because both the Columbia Boulevard
and Tryon Creek plants have existing treatment processes, any
expansion or upgrading would be compatible with these pro-
cesses, as was done in the alternatives developed in the
Facility Plan. Of all the alternative systems initially con-
sidered, half were considered to be infeasible. Of the
remaining twelve alternatives, ten included sludge
stabilization by digestion. During the ranking analysis in
the Facility Plan those projects that included sludge stabili-
zation by digestion were preferred. On the basis of that
analysis and the fact that the city needed additional sludge
treatment components operational by 1980, due to existing
capacity limitations, the Facility Plan divided the project
into two phases.
The two phases essentially separate the onsite components
for sludge treatment from the components required for sludge
reduction, conveyance and disposal. Phase I therefore
includes the construction of additional anaerobic digesters
together with the cleaning and upgrading of the sludge
lagoon (Triangle Lake). This phase of the project is in
design and should be operational by 1980. Phase II com-
ponents are considered in this EIS.
Alternative Sludge Management Systems Considered. A total
of twenty-one sludge management systems were initially con-
sidered. These alternatives are briefly described in this
section. In every case, the assumption was made that sludge
from Tryon Creek and Clackamas could be conveyed to Columbia
74
-------
-------
Boulevard plant for final disposal without significantly
affecting a recommended altervative system for the Columbia
Boulevard plant. However, no analysis is presented in the
Facility Plan or this EIS to show that the combined handling
of the sludges is the most cost-effective method for sludge
disposal for these entities. The following are the alternatives
initially considered in the Facility Plan.
Alternative A-l - Land Application of Separately
Digested Liquid Sludge. This alternative provides for the
transportation of liquid digested sludge by barge up the
Columbia River to Morrow County, where the sludge would be
incorporated into the soil. Sludge treatment is by anaerobic
digestion for primary sludge and separate anaerobic digestion
followed by lagooning for the secondary sludge. Digested
sludge would be pumped to a barge-loading facility on the
Oregon Slough and then would be barged to Morrow County.
At Morrow County sludge from the barge is then pumped to a
small sludge lagoon and from there it is pumped to land dis-
posal sites for soil incorporation.
Alternative A-2 - Land Application of Separately Digested
Dewatered Sludge. Under this alternative primary digested
sludge is dewatered by vacuum filtration, trucked to a barge
loading dock and barged for soil incorporation in Morrow
County. The secondary digested sludge is again lagooned and
pumped to the barges for transport to Morrow County as ex-
plained in Alternative A-l. Two types of barges would be
required, one to handle dewatered sludge and the other liquid
sludge. Unloading facilities at Morrow County would have to
be suitable for both types of sludge.
Alternative A-3 - Land Application of Liquid Digested
Sludge. As in Alternative A-l, this alternative requires land
application of liquid digested sludge in Morrow County,
using barge transportation. Sludge treatment is by anaerobic
digestion of a mixture of separately thickened primary and
waste-activated sludge. The digested sludge would be
pumped directly for barge transport to the land application
site in Morrow County.
Alternative A-4 - Land Application of Digested Dewatered
Sludge. Thickened primary and waste-activated sludge would
be blended together and anaerobically digested. The digested
sludge would be dewatered using existing vacuum filters and
hauled by truck to a barge loading dock for transport to
Morrow County. The dewatered sludge would be off-loaded and
applied to the land.
76
-------
Alternative A-5 - Land Application of Digested and
Heat Treated Dewatered Sludge. This alternative makes
maximum use of the existing facilities by incorporating both
anaerobic digestion and heat treatment for sludge processing.
Thickened primary sludge would be anaerobically digested with
about 20 percent of the thickened sludge being blended with
thickened waste-activated sludge for heat treatment process-
ing. Thickened waste-activated sludge in excess of the
capacity of the heat treatment system would be blended with
thickened primary sludge and anaerobically digested. The
thickened primary sludge is incorporated with thickened waste-
activated sludge for operational reasons affecting the heat
treatment process. The digested and heat-treated sludge
would then be blended and dewatered using existing vacuum
filters and hauled by truck for loading onto barges which would
transport the sludge to Morrow County. The sludge would
then be incorporated into the soil.
Alternative B- and B-2 - Incineration and Landfill of
Sludge Ash. Under this alternative, thickened waste-activated
sludge would be conditioned by heat treatment and blended with
thickened raw primary sludge prior to discharge into a decanting
tank. Thickened sludge would be drawn from the bottom of
the decant tank and pumped to the existing vacuum filters
for dewatering. The dewatered sludge would then be conveyed
to an incinerator (Multiple hearth [B-l] or fluidized bed
[B-2]) where the sludge would then be burned and the resulting
ash landfilled at the St. Johns or other suitable site.
Alternative C - Blended Digested Sludge Drying or
Fertilizer Production. This alternative requires that
the primary and secondary sludges be separately, anaero-
bically digested, then blended and dewatered using belt
filter presses. The dewatered sludge would be conveyed
to the drying system, a proprietary process called the Basic
Extractive Sludge Treatment (B.E.S.T.) process. The dried
sludge would then be marketed as a fertilizer in the Portland
area. The drying process is new and pilot tested; however,
no full-scale system is in operation. An offer has been
made to the City of Portland for a 1-year money-back perfor-
mance guarantee on the required process equipment.
Alternative C-l - Separate Digested Sludge Drying for
Fertilizer Production. The raw primary and waste-activated
sludge are separately thickened and anaerobically digested.
The digested primary sludge is dewatered and separately dried
by the B.E.S.T. process. The digested secondary sludge is not
thickened, but is pumped directly to a second B.E.S.T. process
installation. The dried sludge would then be combined and
marketed as a fertilizer. A marketing study has been done
to identify and evaluate potential markets.
77
-------
Alternative C-2 - Primary Digested Sludge Drying for
Fertilizer Production Plus Land Application of Digested
Secondary Sludge. This is basically a combination of alter-
natives, an alternative in which primary sludge is B.E.S.T.
process treated and waste-activated sludge is barged to
Morrow County. Raw primary sludge would be anaerobically
digested and dewatered using the existing vacuum filters and
heat dried in the B.E.S.T. process. This dried sludge would
be marketed as a fertilizer. The secondary sludge would be
thickened and anaerobically digested, followed by lagooning
in the Triangle Lake Sludge Lagoon. Concentrated sludge
from the lagoon would be transported by barge to Morrow
County and there incorporated into the soil.
Alternative D-l - Land Application of Separately Digested
Sludge in Western Oregon. Alternatives D-l and A-l are similar
except that the sludge is applied to agricultural lands in the
upper Willamette Valley in D-l. Thickened raw primary and
secondary sludges are separately, anaerobically digested.
Liquid digested primary sludge would be hauled by tank trucks
for agricultural use in the area south of Canby. The digested
secondary sludge would be pumped to the Triangle Lake Sludge
Lagoon for temporary storage. This sludge would also be
hauled by tank truck for application to agricultural lands
south of Canby.
Alternative D-2 - Barge Haul and Land Application of
Separately Digested Sludge in Western Oregon. Alternatives
D-l and D-2 are identical except that the mode of sludge
transport is by barge up the Willamette River in D-2.
Liquid digested sludge would be pumped to a barge loading
facility, and the loaded barges would transport the sludge
up the Willamette River to an unloading dock. The sludge
then would be pumped from the barges directly into tank
trucks for land application on agricultural lands or into a
sludge storage lagoon for temporary storage.
Alternative E - Composting of Digested Primary Sludge
for Local Use and Land Application of Digested Secondary
Sludge. Under this alternative, thickened primary sludge
would be anaerobically digested, dewatered and transported
by truck to the city landfill site for composting. The
composted material would then be made available for community
use as fertilizer aid and soil amendment. The thickened
secondary sludge would be anaerobically digested, separated,
and pumped to the Triangle Lake Sludge Lagoon. The solids
would be allowed to accumulate and concentrate in the lagoon
for about three years and then would be removed by dredging
and transported by barge to eastern Oregon. The sludge
would then be incorporated in the soil as previously described
for Alternatives A-l through A-5.
78
-------
In addition to these alternatives/ several other alter-
natives were also briefly considered in the Facility Plan.
These additional alternatives were subsequently screened from
the list without making cost estimates. The reasons for
rejecting these alternatives are given at the end of each
description. For convenience, these additional alternatives
have been numbered consecutively with the prefix letter S.
Alternative S-l - Oaean Disposal of Sludge. This alter-
native would anaerobically digest the sludge and pump the
digested sludge directly into bottom dump barges. The barges
would then be towed to an ocean dumping site off the west
coast of Oregon and the sludge dumped.
As already stated this method is not approved by the
EPA and, in fact, east coast cities that have used this
method for a number of years have been ordered to stop.
In addition, the Department of Environmental Quality (DEQ)
prohibits the ocean dumping of sewage sludge. This method is
controversial, has not received public acceptance, and has
been dropped from further consideration.
Alternative S-2 - Pyrolysis of the Sludge and Landfill.
This is a sludge reduction method in which organic material
in sludge is decomposed at high temperature in an oxygen-
deficient environment. Three products result from this pro-
cess, gas, oil and char (solid residue). The system is
intended to be self-supporting and to generate sufficient
heat to provide an excess for other uses. The process has
been used on municipal refuse in many areas, but has not been
demonstrated to be reliable in full-scale operations on
sewage sludges.
Alternative S-3 - Sanitary Landfilling of Dewateved
SludgeThis alternative would require that stabilized
sludge be dewatered and hauled by truck to a sanitary land-
fill for disposal. Stabilization would be by anaerobic
digestion, as presently practiced. However, there would have
to be a substantial increase in the construction of dewatering
facilities to yield the necessary minimum solids concentra-
tion of 20 percent. Also, a truck transport fleet and a
suitable landfill site would be required.
Sludge disposal by sanitary landfill was screened from
more detailed consideration for the following reasons: 1) there
is no possibility of providing a beneficial use for the
sludge; (2) a sanitary landfill site could not be located
within a reasonable distance of the Columbia Boulevard plant;
(3) truck transport of sludge is generally more expensive than
other means of transport, such as barge or pipeline; and (4)
there would be a requirement for additional dewatering facilities.
Considered together this method would be more expensive and
neither beneficial nor environmentally acceptable.
79
-------
Alternative S-4 - Oil Tanker Ballast to Oil-Producing
Countries. This alternative has been suggested by many
people as being logical and environmentally beneficial. The
idea is simple. Middle East oil tankers, which
presently use water as ballast for their return journeys,
could replace the water with liquid digested sludge. Once
at the country of origin, the sludge could be used to reclaim
desert lands through its use as a soil conditioner or binder
to provide waterholding capacities to the sands.
Although this alternative represents a beneficial use
of the sludge, arid at minimal cost to the city, implementing
such a scheme would pose an insurmountable obstacle. Inter-
national politics would be involved and agreements would have
to be arranged, so that the scope of such an undertaking
would be well beyond the resources, or perhaps even the
authority, of the city.
Alternative S-S - Sludge Reduction by Heat Drying.
Sludge reduction would be achieved by evaporation drying.
Because Alternatives C, C-l and C-2 provide essentially the
same product through the solvent extraction method, and because
drying tends to be more expensive, consumes more energy and
requires more air pollution control equipment, this alternative
was not considered further.
Alternative S-6 - Application on Forest Lands. This
alternative requires the application of either dewatered or
liquid digested sludge onto forest lands to enhance the
growth of trees. The feasibility of this system is directly
related to transportation distances, topography, density of
undergrowth and whether control of run-off and leachate
is necessary. For the City of Portland, suitable forestry
sites are a considerable distance away and transportation
costs would consequently be high. Also, the application
costs would be much higher than for those alternatives
that included soil incorporation in eastern Oregon.
On the basis of the experience of the Municipality of
Metropolitan Seattle, the unit cost for this type of disposal
is significantly higher than for the other alternatives con-
sidered. The cost was based on estimates that a suitable
forest site could be found within 30 miles (one way) of the
Columbia Boulevard plant, estimated at $90. per ton of solids.
As will be shown, this is significantly higher than the other
alternatives.
Alternative S-7 - Land Application of Digested Sludge
Downriver from Portland. This alternative is similar to
Alternatives A-l through A-5 except that the land applica-
tion site was downriver from the City of Portland. Again,
the sludge would be barged to a suitable site for sludge
application on riverfront lands. The application would pro-
vide soil conditioning and the enhancement of wildlife
habitat.
80
-------
On the basis of preliminary study, appropriate land
acreages were not evident. Also, a majority of the suitable
lands are in the Columbia River floodplain where the ground-
water table is close to the surface. Therefore, this alter-
native was not considered further.
Alternative S-8 - Sludge Pelletizing for Land Utiliza-
tion. This system requires that stabilized, dried sludge be
pressed in pellets for use as a fertilizer. Many agencies
have investigated the economics of pelletizing for the
nutrient value of the sludge, but the economics of the pro-
cess have not been favorable. In addition to costs for
drying sludge, there are additional capital and operational
costs for pelletizing equipment. Another problem is one of
an uncertain market value for the pelletized product.
Because of these uncertainties and high initial costs,
this process was not considered in further detail. Also to
be considered are the results of an investigation by the
Forestry Products Industry. Their investigation disclosed
that truck transportation of low-nutrient pellets and their
application over forest lands from aircraft is not as cost-
effective as the purchase and similar application of high-
nutrient, commercialized fertilizer.
Alternative S-9 - Conversion of Sludge to Livestock
Feed. Many scientists and researchers have suggested that
sludge be converted to livestock feed because of the high
protein and nutrient value of the material. The Coors
Brewing Company of Golden, Colorado, has done some research
on their brewery waste which is proving attractive. However,
the U. S. Food and Drug Administration (FDA) will not approve
the product because it has some traces of human waste in the
wastewater (less than 5 percent). Because of the problems
associated with FDA approval of wholly municipal sludge
conversion and the fact that approved conversion methods have
not yet been developed, this alternative was not considered
further.
Other alternatives can be conceived such as composting
in furrows with grass straw that is presently burned and
composting in soil with cellulose wastes from paper plants.
However, all conceivable alternatives have not been considered
in depth due to the overwhelming number of possibilities and
the lack of technical, economic or social feasibility.
Summary of Alternatives
Twenty-two alternative sludge management plans have
been described briefly. Thirteen were evaluated in detail
by the Facility Plan and nine were dismissed from further
consideration for the reasons described above. A critical
81
-------
review of the candidate systems to be evaluated shows that
these alternatives actually represent modifications or com-
binations of only three basic alternatives. These are as
follows: (1) land application of digested sludge; (2)
incineration and landfill of the resulting ash? and (3)
sludge drying for production of a fertilizing aid.
Estimated Annual Cost of Alternatives. The City of
Portland prepared cost estimates, including both capital and
operation and maintenance costs for each of the alternative
sludge management systems. These costs are summarized in
Table 13. For more details on these costs, the reader is
referred to the Facility Plan.
Also included on Table 13 are the equivalent basic
alternative numbers to determine which of the detailed
alternatives can be represented by one of the three basic
management plans discussed. Inspection of the table shows
that the land application alternatives are the least expensive
followed by sludge drying using solvent extraction and, lastly,
the incineration system. Moreover, land application in the
northern Willamette Valley and a combination of land appli-
cation and composting prove to be the most expensive of all
the alternatives.
Based on the premise than any cost estimates within
10 percent of each other can be considered equal, Alternatives
A-l, A-2, A-3 and C-l are cost equivalent.
Rationale for Selection or Rejection of Alternatives from
Further Consideration. Although Alternatives A-l, A-2, A-3
and C-l can be considered cost equivalent, cost alone was not
used for the selection or rejection of alternatives for more
detailed consideration. The following discussion, on an
alternative by alternative basis, presents the rationale
for selection or rejection of the remaining thirteen alternatives.
Alternative A-l - Land Application of Separately Digested
Liquid Sludge. This alternative was retained for detailed
evaluation. It is the lowest cost alternative, and consumes
less energy than any of the other "A" alternatives.
Alternative A-2 - Land Application of Separately Digested
Dewatered Sludge. This alternative was deleted. Due to the
use of two different types of barges, for dewatered and liquid
sludge, it is unnecessarily complex and lacks flexibility.
Although only slightly more expensive than A-l, it is more
energy intensive.
82
-------
Table 13
ESTIMATED TOTAL ANNUAL COSTS - ALL ALTERNATIVES1
Amortized Total
Alternatives Capital Capital 0 & M Annual
Basic Detail Costs Costs Costs Costs
Number
Number
($1000's)
($1000's)
($1000's)
($1000's)
I
A-l3
11,555.5
1,059.2
1,043.3
2,102.5
I
A-2
11,417.6
1,046.5
1,208.2
2,254.7
I
A-3
12,076.4
1,106.9
1,166.2
2,273.1
I
A-4
9,495.4
870.4
1,243.1
2,113.5
I
A-5
5,365.3
491.8
2,088.1
2,579.9
II
B-MH
8,540.5
782.8
2,259.2
3,042.0
II
B-FB
10,931.6
1,002.0
1,976.4
2,978.4
III
C
11,634.5
1,066.4
1,594.0
2,660.4
III
C-l 2/ 3
12,471.9
1,143.2
1,079.0
2,222.2
III
C-2
12,833.5
1,176.3
1,232.0
2,408.3
I
D-l
12,505.7
1,420.1
1,777.7
3,197.8
I
D-2
16,325.3
1,577.3
2,008.7
3,586.0
I
E
13,045.7
1,252.6
1,944.1
3,196.7
These values represent the updated cost estimates (1977) for the
alternatives presented in the facility plan. The costs for the
three selected alternatives were updated by the City of Portland
in April 197 8 and these costs are presented in Appendix F.
2 B.E.S.T. Process
3 Alternative A-l and C-l costs do not include any revenue
from the sale of sludge.
83
-------
Alternative A-3 - Land Application of Liquid Digested
Sludge. This alternative was deleted. A key consideration
was the lack of long-term sludge storage and treatment in the
Triangle Lake Lagoon, as accomplished in A-l. The lack of
treatment which would be provided by this long-term storage
could cause some instability in the final product. Odor,
fly and pathogen problems could result. An additional
consideration in rejecting this alternative was the extremely
high energy requirement.
Alternative A-4 - Land Appliaation of Digested Dewatered
Sludge. This alternative was deleted. Although slightly less
energy intensive than A-l, A-4 was deleted primarily due to
its high annual operation/maintenance cost.
Alternative A-5 - Land Appliaation of Digested and Heat
Treated Dewatered Sludge. This alternative was deleted.
Although capital costs are low, due to use of existing
facilities, the operating cost is extremely high. Overall,
the annual costs are about 25 percent higher than A-l.
Additionally, A-5 is a very energy intensive process.
Alternative B-l and B-2 - Incineration and Landfill of
Sludge Ash. These alternatives were deleted. Use of
incineration, either multiple hearth (B-l) or fluidized bed
(B-2), is incompatible with the on-going Phase I project.
In reality, this alternative was eliminated from consideration
even prior to the Facilities Plan, due to the strong public
reaction which followed its initial proposal.
Alternative C - Separate Digested Sludge Drying for
Fertilizer Production. This alternative was rejected. It
is roughly 20 percent more costly than C-l, yet provides no
advantage over C-l. This is the primary reason for rejection.
Alternative C-l - Separate Digested Sludge Drying for
Fertilizer ProductionThis alternative was retained for
detailed evaluation. It is the least costly of any "C"
alternative, and has operation/maintenance and total annual
costs nearly equivalent to A-l.
Alternative C-2 - Primary Digested Sludge Drying for
Fertiltzer Production plus Land Application of Digested
Secondary Sludge. This alternative was deleted. It exhibits
no cost or other advantages over C-l, assuming of course,
that a sufficient market can be developed for the greater
volume of dry sludge produced by C-l.
Alternative D-l and D-2 - Land Application of Separately
Digested Sludge in Western Oregon. These alternatives were
retained for detailed evaluation. Although neither shows a
cost advantage over A-l or C-l, EPA desired that these alterna-
tives be retained. The EPA decision was made principally on
the basis of retaining a Western Oregon land application
alternative in the detailed evaluation.
84
-------
Alternative E - Composting of Digested Primary Sludge
for Local Use and Land Application of Digested Secondary
Sludge. This alternative was deleted. In addition to having
an annual cost 50 percent greater than A-l, space require-
ments, labor intensity, and the necessity for protection from
rainfall were the principal reasons for deletion.
Description of Selected Alternatives
The previous section in this chapter identified
Alternatives A-l, C-l, D-l and D-2 as viable solutions to
the sludge handling problem at the City of Portland's
Columbia Boulevard plant. These alternatives consist basi-
cally of land application of liquid sludge for agricultural
or reclamation purposes and the marketing of B.E.S.T. process
dried sludge as a fertilizer aid. The predominant use of
B.E.S.T. dried sludge would probably be one of local and possiblv
national use, as is the case with the City of Milwaukee,
Wisconsin's product, Milorganite. These alternatives will
be described and a more detailed cost analysis presented.
One additional alternative, similar to C-l, is also considered.
This alternative considers the use of the Carver-Greenfield
process to produce a marketable soil amendment product.
Alternative A-l, Land Application of Liquid Sludge in
Eastern Oregon. Alternative A-l exists as an optional
category for land application of liquid sludge. The ele-
ments and facilities required for this alternative are
shown schematically in Figure 10, and are described below.
The overall system entails the transportation of liquid
digested sludge up the Columbia River by barge for soil
incorporation in Morrow County.
The sludge collected from the primary sedimentation
basins would be gravity thickened and anaerobically digested
in a two-stage digestion system. The second stage permits
partial thickening of the digested sludge to concentrations
in the range of 7 to 8 percent solids content. This
digested sludge would then be pumped directly to a barge
loading facility on the Oregon Slough and loaded into river
barges.
The waste-activated sludge collected from the secondary sedi
mentation basins would be thickened by centrifuge and anaero-
bically digested in a separate two-stage digestion system. The
digested sludge would be pumped to a sludge storage lagoon
where sludge thickening would occur. The lagoon used for
this thickening process, the Triangle Lake Sludge Lagoon,
will be renovated by cleaning out the existing sludge,
enlarging the lagoon, and installing additional sludge
distribution piping. After the sludge discharged to the
lagoon has settled and consolidated, the free standing water
85
-------
FIGURE 10
SCHEMATIC DIAGRAM
FOR ALTERNATIVE A-l
86
-------
above the deposited solids, supernatant, would be drawn off
through three polishing ponds prior to being pumped to the
primary sedimentation basins. After about 3 to 4 years the
concentrated sludge will be pumped to the barges for loading,
conveyance and land application. The refurbishment of
Triangle Lake is presently in the design stage under
Phase I of this project.
All liquid digested sludge would be conveyed by barge
approximately 150 miles up the Columbia River to Morrow
County. A barge unloading dock would be constructed at a
location west of the City of Boardman. The liquid sludge
would be pumped off the barge to a holding pond located on
the land application site.
The land application technique has not yet been selected;
however, the technique eventually chosen will be dependent
upon more detailed analysis of the specific site. The
system would probably be one of the following:
o The sludge could be pumped from temporary storage facilities
through pipes to a special injection device being towed
behind a tractor. The injection device, similar to
a plow, provides a means for pumping the sludge
directly under the ground surface. The injector is
connected to the permanent piping by a long, flexible,
reinforced hose attached to above-ground valves. The
amount of sludge applied per acre is adjusted by
varying the speed of the tractor. This method
essentially eliminates the potential for odor or
vectors and other nuisance conditions.
o Liquid sludge could be pumped through piping to large
orifice sprinkler guns. These "guns" can cover a large
area and many are self-propelling. After application
the sludge is plowed into the ground with a discing plow.
o A third method is to spread liquid sludge from specially
designed tank trucks. The trucks would be filled
from either the temporary storage lagoon or directly
from the barge. These tank trucks would then spread
the liquid sludge on the ground. Again, this sludge
would be ploughed into the ground using a disc.
o Finally, the sludge could be pumped into shallow
drying beds or lagoons. The sludge is then dried
using the high net evaporation rate in Morrow
County. The dried sludge would be spread on the
ground and plowed into the soil to avoid odor and
vector proliferation. Dried sludge could also be
stored during inclement weather for land application
in other areas.
87
-------
This description of Alternative A-l provides the basis
for identifying the capital improvement facilities and
operational and maintenance (0 & M) practices required for
the project. These facilities, the estimated capital, and
0 & M costs are presented.
Alternative C-l, Sludge Drying for Production of
Fertilizer Aid" Alternative C-l is covered by the third
basic alternative sludge management system of sludge drying
for the production of a fertilizer aid. The elements and
facilities required for this alternative are shown schema-
tically in Figure 11 and are described in detail below. The
overall system includes drying of the digested primary and
secondary sludges by a solvent extraction method. The
product would then be marketed in the northwest.
The process schematic has been revised based on 1977
pilot-plant studies by adding a blending step for combining
the primary and secondary sludges, adding a belt-press
dewatering step, and replacing two smaller drying units
with one larger unit.
The sludge from the primary sedimentation basins would
be gravity thickened and anaerobically digested in a two-
stage digestion system. The second stage digester is used
to settle and thereby thicken the sludge in the range of 7
to 8 percent solids concentration. This thickened sludge
would then be pumped to vacuum filters for dewatering to a
cake concentration of 25 percent solids.
The waste-activated, or secondary sludge collected from
the secondary sedimentation basins, would be thickened by
centrifuges and anaerobically digested in a two-stage
digestion system. Because digested secondary sludge does
not settle or thicken easily, the second stage is used
only for additional digestion and storage. The reason for
including the second stage is to provide the flexibility of
combining the sludges in the future for digestion and thicken-
ing. The digested liquid sludge from the second stage is
pumped to a tank where it is blended with the primary sludge
cake. The mixture is belt-press dewatered to 20 percent
solids before drying.
The proposed sludge drying system is a proprietary
process called Basic Extractive Sludge Treatment (B.E.S.T.)
process. The process is being developed by the Resources
Conservation Company, which is a totally owned affiliate of
Reading and Bates Offshore Drilling Company and the Boeing
Company. The B.E.S.T. process is designed to utilize the
unique properties of an industrial solvent (Triethylamine)
to enhance the extraction of the water in the sludges. Side
benefits of using this solvent involve the collection of
oils and fats from the sludge during the final drying process.
88
-------
FIGURE 11
SCHEMATIC DIAGRAM
FOR ALTERNATIVE C-l
-------
The system is described very briefly here. The sludge
entering the process is mixed with the solvent and the temper-
ature reduced to 60°F, at which point the solvent and water
become totally miscible. The mixture is then dewatered in
centrifuges and the liquid collected while the dewatered
sludge is conveyed to the drying process where the solids
are heated and the remaining moisture is driven off. The
vapor from the driers and the liquid from the centrifuges
are collected and pumped to a decanter where the solvent is
removed from the water by adjusting the temperature. The
solvent is therefore captured and returned for reuse while
the water is pumped to the wastewater treatment process. The
solvent also contains oils and fats that are removed by a
distillation process and conveyed to storage. The oil has a
heat value of about 16,000 BTU's per pound. The oil there-
fore has a value and can be sold to help defray some of the
operational expenses.
The dried sludge would have a solids concentration of
about 95 percent. This material would then be marketed,
either by the City of Portland or through a contractor, as a
light fertilizer and soil conditioner. The product would be
similar to that produced by the Cities of Milwaukee, Wiscon-
sin, and Los Angeles, California. Typical nutrient quanti-
ties of the product consist of 4 percent nitrogen, 4 percent
phosphorous, and 3 percent potassium. The marketing and sale
of the product would also alleviate the operational costs.
The Resources Conservation Company has given a money-
back guarantee to the City of Portland. Under terms of this
guarantee the Company would train city personnel in the
operation and maintenance of the B.E.S.T. process equipment and
demonstrate its performance against operational parameters
previously formulated and agreed to by the city and the
Company. If these operational parameters are not achieved,
the Company would remove the B.E.S.T. equipment at no cost to the
city.
Carver-Greenfield Alternative
The Carver-Greenfield Process is a proprietary sludge
drying process, in which light oil is mixed with the sludge-
water mixture. The sludge-water-oil mixture is then passed
through a multi-effect evaporator, and water is removed by
evaporation. Although the manufacturer claims that the water
removed is virtually "distilled" in quality, considerable
evidence exists to support the contrary. The purpose of
adding the oil is to increase fluidity of the mixture as
drying occurs. After all water is removed, the remaining
oil is removed by centrifugation of the oil-solids suspension.
A small percentage of the oil remains in the sludge, but the
oil which is removed by centrifuging may be reused in the process.
After removal of the remaining oil, a portion of the dry
solids are pyrolized, to provide energy for the multi-effect
evaporator. Remaining dry solids may be used for additional
fuel purposes or as a soil conditioner.
90
-------
In this alternative, separate anaerobic digestion of
primary sludge and waste-activated sludge is accomplished
using two-stage digestion. In the second stage, the digested
sludge thickens by gravity to 8 percent solids. The two
digested sludge streams are then combined and passed through
a centrifuge, to thicken the sludge to approximately 2 0 percent
solids. Sludge then enters the Carver-Greenfield Process
treatment. The resultant sludge produced by the Carver-
Greenfield Process is normally over 95 percent solids. A
schematic flow diagram for the Carver-Greenfield Process
is shown in Figure 12.
Cost Analysis. Costs for purchasing, operating, and
maintaining the Carver-Greenfield Process were obtained from
the manufacturer, Dehydro-Tech Corporation of East Hanover,
New Jersey. These costs were combined with costs for digestion,
cleaning of the Triangle Lake Lagoon, and for electrical
generating equipment to determine the present worth cost of
this concept. These costs are presented in Appendix G.
Resource Consumption. Resources used in the Carver-
Greenfield Process are electricity (5,325,080 kw-hr/yr),
makeup light oil (44,000 gallons/year) and polymer prior to
centrifugation (87,600 pounds/year). An analysis of electrical
energy consumption for the entire treatment process is shown
in Appendix H.
Summary of Marketing Analysis.
Introduction. Heat-dried sludge has been marketed elsewhere
as both a soil amendment and a low-analysis fertilizer. An assess-
ment of the feasibility of disposing of the heat-dried sludge which
the City of Portland might produce, either through a commercial
marketing program or a free distribution system, was conducted
and its findings are summarized here. While the primary purpose
of this assessment was to estimate the amount of heat-dried sludge
which could be marketed or given away, other important information
was developed. First, potential retailers and users indicated
product characteristics that are important to them. One of those
characteristics was inevitably the price of the product which
was then related to the volumes retailers and users estimated
they would purchase in order to develop the demand estimates
given here. Second, descriptions of many of the characteristics
which appear to determine the long-term success of a marketing
program were developed.
Background. The experiences of other sludge marketing
programs are important indicators of market parameters. A
brief survey of past and present marketing programs in the
Portland, Los Angeles, Milwaukee, Houston, Amarillo, Corpus
Christi and Birmingham areas indicated the following:
91
-------
FIGURE 12
SCHEMATIC DIAGRAM FOR
CARVER- GREENFIELD
PROCESS ALTERNATIVE
MARKETING S
DISTRIBUTION
OF DRIED SLUDGE
92
-------
Successful marketing programs do not result in sufficient
revenues to pay the agency's treatment costs. A marketing
program may be one element of a sludge disposal system which
minimizes total disposal costs. Successful operations typically
involve a private contractor in addition to the treatment agency.
In some cases the contractor is paid to take the sludge as it
comes from the treatment process and in the other cases the
contractor pays the agency for a more finished sludge product.
All successful marketing programs are characterized by
consistent quality control in the production process. There
is likewise a history of failures primarily attributed to user
dissatisfaction caused by variable product quality.
All successful marketing operations seem to exercise some
control over their markets. This control has been exercised
either through a brand name which differentiates the product
from comparable products or through simply being at least the
only sludge-based product.
No examples of sludge marketing programs which attempted
to serve all potential markets for such a product were found.
Whether by planning and design or by trial and error, all
successful operations operate with products and marketing
approaches that are pinpointed to specific user groups. These
user groups can generally be classified into three types of mar-
kets: agriculture, professional or specialty, and home and gar-
den.
The discussion of the findings which follows is divided
into three sections, each dealing with one of the markets
mentioned above. At the conclusion of these discussions are
a summary of the feasibility assessment and a discussion of
approaches to implementation and potential outcomes.
The agricultural market. Growers in the Portland area use
vast quantities of fertilizers. For example, about 25,400 tons
of fertilizer containing 30% nitrogen is required to fertilize
wheat and barley crops in the four counties surrounding
Portland. Assuming the heat-dried sludge product has a nitro-
gen content of 4%, which is a conservative but realistic
estimate of its content, it would take 402,000 tons of sludge
to provide the same amount of nitrogen to the same crops.
Sludge has not been widely used in commercial agriculture.
Recent research by Oregon State University estimated a return
to land and management from sludge use of -$3.30 to $8.30
per ton of sludge used assuming the sludge were provided
delivered and spread free of charge. It is estimated that
delivery and spreading costs would be from $8.50 to $10.00
per ton leaving the sludge itself with a negative value. It
was therefore concluded that a commercial marketing program
serving agriculture would not be feasible.
93
-------
Growers of grain crops and perhaps some other crops would
be willing to accept sludge if it were delivered and spread.
While they would not pay anything for the sludge and would not
pick it up or spread it themselves, the growers might be
willing to pay some of the delivery and/or spreading cost if
they were convinced of the nutrient value of the sludge for
their crops. The sludge would have to be distributed to users
on schedules coordinated with their planting programs, not
with the production of the sludge.
The specialty market. Table 14 lists the general uses
and significant user groups which comprise the specialty market
for soil amendments and fertilizers.
Table 14
SPECIALTY USES AND USERS
General Uses: New Landscaping
Landscaping Maintenance Plant Propagation
Significant
Users:
Landscape archi-
tects and
Landscape contrac-
tors
Landscape contractors
Golf course operators
Cemetery operators
Public park districts
Public works departments
Schools & colleges
State highway maintenance
divisions
US, Forest Service
Field nurseries
Container nurseries
Turf growers
Grass and other seed
growers
SOURCE: Gruen Gruen + Associates
Landscape contractors use between 215,000 and 2 70,00 0
cubic yards of soil amendments annually in the Portland area
for both new landscaping and maintenance of existing plantings.
Most of the soil amendment is barkdust although some steer
manure is also used. Since bark is becoming more valuable as
an energy resource, it is expected that there will be an
increasing market for soil amendments such as heat-dried sludge.
If landscape architects, who frequently specify which material
will be used, are convinced of the horticultural value of the
sludge product, it is estimated that a market for 100,000 to
140,000 tons would be created. This estimate is based on
assumptions that: the sludge product will be priced at $4.50
to $5.00 per cubic yard, comparable to barkdust; the sludge
will have no weed seeds, have a granular texture which is not
dusty and does not solidify in storage and have mulching
qualities similar to other organics? and will be readily and
consistently available.
94
-------
Of those who maintain landscaping, only golf courses, park
and public works departments, and schools indicated any demand
for a sludge product at a price greater than zero. The estimated
demand for these three user groups is only about 300 tons per
year at a price of $7.50 to $11.25 per ton, comparable to the
price they are paying for the manures and barkdust they currently
use. This estimate is contingent upon the same product charac-
teristics described in the previous paragraph. These users were
only willing to use the product as a substitute for the soil amend-
ments they currently use on the small amounts of new or replace-
ment planting they do annually. If the heat-treated sludge were
made available free-of-charge, these three users would increase
their volume and the U.S. Forest Service and highway department
would use some as well for total use of as much as 22,000 tons
per year. Much of the additional uses which would be made if
the product were free reflect needs which it is not economic to
satisfy with products available commercially.
Among plant propagators only container nurseries would
consider purchasing heat-dried sludge at a price above zero.
They would be willing to purchase between 640 and 850 tons
per year to use as a part of their potting mixes if it has the
properties described previously and were available for $6.75
to $7.50 per ton. If the product were offered free-of-charge
on a delivered and spread basis, turf farms, field nurseries
and rye grass seed growers would use from about 75,000 to
95,000 tons of heat-dried sludge annually. These specialty
users are like commercial agricultural users in that the product
must be delivered and spread on a schedule adapted to their
individual growing cycles.
The home and garden market. Three different home and
garden uses for a sludge product were identified in the Portland
area. First, there is a significant local trade in soil amend-
ments, primarily barkdust and most of which is sold in bulk,
estimated at 45,000 to 60,000 tons annually. Since bark supplies
available to the home and garden soil amendment market are
being affected by the same forces as those available to the
specialty market (in fact, many bark dealers serve both markets),
it was estimated that the sludge product would be substituted
for about 50% of the material currently sold for this purpose
or 23,300 to 30,000 tons per year. This estimate is conditioned
upon the assumption that the sludge would be sold at $6.75 to
$7.50 per ton, a price comparable to that of wood products.
Home and garden soil amendment users are not as sensitive to
the characteristics of the product as specialty users, but
they will not accept an odorous product or an excessively
dusty one.
The second potential home and garden use of heat-dried
sludge identified and studied in this effort is as an ingredient
in a potting soil. It is estimated that approximately 27,000
tons of potting soils are marketed in Oregon, Washington and
95
-------
Idaho annually. If the sludge product did not have an objection-
able odor or potentially damaging concentrations of heavy metals
it would be substituted for much of the wood products used in
these mixes currently. If the sludge were sold at $6.75 to
$7.50 per ton it is estimated that this market might amount to
6,700 to 9,300 tons per year.
Finally, northwestern gardeners use an estimated 3,000 tons
of organic-base fertilizers annually. These fertilizers are
manufactured primarily by three firms in the area, each of whom
feels there will be the potential to expand sales to as much
as three times its current level in the near future if the price
of chemical fertilizers continues to rise. Heat-dried sludge
provides a very acceptable organic base for such fertilizers
and the firms accordingly are willing to pay $10.00 to $50.00
per ton depending on its nutrient content. Since only one of
these producers is in the Portland region - the other two are
nearer the City of Seattle, which is also studying the feasibility
of producing and marketing a heat-dried sludge - this potential
market for Portland's heat-dried sludge has been estimated at
3,000 tons annually.
Summary of Conclusions. Table 15 presents a summary
of the volumes of heat-dried sludge estimated to be market-
able at the given prices and of the volumes which could
be distributed free-of-charge to various users. These
estimates indicate that it would be feasible to market all of
Portland's sludge if it were heat-dried. Additionally, if the
city did not desire to undertake a marketing program, there are
willing users for many times the city's potential production if
the material were offered free-of-charge. It should be recalled,
however, that many of this latter group would only accept the
sludge if it were also delivered and spread for them on a
schedule coordinated with their activities.
Implementation strategies. One alternative would be for
the city to set up a free distribution program at the treatment
plant. Demand is likely to be seasonal and unpredictable. No
revenue would be produced though only minimal costs, in addition
to the heat-drying, would be incurred.
Another alternative would be to distribute the product
free-of-charge to one or a few large users. While the arrange-
ments for such a program could provide greater assurance that
all the sludge would be used, large users are the most likely
to require delivering and spreading as a condition of acceptance
of the sludge. This type of a program might, therefore, be
more costly than the first type.
Finally, the city could sell the heat-dried sludge to
a marketing contractor. The research necessary to estimate the
potential return to the city from a marketing program was not
96
-------
Table 15
SUMMARY OF CONCLUSIONS
MARKETING ANALYSIS
Potential Markets
Potential Markets
Market
Home & Garden
Market
User
Specialty
Markets
Volume
(Tons/year)
Landscape architects & contractors 100,000-140,000
Golf courses
Parks & public works
Schools
Container nurseries
Soil amendment
Potting soil ingredient
Organic fertilizer base
130
100-130
70
640-850
23,300-30,000
6,670-9,330
3,000
Price
($/ton)
6
7
7
7
6
6
6
40
.75- 7.50
.50-11.25
.50-11.25
.50-11.25
.75- 7.50
.75- 7.50
.75- 7.50
.00-50.00
Potential for Free Distribution
Market
Specialty
Markets
Agricultural
Market
User
Parks & public works
Schools
Golf courses
Highways
US. Forest Service
Rye grass seed growers
Turf farms
Field nurseries
Wheat & barley growers
Volume
(Tons/year)
2,670-3,330
825-1,010
630
210
17,600
60,000
3,170
15,000-30,000
402,000
SOURCE: Gruen Gruen + Associates
97
-------
undertaken in this study. The potential return and exact
volume likely to be marketed would depend on the marketing
strategy pursued. For instance, at one extreme would be a
strategy aimed at maximizing sales by serving as many of the
markets as possible and by maintaining a low price. At the
other extreme would be a strategy aimed at maximizing the return
per unit sold by restricting the volume sold and markets served
and by heavily advertising in order to differentiate the city's
sludge product from other soil amendments and/or fertilizers
in the eyes of the users. Somewhere between these extremes
lies an optimum strategy for the city. The primary determinant
of optimality should be the relative cost of heat-drying and
marketing programs.
The complete marketing analysis entitled The Marketability
of Heat-Dried Sewage Sludge in Portland is available upon
request from the U. S. EPA, Region X office.
Alternatives D-l and D-2, Land Application of Liquid
Sludge-in the Willamette Valley. These two alternatives
are considered together because only the mode of transport
is different. Also, because the method of ultimate sludge
use is by land application, these alternatives fall into the
same basic category of sludge management as Alternative A-l.
The elements and facilities required for this alternative
are shown schematically in Figure 13, and are described in
detail herein. The system generally requires the transpor-
tation of liquid digested sludge, either by truck or barge,
to the northern Willamette Valley for application on
individual farms as a soil conditioner and fertilizer aid.
This could be termed a system for the agricultural reuse of
sludge.
The sludge collected from the primary sedimentation
basins would be gravity thickened and anaerobically digested
in a two-stage digestion system. The second stage permits
partial thickening of the digested sludge to concentrations
in the range of 7 to 8 percent solids content. The sludge
from the secondary digesters is either pumped to the barge
loading dock on the Oregon Slough for loading into barges or
it goes directly into tank trucks for transport to the distri-
bution center.
The waste-activated sludge collected from the secondary
sedimentation basins would be thickened by air flotation
units and anaerobically digested in a completely separate,
two-stage digestion system. Because the digested waste-
activated sludge does not settle and thicken in the secondary
digester, this digested sludge would be pumped to the
sludge storage lagoon where thickening would occur.
98
-------
-------
The Triangle Lake Sludge Lagoon will be renovated by a
thorough cleaning out of the existing sludge, enlargement of
the lagoon system and by installation of additional sludge
distribution piping. The free-standing water above the con-
solidated solids, called supernatants, would be drawn off and
passed through three polishing ponds prior to being pumped
to the primary sedimentation basins for further treatment.
The sludge would be allowed to thicken and concentrate in
the renovated lagoon, and, after about 3 to 4 years, it would
also be pumped to the barge dock or into tank trucks for
transportation to the application site in the northern
Willamette Valley. Similarly, digested sludge from
Tryon Creek would be loaded at a nearby barge loading dock,
or into tanker trucks for transport to the same application
site.
The river barges would transport the liquid digested
sludge approximately 27 miles up the Willamette River to
Clackamas County. A barge unloading dock would be con-
structed at a location 1/4 to 2 miles above the Oregon City
Locks. The liquid sludge would be pumped from the barges
to a sludge storage lagoon or directly into specially designed
tank trucks for application on farm lands. These tank
trucks would have wide wheels for ease of driving onto
privately owned farmlands. The liquid sludge would be
sprayed onto the farm lands, after which it would be
disced into the land by the farmer.
If the sludge transport is accomplished by large tank
trucks, then these trucks would off-load into the sludge
lagoon constructed in the area of sludge application. The
storage lagoon would be required because weather conditions
in the Willamette Valley are such that sludge application is
impractical during the wet winter months. Therefore, a
storage capacity period of approximately 4 months would be
necessary. The lagoon would also provide additional flexi-
bility in the scheduling and operation of the land applica-
tion system.
No-Action Alternative. The EPA regulations for the
preparation of an Environmental Impact Statement (EIS)
require that a "No-Action" alternative also be evaluated
and compared to the alternative sludge management systems
being considered. The no-action alternative for the City
of Portland would entail the continuation of the existing
sludge management system described earlier in this section.
The no-action alternative would be categorized in terms
of the existing basic alternative sludge management system
because most of the sludge is transported to the Rivergate
area and incorporated into the soil. The elements and
100
-------
facilities utilized in the existing system are shown in
Figure 14 and are described below. The existing sludge
handling systems generally consist of applying liquid digested
sludge to Port of Portland property in the Rivergate area
by means of large sprinkler "guns". The sludge is then
incorporated into the soil.
In the future, the sludge from the primary sedimenta-
tion basins would continue to be gravity thickened and
anaerobically digested in the existing facilities. The
sludge from the digesters would then be hauled by tank truck
to the Rivergate area for incorporation into the soil.
The waste-activated sludge from the secondary sedi-
mentation basins would be thickened by air flotation units
and aerobically digested in two of the unused aeration tanks.
The aerobically digested sludge would be pumped to the
Triangle Lake Sludge Lagoon, where the sludge would be
allowed to settle and consolidate. After 3 or 4 years the
sludge in the lagoon would also be hauled by tank truck to
the Rivergate area for incorporation into the ground.
As already mentioned, the existing sludge disposal
sites are fast approaching capacity. The time available to
accommodate sludge at the Rivergate site is totally dependent
upon the rate of industrial development in the area. Current
projections are for the Rivergate site to be at capacity by
the mid-1980's. The St. Johns landfill site is also approach-
ing capacity, but could be used if the Rivergate site cannot
be used. This would require start-up and operation of the
heat treatment system and the vacuum filters for dewatering
the sludge. However, the existing digestion system is also
nearing capacity and as the wastewater flows increase the
capacity may be reached sooner. These higher flows also
may require the use of the two aeration tanks that are now
being used as aerobic digesters.
Even if wastewater flows do not increase, the existing
disposal sites are severely limited and alternative sludge
handling systems will eventually have to be developed.
Since several years are required to design and construct
new treatment facilities, the solids handling facility
expansion should be started at least 4 to 5 years prior to
the date scheduled for their operation.
101
-------
FIGURE 14
SCHEMATIC DIAGRAM
FOR THE NO-ACTION ALTERNATIVE
102
-------
ANALYSIS OF THE ENVIRONMENTAL
IMPACTS OF THE ALTERNATIVES
Introduction
This section of the EIS identifies and discusses the
environmental, social and economic impacts of four alterna-
tive plans (including no-action) for the transport and disposal
of sewage sludge from the City of Portland's Columbia Boulevard
sewage treatment facility. The impacts discussed include
primary (direct) effects, the immediate results of an action,
and the secondary (indirect) effects, the consequences of
direct effects. The time frame of the impact (long- or short-
term) is described wherever possible. Measures (sometimes
in the form of regulations or guidelines), which could
mitigate (reduce in magnitude) or avoid an adverse effect,
are also identified.
The long-term impact section of this chapter is organized
into several subsections based on the three phases of the
project, sludge processing, sludge transport and storage and
disposal.
The short-term (construction) impacts section deals
with all phases of the project since such impacts can be
commonly dealt with from the standpoint of mitigation.
Short-Term Impacts
Short-term impacts, as the name implies, have a short
but finite period of impact, i.e., usually from the incep-
tion of construction until completion of the physical
structures of the project. Such impacts can usually be
effectively mitigated. Short-term impacts and common
mitigation measures are presented in Table 18.
Long-Term Impacts - Sludge Processing
The processing of sewage sludge at the Columbia Boulevard
STP represents a common operation among the four alternatives
considered in this impact analysis. All of the alternatives
depend upon the existing anaerobic digestion (primary and
waste-activated sludge) and sludge treatment to produce a
sludge product suitable for either disposal as a liquid or
drying before reuse. Since the processing facilities re-
present existing facilities (or those covered under the Phase
I Negative Declaration) an analysis of the impacts of such
processing will not be necessary.
103
-------
Table 18
SHORT-TERM IMPACTS - PORTLAND SLUDGE DISPOSAL
The direct short-term impacts of this project are related to construction activities. These
impacts are relatively minor in effect and magnitude and in most cases the adverse impact
can be easily mitigated. The impacts considered, their mitigation and our judgement of the
relative positive or negative merits are given in the following matrix.
Short-term Impacts
Construction-
related traffic
Disruption of
through and local
traffic
Dust
Employment
Turbidity and
disturbance of
fish life
0)
0)
•H
•H
H
C
c
~H G
0
o
(J O
•H
¦H
flj «H
4J
4J
41 U
a
1 O
C 3
3
0 3
•H U
u
tJ> M
0
a* o
w o
X
X
X
Alternatives
A C D No-action
XXX
XXX
X X
Noise
- A
B B B
A o A
Recommended Mitigation Measures
Barricades and flagmen should be
posted as necessary to guide
traffic through construction zones;
residents in area should be
notified as to location, nature
and duration of construction.
Keep soil wetted down in con-
struction area.
None necessary.
Construction should occur during
low flow periods (late summer)
and when anadromous fish popula-
tions would be least affected.
All equipment should have
mufflers, properly installed
and maintained. Construction
activities should be limited
to daylight hours.
Economic
activity
Aesthetics
Soil erosion
XXX
XXX
XXX
B B B
A - A
Disruption of
benthic habitat
Safety hazard
None necessary.
Equipment should be stored in
a designated area. All litter
should be picked up.
Fence or otherwise screen con-
struction maintenance area.
If possible, construction should
be done during the drier months
of the year.
After construction, exposed soil
areas should be reseeded using
grasses native to the area.
Limit the area of disturbance
to the immediate dock location.
All open trenches should be
covered or fenced at the end
of each work day.
All construction equipment should
be secured against unauthorized use.
Aerial pollutants
All vehicles and equipment should
be fitted with appropriate
pollution control devices that
are properly maintained.
Disruption of
wildlife
Temporary loss
of vegetation
A o A
beneficial impact
minor adverse impact
104
Vegetation stripping for the
pipelines should occur during
the late summer or fall months
when nesting birds are not present.
Replant after construction or
allow for natural regrowth of
shrubs and trees.
Vegetation adjacent to pipelines
should be flagged or fenced to
keep vegetative destruction
to a minimum.
moderate adverse Impact
no impact
-------
However, Alternative C (local reuse of sludge) represents
an alternative that requires sludge processing beyond existing
or proposed operations under Phase I. Two sludge drying
processes are identified for consideration. The B.E.S.T.
process employs the use of an industrial solvent (triethylamine)
and heating and cooling to produce a dry, reportedly pathogen-
free sludge product. The Carver-Greenfield process is a
dehydration technique involving oil emersion. The following
section discusses the impacts associated with the B.E.S.T.
and Carver-Greenfield processes prior to the sludge transport
and disposal.
Energy Use
The B.E.S.T. process requires both steam and electrical
energy, but it generates an oil which can be reclaimed and used
to produce a portion of the steam. Steam is required primarily
for evaporation of the extraction solvent (triethylamine)
from the sludge and for drying the sludge. Electrical energy
powers the various motors utilized in the process, as well
as the process controls and instrumentation.
Steam energy requirements are 4,775,000 BTU/ton of sludge,
which, assuming an 85 percent conversion efficiency from
natural gas to steam, is equivalent to 5,617,650 BTU of natural
gas. Estimates indicate that over 99 percent of the steam
required can be produced from digester gas and oil reclaimed
during the drying process. Less than 1 percent of the energy
requirement for steam would come from natural gas.
Electrical energy requirements for the B.E.S.T. process
are estimated to be 375 kw-hr/ton of input sludge. Dewatering,
which is a pretreatment operation to the B.E.S.T. process,
would require an additional 9.6 kw-hr/ton of sludge, for a
total electrical energy requirement of 422 kw-hr/ton of input
sludge.
The Carver-Greenfield process has an electrical energy
input of 139 kw-hr/ton of sludge, on the basis of an input of
sludge having 20 percent dry solids. The higher the water
content, the higher the electrical energy requirement. Fuel
for heating amounts to 3.3 million BTU/ton of dry solids.
The oil extracted frcm the sludge is used as a fuel. Heat
in excess of process needs is then available frcm the dry
sludge if a use for that heat can be identified and economically
exploited. The net combined energy requirement is 1 to 2
million BTU/ton (San Francisco Bay Region Wastewater Solids
Study, 1977).
105
-------
Chemical Use
In addition to the extraction solvent (triethylamine),
the B.E.S.T. process requires either potassium hydroxide,
calcium hydroxide or sodium hydroxide for pH adjustment
and an antifoaming agent. Expected chemical requirements
are shown in the following table:
Triethylamine (TEA) is a tertiary alkylamine classified
as stable but flammable. Acute toxicity bioassays using the
California stickleback indicate a TLm (50 percent mortality
in 8 hours) of 27 mg/liter (pH*10). At a water pH of 7.0
the TLm ranged from 980 to 1,300 mg/liter.
Table 19
ESTIMATED CHEMICAL REQUIREMENTS FOR B.E.S.T. PROCESS
lb/ton of
input
sludge
1980
lb/year
1990
2000
Triethylamine (makeup)
7
178,850
204,400
229,950
Potassium Hydroxide
19
485,450
554,800
624,150
Antifoaming Agent
2
51,000
58,400
65,700
The Carver-Greenfield process uses a light oil mixed
with the sludge for dewatering. The process is essentially
closed and the oil fraction is recycled by centrifugal sep-
aration of the oil from the solids, then the light oil is
recycled and any recovered heavy oil is used for heating.
Air Emissions
The B.E.S.T. process is principally a closed cycle
operation. The main source of odors originates with the
sludge drying operation, although the exhaust air would
be recycled. A condensing operation would be utilized on
the dryer exhaust prior to recycling and/or venting, and this
condenser would remove most of the triethylamine in the dryer
exhaust. A scrubber would also be used on the dry gas prior
to venting to remove any remaining triethylamine or other
odors. The scrubber exhaust is also to be deodorized to
eliminate any chance of odor production.
The Carver-Greenfield system is also closed and does not
generate significant amounts of waste gas. Waste gases are
generated from the combustion of fuel oil for heating and
steam generation. Odors occurring from these processes can
be removed by chemical or thermal treatment.
106
-------
Recycled Water
Water removed from the sludge, plus cooling water used
in the vent gas scrubber, would be recycled back to the
beginning of the Columbia Boulevard treatment plant. The
normal wastewater treatment process would remove any remaining
triethylamine, organics or suspended solids. Due to the
high pH that is maintained during B.E.S.T. processing, a
pH at which most heavy metals are insoluble, there would be
negligible amounts of trace heavy metals in the recycled
water. The estimated amount of water to be recycled would
be in the range of 1,100 gallons per ton of sludge processed,
or about 88,000 gallons per day in 1990.
In the Carver-Greenfield process the initial sludge
moisture is recaptured as condensate. The condensate consists
of distilled water with zero suspended solids, but it contains
volatile components, including oil and soluble oxygen-demanding
materials (San Francisco Bay Region Wastewater Solids Study,
1977) .
Process Reliability
There are no full-scale B.E.S.T. sludge processing
operations from which long-term operational data can be
derived. The best indicator of B.E.S.T. system process
reliability on treating Portland sludge is seen in data
collected during the July 25, 1977 to September 22, 1977
pilot study conducted at the Columbia Boulevard treatment
plant. During this 2-month pilot study, the trailer-mounted
unit was checked out and operated on three different com-
binations of sludge. Over the entire study, including a
shakedown and the checkout, the pilot plant was on line and
processing sludge over 86 percent of the time.
Although the B.E.S.T. process does utilize a "mechanically
intensive" system of components, no component of the system
represents new technology. Each piece of equipment is presently
available and is commonly used in a wide variety of industrial
operations. On this basis, there is no reason to conclude
that a properly operated B.E.S.T. process would be unreliable.
More maintenance time and labor will be required than in a
less mechanically-intensive system, but these costs have been
included in the operation and maintenance costs and do not
in themselves indicate an unreliable system. It should be
recognized, however, that reliability of the B.E.S.T. process
would require the use of highly skilled operators.
107
-------
The Carver-Greenfield process has also had a short history
of pilot plant application with no full-scale experience
handling sewage sludges. The reliability of the process is
expected to be fair since the components are comparable to
those used for mineral and chemical wastes. The Los Angeles/
Orange County Metropolitan Area (LA/OMA Project) regional
program for wastewater solids management recently conducted
a pilot plant study using the Carver-Greenfield process.
Results of that pilot study are not now available.
Consistency of Sludge Quality
The B.E.S.T. process product is similar in both look
and texture to coffee grounds. Consistency in the quality
of the product will be closely correlated with B.E.S.T.
process reliability. The product quality should be sufficiently
consistent to allow intended uses to be satisfactorily met.
As with the B.E.S.T. product, the Carver-Greenfield process
will produce a very dry product, which may cause dust problems
(San Francisco Bay Region Wastewater Solids Study, 1977).
Material Requirements
Because the B.E.S.T. process is mechanically intensive,
it will require such maintenance material items as valves,
fittings, instrumentation, pumps, and other items that period-
ically wear out. The manufacturer estimates these items will
cost no more than 3 percent per year of his original cost.
The 3 percent figure is based upon the system being maintained
in a condition similar to that of a new system.
The Carver-Greenfield process is also mechanically
intensive. Materials selected for construction of equipment
must be suitable to handle sewage sludges and corrosive
ammonia fumes.
Long-Term Impacts - Sludge Conveyance
Barge Transport
A tank barge could be utilized to transport liquid sludge
on the Columbia or Willamette River. Tank barges utilized for
conveyance of liquid material on the Columbia River are typically
242 feet long, 42 feet wide, weigh 550 to 600 tons when empty,
108
-------
and have a fully loaded draft of 13 feet and a carrying
capacity of 500,000 gallons (3,200 tons). The tank barge
contains 8 to 10 compartments for liquid storage with buoy
compartments in the bow and stern. Tank barges utilized for
conveyance on the Willamette River through the Oregon City
lock are 146 feet long, 34 feet wide, have a carrying capacity
of 210,000 gallons (1,400 tons) and a 5- to 8-foot draft.
Twin-screw pusher tugs are regularly used to push barges
upstream on the Columbia and Willamette Rivers. On the Columbia
River tugs with 1,000 to 3,600 horsepower push 1 to 3 barges
in a single tow. On the Willamette River tugs with horsepower
ratings between 1,200 and 1,500 push 1 to 2 barges in a single
tow. Accidents involving tugs and/or barges could adversely
affect resources and beneficial uses of the river through
the spillage of fuel and/or sludge.
Barging Routes
Conveyance of sewage sludge by barge is proposed for the
Columbia and Willamette Rivers. Figure 15 shows the possible
barge routes in the study area. The proposed route on the
Columbia River from the barge loading facility on Oregon
Slough to Threemile Canyon or Sixmile Canyon in Morrow County
(156-170 nautical miles) involves the negotiation of locks
at Bonneville, The Dalles and John Day Dams. Barging on the
Willamette River from Oregon Slough to an off-loading dock
at river-mile 28 or 29 (32 nautical miles) would involve
passage through the locks at Oregon City. Figure 15 gives
information on the sizes and depths of locks on both rivers.
Major uses of the Columbia and Willamette Rivers include
the production of hydropower, commercial and noncommercial
transportation, water supplies for agricultural, industrial,
and municipal purposes, recreation, the passage of migratory
fish to spawning grounds upstream and fish and wildlife habitat.
The Columbia and Willamette Rivers are important
navigational routes for commercial and recreational vessels.
Numerous navigational aids in the form of range markers,
beacons, fixed channel markers and buoys are located on
both rivers. In addition, navigational charts provide
information on channel depths, locations of navigational
aids and locations of hazards. The average daily vessel
traffic for all vessels on the Columbia and Willamette Rivers
in 1976 was 94 and 23 vessels, respectively. Of all vessels
traveling daily on the Columbia River, 56 (60 percent) were
barges. Only 6 (2 6 percent) of 23 vessels traveling daily
on the Willamette River were barges (U. S. Army Corps of
Engineers, 1977).
109
-------
-------
Liquid or dry cargo is transported by barge on the
Columbia River 24 hours a day every day of the year. The
greatest number of barges that are normally moved by pusher
tug boats at a given time is three (Hickey, pers. comm.).
A navigation channel is maintained in the Columbia River
between Portland and Bonneville Dam; the average channel
depth is 22 feet. A minimum channel depth of 12 feet occurs
at low flow in the vicinity of Government Island, northeast
of Portland. Above Bonneville Dam main channel depths exceed
30 feet in most areas.
Barge movement on the Willamette River is less than on
the Columbia River due to natural river characteristics.
Between the mouth of the river and Ross Island the channel
depth is maintained at 40 feet by the U. S. Army Corps of
Engineers. Above Ross Island, the channel begins to meander
and depths at several locations may drop to as low as 3 feet
during low flow periods. Shallow or narrow areas in the river
channel occur at river-mile 25 below the Oregon City lock and
at river-mile 30, 32, 33 and 51 above the lock. Above Newberg
the Willamette River is not considered navigable for most
commercial vessels. In addition, the size and draft of
commercial vessels traveling on the Willamette River past
the Oregon City lock are limited by the size and shallowness
(6 feet) of the lock (see Figure 15). As a result of these
conditions barge transportation upstream of the Oregon City
lock is limited to periods of high flow and barges with
draft less than 6 feet. The characteristic meandering of
the Willamette River limits to two the number of barges that
can be moved at one time (Hassler, pers. comm.).
Potential hazards to barge transportation on the Columbia
and Willamette Rivers include: 1) negotiating locks, especially
Bonneville and Oregon City, which are narrow, short or shallow;
2) severe weather, with high winds and dense fog being the
most hazardous; 3) obstructions in the water such as shoals,
pilings, rocks, sunken and visible wrecks; 4) mechanical or
structural failures; and 5) congestion in the numbers of
vessels.
From 1972 to 1976 a total of 38 accidents involving
barges were reported to the U. S. Coast Guard (U. S. Depart-
ment of Transportation, 1977). The most common types of
accidents (69 percent) involved collisions with fixed objects
such as a lock, dock, or navigational aid or grounding.
Other less common accidents involved collisions with moving
or anchored vessels, capsizing and explosions.
Ill
-------
The most common causes of barge accidents were inclement
weather (4 0 percent), human error (32 percent) and structural
failure (24 percent). Other minor causes of accidents were
improper loading and congestion.
A total of 5 accidents reported to the U. S. Coast Guard
between 1972 and 1976 involving dry cargo barges resulted in
spills. One accident involving a tank barge resulted in a
minor oil spill (U. S. Department of Transportation, 1977).
Another important use for Columbia and Willamette River
waters is in agriculture. Approximately 135 diversions are
located on the Columbia River between Portland and McNary Dam
(Washington Department of Ecology, 1977 and Oregon Water
Resources Department, 1978) (see Figure 15). Approximately
87 percent of these intakes in Oregon supply water for irrigation
at intake rates ranging from .012 to 3 87.0 cfs. The remaining
diversions supply water for industrial or municipal uses.
The exact uses of diversion intakes in the State of Washington
were not determined.
A total of 267 diversion intakes are located on the
Willamette River between Portland and Salem. Nearly all
(99 percent) of these intakes supply water for agricultural
uses at intake rates ranging from .004 to 48.0 cfs. Four
municipal intakes divert water at rates less than .04 cfs.
The Willamette River also supplies water to 3 industries at
rates ranging from .9 to 417.0 cfs (Oregon Water Resources
Department, 1978).
Most of the water used for municipal, domestic and industrial
purposes in the study area is taken from groundwater resources.
Agricultural land irrigators away from the Columbia and Willamette
Rivers and their tributaries also rely on groundwater supplies.
The most prevalent recreational use of the Columbia and
Willamette Rivers within the study area is sport fishing.
Figure 15 shows some locations where access to both rivers
can be reached for bank fishing. Most fishing, however, is
done from boats. In 1975 more than 51,000 recreation days
were spent in fishing for steelhead and resident trout in
northcentral and northeastern Oregon. In the northern Willamette
Valley more than 787,000 recreation days in 1975 were spent
in fishing for chinook salmon, steelhead, sturgeon, resident
trout and warm-water game species (Oregon Department of Fish
and Wildlife, 1977). Numerous state parks and recreational
areas on both rivers provide access for fishing and other
water-related uses (Figure 15).
112
-------
Facilities associated with the Columbia and Willamette
Rivers' fish and wildlife resources are the Bonneville, Cascade
and Oxbow fish hatcheries in Oregon; the Spring Creek and
Little White salmon hatcheries in Washington; the Umatilla
National Wildlife Refuge# northeast of Boardman; and the fishways
and fish ladders associated with each dam (Figure 15).
Those fish hatcheries mentioned above release juvenile
anadromous fish into the Columbia River throughout the year.
Water supplies for propagation come from other surface or
groundwater supplies rather than the Columbia River. Addi-
tional fish hatcheries located on tributaries to both the
Columbia and Willamette Rivers contribute juvenile anadromous
and resident species to the basin.
Truck Transport
Trucks currently being used to transport liquid sludge
from Tryon Creek STP to Columbia Boulevard STP are Cummins
Diesel Model NTC 350, manufactured by White Motor Corporation.
The truck and trailer wheelbase is 42 feet in length, the
loaded weight is 77,3 00 pounds and the trailer—carrying
capacity is 6,000 gallons. The capital cost of each truck
and trailer combination is approximately $46,700. The
truck's life expectancy is 8 years. Gas mileage is approxi-
mately 5 miles per gallon with a fully loaded truck. Truck
accidents could adversely affect right-of-way and drainage
resources through the spillage of fuel and liquid sludge.
Trucking Routes
Existing sludge conveyance routes from Kellogg Creek
and Tryon Creek STPs to the Columbia Boulevard STP and
proposed routes from Columbia Boulevard STP to the north
Willamette Valley land application site are shown in Figure 16.
Land use surrounding these routes is primarily high-density
residential and commercial. Low-density industrial uses
occur on North Columbia Boulevard east of the Columbia
Boulevard STP.
Average daily traffic volumes on existing routes from
Tryon Creek and Kellogg Creek STP to Columbia Boulevard STP
are given in Table 20. Heavy trucks comprise approximately
3 to 9 percent of the average daily traffic volume on these
routes (Oregon Department of Transportation, 1976). The
total number of motor vehicle accidents at intersections of
Portland city streets in 1976, on routes from Tryon Creek
and Kellogg Creek STP to the Columbia Boulevard STP, were
56 and 133 respectively (Oliver, pers. comm.).
113
-------
-------
Table 20
AVERAGE DAILY TRAFFIC VOLUMES
ON EXISTING SLUDGE CONVEYANCE ROUTES, 1975
Route ADT
Kellogg Creek to Columbia Boulevard STP
SE. McLoughlin Boulevard 44,383
SE. Grand Avenue 25,425
SE. Morrison 22,800
Interstate 5 North 41,7 00
N. Columbia Boulevard 12,038
Tryon Creek to Columbia Boulevard STP
SW. McAdam Avenue 20,610
Interstate 5 North 46,588
N. Columbia Boulevard 12,038
SOURCE: City of Portland, 197 5
115
-------
Existing routes from Tryon Creek and Kellogg Creek STP
to the Columbia Boulevard STP are approximately 30 miles for
a round trip. Three to four trips are made daily conveying
liquid sludge to Columbia Boulevard STP from each STP.
Traffic Congestion and Transport Hazards
Barging. Depending on the number of barges towed per
trip, by the year 2000 an approximate annual minimum of 56
and maximum of 166 trips (average 111 trips) on the Columbia
River would be necessary to convey the liquid sludge to northern
Morrow County. The conveyance of sludge on the Willamette
River to sites in the northern Willamette Valley would require
between 135 and 406 barge trips per year (average 270 trips).
These trips would be confined to periods of high river flow
or 8 to 9 months of the year. The increase in vessel traffic
on both rivers, in addition to other such increases resulting
from economic growth in the Columbia basin, would increase
river traffic congestion and increase the risk for barge
accidents and sludge spills.
Trucking. By the year 2000 approximately 39 round trips
per day would be necessary to transport sludge produced at
the Columbia Boulevard STP to sites in the northern Willamette
Valley for land application. This assumes 6 percent solids
content of the sludge and a truck with a 6,000-gallon capacity.
This increase in heavy diesel truck traffic on city streets
and highways would add to traffic congestion, particularly
during peak load hours, accelerate pavement deterioration and
increase the potential for truck accidents and spills.
Energy Use
Barging. By the year 2000 the annual fuel consumption
to transport sludge by barge to northern Morrow County would
be approximately 576,000 gallons. Assuming an equivalent
fuel consumption per ton mile for pushing barges on the Willamette
River the annual fuel consumption for sludge conveyance would
be 157,200 gallons.
Trucking. Using an average diesel fuel consumption of
0.2 gallons per mile, approximately 170,000 gallons of diesel
fuel would be consumed yearly to transport sludge to sites
in the northern Willamette Valley by the year 2000.* Convey-
ance of sludge from the Columbia Boulevard STP to the pro-
posed barge loading facility on Oregon Slough would consume
approximately 11,400 gallons of diesel fuel per year by the
year 2000.
* Note: These fuel consumption estimates are based on minimum
distances from the Columbia Boulevard STP to the northern
Willamette Valley. Sludge application farther south will
require more fuel. llfi
-------
Odors
Barging. Onloading and offloading of liquid sludge should
not cause an appreciable odor problem due to the enclosed
pipeline conveyance systems in use from the Columbia Boulevard
STP to the barge loading dock and from the offloading docks
to the sludge storage areas. Any volatilization will be minor
and, with effective air dispersion, should create only localized
odor problems.
Barges will be enclosed, but equipped with proper ven-
tilation equipment to prevent any accumulation of explosive
methane gas. However, odor problems from ventilation should
be minimal provided the sludge is properly digested.
Trucking. The tank trucks used for trucking sludge are
enclosed, kept clean and should not constitute an odor problem.
There is no record of odor complaints from the use of the
present sludge trucking operation. The addition of more
diesel-powered vehicles on the highways will increase the
risk for disagreeable odors, particularly where trucks
travel through heavily congested areas that require stop-
and-go driving situations.
Air Emissions
Barging. Table 21 depicts the projected air emissions
from barging based on a per-trip basis and on an annual basis.
Annually, about 576,000 gallons of diesel fuel would be consumed
in barging operations.
Projected air emissions from barging operations on the
Willamette are shown in Table 22.
Trucking. Based on 1978 estimates, approximately 31
round trips per day would be necessary to dispose of sludge
at the north Willamette Valley site. Each round trip will
cover approximately 60 miles or 1,860 miles per day. Table 23
depicts the emissions expected daily for the years 1978 and
2000 as a result of trucking.
Sludge Loading and Unloading Facilities
Barging~ Barging sludge to either Morrow County (Alterna-
tive A) or north Willamette Valley (Alternative D) will require
the construction of barge docks at Oregon Slough and on either
the Columbia River near Boardman or on the Willamette River
above the Oregon City locks. An existing dock is located at
the Port of Morrow in Boardman.
117
-------
Table 21
PROJECTED EMISSIONS FROM BARGING
SEWAGE SLUDGE TO MORROW COUNTY1'2
Carbon Monoxide3 Hydrocarbons Nitrogen Oxides
Engine Speed lbs/year lbs/trip * lbs/year lbs/trip lbs/year lbs/trip
Idle or Slow 20,529 185 8,294 75 50,734 46
Cruise 18,123 163 14,359 129 134,392 1,339
TOTALS 38,652 348 22,653 204 185,126 1,385
1 Assumes that a 3,600-hp tug will be used and that approximately 76 percent of
the barging time is at cruising speed and 24 percent at idle speed.
2 See Appendix E for projected emissions based on diesel engine size - EPA, 1976.
3 Fuel consumption - 576,000 gallons annually.
Assumes 111 trips per year.
-------
Table 22
PROJECTED EMISSIONS FROM BARGING
SEWAGE SLUDGE TO NORTH WILLAMETTE VALLEY1'2
Carbon Monoxide3 Hydrocarbons Nitrogen Oxides
Engine Speed lbs/year lbs/trip ** lbs/year lbs/trip lbs/year lbs/trip
Idle or Slow 3,268 12 - - 9.910 37
Cruise 5,812 22 - 61,506 302
TOTALS 9,080 34 - 71,416 339
1 Assumes that a 1,580-hp tug will be used and that approximately 83 percent of
the barging time is at cruising speed and 17 percent of time at idle speed.
2 See Appendix E for projected emissions based on diesel engine size - EPA, 1976.
3 Fuel consumption - 157,200 gallons annually. This is based on a minimum
distance from the Columbia Boulevard STP to the north Willamette Valley.
* Assumes 270 trips per year.
-------
Table 23
PROJECTED EMISSIONS FROM TRUCKING
SLUDGE FROM THE COLUMBIA BOULEVARD STP
TO NORTH WILLAMETTE VALLEY1
Grams per day2
Assumed Average
Speed (mph)
30 mph
Hydrocarbons
19783 2000"
6,454 7,703
Carbon
Monoxide
1978 2000
32,996 39,383
Nitrogen
Oxides
1978 2000
34,168 40,781
35 mph
5,876 7,015 27,974 33,389 34,949 41,714
40 mph
5,506 6,571 24,440 29,171 37,386 44,622
1 See Appendix E for emission factors.
2 1 gram = 2.2046 x 10~3 pounds.
3 Assumes: 1,860 miles per day in 1978. sludge application farther
south will increase this mileage.
Assumes: 2,220 miles per day in 2000. Sludge application farther
south will increase this mileage.
120
-------
Long4-term impacts associated with dock construction at
Oregon Slough will be 1) the permanent removal of approximately
1 1/2 acres of riparian vegetation along the river, 2) filling
and dredging to accommodate the docking structure and barges,
3) a change in aesthetics and land use from a presently undev-
eloped portion of the slough to an industrial use and 4) an
intermittent increase in noise and traffic associated with
barge loading.
Two of the candidate barge unloading dock sites on the
Columbia River in Morrow County (Alternative A) would cause
minor impacts on vegetation. Vegetation at both dock sites
is sparse, consisting of sagebrush and grasses. Use of
Threemile Canyon as an off-loading dock would result in the
loss of an island nesting colony of Caspian terns and ring-
billed gulls. Any filling and dredging at dock sites would
impact existing benthic fauna and any fish species that
might use the shallows (particularly juvenile fish).
Both sites represent terrestrial and aquatic habitat
typical along the Columbia River. Due to the openness and
sparse vegetation on the site, a dock at either Threemile or
Sixmile Canyon would be a highly visible feature in the area.
The Port of Morrow dock is now located in an area designated
for industrial use.
An offloading dock for Alternative D could be located
along a 2-mile stretch of the Willamette River above the
Oregon City locks. The area is already impacted by State
Highway 99E and a railroad. Major long-term impacts associated
with dock construction along the Willamette River would be
1) the permanent removal of riparian vegetation, 2) an
alteration of aauatic substrate at the site of the dock,
3) a permanent change in aesthetics and land use, 4) inter-
mittent increases in turbidity levels in the Willamette River
due to barging activities and 5) increases in noise and
river traffic associated with the unloading facility (Figure 17).
The possibility of locating an offloading dock farther
upstream (south) on the Willamette River appears limited.
While the river is considered to be navigable to Newberg, much
of the river from Oregon City to Newberg is shallow or narrow.
A navigation channel is not maintained above the Oregon City
locks and during low flow months river depths are often 3
to 5 feet. Because of these limiting conditions potential
docking locations were confined to the 2-mile stretch above
the Oregon City locks.
Preliminary archeological surveys conducted at each
barge loading and unloading site by Oregon State University
personnel, indicate that no archeological or historical
resources exist at these sites. An archeologist will be on-
call during actual dock construction in the event any sites
are unearthed.
121
-------
mm
.«p Sewage
\S*. Disposal
'est»Linn
'parrot
BIN* 479./
Figure 17 . Area Considered
for Construction of Barge
Unloading Dock, Willamette
River - Alternative D.
-------
Sludge Conveyance Reliability
Barging, Reliability of barging as a means of conveying
sludge is influenced by factors such as weather# navigation
hazards (shallow water, locks, etc.), mechanical reliability
and labor strikes.
According to data from the U. S. Coast Guard (1976),
there were 38 barge accidents on the Columbia River during the
period from 1972 through 1976 for an average of about 8
accidents per year.
Poor weather is probably the major factor in the inter-
ruption of barging service. On the Columbia and Willamette
Rivers weather during the winter months causes most inter-
ruptions of service. Other factors such as accidents at locks,
lock failure, and the annual 2-week lock maintenance program
would disrupt all river traffic temporarily.
The reliability of barging service for transport of sludge
to Morrow County (Alternative A) is considered good. The
Columbia River from Portland to Morrow County is used fre-
quently for barging (56 vessels per day or 60 percent of the
commercial traffic) (U. S. Corps of Engineers, 1977). Naviga-
tion channels are well marked and the river is sufficiently
deep to handle large (3,600 HP tug plus three barges) barges.
Some barge traffic congestion occurs on the Columbia at
certain locations, particularly at the Bonneville Dam, where
it usually takes 4 hours to move three barges through the
short lock (Hickey, pers. comm.).
Barging on the Willamette River (Alternative D) will have
a number of potential problems, all of which will affect the
reliability of the project. Shallow water (particularly during
summer and fall low flow periods), narrow and shallow locks
at Oregon City and meanders in the river, are factors reducing
the use of barges on the Willamette River (Hassler, pers. comm.).
Trucking. The reliability of truck transport is considered
good so longas standby trucks are available and preventive
maintenance procedures are practiced (San Francisco Bay Region
Wastewater Solids Study, 1977). Some problems may be encountered
with traffic congestion, safety and possible uncontrolled
discharges of sewage sludge due to leaky valves or damage
in transit.
Noise
Barging. Noise generated by barge tugs will be limited
in impact to the onloading and offloading dock sites and a
narrow strip from Portland to Motrow County (Alternative A)
or just above the Oregon City locks (Alternative D). The
proposed loading dock at North Portland Harbor is within an
123
-------
industrially zoned area and well away from areas sensitive to
noise. Tugs with diesel engines and adequate exhaust systems
typically emit noise levels of approximately 75 dBA at 50
feet. Much of the noise of the diesel engines is contained
within the hull or transmitted below the water line. Due
to the large size of the Columbia River and the sparse popula-
tion east of Portland, noise will have a minor impact.
Barge travel on the Willamette River (Alternative D) will
be more frequent and closer to heavily populated areas. As a
result the noise created by barging on the Willamette River
would have a somewhat greater magnitude than barging on the
Columbia River. H
Trucking. The 300-350 hp diesel engines most commonly
used in the transport of heavy materials typically emit 90 to
95 dBA at 50 feet (U. S. EPA, 1971). Any use of truck transport
for Alternative D will require routing through several areas that
already experience a great deal of traffic congestion and stop-
and-go driving. The noise generated by the trucks is, for the
most part, unavoidable. Some mitigation can be achieved by
mechanical adjustments to the trucks; however, the most effective
means of reducing the noise impact is by rerouting trucks through
areas less sensitive to noise.
Under the no-action alternative, the impact of noise from
trucks will be minor due to the lack of residential areas and
the compatible industrial use nature of the Rivergate area.
Barge Spill Hazard
Transport of digested liquid sludge in barges cannot be
considered to be perfectly safe, and an accidental spill
of sludge into either the Columbia or Willamette could occur.
Such a spill could occur if a barge ran into another object,
e.g. another barge, a towboat, or a lock. Other situations
which could cause a spill are grounding, sinking or an
accident during loading or unloading. The principal concerns
of sludge spillage relate to protection of public health,
impact on the river fishery, and aesthetics.
From a public health perspective, a spill would add
disease-producing organisms to the river. While the anaerobic
digestion treatment used prior to barging would destroy at
least 90 percent of the organisms initially present, some
would still exist in the sludge during barging. The likeli-
hood of any pathogenic organisms actually infecting a human
would probably only occur following ingestion. To prevent
the possibility of ingestion, an emergency program would have
to be implemented immediately following a spill to warn all
agencies and individuals to cease water withdrawals from the
124
-------
river until the slug of contaminated water passes. Recrea-
tional beaches in the downstream vicinity of a spill would
probably have to be closed for a short time. A monitoring
program would also have to be established. Once the con-
taminated water passes, a higher than normal level of disin-
fection should be used for several days on any domestic water
withdrawals immediately downstream from the spill, to further
lessen the risk of any disease.
The impact of a spill on the river fishery could re-
sult primarily from a lowering of the dissolved oxygen con-
centration. A series of calculations were performed for both
the Willamette and Columbia Rivers, during low flow and high
temperature situations. The calculations for the Columbia
River indicate that the spill of an entire barge, with disper-
sal of the contents in 10 minutes of river flow, could result
in a minimum dissolved oxygen concentration of 6 mg/1. This
minimum concentration would occur from 5.5 to 6.5 days later
as the volume of affected water moves downstream.
In the Willamette River a different situation would
occur. A spill during the summer months would result in
severe dissolved oxygen depletion, with all dissolved oxygen
in the affected water being used up within 3 days. If however,
the affected water moved into the Columbia River prior to this
time, a zero dissolved oxygen condition would be averted. A
complete barge spill into the Willamette River during the
winter months would result in about a 2 mg/1 lowering of
dissolved oxygen.
A spill at the Portland Harbor loading dock would present
one of the worst possible spill conditions particularly during
the Columbia River freshet when Willamette River flow may
actually stop in the harbor due to high water levels in the
Columbia River. Although calculations are difficult to make
for such an estuary situation, it is estimated that a spill
at the loading dock could rapidly deplete dissolved oxygen to
zero if a stagnant water conditions exists. If the spill
were rapidly flushed out into the main stem of the Columbia,
the dissolved oxygen lowering would occur in the main stem of
the river, and would be similar to the situation previously
described. All such calculations are made in the conceivable
worst case conditions for flow and temperature. More precise
estimates would require on-site studies of current patterns
in relation to river flow.
From an aesthetic standpoint, any spill would create a
problem because some of the sludge would float to the sur-
face. In addition, if dissolved oxygen is depleted, a fish
kill could result.
125
-------
Long-Term Impacts - Sludge Disposal
The institutional requirements and the impacts associated
with the disposal of sludge vary with the means of disposal.
For example, regulatory requirements for the disposal of
sludge on nonagricultural land (e.g., shifting sand) or in
a sanitary landfill are not necessarily the same as those
for disposal on agricultural land. The impacts associated
with sludge disposal in each of the four viable alternatives
are different.
Water Resources
Groundwater and surface water are two natural resources
that can be impacted by sludge disposal. The Oregon Department
of Environmental Quality (DEQ) has issued a proposed regulation
(OAR Chapter 340, Division 4, Subdivision 2, September 1977)
stating that it is the responsibility of the permittee to
ensure that "the disposal or application (of sludge) does
not result in surface runoff, contamination of surface water
or wells, or create a nuisance condition or health hazard".
Furthermore, the DEQ has established guidelines governing
site selection (topography, setback, and application rates)
for sludge disposal (OAR Chapter 340, Division 4, Subdivision 2).
In the EPA's Technical Bulletin relating to municipal
sludge management (42 CFR, No. 211), several general require-
ments are outlined regarding land application of sludge:
"Groundwater Protection. Projects for land application of
sludges will be designed so that the permanent groundwater (ground-
water which is not removed from the ground by an underdrain system
or other mechanical means) in the zone of saturation (where the
water is not held in the ground by capillary tension) will be
protected frcm pollution. Consideration should be given to the
extent of the project, the quality of the groundwaters, and the
fact that groundwater is typically used for drinking water supply
with little or no additional treatment. Also, in seme areas,
groundwater recharge of surface streams may be significant.
Specific groundwater criteria will be developed under PL 94-580.
Until such are developed under PL 94-580, criteria contained in
the EPA publication Alternative Waste Management Techniques for
Best Practicable Waste Treatment, EPA 430/9-75-013, should be
followed."
"Controlling Surface Water Runoff* Sound engineering
practice requires the control of surface runoff that may leave
the site as well as that which will enter the site frcm contiguous
properties. Controlled release of runoff frcm sludge application
areas and effective erosion control methods must be practiced as
necessary. Consideration should also be given to materials which
may leach out of the sludge. Surface water criteria are to be
developed under PL 94-580."
126
-------
Alternative A. Alternative A (barge transport and land
application in eastern Oregon) would involve the disposal of
208,250 gallons (52 dry tons) per day of liquid sludge on
either agricultural land or unstable sand areas near Boardman,
Oregon. At Site A (Figure 5) groundwater is greater than
6 feet below the surface (City of Portland, 197 6; Portland
General Electric Company, 1973). At Site B (Figure 5)
(Sections 26, 27, 34 and 35) the groundwater also lies >6 feet
below the surface. At Site C (Figure 5), south of the Board-
man Flight Strip, the depth to groundwater is greater than
6 feet. The depth to groundwater, the type of soil and the
low rainfall (approximately 7 inches per year) will make any con-
tamination of groundwater from sludge leachate highly im-
probable.
The nearest known well is approximately 2,000 feet east
of Site A, which is an adequate distance for protection of
that well water supply (CRAG, Tech. Suppl. 8, 1977).
All three disposal sites are adjacent to intermittent
waterways (Threemile Canyon and Sixmile Canyon), both of which
are tributary to Lake Umatilla (Columbia River). Due to
the low rainfall in the area (7 to 8 inches per year),
stream flow occurs only intermittently from September through
April. Heavy storms have been known to cause occasional flash
flooding in both canyons (Pitney, pers. comm.). These
heavy rains could cause runoff sufficient to transport
the applied sludge to the intermittent streams and hence
to the Columbia River. The topography of the sites is rela-
tively uniform, with a gradual 0.8 percent slope from north
to south. This slope is well within the limits of the 5 percent
established by DEQ for sludge disposal. To ensure that
large quantities are not washed into adjacent waterways,
it may be necessary to immediately plow the sludge into the
soil in the rainy season.
The U. S. Navy property and Sabre Farms have groundwater
resources greater than 6 feet below the surface. No ephemeral
or intermittent waterways flow through the areas. Southern
portions of the Sabre Farms property have slopes up to 20
percent. The steeper slopes may be unsuitable for surface
sludge application.
Drainage control and buffer zones between the waterways
and the lands where sludge is applied will aid in reducing
any flow of sludge into surface waters. These buffer zones
may be approximately 100 to 200 feet in width.
In all likelihood, the application of sludge will be
reduced during the wet season, particularly on agricultural
lands. Sludge barged to Boardman and not applied during
127
-------
the wet season will be stockpiled (if transported in a
sludge-cake form) at the disposal site or held in lagoon
storage (if transported as a liquid slurry) to be spread
at a later date. This practice would greatly reduce any
likelihood of sludge movement into waterways with surface
runoff.
Alternative C. Alternative C (drying by B.E.S.T. or the
Carver-Greenfield method and subsequent sale as a soil con-
ditioner/fertilizer) would probably not involve a significant
impact on either groundwater or surface water resources be-
cause its application would be diverse and in relatively
small amounts.
Alternative D. Alternative D (barge and truck transport
to the Willamette Valley) could involve the disposal of
liquid sludge on agricultural lands between the Cities of
saiem and Canby. Both surface and groundwater are plentiful
throughout the area. Major surface waters include the
Mollala River, Willamette River, Pudding River and Clackamas
River.
Groundwater resources occur at variable depths throughout
the North Willamette Valley. Table 1 shows the depths to
groundwater in the Jory and Bornstedt soil series.
Any sludge application in the Willamette Valley will
include a requirement for buffer strips between private
wells (200 feet), public water supply wells (500 feet), and
surface waters (100 feet for perennial water bodies, 25 feet
for dry, intermittent streams) (CRAG, Tech. Suppl. 8, 1977).
The use of adequate buffer zones should protect wells and
surface waters from contamination.
No-Action Alternative. The no-action alternative
(continuation of present means of sludge disposal) involves
the disposal of sludge by the two now-in-use methods:
1) spreading and plowing into sandy soils at the Rivergate
Industrial District, and 2) disposal in the Triangle Lake
sludge lagoons near Columbia Slough. Disposal in the St.
Johns Sanitary Landfill located at the end of North Swift
Boulevard would also be a possibility.
The Rivergate Industrial District is bordered by the
Columbia and"Willamette Rivers and is bisected by the
Columbia Slough. Bybee and Smith Lakes are located nearby.
Since 1976 the City has disposed of sludge at Rivergate.
The sludge is used as a soil binder to prevent wind erosion
of sandy soils. The Oregon Department of Environmental
Quality approved the Rivergate disposal site with the pro-
vision that the City install wells and monitor groundwater
128
-------
on a monthly schedule. Monitoring data collected during 1976
(see Table 2) indicate relatively low levels of all heavy
metals except zinc. The significance of the high zinc con-
centrations is subject to some debate regarding sampling
methods. If the values measured are fairly accurate, there
may be some concern about lateral movement of contaminated
water from the disposal sites to surface waters such as Smith
or Bybee Lake or the Columbia River. The LD^q for salmonids
exposed to zinc ranges from .09 to 1.1 mg/1 under laboratory
conditions (Chapman, 1973). The detection levels shown for
the other heavy metals (Table 2) appear inadequate for monitoring
purposes.
If the no-action alternative continues it is anticipated
that, depending on the rate of industrial development, 1,500
acres of land will be available for sludge disposal at the
Rivergate site. That acreage is adequate to meet City needs
until approximately 1983 (Nunamaker, pers. comm.).
Once the Rivergate area is no longer available as a
sludge disposal site it will be necessary for the City of
Portland to once again seek a place for sludge disposal.
The St. Johns landfill has an estimated remaining life of
approximately 2 years (full life, 1980). The impact on
groundwater of continuing to dispose of sludge at the landfill
is unreported. The site has been approved by DEQ and is periodically
monitored for compliance with DEQ regulations for solid waste
disposal.
Odor
Stabilized sludge in slurry or dried cake form will not
emit offensive odors so long as it is properly handled.
It does give off a slightly "earthy" smell which is considered
to be inoffensive.
Alternative A. The proposed sites for sludge application
in Morrow County are situated 3 to 8 miles from the City of
Boardman and 1/2 to 1 mile from Interstate 8ON. When sludge
is applied to the agricultural lands, odors should not be
noticeable beyond the immediate vicinity. Improperly digested
wastewater solids could create a significant odor problem,
particularly if sludge is applied with an aerosol gun because
malodorous sludge smells can be carried farther by the wind.
Surface spreading and mixing with soil by injection or tilling
would reduce the aerosols and volatilization.
Alternative C. The B.E.S.T. process is considered to be
a closed cycle and odors would be most associated with non-
condensibles being vented. The odors from the noncombustible
vent gases can be handled by gas scrubbers. The water
129
-------
extracting substance, triethylamine, has a strong odor but is
retained within the closed system. The application of air
cleansing techniques and proper operations would result in a
very minor odor problem at the Columbia Boulevard plant.
The conveyance of any odor to surrounding inhabited areas is
considered unlikely.
The Carver-Greenfield process is also considered to be
a closed cycle system. Some waste gases are generated from
combustion of fuel oil. Any odors from the process can be
removed by chemical or thermal treatment.
Alternative D. Disposal of sludge in the North Willamette
Valley will entail the disposal of liquid sludge on a large
number of relatively small private parcels. In all likeli-
hood, the sludge will be applied by surface spreading or
injection into the soil from tank-truck vehicles with over-
sized tires. Subsurface injection of sludge would greatly
reduce any potential odor problem. Surface spreading reduces
the surface area exposed to the atmosphere and the generation
of aerosols, and consequently the odor-producing potential
is far less than that produced by spraying.
The major odor impact occurs immediately after application
and may dissipate rapidly. Because of the relatively small
size of farms in the valley the potential for odor problems
is greater than in less densely inhabited areas.
No-Action Alternative. The continued disposal of sludge
at Rivergate and in the St. Johns landfill could create
localized odor problems. Application is now made using a
large spray device that tends to enhance the volatilization
of odors. Switching to another means of sludge spreading
(i.e., surface spreading or injection) could greatly reduce
the impact potential. At the present time, there are few
human inhabitants near the Rivergate disposal area; however,
with increased industrialization of the area conflicts could
arise.
Aesthetics
The aesthetics of sludge disposal are, in part, dependent
upon the locations of disposal areas and the methods of
application.
Alternative A. The remoteness of the Morrow County sludge
disposal area tends to reduce the problem of adverse aesthetic
impacts.
Alternative C. There are no significant adverse
aesthetic impacts associated with the B.E.S.T. or Carver-
Greenfield processes because the sludge is dry and of very
low odor content. The appearance of both B.E.S.T. and Carver-
Greenfield solids is similar to many soil conditioners.
130
-------
Alternative D. The application of sludge to agricultural
lands is similar to methods used in farming operations
involving heavy equipment. Such operations are familiar to
agriculturists and should not be displeasing; however,
aesthetic considerations are greatly dependent upon the
attitude of the viewer. Buffer zones between sensitive
receptors (i.e., residences, businesses and public roads)
and lands where sludge is applied would reduce any possible
aesthetic impacts.
No-Action Alternative. Due to the relatively limited
human activity in the Rivergate area, the impact on aesthetics
resulting from sludge disposal is judged to be minor.
Aesthetic concerns could increase with development of the
area.
Heavy Metals
Sludge from the Columbia Boulevard treatment plant con-
tained the levels of heavy metals given in Table 24. These
metals originate in industrial and domestic wastes, pavement
runoff, and from groundwater infiltration into the sewer system.
The major industrial contribution of heavy metals comes from
18 electroplaters, 3 galvanizers, and 6 battery manufacturers.
These sources account for approximately 28 percent of the
chromium, 11 percent of the nickel, 49 percent of the copper,
and 29 percent of the lead in the City's sludge. The percentage
of zinc and cadmium from these sources has not been determined.
Periodic monitoring of industrial sources has indicated
a daily sludge discharge of 6 pounds of chromium, 5 pounds
of cadmium, 4 2 pounds of copper, 18 pounds of nickel, and
26 pounds of zinc, (Edmonds, pers. comm.).
The EPA and Oregon Department of Environmental Quality
have established guidelines and regulations regarding accept-
able levels of heavy metals.
EPA has recommended that sewage sludge be analyzed "to
determine nutrient values, heavy metals, and other constituents
which may be economically recycled or cause environmental
damage ...". "When sludges are to be applied to land, for
beneficial purposes, appropriate nondomestic users of municipal
wastewater treatment works should be required to pretreat
their wastewaters to minimize the presence of potentially
harmful heavy metals and other sludge contaminants from
industrial sources" (42 CFR No. 211).
The DEQ proposed regulations and guidelines (OAR, Chapter 340,
Division 4, Subdivision 2) indicate that "Prior to application
on a beneficial use site, sludge should be tested for the
following parameters: Pb++, Cu++, Zn++, CR++, Ni++, total
131
-------
Table 24
HEAVY METAL CHARACTERISTICS OF SLUDGE
FROM COLUMBIA BOULEVARD PLANT1
Constitutent
Wet Basis
mg/12
Dry Basis
% ppm
Cadmium
Chromium
Copper
Nickel
Lead
Zinc
2.03
12.2
53.8
5.5
60.5
116
.0040 40
.0269 269
.1149 1,149
.0108 108
.1322 1,322
.2408 2,408
1 Averages of samples taken January-December 1977.
Total solids average 4.75 percent.
2 Milligrams per liter.
3 Parts per million.
-------
nitrogen, phosphorous, pH and total solids." DEQ has also
designated allowable cumulative values for metals in soils
(see Table 25). These values are the same as those estab-
lished by EPA and the FDA. In order to determine the allowable
values, "a representative sample of each major soil type in
the region should be analyzed to determine the cation
exchange capacity, conductivity, background pH and heavy
metals concentrations."
Less stringent requirements regarding heavy metals
loading exist where sludge will not be beneficially used
(i.e., an area designated solely as a sludge disposal area
and not for growing crops).
The heavy metal of greatest concern is cadmium. The EPA
and DEQ have established that the cadmium content of sludge
ideally should not exceed 0.5 percent of the zinc concentra-
tion and the total cadmium application per year should not
exceed 2 kg/ha (1.8 lb./acre). It has been found that cadmium
and zinc may be toxic to plants if present in an available
form at sufficiently higher levels. Cadmium may also be
accumulated by some plants and enter the human food chain
(Jackson, et al., 1976). For this reason, the DEQ has
proposed a regulation that no leafy vegetables should be
grown on land where sludge has been applied.
According to the EPA (1976), cadmium is considered a
nonessential element that can be managed so that it does not
pose a hazard to plants, animals or humans. Suggestions
for management include: "(1) maintain soil pH at or above
6.5; (2) grow crops which tend to exclude cadmium from the
whole plant or from reproductive tissues; (3) apply low
annual rates of cadmium, and use sludges which have a low
cadmium concentration; and (4) grow nonedible crops" (EPA, 1976).
Heavy metals such as iron, manganese, aluminum, chromium,
arsenic, selenium, antimony, lead and mercury are considered
to pose relatively little hazard to crop production and plant
accumulation when sludge is applied to soil because all have
low solubility in slightly acid or neutral soil.
The remaining heavy metals — copper, molybdenum, nickel
and zinc — can accumulate in plants and may pose a hazard
under certain circumstances. Two of these metals — copper
and zinc — are generally deficient in the environment and
under good management practices will seldom be toxic to
plants and animals. Zinc is found in Portland sludge in
relatively high concentrations. These concentrations are high
enough to limit the number of years sludge could be applied
to an area before allowable concentrations are reached.
133
-------
Table 25
MAXIMUM METAL ADDITION (POUNDS PER ACRE AND Kg/Ha)
WITH A SOIL CATION EXCHANGE CAPACITY (CEC)(meq/lOOg)1
CEC CEC CEC
Metal
less
than 5
5 -
15
greater
than 15
Kg/Ha
lbs/Acre
Kg/Ha
lbs/Acre
Kg/Ha
lbs/Acre
Pb
500
446
1,000
892
2,000
1,784
Zn
250
223
500
446
1,000
892
Cu
125
111.5
250
223
500
446
Ni
50
44.5
100
89
200
178
Cd
5
4.5
10
00
•
V£>
20
H
•
00
Annual cadmium application rate shall not exceed two (2) kg per hectare (1.8 pounds per acre)
1 CEC: Cation Exchange Capacity is defined as the extent of the ability of soil to hold
positively charged cations. The CEC is expressed in milliequivalents per 100
grams of soil (meq/lOOg).
SOURCE: Dowdy et al., Land Application of Waste Materials, Soil Conservation Society,
1976 In: OAR Chapter 340, Division 4, Subdivision 2.
-------
In October 1977, the EPA published a document, Municipal
Sludge Management: Environmental Factors, which outlines the
factors important to any land application program. Projections
of allowable loading of sludge per acre (based on crop nitrogen
requirements and heavy metal content of the sludge) and the
life of the application areas were made based on procedures
set forth in Appendix VIII of that document.
The annual allowable rate of sludge application per acre
(dry tons of sludge/acre) is dictated by either the nitrogen
requirement of the crop grown or the amount of cadmium in the
sludge. Calculations for sludge loading for Morrow County
(Alternative A) and north Willamette Valley (Alternative D)
were based on nitrogen requirements for growing wheat (150
pounds per acre) and corn (120 pounds per acre), respectively.
Because the levels of cadmium in Portland sludge are relatively
low, it was determined that nitrogen requirements of the crops
would be the factor determining the allowable annual quantity
of sludge per acre.
The impact of heavy metals resulting from Portland sludge
will depend upon the following factors: (1) the characteristics
of the sludge, (2) properties of the soils at the alternative
sites (i.e., pH, texture of soil, cation-exchange capacity,
organic matter and profile characteristics), (3) groundwater
and surface water locations, (4) methods and rates of applica-
tion of sludge, (5) selection of crops, and (6) monitoring.
The following discussion of each project alternative will
relate to these factors.
Alternative A. Site-specific information for the Morrow
County sludge disposal/reuse areas is presented in Table 26.
Given this information, if 9.8 dry tons of sludge per acre per
year were applied on the Morrow County site the projected
availability of the land for this use would be approximately
10 years. An application rate of 4.6 dry tons per acre per year
would extend the project use time to 20 years (Figure 18).
Maximum allowable loading to stay within the total
allowable loading for zinc for a 20-year project (application
site life) would be 4.6 dry tons of sludge per acre per year.
Approximately 4,600 acres would be necessary. If sludge is
loaded at greater than 4.6 tons per acre per year, the life
of the site will be shortened even though less acreage would
be necessary initially. The total acreage ultimately required
would remain the same - 4,600 acres (Figure 18). This acreage
requirement is an estimate based on allowable loading of
heavy metals and on estimated future sludge production.
The actual 20-year acreage requirement will be influenced by
the actual rather than the estimated sludge quantity and
character, the amount of sludge used off-site, future use and
any change in regulatory requirements.
135
-------
Table 26
PROJECTED LIFE, SLUDGE LOADING/ACRE
AND ACREAGE REQUIREMENTS FOR SLUDGE APPLICATION
IN MORROW COUNTY1
Crops to be grown; wheat
Annual nitrogen requirement for wheat: 150 lbs/acre1
Quantity of sludge needed to achieve nitrogen requirement:
4.6 tons/acre (equilibrium rate)
Cation exchange capacity: 5 to 15 meq/100 g
Allowable loading - dry tons of sludge/acre (life of project):
Most limiting heavy metal: zinc
Total amount of zinc allowed/acre: EPA and DEQ guidelines,
446 lbs/acre
Projected life of application area:
@ application rate of 2 tons/acre/year - 47 years
@ application rate of 4.6 tons/acre/year - 20 years
@ application rate of >4.6 tons/acre/year - <20 years
Acreage requirements for year 2000:
@ application rate of 2 tons/acre/year - 10,585 acres
@ application rate of 4.6 tons/acre/year - 4,602 acres
1 Based on EPA, 1977 Appendix VIII; O.S.U., 1972, Disposal of
Municipal Wastes on Sandy Soils
Copper
Nickel
Cadmium
Lead
Zinc
337 tons/acre
93 tons/aere
97 tons/acre
412 tons/acre
112 tons/acre
136
-------
-------
If loaded at less than 4.6 tons per acre, more acreage
will be needed but the number of years sludge can be safely
applied to each acre (before reaching the 93 tons per acre
cumulative loading based on zinc limitation) would be increased
(Figure 19) .
Soil pH is considered to be one of the more important
factors in established sludge application feasibility because
heavy metals are typically more soluble under acid conditions
(<6.5 pH) than under neutral (7.0 pH) or alkaline (>7.0 pH)
conditions. In alkaline soils, heavy metals tend to be bound
more tightly by the soil. The pH of Morrow County site soils
ranged from 6.6 to 9.0 depending upon the location.
The acceptable number of tons of sludge per acre can be
established by two methods: (1) nitrogen and (2) heavy metal
application rates. If a site is to be used only for disposal
and not for agricultural use of sludge, the nitrogen or
heavy metal application rates would be important only in terms
of the potential for pollution of groundwater or surface water
supplies or its effect on future uses of the land.
Due to the relatively low level occurrence of cadmium in
Portland sludge (3 9 mg/kg), an annual application of approxi-
mately 23 dry tons per acre would be required to reach the
limit of about 1.8 pounds of cadmium per acre per year for
agricultural use. Such a quantity would add nitrogen far in
excess of the needs of crops.
In order to ensure that heavy metal concentrations do
not exceed background or established limits in groundwater,
the Oregon DEQ will require test wells on sludge disposal
sites to monitor Zn++, Pb++, Ni++, Cd++ and Cu++. "Sludge
may be applied to disposal sites in limited amounts so long
as a quarterly monitoring of the test well(s) shows no
increase over background concentration of heavy-metal ions
in groundwater" (DEQ, 1977).
"Test wells may be required on a beneficial use site
(agricultural lands) on a case-by-case basis at the discre-
tion of the DEQ field representative" (DEQ, 1977).
Alternative C. In Alternative C (local reuse of dry
sludge), sludge would be converted to a marketable product
than can be used for household or commercial purposes.
Sludge processing does not remove heavy metals because of
the insolubility of such metals at the high processing pH
(11.5). Heavy metals are transferred to the environment
in the end product.
138
-------
-------
Because of the relatively small quantities of dried
sludge used for household or commercial purposes (i.e.,
50- or 100-pound bags) on any one parcel of land, heavy
metal buildup in receiving soils will be low.
Alternative D. Site-specific information for the
Clackamas/Marion County sludge disposal/agricultural reuse
area is presented in Table 27. Given this information/ if
4.6 dry tons of sludge per acre per year were applied/ the
projected life of the land used would be approximately 40
years. Twenty-three hundred acres would be required for a
20-year project.
Maximum loading to stay within the total allowable loading
for zinc for a 20-year project (application site life) would
be 9.2 tons per acre per year, which is far above the nitrogen
requirements for corn or wheat, but is the approximate require-
ment for pasture grass (O.S.U., 1972) (see Figure 18). If sludge
were applied at the level needed to meet nitrogen require-
ments for wheat (moderate) or corn (high), approximately 4.6
tons per acre per year could be applied. At such a rate,
4,602 acres would be necessary. If loaded at less than 4.6
tons per acre, more land would be required.
No-Action Alternative. The no-action alternative would
result in the continuation of the present method of disposal
at the Rivergate area, the St. Johns landfill and in the
sludge-holding lagoons (Triangle Lake). The sludge accumulated
in Triangle Lake would be removed and disposed of by spreading
at the Rivergate area. This would amount to the addition of
200,000 cubic yards of waste-activated sludge on the Rivergate
area.
Under the existing situation, approximately 65 percent
(28 tons) of the annual sludge production is disposed of at
Rivergate. The remaining sludge (14 tons) is stored in the
Triangle Lake. None is presently disposed of at St. Johns
landfill.
The DEQ has required the City of Portland to monitor
sludge disposal at Rivergate by using monitoring wells to
determine levels of heavy metals in groundwater. Such
monitoring is likely to continue.
If it were assumed that 1,500 acres of land were avail-
able for sludge disposal at Rivergate until 1983 (the pro-
jected final year of use of the Rivergate area under optimum
conditions) and that all sludge would ultimately go to the
Rivergate area, there would be a need to dispose of 102,900
tons (6 years of production) or approximately 69 tons per
acre over the life of the Rivergate disposal area).
140
-------
Table 27
PROJECTED LIFE, SLUDGE LOADING/ACRE
AND ACREAGE REQUIREMENTS FOR SLUDGE APPLICATION
IN THE NORTH WILLAMETTE VALLEY
(Clackamas/Marion Counties)
Crops to be grown: corn
Annual nitrogen requirement for corn: 120 lbs/acre
Quantity of sludge needed to achieve nitrogen requirement:
4.6 tons/acre
Cation exchange capacity: >15 meq/100 g
Allowable loading of dry tons of sludge/acre (life of project):
Most limiting heavy metal: zinc
Total amount of zinc allowed per acre: EPA and DEQ guidelines,
892 lbs/acre
Projected life of application area;
@ application rate of 2 tons/acre/year - 93 years
@ application rate of 4.6 tons/acre/year - 40 years
@ application rate of 9.2 tons/acre/year - 20 years
Acreage requirements for year 2000:
@ application rate of 2 tons/acre/year - 10,585 acres
@ application rate of 4.6 tons/acre/year - 4,602 acres
@ application rate of 9.2 tons/acre/year - 2,300 acres
Copper
Nickel
Cadmium
Lead
Zino
675 tons/acre
185 tons/acre
194 tons/acre
824 tons/acre
223 tons/acre
141
-------
Sludge Storage Lagoons
Storage lagoons will be necessary for Alternatives A
and D. Wet or freezing weather conditions will make it nec-
essary to store liquid sludge in holding ponds until it can
be spread on the application areas.
Two-month storage requirements (14.1 million gallons)
will probably be satisfactory at the Morrow County site.
Acreage requirements for the lagoons as well as buffer and
support areas will be approximately 4.5 acres. These
storage ponds will be impermeable to prevent subsurface
movement of liquid. The high evaporation rates in the Morrow
County area will reduce the liquid in the storage lagoons
considerably during the detention time.
For Alternative D, a 4-month storage facility will be
necessary due to the longer period of wet weather. Acreage
requirements for the lagoons and support facilities will be
approximately 9 acres. This will represent a permanent loss
of either agricultural land or native wildlife habitat.
Pathogens
During the normal process of stabilizing sewage sludge
through aerobic and anaerobic digestion, a substantial number
of pathogenic bacteria may be killed. The survival of such
organisms is related to the type of process, the temperature
during sludge digestion, and the retention time (Moore, et al.,
1976).
Of particular importance is the survival of virus and
coliforms in soil. Emonds (1976) found that the fecal coliform
bacterial counts in sludge applied on forest land in Washington
fell from 1.08xl05 to 358/g during a 204-day period and then
fell to 0/g at day 267. He determined that coliform die-off
was most rapid in winter (1.2xl05 to 20/g in a 162-day period).
Results showed that fecal coliforms do not penetrate beyond
the first 5 CM of soil and that groundwater contamination
from vertical movement is unlikely.
Moore, et al. (197 6) determined that soil temperature
and moisture content have a significant effect on polio virus
survival. Virus survival is greater when temperatures remain
low (i.e., at 10 days 68 percent virus survived at 4°C [39°P])
but at warmer temperatures (30°C [86°P]) virus survival is
reduced significantly (at 10 days 0.5 percent virus survival).
Ideal soil moisture (i.e., 15 percent moisture content
may prolong virus survival while drying 5-6 percent moisture
content) significantly reduces survival.
142
-------
Alternative A. Prior to land application in Morrow County,
the stabilization processes will greatly reduce the number
of pathogens in the sludge. The combination of digestion,
stabilization and storage in the sludge lagoons will cause
die-off of most pathogenic organisms. Once the stabilized
sludge is applied, the soil will act as an effective removal
mechanism through filtration, sorption-inactivation, and
subsequent die-off. Movement of the pathogens will be restricted
to the first few feet of soil.
Studies conducted in Solano County, California, indicate
that pathogenic organisms in digested sludge may survive for
long periods after application (over 7 months) and that the
risk of infection would be greatest for farm labor personnel,
but no greater than the risk to sewage treatment plant personnel
(Baier, 1977).
"An evaluation of existing agricultural programs utilizing
sludge reveals that no known disease outbreaks or epidemics
can be traced to land that has been irrigated with stabilized
sewage sludge in conjunction with a program of properly managed
application procedures to prevent water contamination or
direct contact with food crops normally consumed without
cooking" (San Francisco Bay Region Wastewater Solids Study,
1977).
Several factors will reduce the likelihood of pathogen
problems at the Morrow County site: (1) stabilized sludge
will be stored for indeterminate periods at the Portland sewage
plant and at the Boardman site prior to land application,
and (2) sludge will be applied many months prior to the harvest
of any agricultural crop upon which it will have been applied.
Alternative C. The B.E.S.T. and Carver-Greenfield pro-
cess ei~pro3uci—95~percent dry, pathogen-free solids suitable
for land application for agricultural, ornamental (parks,
highway landscaping, etc.) or disposal uses. The combination
of solvent processing, cooling and heating satisfactorily
kills the pathogens.
Alternative D. The impacts associated with agricultural
use of sludge in the Willamette Valley will be the same as
those discussed under Alternative A of this section.
No-Action Alternative. Perhaps the greatest health
risk associated with the no-action alternative is to sewage
treatment plant workers in transporting and applying the sludge.
Direct contact of workers with sludge is the most likely
transmission route for disease-causing organisms, while trans-
mission through spray aerosols (from application) appears less
likely (CRAG, 1977). With proper treatment and care in
application of sludge, the risks are greatly reduced.
143
-------
Nitrates
Nitrates are considered to be harmful pollutants in
water supplies under certain conditions. The EPA has
established an upper limit of 10 mg/1 nitrate/nitrogen con-
centration in public water supply sources (EPA, 1972). High
nitrate concentrations are frequently found in shallow wells on
farms and in rural communities, most often from barnyard
drainage, septic tank leachates or intense crop fertilization.
Stabilized sludge contains varying amounts of nitrogen
(the percentage of nitrogen in sludge is, in part, dependent
upon the source of sewage and the sludge stabilization processes).
Application of sludge to agricultural land can be regulated
to reduce nitrogen leaching and contamination of groundwater.
The rates are established on the basis of: (l) estimated
available-nitrogen content of the sludge, (2) estimated
nitrogen requirements of the crops, and (3) soil testing
for available nitrogen, phosphorous and potassium. More
flexibility in application rates is possible where ground-
water supplies are far below the surface or are not used
for domestic purposes.
Alternative A. The depth to groundwater on the Morrow
County sites is greater than 6 feet. No wells in the area
are used for domestic drinking purposes.
Considering the great depth to groundwater and the low
rainfall of the region, adverse impacts from nitrate con-
tamination are not likely to occur.
At Site B, basaltic bedrock occurs approximately 3 feet
below the surface. Continued sludge application and irriga-
tion could lead to lateral downslope movement of water with
potential outcropping along Sixmile Canyon or Threemile Canyon.
More specific geologic and soils studies will be necessary
to determine the acceptability of that site for sludge
application.
Based on preliminary information on Sites A and C,
there should be no nitrate intrusion problems.
No site-specific information has been compiled for the
U. S. Navy property or Sabre Farms.
Alternative C. Since large-scale disposal of sludge on
concentrated land areas is not anticipated with this alternative,
nitrate contamination will not be considered a problem.
Home or commercial use of the Carver-Greenfield or B.E.S.T.
products is not likely to cause excessive nitrate concentrations
outside the immediate site of use.
144
-------
Alternative D. Within the Alternative D study area,
many parcels of land have high groundwater levels, thereby
making the parcels unacceptable for sludge application.
These areas were broadly defined in the CRAG Technical
Supplement 8 - Sludge Management Study (Soil Suitability,
Figure 4, page 30).
In the event this area is chosen for sludge application,
more specific site studies will be required to establish
the risk of groundwater contamination.
No-Action Alternative, Sludge has been applied on the
Rivergate area since early 1976. Groundwater monitoring wells
are established and periodically checked. No nitrate contamina-
tion has been recorded even though the groundwater is seasonally
close to the surface and the soil type is sandy and porous.
No groundwater contamination problems have been found
at the Triangle Lake sludge lagoons or at the St. Johns land-
fill site (Lynd, pers. comm.).
Continued heavy application of sludge at Rivergate
increases the potential for groundwater contamination,
contamination of nearby Bybee and Smith Lakes and the Columbia
or Willamette Rivers. Nitrate contamination of surface
waters typically results in greater algal blooms, dissolved
oxygen fluctuations, and possible adverse affects on fish
life. Aesthetic benefits typically decrease in relation to
the intensity of eutrophication.
Noise
Alternative A. Noise generated from sludge disposal
activities will be intermittent and of minor impact. While
off-loading activities at the dock site on the Columbia River
will generate local noise, the docking site will be sufficiently
distant from receptors to minimize off-site noise impacts.
At the disposal site the amount of noise generated will
be dependent upon the application methods employed. Spray
spreading via large-nozzle sprinklers will create very low
localized noise levels. Truck-spreading will be noisier
but intermittent and probably limited to 7 months of the
year. These activities should be no noisier than typical
farming activities of the region.
Alternative C. Disposal of the B.E.S.T. or Carver-
Greenfield product is likely to be by truck. If a local
market is generated for the product, distribution from the
Columbia Boulevard plant site to consumers will probably be
made by diesel truck. Large diesel-powered trucks typically
emit noise ranging from 75 to 100 dBA. Most trucking probably
will be done through existing industrial or commercial areas
and along major thoroughfares.
145
-------
Alternative D. Noise generated by disposal of sludge in
the north Willamette Valley will be of greater volume than at
the Morrow County site. The small parcels of land in the
north Willamette Valley will require that trucks be used for
spreading. Such spreading will be confined primarily to the
svimmer and fall months due to rainy weather and soft soil
conditions during the winter and spring.
Since parcels of land are smaller in the Willamette
Valley, there will be more sensitive noise receptors (i.e.,
residential areas) near the sludge spreading operations.
Operations will be confined to daylight hours and will be of
an intermittent nature. Noise levels are expected to be
similar to those generated by farm equipment.
No-Action Alternative. The present areas of disposal
(Rivergate, St. Johns landfill, and Triangle Lake) are within
an industrial zone. Noise generated by the present method
of disposal (truck mounted with a "Big Gun" sprinkler and
trucking to the St. Johns landfill) is expected to be due
to the absence of sensitive receptors and compatible uses in
the immediate area.
Land Use and Land Planning
With any project it is important to establish its impact
on existing and proposed land uses and planning. Land use
planning typically involves a number of jurisdictions and may
include a city (if the project is within an incorporated area);
county; region (i.e., Columbia Region Association of
Governments); state (Land Conservation and Development
Commission), and federal (if any federal lands are involved).
Alternative A. According to the Morrow County General
Plan, the three proposed sites on land leased by the Boeing
Agri-Industrial Company from the State of Oregon, are designated
for existing or future agricultural uses. Site A is subleased
from Boeing by an agricultural group called SIMTAG. All of
the 1,8 09 acres of Site A is in agricultural production* Crops
typically rotated are wheat, alfalfa and some grass (Martin,
pers. comm.). This site is projected to continue in agri-
cultural uses.
In view of existing guidelines regarding use of sludge
on cropland, the use of Site A for sludge application appears
to be feasible. Alfalfa, wheat and grass all represent crops
acceptable for sludge application.
Approximately 4 0 acres of disposal Site B is in crop
production and is identified as having a future use for
agriculture, either for grazing or crop production. Use of
sewage sludge on this site would be compatible with that
projected land use? however, physical factors peculiar to
the site may limit the use of sludge (see PRESENT ENVIRONMENT
section on Suitability of Land for Sludge Disposal).
-------
Disposal Site C is presently in sagebrush and is also
projected for agricultural uses.
The U. S. Navy Bombing Range is now used by Navy air-
craft for practice in approach and deployment of simulated
weapons. The future use of the area is uncertain.
Of the 16,000 acres on Sabre Farms property, approximately
8,900 acres are used for a wheat/potato crop rotation. Since
sludge cannot be applied to land growing potatoes or other
root crops, the 8,900 acres would not be available for sludge
application. Crops grown on the remaining 7,100 acres would
likely be suitable for sludge use.
Alternative C. The ultimate disposal method for the
B.E.S.T. product is undetermined at this time. In the event
that the product can be marketed locally, the sludge would
be routinely applied on home gardens, for commercial agri-
cultural use or public landscaping. Otherwise, the sludge
could be stockpiled and barged to Morrow County for disposal.
The land use implications of such an alternative would be
the same as defined under Alternative A.
Alternative D. The land designated as a possible sludge
application area in the north Willamette Valley covers nearly 400
square miles and has a variety of zoning designations (see
Figure 6).
According to the CRAG Sludge Management Study (1977) ,
Clackamas County contains 108,000 acres of cropland, with at
least 80,000 acres planted in crops considered suitable for
sludge application (grain, fodder, orchards). However, not all
this acreage necessarily has soil suitable for sludge application.
Preliminary analysis of the Marion County portion of
the Alternative D sludge application area indicates that the
average farm size is 118 acres and that much of the land is
zoned for exclusive farm use.
The projected future use of those areas zoned agriculture
is in 20-acre parcels. Use of sludge on those lands where
the aforementioned crops are grown would be in keeping with
the agricultural use of the land.
Perhaps the most significant consideration regarding a
sludge application program in Clackamas/Marion Counties is
the relatively small size of farms. Average farm size in
Clackamas County is 72 acres and is 118 acres in Marion
County. If it is assumed that the average size of all farms
in the application area is 95 acres, and that by the year 2000
the City of Portland will need 10,585 acres of land (if sludge
is applied at a rate of 2 tons per acre per year), it will be
necessary for the city to have agreements with over 112 separate
farms. If sludge is to be applied at the rate of 4.6 tons
per acre per year, (4,600-acre requirement), approximately 48
farm agreements would be needed.
147
-------
No-Action Alternative. The entire Rivergate area (except
for parkland at the confluence of the Columbia and Willamette
Rivers and Smith and Bybee Lakes) is zoned for industrial
use. The present program for sludge disposal in that area
is not in conflict with the present use; however, continued
industrialization of the area will reduce the amount of land
available for sludge disposal. Ultimately the entire area will
be industrialized and sludge disposal will cease.
From the standpoint of future land use of Rivergate,
sludge disposal there is at best a temporary measure.
Soils
"Once sewage sludge is applied to the land, changes in the
physical structure of the soil take place, the most obvious
of which is the formation of a crust of sludge on top of the
soil. The crust develops because liquid sludge infiltrates
the soils slowly due to the solids content and possibly
the cation content. The rate of infiltration of sludge liquid
will depend on the initial soil moisture content and the
solids content of the sludge. The higher the soil moisture
and sludge solids content, the lower is the rate of infiltration.
Initially, after a sludge application, the hydraulic conductivity
of sand (or infiltration rate of sludge into sand) is greater
than that of silt loam soils. After a few days of successive
applications of sludge, the infiltration rate is about the
same regardless of soil type" (Kirkham, 1974) . If the sludge
is allowed to dry and is plowed in, infiltration capacity is
usually maintained.
Liquid sludge has been viewed as a beneficial soil con-
ditioner. Sludge application increases soil aggregation,
changes pore spacing in clay soils, and acts as a binder to
sandy soils. Additionally, anaerobically-digested sludge is
known to dramatically increase the humus content of soils.
Hinesly (In: Kirkham, 1974) reported that the organic carbon
content oT~land treated with 13 6 dry tons per acre over a
4-year period increased from 1.2 to 2.4 percent in the surface
6 inches.
Alternative A. The soil series encompassing the
proposed sludge application sites in Morrow County have
predominantly sandy texture and very low organic content
(<0.5 to 1.0 percent) (see Table 1). Depending on location,
these soils are considered suitable for the production of
wheat, grass and alfalfa.
The application of sludge on these soils will improve
the physical characteristics (aggregation, water retention
capacity, nutrient content, and percentage of organic matter)
of the soil on which it is applied. Furthermore, it is expected
that the continual application of sludge will reduce the
wind erosion hazard of all soils on which it is applied.
148
-------
The application of 92.6 tons of sludge per acre (the
allowable loading per acre based on zinc as the most limiting
metal) will constitute approximately 3 percent volume of the
top 1-foot of soil. The continued addition of organic material
will reduce the amount of soil now lost by wind erosion and
will help to replace that which is continually lost annually.
Alternative C. The use of the Carver-Greenfield or
B.E.S.T. product on agricultural lands, home gardens, land-
scaping, etc., will enhance the quality of the soil. The
beneficial effects will be similar to those discussed in the
introduction to this soils impact section.
Alternative D. Soils in the north Willamette Valley
sludge application area are predominantly silty clay loam
and silt loam. The organic matter content varies from 3 to
8 percent and pH from 4.5 to 6.0 (see Table 1). Sludge
application will improve both aggregation and soil porosity
of the clay soils (Kirkham, 1974).
The application of 185 tons per acre of sludge over the
life of the application area will add approximately 292 cubic
yards of material per acre, or approximately 6 percent
volume of the first foot of soil.
No-Action Alternative. The continued application of
sludge at Rivergate will further improve soil organic content
(humus), nutrient content and act as a soil binding mechanism.
The addition of the sludge will result in a more substantial
vegetative cover.
Property Values
The addition of sludge to agricultural lands can be
expected to increase the nutrient value, organic content
and overall value of the property for agricultural uses.
The use of sludge may markedly reduce the amount of commercial
fertilizer necessary, and in some cases totally eliminate
the need for commercial supplements.
Alternative A. Land in the vicinity of the proposed
sludge application sites is valued at $400 to $1,000 per acre
unimproved. Improved land (water, power and access available)
is worth substantially more ($1,500 per acre). Wheat, alfalfa
and grass crops now grown on or near the sites are considered
to be "marginally profitable" (Martin, pers. comm.).
It is anticipated that increased crop yields resulting
from sludge application will increase the yield and therefore
the profitability of the crops (discounting the vagaries of
crop market value and demand).
149
-------
Alternative C. Any agricultural land on which the Carver-
Greenfield or B.E.S.T. product is applied is expected to have
increased crop yields. This increased productivity could lead
to some escalation in the value of land for certain agricultural
crops (those to which sludge application is acceptable).
Alternative D. Impacts comparable to those defined for
Alternatives A and C will occur under this alternative.
Accidents or Failures
The storage and disposal of liquid sewage sludge will not
constitute a significant risk of accidents or of mechanical
failures. Storage facilities will consist of holding lagoons
to which sludge is pumped from the off-loading docks. Applica-
tion equipment will either be stationary, employ large-orifice
sprinklers or will consist of diesel trucks with tanks and spreaders.
The major threat associated with liquid sludge handling
is that of a large spill, either because of storage lagoon
failure or rupturing of an application truck-tank. In either
case, the impact would be localized unless a transport
mechanism such as water were present. While it is unlikely,
if the sludge entered a water body from the storage or disposal
area, oxygen depletion could occur in the water and thus
jeopardize aquatic species.
Dry sludge such as that produced by the Carver-Greenfield
or B.E.S.T. system would not represent a significant environ-
mental hazard in case of accidental spillage.
Conversion or Loss of Wildlife Habitat
Alternative A. Much of Site A in Morrow County (Figure 5)
is in irrigated agriculture. The circular irrigated areas
typically encompass 100 to 13 0 acres and support crops of
grains and alfalfa. Areas between the irrigated circle
patterns often support remnant natural vegetation such as
big sagebrush, low sagebrush, shadscale, bitterbrush and
grasses such as bluebunch, wheatgrass, Idaho fescue and
cheatgrass brome (Franklin, J. F. & E. T. Dryness, 1969).
A majority of Site B is in sagebrush although a small
portion along the southern boundary is in agricultural use.
Site C is entirely covered with natural vegetation - sage-
brush, bluebunch, wheatgrass, cheatgrass brome and medusa-
head wildrye.
150
-------
Application of sludge would necessitate the removal of
natural vegetation, probably in a way that would conform
to the pattern of irrigation. The major impact on wild
plants and animals will be in those areas that do not now have
agricultural operations (most of Site B and all of Site C).
The following acreages of sagebrush habitat are projected
for conversion: Site A - 34 0 acres; Site B - 1,880 acres; and
Site C - 3,210 acres.
Attendant wildlife species, including subsurface-dwelling
and sedentary mammals and reptiles, will be lost.
The U. S. Navy property is dominated by native shrub-
steppe vegetation and broad areas of barren ground (shifting
sands), particularly along the northern and southeastern
boundaries. In the event sludge is applied on this property
it will probably be to stabilize the now barren soils.
The subsequent growth of vegetation will represent an improve-
ment of wildlife habitat.
Land on the Sabre Farms is almost exclusively agricultural,
Conversion of native vegetation has already occurred.
No federal or state rare, endangered or threatened
vertebrate or plant species will be impacted by the project.
Alternative C. No natural resources will be adversely
affected by the Carver-Greenfield or B.E.S.T. process if
sludge disposal is accomplished through local marketing. If
large-scale disposal in eastern Oregon or the Willamette
Valley is necessary, the land conversion impacts would be
similar to those identified in Alternative A.
Alternative D. Existing lands in the north Willamette
Valley where sludge would be applied are now either in cropland
or pasture. Small changes in the types and amounts of natural
vegetation are anticipated. Sludge can be satisfactorily
spread on most of the existing cropland or pasture without
conversion of land use.
No-Action Alternative. Little native vegetation is
present in the Rivergate area. Most of the 1,500 acres is
comprised of unstabilized sandy soil. Application of sludge
should improve the soil quality to the extent that grasses
and other types of vegetation can exist.
Vectors, Pests and Nuisances
Vector problems associated with sludge disposal would
probably vary among the alternatives. Studies conducted in
Solano County, California (San Francisco Bay Region Waste-
water Solids Study, 1977), indicated that when freshly
digested sludge is surface-applied to land, flies and other
insects are attracted, but in small numbers when compared
to undigested organic wastes.
-------
Sludge applied in a dried form is not as attractive to
insect pests. Additionally, liquid sludge that has dried on
the surface does not attract insects as much as does liquid
sludge.
Sludge applied too thickly on the land poses the greatest
potential for vector problems. Under proper moisture conditions
house flies may lay eggs in the undried sludge.
The method used for sludge application and the location
chosen will influence the extent of pest or vector problems.
Sludge applied in a dry form or injected below the surface
will be less of an attractant to vectors than will liquid
sludge applied on the surface. Likewise, sludge plowed or
tilled into the soil soon after application reduces the likeli-
hood of vector problems.
Alternative A. Under proper operating conditions, vector
problems at the Morrow County site are expected to be minor.
During recent years some mosquito infestation problems have
occurred on irrigated areas in the Boardman area. Areas of
standing water have developed from excessive irrigation and/
or sealing of the upper soil layer (Runyan, pers. comm.).
Although the Boardman area has high annual evaporation,
constant winds and relatively sandy soils, some areas of
standing water may occur on sludge application sites. Proper
maintenance of the soil (i.e., tilling shortly after sludge
application) should prevent any serious vector problems.
Alternative C. The end product of the B.E.S.T. or
Carver-Greenfield process becomes dry and sterilized and will
not support a vector problem.
Alternative D. No vector problems are foreseen with
sludge applications in the northern Willamette Valley, except
when sludge is applied so heavily that it does not dry completely
in 4 days or less. The exact drying time to prevent fly
breeding will vary with the weather conditions and the soil
type. Vector problems are not associated with other sludge
disposal projects in the Willamette Valley.
Crop Type and Crop Production
The U. S. EPA and Oregon DEQ have broadly defined the
types of crops for which the application of sludge is
acceptable or unacceptable. The acceptability of using
sludge on crops is, in part, dependent upon the ultimate
use of that crop (i.e., whether consumed by humans directly
or used indirectly) and the susceptibility of crops to the
presence of heavy metals, pathogens and parasites. In its
Sludge Management Study CRAG (1977) classified crops as to
suitability for sludge application. Table 28 depicts that
classification.
-------
Table 28
CROP SUITABILITY FOR SLUDGE APPLICATION
Crop Type
Vegetables
Fresh produce
Suitability
Generally unsuitable because of
the danger of transmitting pathogens
to humans.
Processed vegetables
Grain
Generally suitable because pathogens
would be destroyed during processing,
Suitable because heavy metals
do not accumulate in the seed.
Fodder
Small fruit
Generally suitable for cattle if
fodder is not harvested for 2 weeks
after sludge application because
pathogens would be destroyed during
that period; a 2-month period is re-
quired for dairy animals.
Generally unsuitable because of the
danger of transmitting pathogens to
humans.
Orchards
Generally suitable because the direct
application on trees can be prevented,
SOURCE: CRAG, 1977
153
-------
The requirements for applying sludge on "food chain
crops" vs. "nonfood chain crops" are significantly different.
In general, annual applications may be made where food-chain
crops are removed annually and the soil worked. More frequent
application may be made on permanent cover crops (nonfood
chain crops) such as grass seed and pasture. DEQ has estab-
lished that sludge should not be applied where leafy vegetables
are grown, and that "no root crops or low-growing fruit and
vegetables crops which are edible when raw should be grown
on land fertilized with liquid sludge for a period of 1
calendar year from date of application; exceptions would be
crops to be commercially processed and which may be grown
one winter season (minimum of 4 months) after application"
(OAR 340, Division 4, Subdivision 2, September 29, 1977).
A number of studies have been done relating to the
nutrient values of sludge and crop yields resulting from
sludge use. The Oregon Agricultural Experiment Station
(Oregon State University) has been studying the use of
sewage sludge as a fertilizer material. Sludge has been
applied to a variety of crops - corn, wheat and fescue
(as a forage grass) (Jackson, et al., 1976).
The O.S.U. studies have demonstrated the attributes of
using sewage sludge as a soil amendment. Most anaerobically
digested sludge ranges from 1 to 15 percent total nitrogen
(Portland sludge averages approximately 4 percent), 1 to 6
percent phosphorous, and 0.05 to 1 percent potassium. In
general, sludge contains little nitrate-nitrogen and an
ammonium-nitrogen content ranging from 1 to 4 percent on a
dry weight basis. The nitrate nitrogen is readily available
for plant growth; however, a large part of the ammonia
portion of the sludge nitrogen (50 percent or more) may be
lost by volatilization. The remaining organic nitrogen
"decays" slowly over time and becomes available to plants
at a later date. Because of the nitrogen "carryover" from
one year to the next, it is possible after 3 or 4 years of
repeated sludge application to maintain a constant nitrogen
level (Table 29).
Studies conducted at the north Willamette Experimental
Station indicate that crop yields after 2 years of sludge
application were substantially improved, apparently because
of the steady-state release of residual organic nitrogen.
First-year yields (even on experimental plots receiving the
highest rate of sludge application) did not reach those of
plots receiving ammonium-nitrate fertilizer (Jackson, et al.,
1976) .
In similar studies conducted in California (Hyde, N. D.)
all crops tested (field corn, dry-land pasture and irrigated
pasture) had higher yields from plots receiving sludge (3 to
25 dry tons/acre/year) than from those receiving chemical
154
-------
Table 29
YEARLY SEWAGE SLUDGE APPLICATIONS REQUIRED TO
PROVIDE A CONSTANT LEVEL OF AVAILABLE NITROGEN
Year
Total
kg/ha/yr
N1
lb/ac/yr
Sewage
mton/ha/yr
2
sludge
ton/ac/yr
1
472
421
11.8
5.3
2
426
380
10.7
4.8
3
403
360
10.1
4.5
4
392
350
9.8
4.4
5
388
346
9.7
4.3
6
384
342
9.6
4.3
¦^Total N to be added each year; calculated on basis of 25 percent of
total N = NH4-N in sludge and mineralization decay rate of 0.3 0, C.10,
0.05, 0.03, 0.03.
Calculated on basis of 4 percent total N in dry sewage sludge.
SOURCE: Jackson, et al., 1976
-------
fertilizer (field corn only) or no fertilizer (dry-land and
irrigated pasture). Optimum sludge application rates for
field corn were 30 dry tonnes per hectare per year (12 dry
tons per acre per year) and 20 dry tonnes per hectare per
year (10 dry tons per acre per year) for irrigated and dry-
land pasture (Hyde, N. D.).
Few studies have been conducted dealing with the continual
application of sludge and its effect on crop yield. Assuming
that annual application rates are within the guidelines
established for crop nitrogen requirements and heavy metals,
good crop yields should continue.
Alternative A. Wheat, alfalfa and grass are the crops
predominately grown in the Boardman area. Potatoes are also
grown on more suitable soils to the south of the three pro-
posed sludge application sites. Use of sludge on such crops
as wheat, alfalfa and grass is considered acceptable. Potatoes
are a root crop and therefore cannot be grown using sewage
sludge. The annual nitrogen requirements for wheat are 75
to 100 pounds per acre; 125 pounds per acre for grass and no
soil nitrogen requirement for alfalfa because it is a legume.
The use of sludge for growing those crops could represent a
major benefit in terms of increased productivity.
Alternative C. The Carver-Greenfield or B.E.S.T. product
could be used as a soil amendment in much the same manner as
liquid digested sludge. Due to the fact that the sludge is
reportedly pathogen free, requirements for agricultural use
may not be as stringent.
Alternative D. The north Willamette Experimental
Station studies have established the value of using sludge
for wheat, fescue and corn. Comparable results could be
expected in the event Portland sludge is applied in the
Willamette Valley.
The City of Salem has been applying sludge on 1,600
acres of agricultural land. Applications have been made on
pastureland, nursery crops, berries, mint, grain, dill,
orchards, hay, corn and grass seed (applications to edible
crops are presumably done in accordance with DEQ regulations).
On some agricultural lands, sludge has been applied for 7
years. The sludge has been used mostly as a fertilizer
supplement, however, sludge alone is sufficient to fertilize
grass and grain crops.
In the event this alternative is chosen, Portland sludge
could be used on agricultural lands that grow those crops.
156
-------
No-Action Alternative. No agricultural crops will be
grown under the no-action alternative.
Financial Impact
The City of Portland will be required to pay the annual
operating and maintenance costs for sludge treatment and
disposal, as well as the local share of the capital costs.
As part of EPA's Construction Grants program, this project
is eligible for up to 75 percent EPA funding of the capital
cost of the sludge handling facilities. The remaining 2 5
percent would represent the City of Portland's local share.
This local share cost could be paid in a number of ways, but
the approach which probably would be utilized is to sell bonds.
Table 30 presents an estimate of the local share costs
for the year 1990, the midpoint of the period under consideration.
In this estimate, it was assumed that the 25 percent local share
cost was paid for by bonds, sold at an 8.5 percent interest
rate and with a 20-year life. Costs were allocated between
domestic and industrial users according to the tons of sludge
contributed annually by each category. Many other methods
could be utilized to allocate the costs, and this may or may
not be the general concept adopted in the final revenue
program. It does, however, indicate the general magnitude
of cost per person per year.
As shown in Table 30, Alternative A-l is the lowest in
cost at $2.65 /person/year, with Alternative D-l being the most
costly at $3.41/person/year. Alternative D-l represents a 56
percent cost increase over Alternative A-l.
Mitigation Measures
Environmental impacts can be divided among those con-
sidered unavoidable and those which can be mitigated,
those impacts whose adverse nature can be lessened or eliminated.
Many short-term impacts (those lasting for the con-
struction period of the project) can be mitigated by using
established guidelines for construction activities. Miti-
gation measures for short-term impacts were previously
identified in Table 18.
Mitigation measures designed for long-term impacts
are typically more complex and of greater importance due to
the longer time period and, generally, the greater potential
magnitude of their impact. Agency regulations and guidelines
pertaining to the many aspects of a project may serve to
reduce or eliminate the need for special mitigations due to
the regulations having been established to avoid or minimize
specific adverse conditions. For that reason, many of the
mitigation measures outlined here relate to regulations or
guideline criteria that minimize potential adverse impacts.
157
-------
Table 30
Alternative
A-l
C-l
D-l
I-"
ui
00
LOCAL SHARE ANNUAL COSTS - YEAR 1990
Total
Capital
Cost
$16,329,000
15,015,500
17,272,600
Local Share*
Capital Cost
$4,082,250
3,753,880
4,318,150
Annual Bond
Payment for
Local Share**
$431,380/yr
396,680/yr
456,300/yr
Annual Operation
and Maintenance
Cost
$1,362,200
1,507,000
1,857,300
Sunrnation of
Annual Costs
$1,793,580
1,903,680
2,313,600
Allocation of Cost
Domestic UsersTotal Industrial
$2.65/capita/yr
2.81/capita/yr
3.41/capita/yr
$695,010/yr
737,680/yr
896,520/yr
~Estimated at 25% of the Total Capital Cost
~~Estimated using a bonding rate of 8.5% and a bond life of 20 years
-------
Measures to Minimize Adverse Sludge Processing Impacts
The only impacts of sludge processing dealt with in
this section of the EIS relate to the Carver-Greenfield
and B.E.S.T. processes. Anaerobic digesters, sludge transfer,
storage, etc., were included in Phase I of this project and
are either in operation or design.
Odors. Gas scrubbers should be incorporated to handle
odors created by the centrifuges, triethylamine, and the
noncondensible vent gases.
Noise. Centrifuges should be adequately housed and
damped to reduce high noise levels typical of such equip-
ment.
Cleanup and Disposal of Spilled Sludge. All sludge
spilled during or after BEST processing should be cleaned
up and stored immediately to insure that it does not enter
nearby waterways or groundwater supplies.
Cleanup and Disposal of Spilled Triethylamine. Because
of its toxic nature, triethylamine should be cleaned up
immediately and all washdown water recycled for solvent
recovery or disposal.
Health and Safety. The B.E.S.T. and Carver-Greenfield
systems should be devised to warn employees of malfunctions.
Contingency plans to deal with potential employee safety
should be devised.
Measures to Minimize Sludge Conveyance Impacts
Barge or Truck Accidents. During 197 6, ten State of
Oregon agencies formed the "Oregon Accident Response System"/
which is designed to provide communication and line function
responsibility in the event of a spill involving toxic or
dangerous materials. Members of the team also notify any
federal agencies having jurisdiction in the event of a spill
(i.e., U. S. Coast Guard, U. S. EPA).
To ensure that the most immediate action is taken in
the event of a sludge spill, either from barges or trucks,
the City of Portland could establish a contingency plan
linked to the Oregon Accident Response System.
It is anticipated that the liquid tank barges to be
used for sludge transport on the Columbia River will contain
8 to 10 compartments for sludge in addition to bow and stern
buoy compartments designed to prevent complete sinking of the
barge. The tank barges were designed to carry liquid petro-
leum products — materials considered to be more hazardous
than liquid sewage sludge.
-------
In the event a barge does spill its load of sludge, the
City of Portland should immediately notify responsible federal,
state and local authorities of the event and warn any water
users downstream of the spill to terminate pumping from either
the Willamette or Columbia River until the sludge load has
been dispersed. Water withdrawn from the Columbia between
Boardman and Portland is used exclusively for agricultural
purposes while water from the Willamette is used for agriculture
and industry. Municipalities using the water are limited to
two on the Columbia River (Dallesport and Boardman). Four
domestic intakes are located on the Willamette River between
Newberg and Lake Oswego.
The DEQ proposed "regulations for handling, disposal
and use of municipal sludge relating to land application"
state that "the transportation of sludge from the treatment
plant to the disposal or application site shall be made in
such a manner as to prevent leaking or spilling the sludge
onto highways, streets, roads or waterways."
Odors. In order to reduce the likelihood of odor
problems during transfer and transit of sludge, all loading,
offloading and conveyance systems should be "closed". At
points where odors would be emitted and impact residents air
scavenging systems could be installed to reduce the problem.
Archeological Resources. Preliminary field surveys at
the proposed dock sites at Portland and Boardman indicate
no archeological resources are present. To ensure that
hidden archeological sites are not destroyed during con-
struction, an archeologist should be on call in the event
any such sites are located.
Traffic. In the event Alternative D (transport of sludge
to the north Willamette Valley) is chosen, traffic congestion
is likely to occur in two locations — at the Oregon locks
if barge transport is used, or in Oregon City if truck transport
is used. The only mitigation possible at the Oregon locks
is to enlarge facilities to handle larger barges more
efficiently. Such an event is unlikely.
Routing tanker trucks via the least congested routes to
the sludge application site represents the most effective
means of mitigating traffic congestion impacts.
Measures to Minimize Sludge Disposal Impacts
The establishment of regulations and guidelines by the
Oregon Department of Environmental Quality and the U.S. EPA,
regarding the beneficial reuse or disposal of sewage sludge
on land, is meant to minimize as much as possible any
undesirable effects of sludge application.
160
-------
The DEQ has identified a number of regulations relating
to site approval, restricted use and permittee responsibility
(OAR, Chapter 340, Division 4, Subdivision 2, 1977). Prior
to the use of any site for sludge disposal or application
the Department of Environmental Quality must approve the
location. Furthermore, DEQ has the right to require a
management plan for the application or disposal of the sludge.
The permittee is also responsible for ensuring that the disposal
or application of sludge "does not result in surface run-off,
contamination of surface water or wells or create a nuisance
condition or health hazard."
Guidelines established by DEQ and EPA should be utilized
to the fullest when finalizing the site for sludge disposal
or application for agricultural use. These guidelines
represent the most up-to-date knowledge of the state-of-the-art
of using sludge on the land and should be used until more
definitive information becomes available.
Heavy Metals. Data indicate that several heavy metal
constituents m the Portland sludge are concentrated enough
to substantially limit the number of years sludge can safely
be applied to agricultural land. The two most limiting
constituents are zinc and cadmium. Based on 1978 sludge
production and an application rate of 4.6 tons of dry sludge
per acre per year, approximately 3,600 acres will be needed
to handle 16,425 tons of sludge per year, and by the year
2000, 1,200 additional acres will be needed. Because of heavy
metal loading, it will be necessary to abandon the application
sites at 20 years and move to a new location. Lower applica-
tion rates would extend the life of the sites; however,
more acreage would be needed initially.
Both DEQ and EPA have recognized the need for source
control (pretreatment) when heavy metal concentrations are
high. The DEQ-proposed regulations and guidelines state that
"in service areas where industrial processes are likely to
create heavy metal concentrations higher than those found in
domestic sludge, pretreatment at the source should be
strongly encouraged, to extend the useful life of the appli-
cation site".
The City of Portland has already exhibited the success
of a source control program. Concentrations of several heavy
metals have been reduced since 197 5. Examples are: chromium
from 365 ppm to 269 ppm; lead from 1,440 ppm to 1,322 ppm;
and zinc from 3,28 0 ppm to 2,4 08 ppm (City of Portland, 1975;
Edmonds, pers. comm.). Continued pretreatment programs should
further reduce heavy metals in the sludge.
161
-------
The U.S. EPA guidelines on municipal sludge management
state: "When sludges are to be applied to land, for bene-
ficial purposes, appropriate nondomestic users of municipal
wastewater treatment works should be required to pretreat
their wastewaters to minimize the presence of potentially
harmful heavy metals and other sludge contaminants from
industrial sources." (42 CFR, No. 211, 1977)
Overall Suitability of Land
for the Application of Sludge
The suitability of land for the application of sewage
sludge is dependent upon a wide variety of factors, among
which are the project objectives (disposal or beneficial
reuse), institutional considerations, present and projected
land uses, soil types, topography, depth to groundwater,
characteristics of the sludge and locations of surface
water (EPA, 1977).
The project objectives may, in part, be dictated by
other factors such as soil types, land use, groundwater
and particularly, the chemical characteristics of the sewage
sludge. If, for example, it is found that the sewage sludge
contains concentrations of heavy metals judged to be too
high for use on agricultural lands (or for other beneficial
reuses) then the only acceptable means of sludge application
on land may be disposal rather than reuse. In some cases
source control of heavy metals may be in order. In the
EPA document on Municipal Sludge Management: Environmental
Factors, mention is made that, "when sludge is to be applied
to land, for beneficial purposes, appropriate nondomestic
users of municipal wastewater treatment works should be
required to pretreat their wastewaters to minimize the pre-
sence of potentially harmful heavy metals and other sludge
contaminants from industrial sources".
This EIS analyzes three major locations for sludge
application - Morrow County near Boardman, the Rivergate
Industrial area of Portland and a 4 00-square-mile area of
the north Willamette Valley south of Oregon City.
Portland - Rivergate Industrial District
According to the 1976 SCS survey, three major soil
series occur at the Rivergate Industrial area. Sludge dis-
posal now occurs almost exclusively on the Sauvie-Rafton
complex. Since the sites are used exclusively for sludge
disposal and not for beneficial reuse (agriculture), the
environmental requirements are not as limiting as they are
for agricultural reuse. Major concerns of EPA and DEQ
relative to disposal are contamination of surface and/or
groundwater and the development of public nuisance conditions.
162
-------
The Rivergate area has been used for sludge disposal
since 1976. In July 1975, DEQ approved the use of an area
"immediately east of the Fulton Terminal" for sludge disposal.
Conditions of the approval were:
"1) Only liquid digested sludge shall be applied to the above described
site;
"2) A minimum buffer strip of 100 feet must be left on all sides
of the area;
"3) Ponding and runoff must be controlled such that nuisance con-
ditions and/or water pollution do not occur.
"4) The sludge must be transported in vehicles approved for
over-the-road travel and any spillage that occurs must be promptly
cleaned and/or removed by the city.
"5) At least three monitoring wells should be provided to determine
any changes that may occur in the general groundwater. The wells
should te located in the buffer strip with at least one on the
south side and the others spaced on the north side along the
harbor. Samples should be collected at least weekly and analyzed
for the following:
a. temperature
b. pH
c. alkalinity
d. total and fecal coliform
e. heavy metals, to include Zn, Pb, Cu, Cd, Ni and Cr
The results of the monitoring should be included with the monthly
operational reports for the Columbia Boulevard plant" (DEQ
letter to H. Harris frcm L. Kramer, July 18, 1975).
The Fulton Terminal disposal area has since been abandoned
(it is now a parking lot), and a new area between Kelley Point
and the Fulton Terminal has been put into use. Based on
the results of groundwater monitoring, it was determined by
DEQ that monitoring wells would not be necessary at the new
site. This action appears to conflict with DEQ proposed regula-
tions and guidelines (OAR, Chapter 340, September 1977) that
recommend:
"Test wells are required on sludge disposal sites to determine
the depth and background quality of groundwater. The minimum
parameters to be monitored are Zn*-1", Pb++, Ni"*"*"/ Cd++ and CU++,
furthermore,
"Sludge may be applied to disposal sites in limited amounts
so long as a quarterly monitoring of the test well (s) shews no
increase over background concentration of heavy metal ions in
groundwater."
163
-------
Heavy metal concentrations reported in the earlier
monitoring program are shown in Table 2; however, there are
no background data with which to compare these concentrations
and interpret the concentrations reported.
The continued use of the Rivergate area for sludge
disposal would appear to be acceptable; however, it is likely
that a well-planned monitoring and data interpretation
program would be necessary. The quantities of dry sludge
that can be safely applied per acre without groundwater
contamination have not been determined.
Morrow County
Several areas in northcentral Oregon were examined by
the City of Portland for their potential as land application
sites for sludge. The landowner, lessee, or manager was
contacted on three sites: the Boeing Agri-Industrial property;
the U. S. Navy Bombing Range; and Sabre Farms. The Boeing
Company indicated interest and a commitment in the use of
sludge as a soil amendment on land currently utilized as range
for grazing cattle and sheep. The U. S. Navy indicated that
no long-term agreements could be made to use the Bombing Range
as a disposal site; however, interest was shown in utilizing
limited amounts of sludge to stabilize sandblows (Rappel,
pers. comm.). Sabre Farms also expressed interest in -using
limited amounts of sludge on a trial basis for stabilization
of sandblows, or as a soil amendment on alfalfa and pasture
grass crops (Fritz, pers. comm.).
Additional areas in northcentral Oregon that were
evaluated by the City of Portland, and where no contact was
made with the landowners, were Blalock Canyon, a large wheat-
producing area in Gilliam County, and the Irrigon area in
Morrow County.
Detailed site studies have not been conducted for the
Morrow County areas under consideration for the disposal of
sludge. However, soil studies conducted by the USDA, Soil
Conservation Service (SCS) (1972, 1976) (see Table 1) provide
adequate initial information on soil types, topography, erosion
hazard, depth to groundwater and other soil properties in the
area. The major soil series occurring on the sites have silt
loam, sandy loam or loamy fine sand texture with slight to
moderate water erosion hazard and severe wind erosion hazard.
These textures are considered suitable for sludge application.
The cation-exchange capacity (CEC) varies from 8 to 16 meq/lOOg,
the depth to water table is greater than 6 feet, and permeability
is moderate to rapid. Slope varies from 0 to 20 percent (most
of the site areas have less than 5 percent slope). No
perennial waterways occur near any of the sites (the Columbia
River lies approximately 2 to 3 miles north of the sites).
164
-------
Existing land uses vary from one site to another. Sites
A and B, on Boeing property, now support wheat, irrigated
pasture grass and alfalfa. Site C is in natural sagebrush
vegetation. The U. S. Navy site consists of native vegetation
and barren ground. Sabre Farms support potatoes, wheat,
alfalfa and pasture grasses.
All preliminary indications are that these sites could
satisfactorily be used for sludge application. One site on
Boeing property (Site B) may have limitations due to shallow
soils (less than 6 feet of basaltic bedrock). The ultimate
use of the sites for either fertilization of agricultural crops
or sludge disposal will be dependent upon institutional con-
sideration and the acceptability of sludge (in terms of heavy
metals) for use on agricultural lands.
Recently, the Land Use Research Institute (Mr. George Ward)
conducted studies using sewage sludge to stabilize active,
windblown sand dunes on the 50,000-acre Naval Weapons System
Training Facility. During 197 6 the Land Use Research Institute
requested that a northern portion of the bombing range be made
available for sludge disposal. A decision made by the U. S.
Nave in November 1976 concluded that although benefits of dune
stabilization would be accomplished, it was "essential that
the training facility (Naval Weapons System Training Facility,
Boardman, Oregon) maintain its character as an air-to-ground target
range". Such a decision precluded the use of any portion
of the area for sludge disposal (Executive Correspondence,
Department of the Navy to G. D. Ward, November 3, 1976).
Despite the earlier refusal by the U. S. Navy, the
training facility is considered to represent a suitable
location for sludge disposal. Much of the area has Koehler-
Quincy soils which are loamy fine sand having 0 to 12
percent slope, high cation-exchange capacity (>15 meq/lOOg),
high pH (6.6 to 8.4), and a groundwater table greater than
6 feet below the surface (USDA, 1972, 1976).
The feasibility of the City of Portland using the
training facility for sludge disposal will be dependent upon
a change of policy by the U. S. Navy regarding use of the
facility and formulation of an agreement between the city
and the U. S. Navy.
Clackamas County
Specific-site studies have not been conducted on the 400-square-
mile sludge application area in Clackamas and Marion Counties.
However, a preliminary analysis of the area was made in the
165
-------
Sludge Management Study conducted by CRAG (1977). Based on
an evaluation of seven soil properties, the CRAG study
estimated that approximately 250,000 acres of land in Clackamas
County contain suitable soils for sludge application, much of
that lying within the proposed sludge application area.
However, considering present land use, roads, forests, etc.,
the availability of land for sludge application would be
considerably less than 250,000 acres. The cation-exchange
capacity for the two major soil series is well above 15 meq/lOOg
(16 to 30), meaning that the allowable heavy metal loading
per acre is much greater than at the Morrow County sites.
However, the soil pH is generally less than 6.5 (4.5 to 6.0)
meaning that heavy metals may be more "available" to plants
unless the pH is raised by using lime. Approximately 7 tons
of lime per acre is required to raise the pH of soil from
6.0 to 6.5 (Sommers, N.D.). No suitability analysis was done
for Marion County since the county was outside of the CRAG
study area.
Existing land use is a mix of rural residential and
agricultural tracts. Several areas are zoned for
1/2- to 1-acre parcels. The small size and mix of parcel
sizes represents a potential constraint due to the lack of
flexibility in dealing with a large number of small landowners.
A determination of the si?e of agricultural parcels and the
general availability of the lands for sludge application
has not been made but will be necessary to determine the
feasibility of using such areas. Due to present agricultural
use of the area, it is unlikely that sludge disposal (with-
out beneficial reuse) would be an acceptable alternative.
166
-------
UNAVOIDABLE ADVERSE IMPACTS
Each of the four alternatives evaluated would create
unavoidable adverse impacts. These impacts have been
described on preceding pages, and mitigation measures
capable of reducing the magnitude of the impacts have been
suggested where appropriate. The following table summarizes
the unavoidable adverse impacts of construction and operation
of the four systems.
Summary of Unavoidable Adverse Impacts
Alternatives
Impact - Short Term A C D No-Action
Construction
Construction-related traffic
X
X
X
Disruption of local traffic
X
X
X
Local creation of dust
and/or mud
X
X
X
Local turbidity and disturbance
of fish life
X
X
Wildlife and wildlife
habitat loss
X
Noise
X
X
X
Aesthetics (visual disruption)
X
X
X
Soil erosion
X
X
X
Aerial pollutants
X
X
X
Local disruption of wildlife
X
X
Temporary loss of vegetation
X
X
Impact - Long Term
Sludge Processing
X
Energy use
Chemical use
X
Air emissions
X
Sludge Conveyance
Traffic congestion and
transport hazard
X
X
X
X
Energy use
X
X
X
Odors
X
X
X
X
Air emissions
X
X
X
X
Sludge loading and
unloading facilities
X
X
Noise
X
X
X
X
Sludge Disposal
Odor
X
X
X
X
Aesthetics
X
X
X
Heavy metals
X
X
X
X
Pathogens
X
X
X
Nitrates
X
X
Conversion and loss of wildlife
habitat
X
Vectors, nuisances
X
X
X
Costs to taxpayer 167
X
X
X
X
-------
LOCAL SHORT-TERM USES OF THE
ENVIRONMENT VS. MAINTENANCE AND
ENHANCEMENT OF LONG-TERM PRODUCTIVITY
All of the alternative sludge disposal or reuse alter-
natives, including no action, involve tradeoffs between
beneficial and adverse impacts. The alternative selected
as being most appropriate is intended to achieve the maxi-
mum beneficial effect at the lowest possible environmental,
social and monetary cost.
The major benefit sought by each project alternative
is the solution to the problem of sewage sludge disposal for
the Columbia Boulevard Sewage Treatment Plant. The present
places of disposal, i.e., the Rivergate Industrial District,
St. Johns landfill and Triangle Lake, are temporary, and while
there is no recognized water quality or public health
problem associated with the present disposal, the land area
available is insufficient to meet disposal needs beyond
about 1983.
Alternatives A, C and D require certain environmental
trade-offs to achieve the long-term benefits sought. While
all three alternatives require increased fuel (energy) for
transport, Alternative C would require additional power and
chemicals for sludge processing. Each of the three alter-
natives beneficially reuse sewage sludge as a soil conditioner/
amendment and as a source of nutrients. In all cases the
objectives of the City of Portland to dispose of its sewage
solids are accomplished.
Because of moderate levels of some heavy metals in the
sewage solids, especially zinc, the use of sludge for agri-
cultural purposes may represent only a short-term aid to soil
productivity. Such short-term enhancement can be extended by
proper management, either in terms of further controlling the
source of heavy metals or reducing the application rates.
In the event that sludge is disposed of in Morrow County on
wind-eroding sand rather than reused for agricultural pur-
poses, the long-term productivity of what are now unusable
or threatened lands could be enhanced. Shifting sand areas
would be stabilized to eliminate the continual movement of
sand onto productive farmlands and across roadways.
169
-------
The long-term dedication of land areas for docking
structuresr storage lagoons and sludge disposal or
agricultural application, is justified because of the
limited size of the current means of disposal and the
anticipation of potential adverse environmental problems
to come if the Rivergate sites are overloaded.
170
-------
IRREVERSIBLE AND IRRETRIEVABLE
COMMITMENTS OF RESOURCES
Minor and major irreversible and irretrievable
commitments of both renewable and non-renewable resources
will occur if one of the proposed alternative projects
is implemented. Construction will irretrievably commit
mineral resources in the form of aggregate, pipe, wood;
excavated, displaced and submerged soils and vegetation;
and petroleum fuel sources. A considerable amount of man-
hours, capital and energy resources will be required.
After a project is in operation, man-hours and
chemical and energy resources will continue to be utilized
for sludge processing, conveyance and disposal.
171
-------
UNRESOLVED ISSUES
During the course of report preparation, it became clear
that there are several key issues relative to the Portland
sewage sludge disposal project. These issues were identified
in the INTRODUCTION to this Draft EIS and were further dis-
cussed throughout the report. The resolutions to several
of the issues are regulatory or institutional problems
that must await further governmental action.
o Review of heavy metal constituents of Portland
sludge indicates moderate concentrations of zinc
(2/408 mg/kg). Zinc concentrations are sufficiently
high to reduce the projected life of application sites
when sludge is applied at rates greater than 4.6
tons per acre per year at Morrow County and to signi-
ficantly increase the area of land needed to the year
2000. Three apparent options are available to deal
with this loading: 1) additional source control of
those industries contributing heavily to the metal
loading and 2) utilization of larger amounts of land
if sludge is used for agricultural purposes and 3)
disposal of sludge on a smaller area with no bene-
ficial use and the possible long-term degradation of
such land.
o Preliminary review of test well monitoring results
at the Rivergate industrial area indicated high amounts
of zinc in the groundwater. No predisposal background
data exist with which to compare the monitoring
results. The acceptability of continued use of
Rivergate as a disposal area must be reviewed and
evaluated.
o The use of Boeing agri-industry land or the U. S.
Naval property in Boardman strictly for disposal
of sludge (rather than for beneficial agricultural
reuse) may be unacceptable to land owners and lessees
in Morrow County.
173
-------
BIBLIOGRAPHY
References
Bair, D. C. 1977. East Bay Municipal Utility District
soil enrichment study, progress report no. 7, March,
1977.
Bartholomew, W. S., M. E. Graham and J. Feusner. 1973.
Groundwater levels. 1968-1972. Oregon State Engineer
groundwater report 18. 134 pp.
Battelle Pacific Northwest Laboratories. 1973. An inventory
and evaluation of areas of environmental concern in
Oregon. Prepared for the Oregon State Executive
Department and Natural Resources Agencies. 104 pp.
Chaney, E. and L. E. Perry. 1976. Columbia Basin salmon
and steelhead analysis. Summary report prepared for
the Pacific Northwest Regional Commission. 74 pp.
Clackamas County. Planning Department. 1974. Comprehensive
plan, Clackamas County, Oregon.
Columbia Region Association of Governments. 1977. 208
areawide waste treatment management study. Main report
plus 12 technical supplements.
East Central Oregon Association of Counties. 1977. Preliminary
population and labor force projections for Umatilla
and Morrow Counties, 1975-2000.
Emonds, R. L. 1976. Survival of coliform bacteria in sewage
sludge applied to a forest clear-cut, and potential
movement into groundwater. Applied and Environmental
Microbiology 32(4): 537-546.
Franklin, J. F. and C. T. Dyrness. 1973. Natural vegetation
of Oregon and Washington. U. S. Forest Service General
Technical Report PNW-8. 417 pp.
Hampton, E. R. 1972. Geology and groundwater of the Molalla-
Salem slope area, north Willamette Valley, Oregon. U. S.
Geological Survey Water-Supply Paper 1997. 83 pp.
Harris, D. D. 1968. Travel rates of water for selected streams
in the Willamette River Basin, Oregon. U. S. Geological
Survey Hydrologic Investigation Atlas HA-273.
Hogenson, G. M. 1974. Geology and ground water of the Umatilla
River Basin, Oregon. U. S. Geological Survey Water-Supply
Paper 1620.
-------
Hyde, Henry C. [n.d.] Sewage sludge: can it be used to
enrich agricultural soil? San Francisco Bay Region
Wastewater Solids Study. 9 pp. [reprint]
Jackson, T. L., et al. 1976. Sewage sludge use as a
fertilizer material. 20 pp.
Kirkham, M. B. 1974. Disposal of sludge on land: effect
on soils, plants and groundwater. Compost Science, March-
April, 1974. 10 pp.
Mid Willamette Valley Council of Governments. 1972.
Comprehensive plan, Marion County, Oregon. 120 pp.
Moore, B. E., B. P. Sagik, C. A. Sober. 1976. An assessment
of potential health risks associated with land disposal
of residual sludges. In: Sludge management, disposal
and utilization. 210 pp.
Multnomah County. Planning Commission. 1977. Comprehensive
framework plan, Multnomah County, Oregon. 407 pp.
The Nature Conservancy. 1976. Oregon natural areas. Western
Oregon. Vols. 1 & 2 plus maps.
Oregon. Department of Environmental Quality. 1975. Water
quality control in Oregon; a status report. 68 pp.
1976. Oregon air quality report 1976. 49 pp.
+ appendices.
19 77. Assessment of stream quality in Oregon
based on evaluation of data collection in the 1976 stream
sampling program. 6 8 pp.
Oregon. Department of Fish and Wildlife. 1958. Fish passaqe
facilities, Bonneville Dam. Report no. 66-1.
1971. General life histories of some anadromous
fish entering the Columbia River. 3 pp.
1976. Columbia River fish runs and fisheries,
1957-1975. Status report vol. 2, no. 1. 74 pp.
1977. Fishery data catalog, county summaries.
1977. Oregon's threatened or endangered wildlife.
13 pp.
Oregon. State Highway Division. 1977. Traffic volume
tables for 1976. Official publication #77-1.
176
-------
Oregon State University, Agricultural Experiment Station.
19 77. Projecting farm income effects of sewage sludge
utilization in the Tualatin Basin of Oregon. Special
Report 49 8. 67 pp.
Oregon. Water Resources Department. 1978. Water rights
permits.
Pacific Northwest Regional Commission. 1977. North Columbia
Basin Boomtown project report. 90 pp. + appendices.
Piper, A. M. 1942. Groundwater resources of the Willamette
Valley, Oregon. U. S. Geological Survey Water-supply
Paper 890. 194 pp.
Portland (City of). 1977. Flood control statement, sludge
lagoon modifications.
Portland (City of). Department of Public Works. 1976.
Alternative methods for the disposal of sewage solids.
292 pp. + appendices.
Portland General Electric Company. 197 3. Boardman nuclear
plant; environmental report, construction permit stage.
Vols. 1 and 2.
1974. Demographic characteristics of the Boardman,
Pebble Springs and Fulton Ridge potential power plant sites,
north central Oregon. July 1974.
Portland (City of). Traffic Engineering. 1975. Average daily
traffic volumes map, 1975.
Rickert, D. A, et al. 1977. Algal conditions and the potential
for future algal problems in the Willamette River, Oregon.
U. S. Geological Survey Circular 715-G. 39 pp.
Robison, J. H. 19 71. Hydrology of basalt aquifers in the
Hermiston-Ordnance area, Umatilla and Morrow Counties,
Oregon. U. S. Geological Survey Hydrologic Atlas HA-387.
San Francisco Bay Region Wastewater Solids Study. 19 77.
Wastewater solids process, transport and disposal/use
systems task report. November 1977.
Snyder, P. W. 1975. Letter to Mr. George Ward, February,
1975.
177
-------
Sommers, L. E. [n.d.] Principles of land application of
sewage sludge. Prepared for the EPA, Technology
Transfer design seminar for sludge treatment and
disposal, pp. 228-271.
Stevens, Thompson, and Runyan, Inc. 1973. Environmental
assessment of the pressure outfall sewer for the
Columbia Boulevard sewage treatment plant.
Thompson, K. E., et al. 1966. Fish resources of the
Willamette Basin. Oregon Department of Fish and
Wildlife publication. 161 pp.
U. S. Army Corps of Engineers. 1969. Lower Columbia
River standard project flood and maximum probable
flood. Memorandum report.
1977. Report on commerce for the Willamette/
Columbia and Snake Rivers.
U. S. Department of Agriculture. 1961. Water and related
land resources; John Day River Basin, Oregon. 81 pp.
1962a. Water and related land resources;
Umatilla Drainage Basin, Oregon. 138 pp.
1962b. Water and related land resources; Middle
Willamette River Basin, Oregon. 180 pp.
1963. Water and related land resources; Lower
Willamette River Basin, Oregon. 149 pp.
U. S. Department of Commerce. 1974-1976. Climatological
data; annual summary, Oregon. Vols. 80-82, no. 13.
1977. 1974 census of agriculture, Oregon.
Vol. 1, part 37.
U. S. Department of Transportation, U. S. Coast Guard. 1977.
Accident data for commercial vessels in the Columbia
River Basin, fiscal years 1972-1976.
U. S. Environmental Protection Agency. 1971. Transportation
noise and noise from equipment powered by internal
combustion engines. Dec. 31, 1971. NTID 300.13, 274 pp.
+ appendices.
1972. Water quality criteria 1972 - a report
of the Committee on Water Quality Criteria, National
Academy of Sciences. 594 pp.
178
-------
1976. Application of sewage sludge to cropland:
appraisal of potential hazards of heavy metals to plants
and animals. MCD-33. 63 pp.
1976. Compilation of air pollutant emission factors.
Second edition. Publication no. AP-42.
1977. Municipal sludge management: environmental
factors. EPA 430/9-77-004. MCD-28. 25 pp. + appendices.
U. S. Fish and Wildlife Service. 197 3. Threatened wildlife
of the United States. Resource Publication 114.
. 1977. Endangered and threatened wildlife and
plants. Federal Register 42(135): 36419-36431.
U. S. Geological Survey. 1949. Floods of May-June 1948
in the Columbia River Basin. Water-Suppy Paper 108 0.
1964. Magnitude and frequency of floods in the
United States. Water-Supply Paper 1689.
1975. Surface water supplies of the United States
1966-70, part 14, Water-Supply Paper 2135.
1976. Quality of surface waters of the United
States, 1970. Water-Supply Paper 2160.
1977. Water resources data for Oregon, water
year 1976. Water-data report OR-76-1.
U. S. Soil Conservation Service. 1972. Soil survey of Marion
County area, Oregon. 132 pp. + maps.
1972 and 1976. Soil interpretations for Oregon,
Clackamas, Multnomah and Morrow County.
Washington. Department of Ecology. 19 77. Use and water
diversion maps - Columbia River.
Williams, J. R. 1976. Letter to George Ward from Department
of the Navy, Western Division, November 3, 1976.
179
-------
Personal Communications
Abraham, David. 1978. Utilities Director, Clackamas County
Public Works Department.
Fritz, D. 1978. Sabre Farms agronomist, Boardman, Oregon.
Hassler, R. 1977. Knappton Towboat Company, Portland, Oregon.
Hickey, R. 1977. Tidewater Barge Lines, Portland, Oregon and
Vancouver, Washington.
Jonasson, C. 1978. Port of Portland Rivergate Industrial
District, Portland, Oregon.
Klampe, Lyle. 1978. Field Representative - Biogro, City of
Salem, Oregon.
Lynd, E. R. Water Quality Division, Department of Environmental
Quality, Portland, Oregon.
McGough, Paul S. 1978. Resources Conservation Company.
Martin, S. 1978. Sim-Tag Farms, Boardman, Oregon.
Meyers, Marsh. 1978. Umatilla Vector Control District,
Umatilla County, Oregon.
Moon, David. 1978. Morrow County Planning Department.
Naef, Randy. 1978. CHjM Hill, Portland, Oregon.
Nelson, Robert. 1978. Arthur Forsyth Company, Portland,
Oregon.
Ness, A. 0. 1978. U. S. Department of Agriculture, Soil
Conservation Service, Portland, Oregon.
Nordgren, Gene. 1978. Manager, Clackamas County District #1.
Norman, Jeanette. 1978. Manager, Oak Lodge Sanitary District.
Norton, V. E. 1978. The Boeing Company, Boardman, Oregon.
Nunamaker, Dale. 1978. City of Portland, Oregon.
Oliver, Neil. 1977. City of Portland, Traffic Engineering,
Portland, Oregon.
Pitney, W. 1977. Oregon Department of Fish and Wildlife,
Portland, Oregon.
Rappell, D. C. 1978. U. S. Department of the Navy, Staff
Forester, Seattle, Washington.
180
-------
Runyan, George. 1978. Vector Control Section, Oregon State
Health Division, Portland, Oregon.
Siddall, G. 19 78. Botanist - rare and endangered plant species
of Oregon. Lake Oswego, Oregon.
Volk, Van. 1978. Associate Professor, Department of Soil
Science, Oregon State University.
181
-------
Appendix A
, Environmental Protection Agency
Technical Bulletin
Municipal Sludge Management
183
-------
WEDNESDAY, NOVEMBER 2, 1977
PART IV
ENVIRONMENTAL
PROTECTION
AGENCY
Municipal Sludge Management
ENVIRONMENTAL
FACTORS; TECHNICAL
BULLETIN
184
-------
57120
NOTICES
[6560-01 ]
ENVIRONMENTAL PROTECTION
AGENCY
| FRL 810-7]
MUNICIPAL SLUDGE MANAGEMENT
Environmental Factors; Technical Bulletin
On June 3, 1976, in the Federal Regis-
ter (41 PR 22532), the Environmental
Protection Agency published for public
comment a proposed technical bulletin,
"Municipal Sludge Management: En-
vironmental Factors." The Bulletin has
been prepared to assist EPA Regional
Administrators in evaluating grant ap-
plications lor construction of publicly
owned treatment works under Section
203(a> of the Federal Water Pollution
Act as amended. It also provides de-
signers. municipal engineers and others
with information for selecting a sludge
management option. The Bulletin ad-
dresses only factors important to the
environmental acceptability of a particu-
lar sludge management option and does
so In a general manner to allow maxi-
mum flexibility.
Written comments on the proposed
Technical Bulletin were invited and re-
ceived from interested parties. EPA has
carefully considered all comments re-
ceived. All written comments are on file
with the Agency, and are available for
examination at the Municipal Construc-
tion Division, Office of Water Program
Operations.
Many of the comments received clearly
expressed concerns over the need for
regulations, criteria and detailed guide-
lines to provide better control of sludge
disposal and utilization activities. Al-
though this Bulletin will exercise some
control over the design of sludge manage-
ment systems, it does not address in de-
tail the control of operating systems.
Efforts pursuant to the recently passed
Resource Conservation and Recovery Act
of 1976 (Pub. Ij. 94-580) are underway to
develop specific criteria and guidelines
for sludge management activities.
Comments were received from a wide
variety of sources (Federal agencies,
State regulatory agencies, environmental
groups, municipalities/counties/cities,
consultants, university extension and re-
search groups, special interest groups
and the perioral public). These com-
ments indicated both support for and
opposition to a number of points made
in the proposed Technical Bulletin. Con-
flicting points of view were often noted
among comments received on a particu-
lar topic, even when received from the
same type of reviewer. In many cases,
agreement was indicated by numerous
commenters who favored or supported a
certain position. Modifications were
made to the document wherever there
was clear and strong support for change.
The principal comments received and
the responses to them are summarized
below:
(a) Several comments requested that
public hearings be held prior to final
publication of the Technical Bulletin.
Numerous versions of the proposed doc-
ument have been extensively reviewed
and the comments received were care-
fully considered. The major Issues raised
were generally the same issues that were
identified during the early efforts to de-
velop this document and center on regu-
latory concerns. The need for specific
criteria and guidelines for the control of
land disposal and utilization practices
was the major concern expressed in the
comments. Criteria for State regulatory
programs for the control of solid waste
activities, including municipal sludge
management, are being developed as part
of implementation of the Resource Con-
servation and Recovery Act of 1976 (Pub.
L. 94-580). Public Hearings will be con-
ducted as part of efforts to establish cri-
teria and guidelines under that Act.
(b) Many comments were received
that indicated a need to clarify the roles
of the Food and Drug Administration
(FDA) and the U.S. Department of Agri-
culture (USDA) in the development and
review of facility plans addressing sludge
management. The detailed monitoring,
review and approval activities by USDA
and PDA for certain projects as indi-
cated in the proposed document could
lead to excessive manpower and funding
requirements for these Agencies. The
final version recognizes FDA as the
agency which should establish recom-
mended acceptable levels of various con-
taminants in human foods and animal
feeds. In addition to indicating the avail-
ability of USDA assistance to munici-
palities, the Bulletin encourages USDA
to continue to develop and provide site-
specific recommendations on the best
agricultural practices for use of munici-
pal sewage sludge by farmers on pri-
vately owned lands. The objectives of
such recommendations are to minimize
or eliminate monitoring requirements on
the farm while protecting farmland for
future agricultural use, maintaining nor-
mal productivity, and assuring continued
farm income. Technical assistance is a
major role and will be available from
FDA. various USDA extension and re-
search offices, as well as EPA and the
State Agricultural Experiment Stations.
(c) Numerous comments were received
regarding the need for establishing al-
lowable levels for heavy metals and other
contaminants in sludges applied to tlio
land. This document is not intended to
be regulatory in nature, but rather to
provide information on items to be con-
sidered in evaluating construction grant
applications. More specific guidance on
acceptable levels of contaminant addi-
tions to agricultural land from solid
waste (including sludge) are planned to
be developed and published under the
Solid Waste Disposal Act, as amended by
the Resource Conservation and Recovery
Act of 1976 (Pub. L. 94-580).
In an effort to provide the most cur-
rent state-of-the-art information avail-
able on the potential effects on agricul-
tural crops and animals by heavy metals
In sewage sludges applied to cropland.
EPA has recently published a report
titled "Application of Sewage Sludge to
Cropland: Appraisal of Potential Haz-
ards of the Heavy Metals to Plants nnd
Animals" prepared by the Council lor
Agrciultural Science and Technology
(EPA 430 9-76-013; November 1976).
This report and others that are planned
for publication in the near future will
provide in-depth presentations of avail-
able information on topics of major in-
terest and concern related to municipal
sewage sludge management.
The revised Bulletin recommends that
adequate testing of the sludge be under-
taken to provide the user with a basis for
designing and operating the system and
for developing future control mecha-
nisms. It recommends that all sludges be
analyzed to determine the range of levels
of heavy metals (especially Cd, Zn, Mo,
Ni and Cu), persistent organic com-
pounds (such as chlorinated pesticides,
and PCB's), and other chemical or bio-
logical contaminants of concern when-
ever land application of sludge is pro-
posed.
(d) Numerous comments addressed
the section on "Projects of Minimal Con-
cern." In response to these comments
and other factors, this section has been
rewritten to only address demonstration
projects. For demonstration projects
where significant resources and man-
power are available for control and moni-
toring, it is Indicated that recommenda-
tions within the Bulletin may be exceed-
ed in an effort to investigate new ap-
proaches for sludge management. Gen-
eral guidance for "dedicated" utilization
or disposal sites is provided in other sec-
tions.
(e) Numerous comments expressed the
need for additional detailed information
to be included in the Bulletin covering
each utilization and disposal option. The
final Bulletin has been maintained as
short and precise as possible while pro-
viding general guidance to the Construc-
tion Grants Program on those environ-
mental factors to consider when
reviewing proposed municipal sewage
sludge management projects. It was not
written as a regulatory document or de-
sign manual. Current pertinent regula-
tions are either cited or referenced. Cri-
teria and guidelines for solid waste
(including sludge) disposal onto land
which are planned to be developed and
issued under Pub. L. 94-580 should pro-
vide more specific Guidance. Detailed re-
ports are being planned to supplement
the Bulletin and provide the detailed
data base and information on other
topics of concern to municipal sludge
management.
cf) Clearly conflicting comments were
received regarding the general tone of
the proposed bulletin towards land ap-
plication of municipal sewage sludge.
Many comment.', indicated that the in-
tent of the Bulletin was far too restric-
tive on agricultural use of sludge. Others
felt that the coverage of cropland uses
was too liberal. Both support of and op-
position to the application of municipal
185
fEDEAAl REGISTER, VOL. 42, NO. 21 1—WEDNESDAY, NOVEMBER 2, 1977
-------
NOTICES
sludge to park lands, disturbed land and
forests were indicated by different com-
roenters. The revised document attempts
to encourage the beneficial utilization of
municipal sludge as a resource, and cites
experience as guidance fn evaluating
construction grant applications on
sludge uitilization procedures that have
experienced no Known environmental
problems.
(g) Numerous comments were received
concerning the intent of this document
towards supporting the utilization or
disposal of municipal sludges. Since Jand
application of many sludges can be bene-
ficial to the soil and crops, this method
would be preferable to sludge disposal
pi act ices that preclude these beneficial
effects. Of course, these practices should
be implemented in a manner that is also
environmentally acceptable. The guid-
ance given in the Bulletin concerning the
utilization of sludge by land application
is intended to provide maximum flexibil-
ity to minimize possible environmental
problems, since the available informa-
tion is still limited.
(h> Comments received in regard to
the monitoring requirements of the pro-
posed document generally favored the
need for some monitoring of sludge dis-
posal and utilization projects, but dis-
agreed on the extent to which monitor-
ing should be required. The revised
document recommends the development
of an adequate baseline analysis for
specific heavy metals and persistent or-
ganic compounds in the sludge to provide
the basis for additional site-speciflc
monitoring requirements. The monitor-
ing plan developed for a*land application
project should be designed for the local
site conditions, project operation and
sludge analysis.
(I) Numerous comments were received
recarding the importance of adequate
pretreatment requirements to control
industrial discharges of contaminants
into publicly-owned sewage treatment
works that may eventually create sludge
management problems. The Bulletin
strongly emphasizes the importance of
pretreatment as a means of reducing the
contaminant levels in sludges, while not
specifically addressing possible pretreat-
ment actions. The Agency has embaiked
on an accelerated program under Pub. L.
02-500 to develop (X) pretreatment
standards for the most significant pol-
luting Industries, and 12) standards per-
taining to the discharge of designated
toxic pollutants. Additionally, the Agency
has recently issued revised pretreatment
guidelines to assist municipalities in
developing local pretreatment require-
ments.
(J) A number of comments were re-
ceived regarding the determination of
appropriate application rates for sludges
applied to the land. Most agreed with the
approach taken in the proposed docu-
ment calling lor maximum application
Kites to be based upon crop nitrogen
needr and groundwater concerns. There-
fore, this approach was maintained in
the final document.
tic) Numerous comments were received
indicating a need for defining, or at least
clarifying, the meaning of such terms as
"stabilization," "food chain and non-
food chain crops," "utilization and dis-
posal," "agricultural and non-agricultu-
ral uses." "high/average/low sludge
quality" and "application rates." Efforts
were made in the final bulletin to provide
definitions or at least clear indications
as to the intended meaning of such
teims. In addition, an appendix is in-
cluded that provides typical values ob-
served for various contaminants in
municipal sludce under different circum-
stances.
(1) Numerous comments were directed
ai the technologies available to meet
the stabilization requirements of various
sludge management practices. It was
generally agreed that the stabilization
discussion in the proposed document was
too restrictive. In the revised Bulletin,
efforts were taken to establish the need
for stabilization, but not to provide a
complete list or details of available sta-
bilization technologies. The reader
should refer to the "Process Design
Manual for Sludge Treatment and Dis-
posal" (EPA 625/1-74-006; October
1974) for more specific information on
sludge stabilization techniques.
(m) Several comments were received
indicating the need for clearer guidance
on when additional pathogen reduction
techniques are required and what path-
ogens need to be controlled. The final
Bulletin indicates that under certain
site-specific project conditions, pathogen
reduction list of methods that have been
used to further reduce pathogen levels
in sludge. Since the conditions that
would require the need for additional
pathogen reduction are generally site- or
project-specific, no attempt was made to
identify when this would be required, ex-
cept with regard to the production of
directly consumed human foods.
(n) Numerous comments were received
regarding the restrictions recommended
for the protection of-food products and
agricultural land. Most, but not all, re-
viewers agreed that this section was too
restrictive as presented in the proposed
document. Many reviewers strongly op-
posed the restrictions requiring (1) three
years after sludge application before hu-
man food crops may be grown to be eaten
raw, and (2) the sludge applied to be
negative for Salmonella and Ascaris ova
II applied to soils where crops are grown
which are normally cooked in the borne
before consumption, but marketed with-
out being subjected to a process which is
lethal to pathogenic microorganisms and
pathogens.
The revised document encourages the
use of stabilization methods together
with additional precautions to minimise
pathogen, parasite and viral content of
sludge used In agriculture. Application
methods that prevent direct contact oi
the sludge with the portion of the crop
to be consumed are encouraged. The
Bulletin also recommends that projects
conform to any limitations for crop
quality (both human and animal feeds)
57421
established by FDA, USDA or State
agencies.
The Technical Bulletin exclusive of the
cited appendices Is printed below. A copy
of the complete Bulletin, including ap-
pendices, may be obtained by writing to
the General Services Administration
18FFS), Centralized Mailing Lists Serv-
ices, Bldg. 41, Denver Federal Center,
Denver, Colo. 80225. Please indicate the
title of the publication and the document
number: MCD-28
-------
37122
NOTICES
Appendices
Appendix I—"Preparation of Environmen-
tal Impact Statements," 40 CFR fl.
Appendix II—Groundwater extract from
"Alternative Waste Management Techniques
for Best Practicable Waste Treatment,"
EPA-430/9-75-013, October 1975. Supple-
ment (February 11,1978).
Appendix in—Guidelines for the land dis-
posal of solid wastes, 40 CFR 241.
Appendix IV—Standards of performance
for new stationary sources; Subpart 0—
Standards of Performance for Sewage Treat-
ment Plants, 40 CFR 61.150, and proposed
amendment.
Appendix V—"National Emissions Stand-
ards for Hazardous Air Pollutants," Subpart
E—National Emission Standard for Mercury,
40 CFR 61.50.
Appendix VI—Subchapter H—Ocean
Dumping. 40 CFR 220-229 (42 FR 2462-2490)
January 11, 1977.
Appendix VII—Sludge characteristics.
Appendix VIII—Considerations for apply-
ing sludge on agricultural land.
Appendix IX—FDA recommendations.
Appendix X—Sources of data and technical
assistance.
U.S. ENVIRONMENTAL PROTECTION
AGENCY
Technical Bulletin
MUNICIPAL SLUDGE MANAGEMENT:
ENVIRONMENTAL FACTORS
Foreword
Tills Technical Bulletin has been prepared
to assist Environmental Protection Agency
(EPA) Regional Administrators In evaluat-
ing grant applications for construction of
publicly owned treatment works under sec-
tion 203(a) of the Federal Water Pollution
Control Act as amended. It also provides
designers, municipal engineers and others
with Information on sludge management op-
tions.
The Bulletin was developed from the out-
puts of an Agency workgroup that attempted
to prepare an Agency policy statement and
guidelines on sludge, management. These
efforts were undertaken with substantial as-
sistance provided by Individuals from the
Council on Environmental Quality, the U.S.
Department of Agriculture, the Food and
Drug Administration, and the Department of
the Army.
The relative risks, benefits and costs of
various sludge management practices should
bo thoroughly considered when evaluating
potential Alternatives for specific projects.
While some degiee of risk is inherent In any
sludge management option, trade-offs among
risks, benefits and costs should help direct
projects toward the selection of both an en-
vironmentally nnd economically viable utili-
zation or disposal alternative.
The Bulletin addresses only factors impor-
tant to the environmental acceptability of
particular sludge management options and
does so in a general manner to allow a maxi-
mum ilcx'binty in its interpretation to meet
varying Regional needs and site specillc fac-
tors. It was not written as a regulatory docu-
ment or design manual. An environmental
assessment/environmental Impact statement
procedure Is used to determine the accepta-
bility ut a specific site. Tills procedure is
described in EPA's regulations for "Prepara-
tion of Environmental Impact Statements"
(40 CFR 0, Appendix I).
The cost-e:reetlveness of a proposed sludge
management option is of great Importance.
Information on the EPA cost-effectiveness
program is contained In Appendix I. Detailed
Information on prctreatraont guidelines nnd
regulation*, sample collection/preservation/
analysts procedures, as well as in-depth re-
views of the somewhat controversial poten-
tial environmental impacts of land applica-
tion are or will be covered in additional sup-
porting documents.
While the main body of the Bulletin in-
cludes considerable detailed information on
land application alternatives, it is not in-
tended to indicate a preference for this or
any other sludge management option. The
Bulletin emphasizes land application alter-
natives since no EPA guidance has been Is-
sued on this subject in the past. It Incorpo-
rates existing Agency guidance (and regula-
tions where applicable) on the other major
options—Incineration, landfill, and ocean
disposal—mainly by means of references and
appendices. It is Important that all of the
Available options must be considered, Includ-
ing incineration and landfllllng as well as
land application, to assure tliat the best al-
ternative, In terms of environmental accepta-
bility. cost-eflfectlveness, and benefit. Is
selected.
The requirements of the Act for higher
levels of wastewater treatment will result
in a substantial increase in the quantity of
sludge produced at publicly owned treat-
ment works. Disposition of these sludges la
not simple. Methods used In the past are
now restricted by specific laws or regulations,
or are subject to other constraints in view
of new information of environmental signifi-
cance.
EPA, continuing the work of its predeces-
sor agencies, has been developing environ-
mentally acceptable methods for the man-
agement of municipal sludge since the
enactment of the first Federal water pollu-
tion control laws. The initial phases of the
research program were concerned with the
characteristics and dewatering properties of
primary and secondary sludge because of the
need to dewater sludge before Its ultimate
disposal. The current program emphasis has
shifted toward development of improved
technology for returning the sludges to the
environment in an acceptable manner. Also,
the Agency Is requiring new measures, such
as source control and pretreatment, which
should reduce the heavy metals problem as-
sociated with sewage sludges.
The Agency has been aware of the growing
sludge disposal problem and the need to
verify and expand the technology that is now
being utilized. For example, a long-term land
application project has been directed at de-
termining the beneficial uses of sludge for
strip mine reclamation and for soil enrich-
ment In crop production. These studies have
carefully monitored the heavy metals up-
take In various forage nnd grain crops.
A large increa.se in the amount of sludge
generated has occurred with the use of
chemical precipitant^ for nutrient control
and the upgrading of secondary treatment
facilities. The Agency has been actively de-
veloping new technology for solving the
problem, Including recovery and reuse of the
chemical additives.
EPA will continue its broad based research
program for municipal wastewater sludge
management. Depending on the availability
of resources, we will concentrate on demon-
stration of new technologies which will re-
cycle or reuse resources, reduce energy re-
quirements, or recover residuals contained In
sludges.
For example, new technologies are being
examined to determine If there are cost-
effective methods for producing or recovering
marketable products in the processing of
sludge. These products may Include: metals
recovery, simple organic acids, fertilizer bases,
soil conditioners, the recovery of process heat,
fuels for energy production, and activated
carbon.
Health ellccts research will include investi-
gation Into land application, disinfection,
composing, nnd airborne contaminants from
incineration. The improved technology for
reducing or eliminating pollutant emissions
to the environment will be evaluated from
a health and ecological effects standpoint. It
Is also EPA's Intent to continue cooperative
agreements with local, State, and other Fed-
eral agencies.
The Technical Bulletin is based on current
knowledge. It will be modified from time to
time as additional information becomes
available from current and future research,
development, and demonstration projects as
outlined above. New research, development,
and demonstration projects which offer po-
tential for reducing costs or Improving tech-
nology are encouraged; this includes projects
that do not meet the specific recommenda-
tions of the bulletin, if there is reason to
believe that they will eventually be accept-
able. This Bulletin will also be supplemented
by a series of detailed technical reports on
topics of major concern. Thfe first: "Applica-
tion of Sewage Sludge to Cropland: Appraisal
of Potential Hazards of the Heavy Metals to
Plants and Animals" (EPA 430 9/76-013) is
already available. (A copy of this report can
be obtained by writing to the General Serv-
ices Administration (8 FFS), Centralized
Mailing Lists Services, Bldg. 41, Denver Fed-
eral Center, Denver, Colo. 80225. Please indi-
cate the title of the publication and
MCD-33.)
It is believed that the techniques discussed
in this bulletin can be environmentally
acceptable if properly designed, constructed
and managed. It must be well understood
that proper operation, maintenance, and
monitoring of any sludge management sys-
tem are essential. The operators of such
systems must clearly demonstrate the mana-
gerial capability and resources necessary to
achieve and maintain the expected perform-
ance on a continuing basis.
The guidance and recommendations In this
technical bulletin are subject to revision
based on future experience In the field. All
users are encouraged to submit suggested
revisions and information to the Director of
the Municipal Construction Division (WH-
547), Office of Water Program Operations,
U.S. Environmental Protection Agency, Wash-
ington, D.C. 20460.
Dated: October 28. 1977.
Thomas Jorling,
Assistant Administrator,
Water and Hazardous Materials.
U.S. ENVIRONMENTAL PROTECTION
AGENCY
Technical Bulletin
MUNICIPAL SLTJDGE MANAGEMENT:
ENVIRONMENTAL FACTORS
Chapter I
Introduction
1-1. The treatment of wastewaters for pol-
lutant removal produces not only relatively
clean water for discharge, but also a signifi-
cant quantity of residue material. For do-
mestic sewage, treated In publicly owned
plants, this residue Is essentially organic in
nature, although measurable quantities of
metals, minerals, and other compounds are
also invariably present. The residue may also
contain pathogenic organisms which survive
the wastewater treatment process. Where in-
dustrial wastewaters are treated together
with domestic sewage, the potential for Add!-
187
FEDE4AI REGISTER, VOL. 42, NO. 211—WEDNESDAY, NOVEMBER 1, 1977
-------
NOTICES
57423
tlonal materials of concern In the resulting
»)udj;o Is Increased.
1-2. Depending upon the composition of
the wastewater treatment plant sludge and
the quantity Involved, disposal of this resi-
due materia! ran have a significant impact
on the environment. It Is essential for -waste-
water treatment installations to consider the
proper disposal of treated wastewater, as well
as all byproducts and residues such as sludge.
The requirements of the Federal Water Pol-
lution Control Act. as amended /rub. L.
P2-500), emphasize the need for environmen-
tally sound means for sludge utilization or
disposal. The national requirement i;nder
Pub. t. 02-600 for secondary treatment, for
example, will result in production e.f greater
quantities of MudRc.
1-3. The disposition of wastewater treat-
ment plant sludges is a complex problem. It
can affect the quality of air, land, and water,
and requires considerations of human
health, animal health, plant growth, and
protection of ground and surface water from
pollution. EPA P.egional Administrators
must consider all these matters as they eval-
uate sludge management systems Included
In the design of publicly owned treatment
works for which construction grant appli-
cations are made. Despite the still limited
information available on the complex issue
of sludge utilisation and disposal, the need
lor definition, of a baseline of acceptable
sludge utilization or disposal practice re-
mains. such a baseline Is planned for devel-
opment under the authorities of the Re-
source Conservation and Recovery Act (Pub.
h. 84-660).
1-4. For the reasons cited above, a descrip-
tion of Items to consider when selecting a
specific sludge utilization or disposal alterna-
tive are presented in this document. This
technical bulletin provides general guidance
on the factors to lie considered in the envir-
onmental assessment and to be used In re-
viewing the facts of a particular situation.
For the utilization and disposal methods dis-
cussed no attempt is made to limit the im-
plementation or innovative technologies or
to Imply that any particular method Is opti-
mum for sludge utilization or disposal. The
final determination or acceptability should
be based on the environmental assessment
and. If necessary, the environmental impact
*>t ate merit Icr a specific project.
1-5. ilia bulletin is divided Into two dis-
tinct parts. The first part includes methods
in which the sludge is utilized as a resource
by land application. The second part de-
scribes those methods where a beneficial use
is not emphasized. System involving the re-
covery and utilization of energy or residuals
contained In sludges are not specifically cov-
ered in this document. Examples of such
systems are the production and utilization
of digester gas. incinerator yas or steam;
jecovcry and reuse of chemical conditioners;
recovery and sale of metals. However, the
environmental impacts associated with en-
ergy recovery systems would be similar to
those identified for the sludge Incineration
practices covered, in this bulletin.
1-6. Methods which may have future prom-
ise, but which have not been used in exist-
ing facilities, are not Included. As these de-
veloping technologies are demonstrated In
practical use. and as supporting Information
is obtained, they will be added in updates of
this bulletin. Because St Is the policy of EPA
to encourage and, where passible, assist in
the development ot new or advanced waste-
water treatment procedures, PederoT grant
funds may be awarded for the coivMruct'.on
of sludge titllfrarlon or disposal facilities not
addressed lu the bulletin, provided sufficient
information lt> presented by the grant appll-
tormnnee. Smaller plant* usually use stane"-
c«nt to determine that these tacilittes would
meet applicable1 (statutory and regulatory re-
quirements and would be environmentally
acceptable.
1-7. Proper operation, maintenance, and
monitoring of sludge utilization or disposal
prueticcn are essential to ensure that adverse
environmental effects do not result. Grant
applicants must demonstrate that they will
have managers, operators, and resources nec-
essary to achieve and maintain the required
performance on a continuing basis.
1-8. Elliclent energy utilization, conserva-
tion and recovery ere increasingly critical
topics. Pull consideration of these factors Is
necessary in the comparison of alternatives
In the selection of a sludge management
method.
Chapter II
Land Application ot Sludce
2-1. General. In order to contribute to
energy and resource conservation in waste-
water treatment facilities, sludge manage-
ment technologies which will beneficially
recycle or reuse sludges are actively encour-
aged. Because laud application oi sludge pro-
vides an excellent soil conditioner while con-
serving and recycling organic matter, nitro-
gen, phosphorus, and certain essential trace
elements, such utilization is encouraged
when it Is supported by an environmental
assessment.
Specifically, the use of stabilized sludge by
land application for enhancement of parks
and forests and reclamation of poor or dam-
aged terrain should be considered (or the
Utilisation of sludge. Application of stabi-
lized sludge to agricultural lands may also be
regarded as an environmentally acceptable
method of sludge utilization/disposal, but
must be examined closely In terms of pro-
tection of human health and future land
productivity. Thla Is due to the present lim-
ited Knowledge and uncertainties as to the
extent to which this practice could result
in the entry of toxic substances into the
human food chain and pose a health risk.
Regulations, criteria, and guidelines being
developed under the authorities of Pub. L.
02-600, TSCA, RCRA and other recent envi-
ronmental legislation may impact the future
acceptance oi various land application prac-
tices in various ways. The development of
criteria and guidelines under RCRA will de-
fine acceptable levels of pollutants for land
application of solid wastes. The implemen-
tation of the anticipated Agency pre treat-
ment strategy now under development will
substantially reduce contaminant concen-
trations of many municipal wastewater treat-
ment plant sludges (especially cadmium and
persistent organics). These efforts should
further enhance the acceptability of sludges
for agricultural uses. By this emphasis on
prevention ot futur« problems, we hope to
move toward a goal of waste recovery and
recycling.
The environmental concerns associated
with the beneficial utilization of sludge by
laud application practices are discussed at
length in the following paragraphs.
2-2. /n/ormation /or Project Evaluation.
2-2.1 Sludge characteristics. Sludge from
existing plants should be tested to deter-
mine nutrient values, heavy metals, and
other constituents which may be economi-
cally recycled or cause environmental dam-
age (Appendix VII). The type ot tests and
their scheduling is site specilic and depend-
ent on regulatory tequiremcnts. the Intended
use of the sludge, the contaminants likely to
be present., o.nd U\e Uiundtd vise oC the crop
if one is grown. Far uevr projects, it will be
accessory to estimate the tludge character-
istics; the application rates actually used on
• project should, however, be based upon ac-
tual sltidg© analyses. Some Indication may be
available from pilot plant studies, but such
studies ape rarely conducted at smaller
plants.
When sludges are to be applied to land, for
beneficial purposes, appropriate non-domes-
tic users of municipal wastewater treatment
works should be required to pretrcat their
wastewaters to minimize the presence of po-
tentially harmful heavy metals and other
sludge contaminants from Industrial sources.
Pretreatment requirements should meet Fed-
eral pretreatment standards. (Current pre-
treatment regulations are covered In 40 CFR
Parts 128 and 403. Also, sec "Federal Guide-
lines: State and Local Pretreatment Pro-
grams," EPA 430/D-76-017 a, b, c) However,
quantities of these ma.terta.ls also may be
present In wastewaters usually considered of
non-Industrial origin.
2-2.2 Site soils. Soils receiving sludge for
agricultural purposes, should be tested for
phosphorus, potassium, pH, and heavy
metals. There should also be knowledge of
the approximate soil cation exchange capac-
ity. Soils data and surveys are available
through the Soil Conservation Service. Soil
testing also enn be arranged through local
county agricultural extension agents, State
Agricultural Experiment Stations and private
laboratories. The number and extent of these
tests may be minimal for largely domestic
sludges where the application rates are low
(paragraphs 2-3.10 and 2-4), or where cer-
tain soli survey information already exists.
2-2.3 Groundwater. A review of existing
Information and/or an investigation of
groundwater conditions should be made for
sites where sludge is to be applied to the
land at greater than crop fertilizer rates
(paragraph 2-3.8). Attention should be paid
to the sites' geology and soli physical prop-
erties to avoid areas underlaid by highly
porous, fractured or statlfled formations. The
extent of the evaluation should be based on
the size of the project and the potential im-
pact on groundwater. Maintaining the pH
of the combined soil and sludge above 6.5
will help prevent solubilization and migra-
tion of most metal lona into the ground-
water.
2-3. General Requirements for Land Appli-
cation of Sludges.
2-3.1 Stabilization. Under most circum-
stances sludge should be stabilized (by
means of chemical, physical, thermal, or
biological treatment processes that result In
the significant reduction of odors, volatile
organics and pathogenic organics) before
land application to reduce public health
and to prevent nuisance odor conditions. The
stabilization method most frequently used
has been anaerobic digestion, but there are
numerous other methods producing compar-
able results. Discussions Involving stabilized
sludge in this document are based on a
product equivalent to. or better than anaero-
bically digested sludge.
Experience shows that consistent and effec-
tive control of odors Is a major factor In the
public attitudes toward sludge transport,
sludge storage and land application tech-
niques. The order conditions are closely re-
lated to anaerobic bacterial action on volatile
organic matter in both the liquid and solid
portions of the sludge. The degree of volatile
matter reduction achieved by anaerobic di-
gestion may vary greatly, depending on the
basic digestor design and the percentage ot
volatile solids in the raw sludge. Well de-
signed and carefully operated high rate an-
aerobic dlgestors can digest sludge to control
odors and reduce pathogen concentrations
when the sludge is digosUid for a least 10 day*
at 06* F. Such high rale digestion require*
close operational control for successful pcr-
188
FEDERAL MGISTH, V01. 47, NO. 811—WEDNESDAY, NOVfMBIi J, 1977
-------
37121
NOTICES
artl rute digestion. |Although digestion can
reduce the number of Influent fecal conforms
by !>7 percent or more, the remaining levels
of microorganisms may Mill have public
health significance |
Other methods to prepare Kludge for land
application may be used Some examples are:
composting of raw as well os digested sludge,
aerobic digestion, chemical treatment (lime
treatment, etc.). licnt stabilization, or heat
drying. In cases where stabilization is deter-
mined to bo necessary, the grant applicant
should show that the performance of the
alternative used for preparing the sludge Is
equivalent to anaerobic digestion 111 reducing
odor potential and volatile organlcs. .
Chemical treatment of sludges may only
provide temporary Inhibition of odors. In-
corporation of the bludgo into the soil is
recommended for those sludges which have
odor potential (paragraph 2-3.7).
At some plants, stabilized sludge Is spread
on drying beds or temporarily stored In prop-
erly designed sludge lagoons. These methods
decrease subsequent odor problems from
sludge applied to land since additional sta-
bilization occurs with time. Caution must be
exercised, however, to ensure that there are
no objectionable odors from the storage site.
2-3.2 Additionul pathogen reduction. Un-
der certain conditions (e.g., due to State
regulatory requirements controlling public
acces.5 or for projects Involving hospital
wastes), It may be necessary to achieve addi-
tional bacteria, parasite, and/or virus reduc-
tion or deactivation beyond that attained by
stabilization. The following methods liave
been used:
a. Pasteurization for 30 minutes at 70° C.
b. High pH treatment, typically with lime,
at a pH greater than 12 for 3 hours.
c. Long-term storage of liquid-digested
sludge for at least 60 days at 20° C or 120
days at 4° C.
d. Complete composting at temperatures
above 55* C as a result of oxidative bacterial
action and curing in a stockpile for at least
30 days.
e. Both gamma and high energy electron,
ionizing radiation under various application
procedures including combination treatment
with thermal conditioning and oxygenation.
2-3.3 Crops suitable for sludge applica-
tion. Crops vary In their reaction to sludge-
enriched soils. Most crops benefit from the
nutrients, such as nitrogen and phosphorus,
and organic matter present In the sludge.
However, some crop species may be adversely
affected by excess heavy metals or other con-
taminants. Additionally, the crop may take
up anil accumulate certain of these trace
elements, and possibly inhibit future use of
the harvested materials, particularly those In
the human food chain.
The degree of contaminant uptake by dif-
ferent crops and specific plant tissues Is
highly variable. For example, vegetative por-
tions or trasses generally contain higher
levels of heavy metals than the grain. Factors
such as soil type. pH, moisture, and organic
matter content, crop species and variety (and
for cadmium, the annual and accumulative
application rates) arc all Important and
ftlfect plant uptake rates of specific contam-
inants. Vegetables such as lettuce, spinach,
and chard, as well as tobacco are among the
highest accumulators of heavy metals such
as cadmium. USDA extension and research
offices and State Agricultural Experiment
Stations are available for additional guid-
ance on the selection of crops which can be
satisfactorily grown on sludge enriched soils
in specific geographic area1),
Forest sites and reclamation projects offer
special opportunities for '.icneticlal use of
sludge to Improve soil fertility and Increase
plant growth without significant risk to pub-
lic health. In these cases It will still be neces-
sary to comply with regulatory requirements
pertaining to Impacts on air. surface waters,
and groundwaters. In a manner similar to
that described for agricultural uses (para-
graph 2-3.B).
2-3.4 Public access should be controlled
In a positive manner where applications are
above rates for agricultural use. In such In-
stances. posted notices, and/or simple bar-
riers. fences, remoteness of the site should be
Adequate.
2-3.5 Groundwater protection. Projects
tor land application of sludges will be de-
signed so that the permanent groundwaters
(groundwater which Is not removed from the
ground by an underdraln system or other
mechanical means) In the zone of satura-
tion (where the water Is not held In the
ground by capillary tension) will be pro-
tected from pollution. Consideration should
be given to the extent ot the project, the
quality of the groundwaters, and the fact
that groundwater is typically used for drink-
ing water supply with little or no additional
treatment. Also, in some areas, groundwater
recharge of surface streams may be signifi-
cant. Specific groundwater criteria will be
developed under Pub. L. 94-580. Until such
criteria are developed under Pub. L. 94-580,
criteria contained In the EPA publication,
"Alternative Waste Management Techniques
for Best Practicable Waste Treatment," EPA
430/9-15-013 should be followed. An extract
on groundwater is reproduced as Appendix
II to this Bulletin.)
2-3.6 Controlling surface water runoff.
Sound engineering practice requires the con-
trol of surface runoff that may leave the site
as well as that which will enter the site from
contiguous properties. Controlled release of
runoff from sludge application areas and ef-
fective erosion control methods must be
practiced as necessary. Consideration should
also be given to materials which may leach
out of the sludge. Surface water criteria are
to be developed under Pub. L. 94-580.
2-3.7 Sludge application methods. Tech-
niques for applying liquid sludge to the land
include: tank truck, plowing. Injection, or
ridge and furrow spreading, Dewatered
sludge, or composted sludge, may also be
spread upon the land. If desired, the sludge
can be Incorporated Into the soil by plowing,
discing, or other similar methods. The use of
Incorporation and Injection methods Is en-
couraged as a means of Improving public ac-
ceptance of sludge application by decreasing
possible odor generation and unsightly de-
posits on crops.
Sprinkler application of digested sludge to
the land Is acceptable when the transport of
aerosols beyond the boundaries of the appli-
cation area is minimized. The use of low
pressure sprinklers, short risers, or remote-
ness of application sites Is suggested. When
sprinkling at low pressures. It is good engi-
neering practice to screen the sludge or
otherwise prevent nozzle plugging.
2-3.8 Application rates. The sludge ap-
plication rate per acre should be determined
in a manner to ensure that environmental
requirements are met. Nitrogenous sub-
stances usually limit annual application
rates. The rate of sludge application to land
should be consistent with the requirement to
prevent nitrate pollution of groundwater as
previously defined (paragraph 2-3 5). The
information required to establish the maxi-
mum sludge application rate based on plant
available nitrogen Includes: (1) total and
Inorganic nitrogen content of .sludge; (2) ni-
trogen, phosphorus, and potassium require-
ments of crop proposed; and (3) soil test for
available nitrogen, phosphorus and potas-
sium. Supplemental fertilizer, especially po-
tassium, may be needed If optimization of
crop production Is desired.
189
As n guide, sludge application rates should
provide total plant available nitrogen equiva-
lent to the nitrogen fertilizer requirement of
the crop grown, nllhougli some experience In
applying 1'., to 2 times the crops nitrogen
fertilizer requirement has not lead to tlie de-
velopment of groundwater problems. Plant
available nitrogen includes that mineralized
from the soil, the inorganic sludge nitrogen
(ammonium and nitrate), plus a mineraliza-
tion rate of 15 to 20 percent of sludge or-
ganic nitrogen (minerallzable organic nitro-
gen) for the first growing season following
application, and three percent of the residual
sludge organic nitrogen for three subsequent
growing seasons. Volatilization of ammonia
from surface applied sludge should be taken
Into account; experience has shown that
about 50 percent of this nitrogen may be lost
If the material is not Immediately Incorpo-
rated. Denitrificatlon may also be a factor
accounting for significant nitrogen losses un-
der certain conditions.
Sludge nitrogen mineralization, volatiliza-
tion, and denitrificatlon rates may vary con-
siderably for different climatic areas of the
Nation. USDA extension and research offices,
and State Agricultural Experiment Stations
should be contacted to obtain specific re-
gional information on nitrogen transforma-
tion rates, plant nitrogen, phosphorus and
potassium requirements and soil test infor-
mation for the local area.
An excess of certain salts, phosphorus ,
compounds, heavy metals, persistent organic
compounds, radionuclides and other mate-
rials In sludges may also limit application
rates. Each prospective land application site
should be assessed on an Individual basis,
with adequate consideration given to sludge
characteristics, soli characteristics, crops to
bo grown, and other factors such as surface
water and groundwater protection. Control
of the total and annual application rates
along with soil pH control and Intensive
monitoring programs are possible approaches
which can be used to avoid problems with
major contaminants of concern such as cad-
mium (section 2-4.2). A useful procedure for
calculating the rate of sludge application
to the land based on the nitrogen require-
ment of the crop grown and the nitrogen
and metal content of the sludge Is given In
Appendix VIII.
Sludge la generated continuously through-
out the year, but continuous field applica-
tion may not be possible. A mass balance Is
necessary to determine the amount of sludge
storage required during Intervals when the
sludge Is not applied to the land.
2-3.9 System operation. The grant ap-
plicant should show the capability to man-
age and operate the system. Operational as-
pects to be described in the operation and
maintenance manual Include the monitoring
plan, review of monitoring data, action to
be taken when monitoring Indicates a prob-
lem, and a commitment to uso expert guid-
ance when required. The operation and
maintenance manual should specifically in-
dicate what actions can be taken to either
upgrade the site to acceptable levels or dis-
continue its use If it is shown to be In vio-
lation of future requirements developed by
Federal or State regulatory agencies.
USDA extension and research programs are
also available to help develop and provide
site specific recommendations for the best
agricultural practices for use of municipal
sewage sludge by farmers on privately owned
lands. Extracts from such guidance that has
been developed for the North Central and
Western states Is provided in Appendix VIII.
Theso recommendations may Include sugges-
tions to help minlmlzo or eliminate soma
monitoring requirements on the farm while
protecting farmland for future agricultural
use. maintaining normal productivity, and
assuring continued farm Income.
FEDERAL REGISTER, VOL. 42, NO. 211—WEDNESDAY, NOVEMBER 3, 1977
-------
NOTICES
57125
2-3.10 A/o?iifi>nng. The grant applicant
xhould develop and Implement a plan for
adequate monitoring of each land applica-
tion site where the application rate may
Impose a significant nitrogen loading on
receiving ground or surface waters (para-
graph 2-3.8), where greater rates of metals
are applied than Indicated In section 2-4.2 or
where hazards are expected from other riludge
constituents such as pathogens are persistent
organlcs. Groundwater monitoring generally
should not be required where the application
rato Is based upon the nitrogen fertilizer
needs of the crop (paragraph 2-3.8).
It will always be necessary to know the
characteristics of sludge (paragraph 2-2.1)
to be applied. For new projects, It may be
necessary to monitor more frequently until
successful performance Is assured.
The monitoring plan should be specifically
designed for local conditions Including site
and sludge characteristics, proposed rate of
application, crops to be grown, si^e of the
project, etc. Where necessary, the plan should
consider monitoring heavy metals, persistent
org&nics, and pathogens, as well as nitrates
In groundwater, surface water, sludge and
soils. In addition to these recommendations
and local or State requirements, additional
monitoring requirements may be developed
\inder Pub. L. 94-580.
2-3.11 Surveillance oj operation and mon-
itoring. The operation and monitoring data
of the system must be periodically reviewed
by the responsible regulatory Agency or
agencies to ensure satisfactory performance.
Where there Is no local or state program for
tills purpose, an alternative Independent re-
view should be established. The grant ap-
plication should show the arrangements
made for surveillance.
Operational and monitoring data must be
available to authorized local, State, EPA and
other Federal agency representatives on
request.
2-4. Additional requirements for sludge
application to agricultural lands. In addition
to the loregoiug general requirements, the
application of sludge to agricultural lands
should be accomplished so as to ensure crop-
land resources are protected and harmful
contaminants are not accumulated In the
human food chain to create a risk to public
health. Review of projects which Include ap-
plication of sludge to agricultural lands
must be based on Informed Judgment and
fully consider the conditions specific to a
given site.
2-4.1 Research, development and demon-
stration projects. As Indicated earlier (para-
graph 1-6), it is the policy of EPA to en-
courage and. where possible, assist in the
development of new or advanced wastewater
treatment procedures, including sludge
processing, utilization and disposal prac-
tices. Therefore, proposals Involving the
demonstration of new and innovative tech-
nologies for sludge management should be
encouraged and expedited.
For such demonstration projects (e.g.,
reclamation of disturbed land with sludge),
where significant resources and manpower
are available for control and monitoring, the
recommendations within this Bulletin may
be cjcceedcd In an effort to investigate new
approaches for sludge management. An en-
vironmental assessment should verify that
this is the case for particular projects. Some
demonstration projects have the capability
(including In-hoiHC effort nnd consultant
assistance) to Intensively monitor and eval-
uate the project as it develops. Work on
these projects should be closely coordinated
Willi EPA, USDA nnd FDA. as well as State
and local authorities, to ensure satisfactory
results Including acceptable crop quality if
crops grown are to be marketed (as described
under section 2-4.2 B). Control criteria for (1) Annual cadmium loadings. The mnxl-
thene projects should be subject to contlnu- mum annual loading of cadmium that
lug modification us Information Is developed, should not he exceeded when applying
For these research, development and demon- sludge to agricultural imid depends upon
stratlon projects, the Agency review tihould stte conditions and management practices
assure that adequate resources are made employed. The annual cudmlum loadings
available for the evaluation of project per- that have been used successfully range from
formance, arrangements are established for less than 1 kg/ha up to 2 kg/ ha. While lower
surveillance of the project, and review of cadmium application rates are preferable,
project data is arranged for EPA and other In those cases where good sue conditions
interested agencies such as FDA, USDA, (I.e., high pH soils) and good management
State Agriculture and Health Departments, practices (i.e., soil pH control, monitoring.
2 4 2 Protection oj foocl products and selecting crop species nnd varieties that do
agricultural lands. Hegulaticms exist to con- not readily take up heavy metals, etc.) prc-
trol the level of mercury and persistent or- vail, annual loadings of 2 kg, ha have been
ganlc chemicals, such as pesticides and poly- employed. Because of the concern over po-
chlorinated biplienyls (PCB's), In certain tcntial health ellects from increased lnges-
components of the human food chain. How- tlon of cadmium In foods, it Is the intent
ever similar regulations have not been of EPA to move toward minimizing cadmium
established for all contaminants in foods, additions to cropland, Movement toward
When other regulations are implemented, lower cadmium additions will be retlected In
those sludge land application projects in- the criteria for land application of eoikj
volving the°production of crops in the human wastes to be developed and Issued under the
food chain will have to produce crops that Resource Conservation and Recovery Act ol
conform to these regulations. Contaminants 1970 (Pub. L. 94-68(11.
of particular concern in municipal sludge as (11) Soil/sfudyc pu control. The pH of the
related to the production of human food nnd soil/sludge mixture should bo controlled to
animal feed crops are cadmium and lead, as limit heavy metal uptake by plants. A pH
well as mercury arsenic, selenium, and per- of 6.5 or greater will minimize uptake of
slstent organics such as pesticides and PCB's. most heavy metals by most crops. As soil
A wide" variety of site specific conditions pH drops, heavy metal solubility In soil and
and management variables can affect the level availability to crops Is increased. Under some
of heavy metals entering crops. These vari- site specific conditions (as in many strlp-
ables have been and continue to be examined mined areas), availability of metals present
by many groups within FDA, USDA and State in the soli before sludge application can ac-
agencies It Is therefore recommended that ually be reduced by the application of
projects conform to limitations for crop sludge, because sludge addition in itself may
quality (human food or animal feed) estab- tend to raise soil pH of a highly acid soil
lished by these agencies. »»d because binding of the heavy metals
The available information concerning the into organic complexes may occur. But It Is
benefits and potential Impacts of applying rare that the final pH will be 6.5 or greater,
municipal sludge to agricultural land has Therefore, consideration should be given to
been reviewed and summarized elsewhere, including supplemental liming. Additional
This available information Indicates that guidance on tailoring soil/Mludge pH to spe-
many municipal sewage sludges can be ap- cific cropping systems may be gained from
plied to agricultural land when good agricul- local agricultural extension agents, State Ag-
tur&l management practices are employed, rlcultural Experiment Stations, USDA, etc.
Upper limits on annual heavy metals load- The pH level maintained should be designed
ings were suggested by various sources, based to meet the Intent of limiting heavy metal
upon the currently available data base, with solubility in soil and possible movement of
the anticipation that modifications will be heavy metals Into groundwater or Into crops
made in time based upon additional research, by uptake.
As discussed In section 2-1 elsewhere, regu- (ill) Total cumulative metal loadings. It
latlons criteria and guidelines being de- has been demonstrated that the following
veloped under authorities of Pub. L 92-500, total cumulative metal loadings from apply-
TSCA RCHA and other recent environmental lug municipal Sludge to agricultural land
legislation may Impact the future acceptance have not led to observed problems (whet)
of°various land application practices In varl- soli pH Is controlled):
ous ways. Pretreatment requirements and
solid waste disposal and utilization criteria
and guidelines currently, under development
will provide numerical limitations aimed at M'«><
reducing the levels of pollutants discharged
Into the environment. Including allowable
cadmium additions to agricultural soila
through solid waste (Including municipal
sludge) application. As a result of progres- pb
slvely imposing more stringent pretreatment zu
regulations on industrial wastes discharged Cu
into municipal systems, there should be a —
corresponding reduction of sludge borne
contaminants. ' .
Until rer»\ilatorv requirements are estab- * Cation t-xenunpo (njuirliv ((F.( ) (Mcrminrit on
lished, the^following guidance will allow tor 1,11 7 "'""ionium
the application of most sludges to agrlcul- ' '
tural land at crop nitrogen fertilizer rnte.-i Note.—It is ri*jignl/<'il iliiii soil ( f.< is noli lie oi,iy
, fuller iniporluiit In seiutin levels »( ineljl ;uIUii1,iiis |U
(paragraph i-J »). Willie its use man iml.-t is riemiitneiiilr.l iproviilino
A. Privately owned agriculttiral lands. The jjmt w,j| pii js uiso cotiiroll>-il) oilier factors such as suit
following guidance Is suggested for appllca- colloidal, oruBiiie ami seMiuiiniilo contents nmy'bo
tlon of municipal sludge to privately owned equally or more linporifini m limiting metal avail-
and managed cropland. These a- application rates
tloiu should protect private farmlands for A (uJful procedJe for calculating the rate
future Agricultural use, maintain their nor- Qf applications to the land (paragraph
mill productivity, and assure continued furm 2-3.8) based on the nitrogen and metal con-
income while minimizing monitoring re- teut ot sludge Is given tn Appendix Viu.
qulrrnient** to those normally used for as- in addition to the above, tho following
surlng good soil nun lavement; measure* are also suggested its possible means
Soil ration rtelian^ capacity
(mlllioqutval^nt por 100 *)•
0-5
5-15
>15
Amount 6/ metal (kilogram tier
hectare) *cr
500
i _'*>
AO
S
1,000
500
100
10
2,000
1.000
500
iJOO
FEDERAL REGISTER, VOL. 47, NO 21 I—WEDNESDAY, NOVEMBER 1, 1977
190
-------
57-126
NOTICES
to overcome problems of dealing with highly
contaminated sludges:
(v) Ratio of rnilmircrrt to fine fn sludgrs.
It la sunrcsted that In naturally oeld •oils
the ratio of rmimulm to zinc In sludge
rhould be conrlclrrrcl In addition to total nn-
irnnl rates of application. An Important
premise of Mils concept Is that with poor
management (eg, mpropcr crop selection
»nd low Boll pH), high enough zinc concen-
trations In sou to kill plants would result be-
fore cadmium could accumulate to levels In
foods considered hawirdon* to animals and
humans. The preferred practice suggested by
USDA and some researchers Is to apply
Kludges (to naturally acid soils) with a Cd/
Zn ^0.015 to these privately owned crop-
lands.
(vl) Prctrcatmmt programs. Implementa-
tion of a local pretrcatment program aimed
at reducing metaJs discharged Into the muni-
cipal system mnv help overcome the problems
that must be faced when considering the
application of highly contaminated sludges
to cropland.
(vll) Other technology. Use of other tech-
nology or management aimed at mlnlmtzlng
Impact upon soil, groundwater and surface
water, crops and/or the human food chain
such as the use of selective crop species and
varieties that minimize contaminant uptake
or application of sludge at less than crop
nitrogen needs. In any case, an expanded
monitoring program should be implemented
to assure control of pollutant migration and
quality ossurance of the project. The moni-
toring plan should be capable of noting
trends in crop productivity decline, contami-
nant uptake in final marketed products,
groundwater and surface water quality.
T$. Publicly controlled agricultural lands.
When municipal sludge Is applied to publicly
controlled (owned or leased) land and crops
are grown and harvested, higher rates of ap-
plication may be used if: (l) the use or these
rates ts acceptable to the responsible regula-
tory agency(s). and (2) a detailed monitor-
ing program is established to assure accept-
able crop quality and to provide close sur-
veillance of groundwater, surface water and
soils. If metal additions exceed those recom-
mended in (A) above, priority consideration
should be given to growing crops that are
not directly consumed by humans.
If human foods or animal feeds are grown
and harvested, higher rates of sludge appli-
cation may be acceptable if resulting levels
of cadmium in the crops or meats marketed
are comparable to those levels present In
similar crops or meats produced locally or as
established by FDA or other responsible
regulatory agencies. Kor example, strip mined
land which lias been reclaimed through high
rate sludge application may be used for pro-
ducing animal feeds; however, organs (e.g.,
kidneys and livers) which may accumulate
cadmium in animals fed such iceda should
not be sold for human consumption unless
their cadmium levels are comparable to those
found in animals produced locally.
C. Sites previously rIcdtratnl tor disposal.
The dedication of publicly controlled or
owned land lor high rate application (in-
cluding trenching) to allow inaxln.um uti-
lization of tl.c "dedicated siic" for the dis-
posal of municipal sludge liu* been practiced,
'i'hls Is a particularly uselul practice for
Kludges with high contamination levels or
•where very high loadings of sludge are de-
sired. Project monitoring is generally estab-
lished to assure close surveillance of ground-
water and surface water us discussed under
monitoring of landfills ^paragraph 3 1.7).
In cases wLt:re crops are grown following
the diupcu>&l of municipal sludge to *ucli
"dedicated sites." the crops are Kcneridly not
JxurvesU-d lor us« m lnu»au fouiU or aulnuU
feeds. However. If hnmnn foods or animal
feed crops are grown and harvested for fur-
ther ime, the marketing of crop* and meat*
produced should be handled to In (U) above.
In all cases where the application of mu-
nicipal sludge fo agricultural lauds and pro-
duction of human foods or animal feeds Is
proposed (whether on private land, publicly
controlled land, or "dedicated sites"), the
project should be coordinated at the State
and local levels to include the approval of
appropriate regulatory agencies.
Experience has shown that under special
conditions specific organisms may survive In
the soil for extended periods of time. There-
fore, unless pathogen reduction by methods
such as those listed in 2-3.3, or other suitable
measures have been employed to minimize
human exposure to such organisms In sludge,
additional precautions should be taken to
assure that the Impact of pathogenic bac-
teria, parasites and viruses in sludge used for
certain agricultural purposes, will be mini-
mal. Measures that have been used include
the following:
(a) Sludge-treated land should not be used
for growing human food crops to be eaten
raw If the edible portion of the plant is in
direct contact with the sludge or soils receiv-
ing sludges until one year after final sludge
application or longer If there are positive
indications of viable Ascaris ova. The avail-
able data base indicates that Ascaris ova
may remain viable in soil for three years or
longer.
(b) Use of application methods to prevent
direct contact of the sludge with the portion
of the crop to be consumed.
(c) Application to pasture land should be
done In a manner that avoids contact be-
tween the freshly applied sludge and grazing
animals raised mainly for milk. Forage and
pasture crops should not be consumed by
these animals when physically contaminated
by freshly applied sludge. Particular atten-
tion should be given to avoiding problems
with lead, cadmium, and PCB's contaminat-
ing the milk through direct Ingestion of con-
taminated sludge.
Although crop quality standards have not
been established to date for many contam-
inants, efforts arc underway by FDA to de-
velop such limitations. FDA has, however,
provided their recommendations to limit the
applications of sludge to land used to grow
human or animal foods (Appendix IX).
2-4.3 Project review. When the project
includes application to agricultural land,
especially if It Involves high application rates
(paragraph 2-3.8), or sludges with a high
concentration of contaminants (paragraphs
2-2.1 and 2-4.2 and Appendix VII), it may
fce necessary for tlie Regional Administrator
to consult with USDA and FDA as port of
the review process. This is especially true for
large agricultural projects. The review must
ensure that all applicable State and Federal
regulatory requirements are met. Technical
assistance during preparation of the fjrant
application and facility plan development is
available from these same agencies as well
as the appropriate State oflices.
2-4.4 Additional monitoring require-
ments. In addition to the monitoring re-
quirements presented in 2-3.10, baseline
sludge analysis should be conducted to serve
a.i a sound basis for setting of application
rates, selection of crops end determining
other monitoring requirements. Sludges
should be characterized in terms of the range
of their contaminant concentration includ-
ing heavy metals (stich as cadmium, zinc,
molybdenum, copper, nickel, lead, mercury,
arsenic and selenium) and persistent or-
ganic compounds (such as chlorinated pes-
ticides and PCB's). The sludges should also
be analyzed for parameters (such ns pH, ni-
trogen, ph(*phorus, potassium. »nd organic
content, ami possibly calcium and mag-
nesium).
Whore products *re grown tor human con-
sumption un soils, especially to which
greater levels of metal:: cir organlcs have
been applied than In this suggested guid-
ance, crop monitoring may be necessary for
suspected problem metals, organlcs, as well
as pathogens and parasites.
Records Including analyses should be kept
by the sludge generating municipality that
Include sludge quality, locations receiving
sludge, annual and total sludge application
rates, crops grown and soil pH.
The monitoring plan should be specifically
designed for local site conditions and take
into account applicable local. State and Fed-
eral regulatory requirements by Including
consideration of sludges, soils, crops, surface
water and groundwater quality.
2-4.5 Technical assistance and use of
other sludges. In recognition of the fact that
the guidance In the preceding paragraphs is
based on limited Information, technical as-
sistance for planning and designing land ap-
plication projects is available from several
sources. These Include EPA Headqnarters and
National Environmental Research Centers
(especially the Municipal Environmental Re-
search Laboratory In Cincinnati, Ohio), FDA,
USDA extension and research elements, State
Agricultural Experiment Stations, and other
sources (Appendix X).
In addition to municipal sludge, other
sludges (e.g., sludges produced by treatment
of food processing and brewery wastes) may
also be acceptable for land application under
carefully defined and controlled practices.
Because of the potential benefits to agricul-
ture from sludge application carried out
under sound agricultural management con-
ditions, full exploration of this and other
beneficial use options Is encouraged.
Chapter lit
Sludge Disposal Methods
3-1. Sanitary Landfill,
3-1.1 General. Sanitary landfill of sludge,
either separately or along with municipal
solid waste, Is acceptable when supported by
an environmental assessment.
3-1.2 Landfill procedures. A sanitary land-
fill accepting sludge should be designed and
operated In accordance with EPA Guidelines
for Land Disposal of Solid Wastes (40 CFR
241 Appeneilx III). Although It does not di-
rectly address landfilllng' of sewage sludge,
specific guidance for the proper design and
operation of a sanitary landfill are Included
in EPA's publication, "Sanitary Landfill De-
sign and Operation" (SW-85ts). Each site
should also comply with appropriate criteria
and guidelines being developed tinder Pub. L.
94-580 for landfilllng of sewage sludge. Pro-
posals involving research, development antl
demonstration of new and innovative land-
fill technologies should be encouraged rind
expedited (as discussed for land application
technologies In paragraph 2-4.1).
3-1.3 Odor Control. The sanitary landfill
must be operated so as to prevent nuisance
odors. Normally, the sludge must be sta-
bilized as described for land application (par-
agraph 2-3.1).
3-1.4 Precautions for protection of public
health, kludge stabilization anel the daily soil
cover are generally adequate protection from
direct health hazards. Additional precautions
may be necessary If the public has unre-
stricted access to the landfill site.
3-1.5 Groundwater protection. The
groundwater underlying the sanitary landfill
accepting sludge must be protected and the
sanitary landfill must meet applicable State
191
FEDERAL «EGISTE», VOU 4J, NO. 211—WEDNESDAY, NOVEMBER J, 1977
-------
NOTICES
57427
groundwater protection requirements. A geo-
hydrologlc assessment Hhould be undertaken
to determine the adequacy of the site prior
to use OB ft sludge landfill.
3-1.8 Operation. If a sanlt&ry landfill ac-
cepting sludgo Is not operated by the waste-
water treatment authority, a binding agree-
ment should be required between the waste-
water treatment authority and the operator
of the sanitary landfill. Such a binding agree-
ment should Include necessary assurances of
compliance with the requirements and rec-
ommendations of the EPA guidelines i40 CFR
241 Appendix III) and criteria being devel-
oped under Pub. L. 94-580.
3-1.7 Monitoring. A plan should be devel-
oped and implemented to provide for ade-
quate monitoring for each sanitary landfill
accepting sludge. This plan should be spe-
cifically designed to protect groundwater and
to ensure protection of surface waters, In the
following manner:
a. Groundwater observation wells tested for
heavy metals, persistent organlcs, pathogens,
and nitrates;
b. Where the surface water could be af-
fected by direct runoff or leachate from the
landfill receiving"sludge, surface water moni-
toring tested for Indicators (such as chemical
oxygen demands and total dissolved solids).
Additional testing may be necessary if It Is
determined that a poor quality leachate Is
entering surface waters.
3-2. Incineration.
3-2.1 General. Sludge Incineration and
disposal of the resulting ash Is an environ-
mentally acceptable method for the disposal
Of sludge when the environmental assess-
ment shows It to be appropriate. Incinera-
tion alone Is a volume reduction method
rather than ultimate disposal. Volume re-
duction, however, can bo an Important con-
sideration where land availability is a prob-
lem. After ineLneratlon, ash, either dry or In
scrubber water, remains to be disposed of to
the land. Ash disposal must be designed to
protect groundwater, to minimize dust pro-
duction, and to ensure protection of surface
waters. Each site should comply with the
criteria being developed unclcr Pub. L. 94-
6B0. Proposals Involving research, develop-
ment and demonstration of new and Innova-
tive incineration technologies should be en-
couraged and expedited (as discussed for
land application technologies in paragraph
2-4.1).
Due to the Increasing costs and limited
availability of energy resources, acceptability
and viability of Incineration processes is de-
pendent on the ability to recover or reclaim
energy from the process. Data available to
dato Indicate that fuel requirements of In-
cineration processes can be reduced by avail-
able energy recovery technologies. In some
cases, energy recovery can possibly even off-
set a substantial portion of the energy re-
quirements for the entire wastewater treat-
ment plant. While the basic concepts of
energy recovery from Incineration of wastes
are not new, the application of these con-
cepts to wastewater treatment and sludge
management facilities.generally requtre spe-
cial design considerations. New facilities can
be designed from the outset to Incorporate
the necessary equipment to utilize energy
recovered from Incineration processes. In
existing plants, retrofitting of equipment
capable of using recovered energy will be
necessary and could be considered to facili-
tate Incineration where cost-otfcctlve. When
-#nergy aspecta arc addressed In Incineration
system designs, they should evaluate future
as well as current energy conservation and
recovery considerations.
3-2.2 Industrial wastewaters. When in-
troduced Into a municipal wastewater treat-
ment works that practices sludge Incinera-
tion, Industrial wastewaters should be pre-
trcated to reduce to a minimum the amounts
of mercury, persistent organlcs. and radio-
active materials. In developing pretreatment
programs, special attention must be given
to the disposal of sludge created or materials
removed during the pretreatment process.
Disposal of these materials must be in an
environmentally sound manner.
3-2.3 Air Quality. The emissions from the
sludge Incinerator must not result in viola-
tion of ambient air quality standards and
must meet the EPA air pollution emission
standards of performance contained In the
New Source Performance Standards for
Sludge Incinerators (40 CFR 60.15, Appendix
IV). Sewage sludge incinerator discharges
into the atmosphere are not to exceed par-
ticulate matter at a rate In excess of 0.65
g./kg dry sludge input (1.30 lb/ton dry sludge
Input) and gases are hot to exhibit 20 per-
cent opacity or greater (except where the
presence of uncomblned water Is the only
reason for failure to meet the opacity re-
quirement). These emission limits are based
on a venturl scrubber, but any similar equip-
ment which meets the standard Is accept-
able. Sludge Incineration is known to va-
porize any meroury present In the incoming
sludge. EPA has published Amendments to
National Emission Standards which do limit
mercury emissions from the Incineration and
drying of wastewater treatment plant sludges
to a maximum of 3200 grama per 24 hour
period (40 CFR 61.52, Included as Appendix V
of this document).
3-2.4 Specific emissions. Tests have shown
that sludge incinerator emissions can con-
tain volatilized mercury as well as persistent
organic compounds, such as polychlorlnated
biphenyls, and particulates containing trace
amounts of metals such as lead and cad-
mium. The effect of these compounds which
are emitted from the Incinerator must be
assessed and the sludge should be tested to
determine the quantities of compounds pres-
ent. If the PCB's exceed 25 mg/kg dry
sludge, then special measures should be
taken to ensure at least 95 percent destruc-
tion of persistent organic compounds In In-
cineration. This could consist of testing the
performance of an incinerator design to
verify satisfactory performance or making
allowances in the design. Increased tem-
perature and residence time Increase the
assurance of destruction.
Regulations being developed under the
Toxic Substances Control Act (Pub. L, 94-
469) and the Resource Conservation and Re-
covery Act (Pub. L. 94-580) should be con-
sulted regarding current standards for dis-
posal of PCB containing substances. Pro-
posed rules on PCB's disposal under TSCA
(Pub. L. 64-469) were published In the Fed-
eral Register on May 24, 1977. Incineration
conditions specified therein for materials
(PCB mixtures, waste materials, and
sludges) that contain 500 ppm or greater of
PCB chemical substances (on a dry weight
basts) are 1200* C (100- C) for a two second
dwell time. While municipal sewage sludges
seldom have contamination levels over 600
ppm, final rules promulgated under Pub. L.
94-409 and those being developed under Pub.
L. 94-580 should be consulted regarding the
disposal of PCB containing municipal sew-
age sludge
3-2.5 Monitoring. A plan must be devel-
oped und Implemented to provide for ade-
quate monitoring of each sludgo Incin-
erator. The stack gas emissions from sludge
Incinerators must be monitored to ensure
compliance with 40 CFR GO.15 (Appendix
IV). In addition, mercury, either in the
sludge or in stack gas emissions, must be
periodically tested to demonstrate compli-
ance with 40 CFR 61 5 (Appendix V). Waste-
water from Industrial users must be moni-
tored if it is determined that such users
will be a significant source of mercury In the
municipal sludge. Additional monitoring for
organic pesticides, PCB's or heavy metals
other than mercury, may be necessary for
.specific projects.
3-3. Ocean Disposal.
3-3.1 General. Although approximately 15
percent of the current sludye volume pro-
duced In municipal treatment plants Is now
disposed of Into the oceans; the practice of
ocean dumping Is now being done only under
Interim ocean dumping permits, because the
sludges do not meet existing ocean dumping
criteria. Sludge dumping Is scheduled to be
phased out by the end of 1981.
The Federal Water Pollution Control Act
as amended (I'ub. L. 02-500), and the Marine
Protection, Research and Sanctuaries Act of
1972.(Pub. L. 92-532) have established a Fed-
eral program of marine pollution abatement
and control. EPA has Issued regulations and
criteria (40 CFR 220-227, Appendix VI) to
govern the disposal of wastes to the marine
environment. EPA controls such disposal by
a system of permits for the discharge, trans-
portation, and dumping of all waste mate-
rials Into the marine environment, except
for dredged material which Is controlled by
the Corps of Engineers, subject to EPA Cri-
teria. Ocean discharge of sludge through out-
falls is regulated by EPA under the National
Pollutant Discharge Elimination System
(NPDES).
3-3.2 Permits. Information available to
EPA from permit, applications to date indi-
cates that those sludges currently being
dumped exceed the criteria and are therefore
being dumped under Interim permits. One of
the conditions of these interim permits is the
requirement for an implementation plan to
either reduce the toxicity of the materials
to meet the criteria or find an alternative
method of disposal. Interim permits are
granted for one year only and the Issuance
of new Interim permits Is based on the prog-
ress demonstrated by the permittee on this
Implementation plan.
3-3.3 Dumping sites. Ocean disposal of
sewage sludge is strictly controlled by EPA.
Currently EPA will approve only existing
dumping sites presently in use for the dis-
posal of particular kinds of wnste, unless
there is extremely strong evidence In favor
of approval of a new location.
(FR Doc.77-31625 Filed 11-1-77:8:45 am]
FEDERAL REGISTER, VOL.
192
42, NO. 211—WEDNESDAY, NOVEMBER 2, 1977
-------
Appendix B
• Fishes of the Willamette and Columbia Rivers
• General Life Histories of Common Anadromous Species
• Common Wildlife Species of Northcentral Oregon
• Common Wildlife Species of the Northern Willamette Valley
• Rare, Endangered or Threatened Species Whose Distribution
Includes the Study Area
193
-------
Appendix B
GENERAL LIFE HISTORIES OF COMMON ANADHOMDUS SPECIES ENTERING THE COLOMBIA RIVER SYSTEM
SPECIES
TIME OF
ENTRY INTO
RIVER
TIME OF
SPAWNING
MAIN SPAWNING
AREAS
TIME SPENT
IN FRESHWATER
TIME OF PERK
DOWNSTREAM
MIGRATION OF
JUVENILES
Chinook
Spring
Surroer
Fall
Cbho
Sockeye
Chun
Steelhead1
Winter
Sinner
American Shad
Smelt
Green Sturgeon
Feb-May
May-Jul
Aug-Sep
Aug-Dec
Jun-Dec
ttov-Dec
Nov-Apr
Apr-Oct
May-Jun
Nov-Feb
Aug
Aug-Sep
Sep
Sep-Dec
Oct-Dec
Oct
NOv-Dec
Dec-Mar
Jan-Jul
Jun-Aug
Feb-Mar
Aug
Mountain streams in
Idaho, eastern Oregon
and Washington and
Willamette River
Salmon River and streams
o£ eastern Washington
Main Columbia and
lower Columbia
tributaries
Lower Columbia River
tributaries
Washington tributaries
Below Bonneville
Belcw Bonneville
Tributaries above
Bonneville
Willamette and
Columbia Rivers
Below Bonneville
Bays of lower
Colombia River
1 year
3-12 months
3 months
1 year
1 year
0
1-3 years
1-3 years
3 months
0
Feb-Jun
Jan-May
Apr-Jun
mr-Jun
Apr-Jun
(Janr-Mar)2
Apr-May
Aug-Sep
May-Oct
(Apr-May)
1 Downstream migration of juveniles occurs all year
2 Parentheses indicate estimate
SOURCE: Oregon Department of Fish and Wildlife (1958, 1971 and 1976)
-------
Appendix B
FISHES OF THE WILLAMETTE AND COLUMBIA RIVERS
Common Name
Scientific Name
Anadromous Game and Nongame Fish
Pacific lamprey
Green sturgeon
American shad
Chum salmon
Coho salmon
Sockeye salmon
Chinook salmon
Steelhead
Eulachon (smelt)
Lampetra tridentata
Acipenser medirostris
Alosa sapidissima
Oncorhynchus keta
Oncorhynchus kisutch
Oncorhynchus nerka
Oncorhynchus tshawytscha
Salmo gairdneri
Thaleichthys pacificus
Resident Game Fish
White sturgeon
Mountain whitefish
Cutthroat trout
Rainbow trout
Golden trout
Black bullhead
Yellow bullhead
Brown bullhead
Channel catfish
Pumpkinseed
Warmouth
Bluegill
Green sunfish
Smallmouth bass
Largemouth bass
White crappie
Black crappie
Yellow perch
Walleye
Resident Nongame Fish
Western brook lamprey
Chiselmouth
Carp
Goldfish
Oregon chub
Peamouth
Northern squawfish
Acipenser transmontanus
Prosopium williamsoni
Salmo clarkT
Salmo gairdneri
Salmo aquabonita
Ictalurus melas
Ictalurus natalis
Ictalurus nebulosus
Ictalurus punctatus
Lepomis gibbosus
Lepomis gulosus
Lepomis macrochirus
Lepomis cyanellus
Micropterus dolomieui
Micropterus salmoides
Pomoxis annularis
Pomoxis nigromaculatus
Perca Flavescens
Stizostedion vitreum
Lampetra richardson
Acrocheilus alutaceus
Cyprinus carpio
Carassius auratus
Hybopsis crameri
Mylocheilus caurinus
Ptychocheilus oregonensis
195
-------
Longnose dace
Leopard dace
Speckled dace
Redside shiner
Tench
Largescale sucker
Mountain sucker
Sand roller
Sculpin
Threespine stickleback
Rhinichthys cataractae
Rhinichthys falcatus
Rhinichthys osculusT"
Richardsonius balteatus
Tinea tinea
Catostomus macrocheilus
Catostomus platyrhynchus
Percopsis transmontanus
Cottus spp.
Gasterosteus aculeatus
SOURCE: Thompson, et al. (1966); W. Pitney (pers. comm., 1977)
196
-------
Appendix B
COMMON WILDLIFE SPECIES IN NORTHCENTRAL OREGON
Seasonal
Species
Scientific Name
Habitat Type
Status
Mammals
Coyote
Black-tailed jackrabbit
Deer mouse
Black-tailed deer
Birds
Western meadowlark
Horned lark
Long-billed curlew
Killdeer
Canada goose
Mallard
Reptiles and Amphibians
Gopher snake
Great basin spadefoot
Canis latrans
Lepus californicus
Peromyscus maniculatus
Odocoileus hemionus
Sturnella neglecta
Eremophila alpestris
Numenius americanus
Charadrius vociferus
Branta canadensis
Anas platyrhynchos
Pituophis melanoleucus
Scaphiopus intermontanus
Shrub-steppe
Shrub-steppe
Shrub-steppe
Shrub-steppe
Shrub-steppe
Shrub-steppe
Shrub-steppe
Shrub-steppe
Columbia River-
agriculture
Columbia River-
agriculture
Shrub-steppe
Shrub-steppe
R
R
R
R
R
R
SR
SK
WR
WR
R
P.
1 Seasonal Status
R = resident
SR summer resident
KR = winter resident
197
-------
Appendix 71
COMMON KIl-DLiri: SPECIIS IN THE NORTHERN WILLAMETTE VALLEY
Spec i c;9
Scientific None
Habitat Typo
Seasonal
Status
Mammals
Black-tailed deer
Opossum
Striped skunk
Raccoon
Muskrat
Nutria
Townsend1s vole
Black-tailed jackrabbit
Birds
Golden-crowned sparrow
Dark-eyed junco
Black-capped chickadee
Ruby-crowned kinglet
Scrub jay
Mourning dove
Cedar waxwing
Rufous-sided towhee
Bewick's wren
Willow flycatcher
Tree swallow
Osprey
Great blue heron
Western meadowlark
Ring-necked pleasant
Marsh hawk
Starling
Common crow
Valley guail
Reptiles and r.r.phibian~J
Valley garter snake
Ked-legged frog
Red-spotted yarlor briaku
Tacit if: tree frog
Odocoileus hemionur.
Dinelphis marpupialis
Mephitis mephitis
Procyon lotor
Ondatra zibethica
Hyocastor coypus
Kicrotus townsendi
Lepus ca3ifornicus
Zonotrichia atricapilla
Junco hyemalis
Parus atricapilla
Regulus calendula
Aphelocoma coerulescens
Zer.aida macroura
Bombycilla cedrorum
Pipilo erythrophthalnws
Thryoir.anes bewicki
L'npidonax traillii
Iridoprocne bicolor
Pandion haliaetus
Ardea herodius
Sturnella nog]ecta
Phasianus colchicus
Circus cyaneus
Sturnus vulgaris
Cox" ' us cor ax
Lophortyx ca) ifornicus
Thar.nophi s clegana
Ran a aurora
Tno_rinr.phi s f;i 1.1a 1 i:)
."Jiii regitla
Conifer and
hardwood forests
Hardwood forests
Hardwood forests
Riparian forests
Stream banks
Stream banks
Grassland
Grassland
Conifer and
hardwood forests
Conifer and
hardwood forests
Conifer and
hardwood forests
Conifer forests
Hardwood forests
Agriculture and
hardwood forests
Conifer and
hardwood forests
Riparian forests
Riparian forests
Riparian forests
Riparian forests
Riparian forests
Riparian forests
Grassland
Grassland-
agriculture
Grassland
Agriculture
Agriculture
Riparian and
hardwood forests
Conifer and
hardwood forests
Conifer and
hardwood forests
Riparian foreata
Riparian forests
R
R
R
R
R
R
R
SM, FM
WR
R
R
SR
SR
R
R
SR
SR
R
R
R
R
R
R
R
R
1 Staiuu:
K i'< MJ fl'-Jlt
.M' ¦¦ uif'.'nOT j"f :! i 'N ¦ i j L.
HP - 1J;I i . • l. rrsi
-------
Appendix B
FARE, ENDANGERED OR THREATENED WIIDLIFE SPECIES WHOSE DISTRIBUTION INCLUDES THE STUDY AREA
Cannon Name
Scientific Name
Oregon Distribution
Study Area Distribution
Status
Federal State
Columbia white-
tailed deer
American peregrine
falcon
Arctic peregrine
falcon
vo
VO
Aleutian Canada
goose
Northern bald
eagle
Western spotted
frog
Odocoileus virginianus
leucurus
Falco peregrinus
anatum
Falco peregrinus
tundrius
Branta canadensis
leucopareia
Haliaetus leucooephalus
alascanus
Rana pretiosa
Remnant populations,
lower Columbia River
floodplain; Roseburg
Nests eastern Oregon;
possibly western Oregon
Possible winter visitor
throughout Oregon
Winter migrant? occa-
sional visitor in
western Oregon
Nests throughout Oregon;
major concentrations in
Deschutes and Klamath
Counties
High cascades; eastern
Oregon; formerly state-
wide
Possible occurrence on
Columbia River islands
Possible use of study area
for foraging or winter
migration
Possible foraging flights
in winter over study area
Possible visitor at
Columbia River and
Willamette Valley refuges
Possible use of study area
for foraging or winter
migration
Possible occurrence in
Columbia and Willamette
River basins
E
SOURCE: Oregon State Department of Fish and Wildlife (1977)
-------
Appendix C
Morrow County Population Projections
Based on ECOAC Scenarios
200
-------
Appendix C
East Central Oregon Association of Counties - 1977
Scenario A
1. Agriculture - Continued growth in new acreage under irrigation at or near
1970-75 rates until irrigable land (U.S. Bureau of Reclamation data) is
consumed. No housing pressure on irrigable land. Agricultural productivity
high (no shortages of petroleum-based products); employment growing
proportional to new acreage. No shortage of water.
2- Food Processing and Light Industry - Continued growth in food processing
and light industry at or near 1970-75 levels.
3. Energy-generation Facilities and Construction - No new electrical-generating
plants in area after completion of Carty facility. Construction of second
powerhouse at McNary Dam and of 1-82 Freeway in Umatilla County to begin in
1980. (Freeway may not be constructed until 1983. Presently uncertain).
A. Other Sectors - Continuation of trends in other sectors of economy at or
near 1970-75 rates, including forestry and wood products.
5. Unemployment - See page 202.
6. Heavy Industry - No new heavy industry in area during forecast interval.
Alumax aluminum reduction plant not built, nor Pebble Springs Nuclear Plant
(as in 3).
Scenario B
1. Same as A.
2. Same as A.
3. In addition to A, construction of two nuclear reactors at Pebble Springs
site in Gilliam County beginning in second quarter of 1978. Construction
of second plant to begin in 1982. (See page 203).
A. Same as A.
5. Differing as shown on page 202.
6. Construction of Alumax plant to begin in second quarter of 1978. New road
north from lone constructed after 1980.
Scenario C *
1. Same as A and B.
2. Same as A and B.
3. Assumes continued construction of all energy-generating facilities currently
projected by Portland General Electric in Morrow and Gilliam Counties and
by Pacific Power and Light at Roosevelt, Washington. (See page 202) .
A. Same as A and B.
* Note: Scenario B and C are identical for 1980.
2ai
-------
CIVILIAN LABOR FORCE PROJECTIONS
Morrow and Umatilla Counties, 1975 - 2000
COUNTY/SCENARIO 1975 1980 1985 1990 1995 2000
UMATILLA - A
Civilian Labor Force*
Total Employment
Unemployed
Percent
21,470
19,950
1,520
7.1
25,600
23,940
1,660
6.5
28,220
26,530
1,690
6.0
30,160
28,410
1,750
5.8
32,010
30,250
1,760
5.3
33,900
32,200
1,700
5.0
UMATILLA - B
Civilian Labor Force
Total Employment
Unemployed
Percent
21,470
19,950
1,520
7.1
27,700
25,980
1,720
6.2
30,030
28,290
1,740
5.8
32,150
30,380
1,770
5.5
34,820
32,970
1,850
5.3
36,540
34,710
1,830
5.0
UMATILLA - C
Civilian Labor Force
Total Employment
Unemployed
Percent
21,470
19,950
1,520
7.1
27,700
25,980
1,720
6.2
31,800
30,050
1,750
5.5
33,990
32,190
1 ,800
5.3
36,430
34,610
1,820
5.0
39,200
37,320
1,880
4.8
MORROW - A
Civilian Labor Force
Total Employment
Unemployed
Percent
3,310
3,130
180
5.4
4,410
4,140
270
6.2
5,080
4,790
290
5.8
5,240
4,950
290
5.5
5,400
5,110
290
5.3
5,610
5,330
280
5.0
MORROW - B
Civilian Labor Force
Total Employment
Unemployed
Percent
3,310
3,130
180
5.4
5,760
5,410
350
6.0
6,050
5,720
330
5.5
6,100
5,760
340
5.5
6,290
5,960
330
5.3
6,570
6,240
330
5.0
MORROW - C
Civilian Labor Force
Total Employment
Unemployed
Percent
3,310
3,130
180
5.4
5,760
5,410
350
6.0
6,090
5,760
330
5.5
6,610
6,260
350
5.3
7,070
6,720
350
5.0
7,530
7,170
360
4.8
* By place of residence consistent with present Oregon Employment Division Benchmarks.
202
-------
Portland General Electric, Alumax Pacific Corporation,
and Federal Construction Projects
Morrow, Gilliam, and Umatil la Counties
1975 - 1995 Yearly Average Employment
Project 1975 1980 1985 1990 1995
Portland General Electric
20
1,350
1,600
1,700
1,870
Carty
20
330
100
100
100
Construction
Operational
(20)
(230)
(100)
(100)
(100)
(100)
Pebble Springs I *
0
1,020
240
170
170
Construction
Operational
—
(1 ,020)
(90)
(150)
(170)
(170)
Pebble Springs II +
0
0
1,260
170
170
Constructi on
Operational
—
—
(1,260)
(170)
(170)
Other (post '85) ++
0
0
0
1,550
1,720
Construction
Operational
—
—
—
(1,400)
(150)
(1 ,400)
(320)
Alumax *
0
1,750
800
800
800
Construction
Operational
—
(1,130)
(620)
(800)
(800)
(800)
Federal
0
500
40
40
40
1-82 **
0
250
20
20
20
Construction
maintenance &
patrol
_ _
(250)
(20)
(20)
(20)
McNary Powerhouse **
0
250
20
20
20
Constructi on
Operational
—
(250)
(20)
(20)
(20)
* Assuming construction to begin, second quarter, 1978.
** Assuming construction to begin, second quarter, 1980.
+ Assuming construction to begin, second quarter, 1982.
++ Assuming construction to begin on third and fourth nuclear plants in area,
second quarters of 1986 and 1990.
-------
Appendix D
Emission Rates
Diesel-Powered Trucks
Diesel-Powered Vessels
204
-------
Appendix D
HEAVY DUTY DIESEL EMISSION RATES
Speed-Corrected Emission Factors
Speed (mph) (grams per mile, except as noted)
HC
CO
N0X
Idle
0.40*
0.66*
1.00
20 mph
4.5
27 .0
20.1
25 mph
3.90
21. 56
18.79
30 mph
3.47
17 .74
18.37
3 5 mph
3.16
15.04
18.79
4 0 mph
2.96
13 .14
20.10
45 mph
2.83
11.83
22.49
50 mph
2.78
10.98
26.33
55 mph
2.81
10.49
32.24
* grams per minute
No vehicle load/engine power corrections made.
1 gram = 2.204 6 x 10"^ pounds
SOURCE: Calculated from data and procedures
presented in U. S. EPA, 1977.
(Mobile Source Emission Factors,
Interim Document, June 1977).
205
-------
Appendix D
DIESEL VESSEL EMISSIONS FACTORS BY OPERATING MODEa
EMISSION FACTOR RATING: C
Emissions'3
Nitrogen oxides
Carbon monoxide
Hydrocarbons
(NOx asN02)
lb/103
kg/103
lb/103
kg/103
lb/103
kg/103
Horsepower
Mode
gal
liter
gal
liter
gal
liter
200
Idle
210.3
25.2
391.2
46.9
6.4
0.8
Slow
145.4
17.4
103.2
12.4
207.8
25.0
Cruise
126.3
15.1
170.2
20.4
422.9
50.7
Full
142.1
17.0
60.0
7.2
255.0
30.6
300
Slow
59.0
7.1
56.7
6.8
337.5
40.4
Cruise
47.3
5.7
51.1
6.1
389.3
46.7
Full
58.5
7.0
21.0
2.5
275.1
33.0
500
Idle
282.5
33.8
118.1
14.1
99.4
11.9
Cruise
99.7
11.9
44.5
5.3
338.6
40.6
Full
84.2
10.1
22.8
2.7
269.2
32.3
600
Idle
171.7
20.6
68.0
8.2
307.1
36.8
Slow
50.8
6.1
16.6
2.0
251.5
30.1
Cruise
77.6
9.3
24.1
2.9
349.2
41.8
700
Idle
293.2
35.1
95.8
11.5
246.0
29.5
Cruise
36.0
4.3
8.8
1.1
452.8
54.2
900
Idle
223.7
26.8
249.1
29.8
107.5
12.9
2/3
62.2
7.5
16.8
2.0
167.2
20.0
Cruise
80.9
9.7
17.1
2.1
360.0
43.1
1550
Idle
12.2
1.5
—
-
39.9
4.8
Cruise
3.3
0.4
0.64
0.1
36.2
4.3
Full
7.0
0.8
1.64
0.2
37.4
4.5
1580
Slow
122.4
14.7
—
-
371.3
44.5
Cruise
44.6
5.3
-
-
623.1
74.6
Full
237.7
28.5
16.8
2.0
472.0
5.7
2500
Slow
59.8
7.2
22.6
2.7
419.6
50.3
2/3
126.5
15.2
14.7
1.8
326.2
39.1
Cruise
78.3
9.4
16.8
2.0
391.7
46.9
Full
95.9
11.5
21.3
2.6
399.6
47.9
3600
Slow
148.5
17.8
60.0
7.2
367.0
44.0
2/3
28.1
3.4
25.4
3.0
358.6
43.0
Cruise
41.4
5.0
32.8
4.0
339.6
40.7
Full
62.4
7.5
29.5
3.5
307.0
36.8
aReference 2.
Particulate and sulfur oxides data are not available.
SOURCE: U. S. EPA - Compilation of air
emission factors. AP-42, Part
edition.
206
pollutant
A, second
-------
Appendix E
Archeological Survey
207
-------
Department of
Anthropology
9 February
r
~\
Oregon
, .Stare ..
University
lWfi
Corvallis, Oregon 97331 (503) 754-4515
TO: Jonathan Ives
Jones and Stokes Associates
FROM: Glenn Hartmann
SUBJECT: Archaeological Surveys for the sludge disposal project,
City of Portland.
Archaeological fieldwork has recently been completed for pipelines and
dock sites outlined in your letter of 18 January. As we discussed
on the phone, survey of disposal areas awaits further decisions for
selection of the final disposal site.
No prehistoric archaeological sites were discovered during survey.
Sites which existed at the mouths of Threemile and Sixmile Canyons were
destroyed during reservoir construction and/or inundated by the raising
of Lake Umatilla. The surface of the Multnomah County dock site was
quite disturbed and covered with dredge spoils. The pipeline route in
Portland was likewise disturbed.
Reconnaissance of pipeline alternatives in Morrow County was somewhat
hampered as I had difficulty locating the precise pipeline routes.
However, there are no surface indicators of archaeological sites in
any of the pipeline corridors. There is one area which has some
potential for containing a buried site. This is the sheep camp in
SE 1/4 Section 23, Township 4N, Range 23E. Survey of the bench on
which the camp is located was all but impossible due to pens full of
lambing sheep, hostile dogs, and less than hospitable shepherds. I
spoke with one individual who said he'd never found any archaeological
materials, but that is no guarantee that a site does not exist there.
I would say that chances for a buried site there are possible, but remote.
Several stone "cairns" were noted in the course of survey, but none
seem to be in the proposed pipeline routes. Interpretation of these
phenomena has been a long-standing problem in the Northwest as it
is difficult to ascertain whether they are prehistoric or historic
structures. Based on previous experience I would say that the cairns
I observed were historic. They are not eligible for the National
Regi ster.
I also noted the remains of an old cabin in Section 28 at a considerable
distance from the pipeline route. The remains of stone footings,
208
-------
page two
9 February 1978
rusted cans, broken pottery and cast iron stove parts were evident.
This site will not be impacted by the present project. It is also
not of National Register quality.
The State Historic Preservation Office in Salem was consulted. As
previously mentioned, there were archaeological sites along the
Columbia River in Morrow County presumable at the canyon mouths.
The sites are now inundated or destroyed as a result of reservoir
construction. There are no National Register Sites in the project
area.
I briefly looked over the alternative disposal sites in Morrow County.
Based on that quick look and on topographic map examination it appears
that there is equally low site likelihood for the three disposal
areas. Still, there should be an archaeological survey of the final
site chosen as it is possible that archaeological resources are
located there.
The final report for this survey is now being prepared. If I can be
of further assistance in the interim, please call me.
Sincerely,
Glenn D. Hartmarn
Contract Archaeologist
209
-------
Appendix F
Detailed Cost Analysis for Alternatives
A-l, C-l, D-l, D-2 and No Action
210
-------
Construction cost estimates in this Appendix are based
upon conceptual designs for each of the alternatives. In
most cases, the costs are identical to those presented in
the City of Portland's Facility Plan, although some changes
were made on the basis of more recent data and the author's
experience in cost estimating and actual plant construction
bids. All construction costs are presented in December 1977
dollars, which is equivalent to an EPA Construction Cost
Index of 152 for the City of Portland.
Operation and maintenance cost estimates were made on
the basis of labor, electrical, fuel and material requirements.
Unit costs for labor, electrical and fuel requirements were:
Labor - $11.00/hr (average loaded rate)
Energy - $ 0.01/kwh (electricity, including load factor)
Fuel - $ 1.90/tcf (natural gas)
Material requirements were adjusted to December 1977
costs using a Wholesale Price Index for the City of Portland
of 11.98.
Sewerage system construction costs are directly dependent
upon material and labor costs as well as the climate for
competitive bidding at the time of advertising for proposals
from contractors. The projection of future costs is also
speculative due to the widely fluctuating inflation rates
of recent years. However, an acceptable inflation rate is
about 8 percent for construction and 6 percent for operation
and maintenance, based on various published forecasts. The
projection of future construction costs can therefore be
estimated by using the compound interest formula below.
Future cost = present cost x (1 + i)n
where n = number of years from December 1977 to
mid-point of construction
i = inflation rate assumed as a decimal
The cost analysis for each Alternative includes a worth
analysis, as mandated by federal regulations, as well as an
analysis of the annual cost to the community. The interest
rate to be used for the present worth analysis is specified
by the Water Resources Council and is 6 5/8 percent for
fiscal year 1978. For local costs, an interest rate of 7
percent is assumed since it is more appropriate for financing
by the City of Portland.
211
-------
The present worth value may be defined as the amount that
must be invested at a specified interest rate, at the start
of a project, to provide funds sufficient to meet annual
expenditures during the life of the project. The resulting
value provides a "one number" way of comparing the total
costs of all the alternatives.
Alternative A-l - Land Application in Eastern Oregon.
The total capital costs for Alternative A-l are $16,329,000
and the average annual operation and maintenance costs are
$1,362,200 as shown in Table F-l. On the basis of these
costs, total annual cost would be $2,903/400, or $99.40
per ton of dry sludge. However, on a local share cost
basis, the average unit cost per ton of dry sludge solids
is only $59.90 per ton, as shown in Table F-2. Table
F-3 presents the costs for each year between 197 8 and 2000.
The total present worth of the costs over this period is
$27,598,400.
Alternative C-l - Sludge Drying System. The total
capital costs for Alternative C-l are $15,015,000 and the
average annual operation and maintenance costs are $1,507,000
as shown in Table F-4. Based on these costs, total annual
cost would be $2,924,400 or $100.20 per ton of dry sludge.
However, on a local share cost basis, the average unit cost
per ton of dry sludge solids is only $58.80 per ton, as
shown in Table F-5. Table F-6 presents costs for each
year between 197 8 and 2000. The total present worth of the
costs over this period is $26,573,800.
Alternative D-l and D-2. The total capital costs for
Alternatives D-l and D-2 are $17,272,600 and $21,117,400,
respectively, and the average annual operation and maintenance
costs are $1,857,300 and $2,104,500, respectively, as shown
in Table F-9. Based on these costs, total annual cost would
be $3,487,700 for D-l and $4,097,800 for D-2 or $119.40
and $140.30, respectively, per ton of dry sludge. However,
on a local share cost basis, the average unit cost per ton
of dry sludge solids for D-l is only $82.30 per ton, as
shown in Table F-10. Table F-10 presents the costs for each
year between 1978 and 2000 for D-l. Total present worth of the
costs over this period is $30,507,100.
No-Action Alternative. Capital cost for no action
would only be for cleaning of the Triangle Lake Lagoon, or
$1,816,000. The annual operation and maintenance cost,
based on 55 tons of sludge per day, would be $404,900. The
total annual cost would be $576,300, which is equivalent to
$28.70 per ton, or a local share cost of $22.30 per ton.
212
-------
Table F-l
ESTIMATED TOTAL ANNUAL COSTS
Alternative
A-l - Land Application in
Eastern Oregon
Amortized
Total
Capital
Capital
O&M
Annual
Costs
Costs
Costs
Costs
Process
($1,0001s)
($1,000's)
($1,0001s)
($1, 0001 s)
Digestion
8,100.0
764.6
259.0
1,023.6
Lagoon Storage
1,816.0
171.4
57.0
228.4
Barge Loading
Dock
780.0
73.6
76. 0
149.6
Transportation &
Land Application
2,775.0
261.9
983. 0
1,244.9
Electric Generating
Equipment
2,188.0
206.5
96.0
302.5
Credit for
Digester Gas
-
-
(157.8)
(157.8)
Sludge Pumping &
Forcemain
670.0
63.5
49.0
112.2
TOTALS
16,329.0
1,541.2
1,362.2
2,903.4l
1 Average cost per ton is $99.4
213
-------
Table F-2
ESTIMATED LOCAL ANNUAL COSTS
Alternative A-l - Land Application in Eastern Oregon
Year
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Capital
Costs
($1,OOP's)
385.3
v
385.3
O&M
Costs
($1,OOP's)
1,362.2
Annual
Costs1
($1,000's)
1,74,7.5
1,362.2
v
1,747.5
Average unit cost per ton is $59.9
214
-------
Table F-3
PRESENT WORTH COSTS
Alternative A-l - Land Application in Eastern Oregon
Year
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Capital
Costs
($1, 000's)
1,306.3
8,164.5
6,858.2
O&M
Costs
($1,000's)
1,362.2
Annual
Costs
($1,000* s)
1,306.3
8,164.5
6,858.2
1,362.2
-5,443.0
v
1,362.2
1,362.2
-4,080.8
P.W. Capital = $12,736,900; P.W. O&M = $14,861,500
Total P.W. = $27,598,400
215
-------
Table F-4
ESTIMATED TOTAL ANNUAL COSTS
Total
Annual
Costs
($1,OOP's)
1,023.6
140.5
293.0
1,730.3
(30.0)
(263.0)
2,924. 41' 2
1 Average cost per ton is $100.2
2 Costs for disposal and/or sale of product are not included
216
Alternative C-l - B.E.S.T. Sludge Drying System
Process
Digestion
Lagoon Storage
Vacuum Filtration
B.E.S.T. Drying
System
Credit for
Reclaimed Oil
Credit for
Digester Gas
Capital
Costs
($l,000ls)
8,100.0
1,488.5
5,427.0
Amortized
Capital
Costs
($1,000's)
764.6
140.5
512.3
O&M
Costs
($1,OOP's)
259.0
293.0
1,218.0
(30.0)
(263.0)
TOTALS
15,015.5
1,417.4
1,507.0
-------
Table F-5
ESTIMATED LOCAL ANNUAL COSTS
Alternative C-l - B.E.S.T. Sludge Drying System
Year
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Capital
Costs
($1y 0001s)
354. 4
O&M
Costs
($1,OOP's)
1,507.0
Annual
Costs1
($l/000,s)
1,861.4
V
354.4
V
1,507.0
V
1,861.4
1 Average unit cost per ton is $63.75.
217
-------
Table F-6
ESTIMATED TOTAL ANNUAL COSTS
Carver-Greenfield Process Alternative
Process
Digestion
Lagoon Storage
Centrifuging
Carver-Greenf ield
Process
Electrical
Generating
Equipment
Credit for
Digester
TOTALS
Capital
Costs
($1,OOP's)
8,100.0
1,488.5
6,333.0
2,188.0
18,109.5
Amortized
Capital
Costs
($1,OOP's)
764.6
140.5
597 .8
206.5
1,709.4
O&M
Costs
($1,OOP's)
259.0
675.2
96.0
(263.0)
767 .2
Total
Annua1
Costs
($1,0001s)
1,023.6
140.5
1,273.0
302.5
(263.0)
2,476.6'
1# 2
1 Costs for disposal and/or sale of product are not included
2 Average cost per ton is $84.8
218
-------
Table F-7
ESTIMATED LOCAL ANNUAL COSTS
Carver-Greenfield Process Alternative
Year
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Capital
Costs
($1,000's)
427.3
O&M
Costs
($1/000's)
767 .2
427.3
v
767 .2
Annual
Costs1
($1/0001s)
1,194.5
1,194.5
1 Average unit cost per ton is $40.90
219
-------
Table F-8
PRESENT WORTH COST
Alternative C-l - Sludge Drying System
Year
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Capital
Costs
($1/0001s)
1,201.2
7,507.7
6,306.5
O&M
Costs
($1,OOP's)
1,507.0
Annual
Costs
($1,OOP's)
1,201.2
7,507.7
6,3P6.5
1,5P7.0
-5,0P5. 2
1,507.0
1,507.0
¦3,498.2
P.W. Capital = $11,712,300; P.W. O&M = $16,441,300
Total P.W. = $28,153,600
220
-------
Table F-9
ESTIMATED TOTAL ANNUAL COSTS
Alternative D-l and D-2
Land Application in Willamette Valley
Amortized
Total
Capital
Capital
O&M
Annual
Costs
Costs
Costs
Costs
Process
($1,000's)
($1,000's)
($1,000 1 s)
($l,000's)
Digestion
8,990.0
848 .6
287.5
1,136.1
Lagoon Storage
1,816.0
171.4
57.0
228. 4
Lagoon Storage
at Destination
2,443.4
230.6
93.6
324.2
Land Application
419.1
39.6
235. 0
274 .6
Electrical Generating
Equipment
2,188.0
206.5
96.0
302.5
Credit for
Digestor Gas
-
-
(157.8)
(157.8)
TRUCK TRANSPORT
SYSTEM 3
Truck Transport
1,416.1
133 .7
1,246.0
1,379.7
BARGE TRANSPORT
SYSTEM 3
Pumping & F/M
670.0
63.2
49.0
112.2
Barge Loading
Docks (2)
1,093.5
103.2
88.4
191.6
Barge Transport
1,714.0
161.8
946.4
1,108.2
Unloading Dock
435.0
41.1
46.8
87.9
Pumping to
Storage Lagoon
930.0
87 .8
35.0
122.8
Truck Transport
418.4
39.5
327.6
367.1
TOTAL WITH
TRUCK TRANSPORT
17,272.6
1,630.4
1,857.3
3,487.7*
TOTAL WITH
BARGE TRANSPORT
21,117.4
1,993.3
2,104.5
4,097 .8 2
1 Average cost per ton is $119.4
2 Average cost per ton is $14 0.3
3 Costs are based on minimum distances computed from the Columbia Boulevard
STP to the northwesternmost portion of the proposed sludge application
area. Transportation costs would be greater for sludge spreading farther-
south.
221
-------
Table F-10
ESTIMATED LOCAL ANNUAL COSTS
Alternative D-l - Land Application in Willamette Valley
Year
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Capital
Costs
($1,OOP's)
408.1
408.1
753.5
v
753.5
O&M
Costs
($1,OOP's)
1,372.7
1,372.7
1,857.3
v
1,857 .3
Annual
Costs1
($1,POP's)
1,780.8
1,780.8
2,610.8
v
2,610.8
1 Average unit cost per ton is $82.3
222
-------
Table F-ll
PRESENT WORTH COSTS
Alternative D-l - Land Application in Willamette Valley
Year
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Capital
Costs
($1/000's)
1/381.8
8,636.3
7,254.5
1,677.3
1,677.3
1,677.3
O&M
Costs
($1,OOP's)
1,372.7
1,372.7
1,857.3
-5,757.5
v
1,857.3
Annual
Costs
($1,OOP's)
1,381.8
8,636.3
7,254 .5
1,372.2
1,372.7
3,534.6
1,857 .3
1,857.3
3,534.6
1,857.3
1/857.3
3/534.6
1,857.3
1,857.3
•3/9PP.2
P.W. Capital
Total P.W.
$15,870,300; P.W. O&M = $14,636,800
$30,507,100
223
-------
Table F-12
ESTIMATED TOTAL ANNUAL COSTS
No Action Alternative
Process
Digestion-aerobic
Digestion-anaerobic
Lagoon Storage
Transportation
Land Application
TOTALS
Capital
Costs
($1,OOP's)
1,816.0
1,816.0
Amortized
Capital
Costs
($1,000's)
171.4
171.4
O&M
Costs
($1,OOP's)
111.7
50.0
57.0
93.1
93.1
404.9
Total
Annual
Costs
($1,OOP's)
111.7
50.0
228.4
93.1
93.1
576.31
1 Average total cost per ton is $28.7 based on 55 tons per day production
and average local cost is $22.3.
224
-------
Appendix G
Energy Analysis for Alternatives
A-l, C-l, D-l, and D-2
225
-------
Sludge treatment and disposal .systems consume and produce energy in a variety
of forms. For the alternatives considered, energy may be used as electrical
energy, fuel oil, or natural gas. Production of digester gas is also a con-
sideration in the overall energy balance. To be able to compare energy
consumption of the various alternatives, all energy/consumption, regardless
of its form, is equated to electrical energy. The conversion factors utilized
were:
1 gallon of #2 Motor Fuel = 40 kilowatt hours
1,000,000 British Thermal Units (M BTU's) = 293 kilowatt hours
1 cubic foot of natural gas = 1,000 BTU's
1 cubic foot of digester gas = 566 BTU's
Alternative A-l utilizes energy for digester heating, sludge pumping, and
barge transport. Overall however, when digester gas production is included,
the alternative is a net energy generator. As shown in Table G-l, a net energy
surplus of 110,600 kilowatt hours per day would result from implementation of
Alternative 1.
In Alternative C-l, energy is utilized for digester heating, vacuum filtration,
and operation of the B.E.S.T process. Produced energy, on the other hand, is
from digester gas production and reclaimed oil produced in the B.E.S.T. process.
Overall, the process is nearly self sustaining, with a net energy consumption
of 900 kilowatt hours per day.
In Alternative D-l and D-2, which are truck transport and barge transport,
respectively, to the Williamette Valley, energy is required for digester
heating and transportation. Production of energy is in the form of digester
gas. Overall, both Alternatives are energy producers, Alternatives D-l and
D-2 having surpluses of 64,500 and 81,000 kilowatt hours per day, respectively.
226
-------
Table G-l
ENERGY CONSUMPTION
Alternative A-l - Land Application in Eastern Oregon
Process
Digester Heating
Sludge Pumping
Barge Transport
Digester Gas Produced
Energy Consumed In-Plant
(Surplus)
Energy
Consumption
(1000 kwh/day)
54.9
0.3
36.3
(165.8)
(110.6)
227
-------
Table G-2
ENERGY CONSUMPTION
Alternative C-l - Sludge Drying System
Process
Digester Heating
BEST Heating
BEST Electrical
Vacuum Filters
Digester Gas Produced
Reclaimed Oil
Energy Consumed in Plant
(Surplus)
Natural Gas Make-up for
BEST Process
Energy
Consumption
(1000 kwh/day)
54.9
111.9
30.0
3.8
(165.8)
(34.9)
(0.1)
1.0
1 This reclaimed oil represents potentially usable energy only.
228
-------
Table G-3
ENERGY CONSUMPTION
Carver-Greenfield Process Alternative
Energy
Consumption
Process (1000 kwh/day)
Digester Heating 54.9
Carver-Greenfield Process 14.6
Digester Gas Produced (165.8)
Energy Consumed In-Plant (Surplus) (96.3)
229
-------
Table G-4
ENERGY CONSUMPTION
Alternatives D-l and D-2 -
Land Application in Willamette Valley
Process
Digester Heating
Alternative D-l
Truck Transportation
Alternative D-2
Sludge Pumping
Barge Transportation-^
Truck Transportation
Digester Gas Produced
Energy Consumed in Plant
(Surplus)
Overall Energy Balance
Alternative D-l
Overall Energy Balance
Alternative D-2
Energy
Consumption
(1000 kwh/day)
54.9
46.4
0.9
24.2
4.8
(165.8)
(110.9)
(64.5)
(81.0)
These energy consumption estimates are based on minimum
distance from the Columbia Boulevard STP to the northern
Willamette Valley.
230
-------
Appendix H
Letter of Interest
Boeing Agri-Industrial Company
231
-------
AGRI-INDUSTRIAL COMPANY
P.O. BOX 97
BOARD MAN. OR EG ON 97818
TELEPHONE if,03) 481-2281 April 26, 1978
Mr. J. P. Niehuser
Chief Civil Engineer
Department of Public Works
CITY OF PORTLAND
400 S.W. Sixth Avenue
Portland, OR 97240
Dear Mr. Niehuser:
The following information is submitted in reply to your
letter of April 3, 1978.
Boeing Agri-Industrial Company is interested in submitting
a proposal for the leasing of land areas to the City of Portland
for use as a soil improvement site utilizing stabilized waste-water
sludge as a soil conditioner. As of this date the amount of land
reguired for the operation has not been established; however, I
believe sufficient land in suitable locations is available for that
purpose. Availability of land, however, is contingent upon pyior
leasing by other parties for agricultural purposes.
We recognize that various operational facilities will be
required near the waterfront as well as farther inland. Any partici-
pation in the provisioning or operation of any of the facilities
would, of necessity, be a matter for study and consideration after
such items have been more clearly defined.
We are interested in assisting in making the soil improve-
ment project a reality and a successful endeavor, however, further
information is necessary before we can make firm commitments.
Very truly yours,
BOEING AGRI-INDUSTRIAL COMPANY
) ;? / •
V. E. Norton
Vice President
232
-------
Appendix I. City of Portland
Ordinance No. 146547
233
-------
ORDINANCE NO.
140547
An Ordinance accepting the recommendation of the City Engineer for a
long term sludge disposal method; authorizing the City Engineer to
negotiate for purchase of land and easements; authorizing application
for a $369,675 grant from the U. S. Environmental Protection Agency;
authorizing an agreement with the U. S. Environmental Protection
Agency; designating an authorized grant representative; authorizing
the Commissioner of Public Works to make certain assurances, and
declaring an emergency.
The City of Portland ordains:
Section 1. The Council finds:
1. Ordinance No. 143406, passed by Council April 6, 1977, directed
the City Engineer to present a recommendation to the Council
concerning the final method for disposal of sewage sludge by
January, 1979.
2. An outline of studies conducted in relation to long term methods
for sludge disposal, the alternatives and the City Engineer's
recommendation are contained in a memorandum to the Mayor and
the Commissioners, dated September 1, 1978, marked "Exhibit A"
attached.
3. It is the recommendation of the City Engineer that the City of
Portland should proceed with the design of facilities for barging
digested sludge to Eastern Oregon for land application as a soil
conditi oner.
4. The Commissioner of Public Works has reviewed and approves the
above recommendation.
5. The Federal Water Pollution Control Act Amendments of 1972,
Public Law 92-500 authorizes the administrator of the Environmental
Protection Agency to make grants-in-aid to local governments to
share in the cost of design and construction of wastewater treatment
works.
6. The Environmental Protection Agency will, if a grant is approved
pay 75?o or $369,675 of the estimated cost of $492,900 for preparation
of engineering plans and specifications for construction of facilities
for transportation 2nd disposal of sewage sludge in Eastern Oregon.
7. That it is appropriate that the City make application for such
a grant, nd if the ;;rant is approved, execute an agreement with
the Environmental Protection Agency.
8. That it is r.ecesparv for the Commissioner of Public Works to
provide certain nssLirances and that it ir, a reouirement of the
Federal f-ovurr.rvnt t hnt an authorized reprt.4 entative for the
City of Portland be -.^pointed by the Council and be a full time
employee of the Ci.Ly.
234
-------
ORDINANCE No.
NOW, THEREFORE, the Council directs:
a. The City Engineer is hereby authorized to proceed vith engineering and
other activities necessary for implementing the recommendation of
barge transportation and land application of digested sludge in Eastern
Oregon.
b. The City Engineer is further authorized to negotiate for purchase of ease-
ments and lands necessary, or as other ways may more appropriately effectuate
the intent of this ordinance in order to accomplish the project, such
purchases subject to Council acceptance and authorization of payment.
c. The Mayor and tne Commissioner of Public Works are hereby authorized to
make application to the U. S. Environmental Protection Agency for a
grant-in-aid for $369,675 for preparation of plans and specifications
for the necessary transportation and disposal facilities and should said
grant be approved, an agreement is hereby authorized.
d. The City Engineer of Portland, Oregon, Cowles Mallory, is hereby designated
as the City of Portland's authorized representative for all administrative
matters in relation to the said grant application and subsequent agreement.
e. The Commissioner of Public Works is hereby authorized to give assurance
to the U. S. Environmental Protection Agency that the City will comply
with Title VI of the Civil Rights Act of 1964 and the regulations of the
U. S. Environmental Protection Agency effectuating that title providing
that no persons shall be discriminated against because of race, color
or national origin in the award of contract for construction of said
facilities.
f. The Commissioner of Public Works is hereby authorized to give the U. S.
Environmental Protection Agency such information and assurances as may
be required by the Agency and the State of Oregon for their consideration
of said grant.
Section 2. The Council declares that an emergency exists because there is an
immediate need to implement the recommended sludge disposal program, therefore,
this Ordinance shall be in full force and effect from and after its passage by
the Council.
Commissioner Connie HcCready
September 21, 1978
BUC 14621717
JTK
Passed by the Council, 2 V 197E
Attest
235
-------
v's'<,71
fc >: -j [>»/. AawV
I
r^"^'..J^?/
.J iJ L..1 -« "
>C*
"EXHIBIT A"
September 1, 1978
MEMORANDUM
DEPARTMENT OF
PUBLIC WORKS
:::nnie mccready
COMMISSIONER
OFFICE OF
PUBLIC WORKS
ADMINISTRATOR
J00 S.W. SIXTH AVE.
"1ATI AND, OH. 97204
TO:
FROM:
SUBJECT:
Mayor Neil Goldschmidt
Commissioner Connie McCready
Commissioner Frank Ivancie
Commissioner Charles Jordan
Commissioner Mildred Schwab
Cowles Mallorj^**'5^'"'
Public Works Administrator
Sludge Disposal
On September 20 the City Council will be asked to consider an
ordinance authorizing design and construction of facilities
to provide a leng term solution to the problems of wastewater
sludge disposal. Presented below is an outline of the history,
the alternatives, and our recommendations.
History
The City originally planned to construct an incinerator for
disposal of sewage sludge. In June 1975 the City Council
decided to re-evaluate this decision and approved a study of
alternative disposal methods.
In March 1977 City staff completed a report entitled "Alternative
Methods for t*e Disposal of Sewage Solids." All known processes
were reviewed and the following sludge disposal alternatives
evaluated in detail: land utilization of digested sludge in
eastern and western Oregon, composting for land utilization,
incineration w-'th landfill disposal of ash, and sludge drying
for local marketing or landfill disposal. Several variations
and combinations of these methods were also considered.
On April 6, "!?77 the City Council narrowed the choice of
disposal alternatives to 1) transporting digested sludge by
barge to eastern Oregon for application to lard, or 2) drying
digested slue're for local marketing. The Council also authorized
design of ac'c'-'tional sludge digesters and rebuilding of the
sewage lagcon, facilities which would be used with either alter-
native. The final selection of a disposal met'iod was scheduled
236
-------
Sludge Disposal
Page 2
9/1/78
for January 1979 to allow time for a) sludge drying pilot
plant work, b) completion of the regional sludge disposal
study conducted by the U. S. Army Corps of Engineers for
CRAG, and c) clarification of state and federal regulations
for land application of sludge.
Design of both the digesters and the lagoon will be finished
in October. Construction of the lagoon is scheduled for
completion in May 1930 and the digesters will be operational
in May 1981.
In November 1977 the Environmental Protection Agency (EPA)
decided to prepare an environmental impact statement (EIS)
for City of Portland sludge disposal alternatives. During
preparation of the EIS, public meetings were held in Boardman,
Oregon City and Portland. A final public hearing was conducted
by EPA in Portland on July 21, 1978. Copies of EPA's draft
environmental impact statement and public comments received
are enclosed. •
Both the Corps study and EPA's draft EIS confirm the results
of the March 1977 City study.
EPA has now requested a City decision on sludge disposal for
inclusion in the final EIS. l-'s believe sufficient information
is available to make that decision.
Alternatives
Two alternatives remain in consideration; barging and drying.
Barging. Digested sludge would be pumped to barges on the
Columbia River, transported i:;: river to Boardman, and used as
a soil conditioner. The sludge would be applied to the land
as a liquid.
Drying. Digested sludge wcjIc' be dried with a proprietory
system developed by the Resources Conservation Company. The
process uses chemicals and heat to extract water from the
sludge. The dried sludge would then be used locally as a
soil conditioner.
Both the barging and the dry'no alternatives are variations
of land disposal. They differ only in the type and extent of
processing and the disposal location.
237
-------
Sludge Disposal
Page 3
9/1/78 '
As a result of the three separate studies, v/e are convinced
that either alternative would be acceptable to the City and
that they are the two best alternatives for City consideration.
We are also convinced that we have delineated the best sludge
drying method now commercially available and have delineated
the best combination of transportation and location for land
application of liquid sludge.
The following factors were considered in analyzing these
alternatives. Detailed analysis of these factors are found
in both the March 1977 City staff report, previously submitted
to your office, and the attached draft EIS prepared by EPA.
A. Cost. Within the accuracy of the report, the two alterna-
tives are cost-equivalent. The City study and the EPA study
show a 10" and 6L' advantage, respectively, for barging.
The Corps study shows a 2% advantage for drying. The accuracy
of the reports are minus 15% to plus 30%.
The value assigned to the product in the drying alternative
accounts for part of the difference in the study results.
In both the City and the EPA study, costs for the drying
alternative assume that the dried product will have market
value equal to the transportation cost of removing it from
the treatment plant. The Corps study assumes a net value
for the dry product of $20.00 per ton after all marketing
and transportation costs. The marketabi1ity study conducted
in conjunction with the EPA report shows thai the market •
value of the dry product would decrease the total cost of
the drying process by approximately 7';j before marketing and
transportation costs are considered. A copy of this marketing
study is attached. It is possible that with an aggressive
marketinn program the value of the product would increase,
thus reducing the overall cost of the drying alternative.
Costs for the barging alternative assume a continuation of
current federal policy for the use of navigable waterways.
If substantial charges are imposed for use of the locks,
the cost of this alternative will increase.
B. Environmental Effects. Both alternatives are environmentally
acceptable. Barging has a minor environmental risk of water
pollution resulting from a barge accident. Drying has a
minor environmental risk of odors resulting from equipment
failure. Otherwise, the alternatives are environmentally
equivalent.
238
-------
Sludge Disposal Page 4
9/1/78 /:
C* Regulations. Both alternatives have the disadvantage^'of
uncertainty with regard to future state and/or federal
regulations governing the application of wastewater solids
to agricultural land.
D. Energy. Barging has an overall energy surplus of 247
million BTU's per day. Drying has a slight energy deficit.
Barging is primarily a user of diesel fuel. Drying is
primarily a user of electric and digester gas energy.
E. Chemical Use. The use of petroleum base chemicals constitutes
11% of the cost of the drying alternative. The barging alter-
native uses no chemicals.
F. Reliability. The barging alternative uses simple equipment
and no new technology. The individual elements of the
barging alternative contain nothing that has not been
successfully done for at least fifty years. The drying
alternative is more equipment-intensive and has not been
previously used in a full scale operation. Resources
Conservation Company did conduct a successful pilot plant
operation at the Columbia Boulevard Treatment Plant. They
have also successfully installed another unproven process
of their own design for removing inorganic solids from power
plant wastewaters.
G. Beneficial Use. Both alternatives use the sludge for a
soil conditioner/fertilizer. Barging removes the product .
to eastern Oregon. Drying retains the product for use in
the Portland metropolitan area.
Recommendation
We recommend that the City Council select the barging alternative.
We base our judgment primarily on the relative simplicity and
proven reliability of sludge pumping, barge transportation and
land application systems.
If the Council wishes to aggressively pursue the retention of
the sludge for use in the metropolitan area, we believe the drying
alternative is an acceptable risk. In order to develop a good
market, the City would have to commit to an extensive marketing
program.
In either case, it is anticipated that engineering plans and
specificatic.'s will be completed by March 1980, that construction
will cor.ime!,:: by Deceiver 1980, and that the facilities will be
fully operational by July 1983.
239
-------
Sludge Disposal
Page 5
9/1/78
We would appreciate an opportunity to review our recommendations
with you or members of your staff prior to the official Council
meeting. If you have any questions concerning the report,
please call me {4103} or Dale Nunamaker, our Project
Engineer (4213).
CM: jd
cc: Public Works Citizen Advisory Committee
240
-------
COMMENTS AND RESPONSES TO THE DRAFT EIS
This section contains letters of comments from agencies,
individuals and groups on the Draft EIS. Those letters which
commented directly upon the Draft EIS have been reproduced in
this section. Wherever a response is required by EPA to the
letter, a response page follows that letter.
Table 31 is a listing of the comment letters received
during the 4 5-day review period, including a general category
listing of their contents. Comment categories are shown
in an attempt to indicate those aspects of the proposed
project about which the commenters were most interested and
concerned. This may serve to direct the reader to those
sections of the document which he may wish to restudy.
In addition to many public meetings on the proposed
project EPA held a public hearing in Boardman, Oregon on
July 20, 1978 and Portland, Oregon on July 21, 1978. The
hearing in Boardman was attended by approximately five
people, one of which commented on the Draft EIS. The
hearing in Portland was attended by approximately 21 people,
three of which read testimony into the official record. A
question and answer session, after agency presentations and
oral testimony, was a part of each hearing and is included in
the hearing record. Because of the length of the official
hearing record and the costs involved we have not reproduced
the document for the Final EIS. Table 32 is provided, however,
listing the speakers and the areas in which they provided
comments. A summary of the testimony follows the public
hearing table. The public hearing record is available for
public scrutiny at EPA's Oregon Operations Office in Portland,
Oregon and EPA's Region 10 Office in Seattle, Washington.
The EPA wishes to express its appreciation to all
commenting agencies, groups and individuals for the time
and effort spent in reviewing the Draft EIS. All comments
were fully considered prior to formulating EPA's recommended
proposed action.
241
-------
Date
Received
Table 31
Conment Received on
Draft Environmental Impact Statement
From
1
i FEDERAL POLICY
ENERGY
! SLUDGE MARKET
AGRICULTURE
! GROUNDWATER
SLUDGE TRANSPORTATION/SPILLS
SOILS
WATER QUALITY
AESTHETICS
LAND USE
SLUDGE PROCESSING
VEGETATION
DRINKING WATER
SLUDGE COMPOSITION
SECONDARY IMPACTS
FISH AND WILDLIFE
SLUDGE APPLICATION
ALTERNATIVES
SLUDGE DISPOSAL
HISTORIC PRESERVATION
SLUDGE REUSE
METEOROLOGY
FLOOD HAZARD
CONSTRUCTION IMPACTS
STATE PERMITS
DISPOSAL SITES
7/24
U.S. Department of Housing and
Urban Development
X
7/31
U.S. Department of the Army
Corps of Engineers
X
X
X
X
X
X
X
X
8/7
U.S. Department of the Interior
X
X
X
X
X
X
X
8/17
U.S. Department of Agriculture
Soil Conservation Service
X
X
X
X
X
7/27
Advisory Council on Historic
Preservation
X
8/9
Intergovernmental Relations Division-
Oregon State Clearinghouse
Department of Fish and Wildlife
X
X
Department of Land
X
X
Department of Water Resources
X
Historic Preservation Office State
Parks and Recreation Branch
Y
7/13
Columbia Region Association of
Governments
X
X
X
X
X
-------
Date
Received
Table 32
Comment Received on
Draft Environmental Impact Statemem
From
FEDERAL POLICY
ENERGY
I SLUDGE MARKET
AGRICULTURE
GROUNDWATER
! SLUDGE TRANSPORTATION/SPILLS
¦ SOILS
¦ WATER QUALITY
AESTHETICS
LAND USE
SLUDGE PROCESSING
VEGETATION
DRINKING WATER
SLUDGE COMPOSITION
SECONDARY IMPACTS
FISH AND WILDLIFE
SLUDGE APPLICATION
ALTERNATIVES
SLUDGE DISPOSAL
HISTORIC PRESERVATION
SLUDGE REUSE
METEOROLOGY
FLOOD HAZARD
CONSTRUCTION IMPACTS
STATE PERMITS
DISPOSAL SITES
7/21
League of Women Voters of Portland
X
X
X
X
X
X
X
7/21
Resources Conservation Company
X
X
X
7/21
CH2M Hill
X
X
X
X
8/2
Arthur Forsyth Company
X
X
X
8/7
The Land Use Research Institute
X
X
X
X
8/7
Oregon Environmental Council
X
X
X
X
X
X
8/7
Resources Conservation Company
X
X
X
X
X
8/11
Resources Conservation Company
X
X
6/21
William EL Culham
X
X
X
X
X
X
X
8/9
Stan Kahn •
X
X
X
X
X
X
X
-
-------
OREGON nBpiiRTMRNT FI Jill NU W1 1'L.I.r'K
0. Box 2Bl*
Hei,'ner, Oregon 97836
Karen J. Miller
Jones and Stokas As3o:;i' !.•>3, Inc
600 S. W. Tent) Ave.
Suite I4.IIC
Portland, Ore. 972^5
Dear Karenj
Enclosed are three pictures of the terns and gulls nestiv;- at Three Mile Canyon
Along the Coiwibia River up from the mouts of Willow Creek.
I tried to find out th<* number of ne ;ti £ birds th t were using the erf® this
year uut both those men taking the inventory are on vacation and the info has
not been filed. Approximately three thousand gulls and three hundred terns were
ing
nest a? Three Mile in 1 77.
Also, the area where sludge was considered for diagonal south of the Boardman
Airport, it.,600 acres, is used by long-bjil ourlew for nesting. The U.S. Fish
and .Vildlife Service, Hii'atilln Psfupje, 'matilla, Oregon, is conducting a our-
lew study and they should nave additional information on curlew populations.
Curlews show up around utaroli 15th prior to newting.
If any additional information can be provided, please contact me.
Sincerely,
Glen Ward, Fish and Wildlife Bio
Ore. Dep't Fish and Wililife
P .0. Box 28J4.
Heppner, Ore. 978^6 tel-676-9195
ccjL«i Grande Office
File
244
-------
Response to Comments from G. Ward - Oregon Department of
Fish and Wildlife
1. Information included in EIS as suggested.
245
-------
ROBERT W STRAUB
OOVllNOt
Executive Department
INTERGOVERNMENTAL RELATIONS DIVISION
ROOM 306, STATE LIBRARY BLDG., SALEM, OREGON 97310
August 8, 1978
Roger K. Mochnick, M/S 44 3
201 EIS Coordinator
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, WA. 98101
Dear Mr. Mochnick:
RE: Sewage Sludge Disposal
for City of Portland
PNRS 7806 4 610
. Thank you for submitting your» draft Environmental
Impact Statement for State of Oregon review and comment.
Your draft was referred to the appropriate state
agencies. The Departments of Fish & Wildlife, Lands, Water
Resources and Historical Preservation offered the enclosed
comments which should be addressed in preparation of your
final Environmental Impact Statement.
We will expect to receive copies of the final
statements as required by Council of Environmental Quality
Guidelines.
Sincerely,
rfffi Martin W. Loring,
/ Manager
Grants Coordination &
Management Section
MWL:wb
Enclosures
246
AN EQUAL OPPORTUNITY EMPLOYER
-------
f # < / T"
OREGON PROJECT NOTIFICATION AND REVIEW SYSTEM
STATE CLEARINGHOUSE
(
Intergovernmental Relations Division X
240 Cottage Street S.E., Salem, Oregon 97310 .j
Ph: 378-3732 Air
PURS STATE REVIEW ofc '
Project ~ : Return Date: JUL 2 ^ Id?3 r
ENVIRONMENTAL IMPACT REVIEW PROCEDURES
1. A response is required to all notices requesting environmental review.
2. OMB A-95 (Revised) provides for a 30-day extension of time, if
necessary. If you cannot respond by the above return date, please
call the State Clearinghouse to arrange fcr an extension.
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( ) This project does not have significant environmental impact.
( ) The environmental impact is adequately described.
(X) We suggest that the following points be considered in the prepara-
tion of a Final Environmental Impact Statement regarding this pro-
ject.
( ) No comment. ,
REMARKS
Please see attached comments.
Agency LiS-fc ^Vk. \ njL^J 2.
ENVIRONMENTAL MANAGEMENT SECTl6£Lj£/4/78
-------
OREGON DEPARTMENT OF FISH AND WILDLIFE
comments on the
Draft Environmental Impact Statement
for
Sewage Sludge Disposal for the City of Portland
PNRS 7806-4-610
The City of Portland Sewage Sludge Disposal Draft Environmental Impact
Statement (DEIS) appears to adequately assess most fish and wildlife
resource impacts.
The alternatives proposing barge conveyance of the liquid sludge to
Morrow County (Alt.A) or to the North Willamette Valley Area (Alt.D)
pose unnecessary environmental risks should an accident occur.
Consequently, it is recommended that Alternative C, which involves sludge
drying and local reuse, be selected. This alternative would have the
least environmental impacts on fish and wildlife resources.
248
-------
Response to Comments from the Oregon Department of Fish and
Wildlife - July 28, 1978
1. Comments noted.
249
-------
OREGON PROJECT NOTIFICATION AND REVIEW SYSTEM
STATE CLEARINGHOUSE
Intergovernmental Relations Division
240 Cottage Street S.E., Salem, Oregon 97310
Ph: 378-3732
P N R S STATE REVIEW
Project #; 7 8 f) 6 b 6 1 n
Return Date:
ENVIRONMENTAL IMPACT REVIEW PROCEDURES
1. A response is required to all notices requesting environmental review,
2! OMB A-95 (Revised) provides for a 30-day extension of time, if
necessary. If you cannot respond by the above return date, please
call the State Clearinghouse to arrange for an extension.
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( ) This project does not have significant environmental impact.
( ) The environmental impact is adequately described.
( ) We suggest that the following points be considered in the prepara-
tion of a Final Environmental Impact Statement regarding this pro-
ject.
laiESBVI
- - ini JUN191978
DIVISION Of STATE LANDS
( ) No comment.
REMARKS
Agency
50 Cubic yards' rr^«eSire fill
Project delays_ to p« JT"" Po^itr"'5''
e obtamed from the n- f fnforination on the n ^ Necessary
'31°- Ph°«e 378-3805. " l«5 Stat,
Inanx you far
r the opportunity to
to comment on th*« ^
250 * pro««-
-------
Response to Comments from the Oregon State Department of
Lands - July 28, 1978
1. Comments noted.
251
-------
OREGON PROJECT NOTIFICATION AND REVIEW SYSTEM
STATE.CLEARINGHOUSE
Intergovernmental Relations Division
240 Cottage Street S.E., Salem, Oregon 97310
Ph: 378-3732
P N R S STATE REVIEW
Project # : { J • Return Date:
FNVTRONMKNTAL IMPACT REVTFW PROCFDI'RFS
1. A response is requirod to all notices requesting environmental review
2. OMB A-95 (Revised)¦provides for a 30-day extension of time, if
necessary. If you cannot respond by the above return date, please
call the State Clearinghouse to arrange for an extension.
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( ) This project does not have significant environmental impact.
( ) The environmental impact is adequately described.
( ) We suggest that the following points be considered in the prepara-
tion of a Final Environmental Impact Statement regarding this pro-
ject.
( ) No comment. t
REMARKS
11 ' "s"e«e *7a**
Agency oJt «¦ r q ^ <- r By
-------
Response to Comments from the Oregon Department of Water
Resources - July 28, 1978
1. Available updated information included in EIS.
253
-------
OREGON PROJECT NOTIFICATION AND REVIEW SYSTEM
STATE CLEARINGHOUSE ,rr~ "
I ,i
Intergovernmental Relations DivisibrtV -j I
Cottage Street S.E., Salem, Oregon ^73T0 f
240 Cottage Street S.E.
Ph: 378-3732 ' . *T£ }¦>-r-r
P N R S S T A T.I: k E V i F W
Project ~ : ' ~ -• ¦ ¦ 1 Return Date:
1
. +*
ENVIRONMENTAL IMPACT REVIEW PROPEnHRFfi
1. A response is required to all notices requesting environmental review,
2. OMB A-95 (Revised) provides for a 30-day extension of time, if
necessary. If you cannot respond by the above return date, please
call the State Clearinghouse to arrange for an extension.
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( ) This project does not have significant environmental impact.
( ) The environmental impact is adequately described.
(\) We suggest that the following points be considered in the prepara-
tion of a Final Environmental Impact Statement regarding this pro-
ject.
( ) No comment. . »
REMARKS
An archeological survey was conducted for this proposed Sewage
Sludge project for the City of Portland. (Appendix E)
A finding of no adverse impact was found for all locations
except in the disposal site. The final site had not been
chosen at the time of the survey. When the final location is
chosen it should be inspected by a professional archeologist
and a final statement of impact prepared for the final EIS. -
Agency
Historic preservation office
iiTATE PARKS A RECREATION BRANCH
525 TRADE STREET SE 254
SAlEM.igR&Cft C97310 By
-------
Response to Comments from the Oregon Historic Preservation
Office - July 28, 1978
1. Comments noted. A final site for sludge application in
eastern Oregon has not been determined. Once an exact
site has been chosen a professional archeologist will
inspect the site as a condition of grant funding by the
Environmental Protection Agency.
255
-------
Advisory Council on
Historic Preservation
1522 K Street N.W.
Washington. D.C. 20005
July 21, 1978
Mr. Roger K. Mochnick, M/S 443
201 EIS Coordinator
Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
This is in response to Donald Dubois' request of June 12, 1978, for
comments on the draft environmental statement (DES) for Sewage Sludge
Disposal for the City of Portland, Oregon. Pursuant to Section 102(2)(C)
of the National Environmental Policy Act of 1969 and the Council's
"Procedures for the Protection of Historic and Cultural Properties"
(36 CFR Part 800), we have determined that this DES does not demonstrate
compliance with Section 106 of the National Historic Preservation Act of
1966 (16 U.S.C. 470f, as amended, 90 Stat. 1320). However, it appears
that the Environmental Protection Agency understands its responsibilities
and will afford the Council an opportunity to comnfent pursuant to Section
106 if surveys of the disposal sites reveal cultural properties included
in or eligible for inclusion in the National Register of Historic Places
will be. affected by the proposed undertaking. Accordingly, we look
forward to working with EPA in accordance with the Procedures in the future,
as appropriate.
The Council is an independent unit of the Executive Branch of the FcJctjI Cox crntnenl charged by the Act of
October /J, 1966 to advise the President end Congress in the field of Historic Preservation.
Louis^S. Wall
Assistant Director, Office of
Review and Compliance, Denver
JUL 27 1978
environmental evaluation
BRANCH
256
-------
Response to Comments from the Advisory Council on Historic
Preservation - July 21, 1975"
1. Comments noted.
See Preface for EPA's grant condition regarding archaeological
resources.
257
-------
LEAGUE of WOMEN VOTERS of PORTLAND
610 DEKUM BUILDING 519S.W. 3rd
TELEPHONE 228-1675
PORTLAND, OREGON 97204
Friday, July 21, 1578
City of Portland public hearing regarding sewerage sludge disposal
The League of Women Voters of Portland recommends Alternative A I as des-
cribed in the Environmental Impact Statement for the disposal of sludge.
We have several reasons for proposing this alternative. First of all^for the long
range, the question of availability of land and the acceptance by landowners to
use the treated sludge on their land is of paramount importance.
The City and the EPA will naturally want to make sure their capital expenditures win
prove worthwhile for the future. The Boardman area does seem to provide the largest
inventory of land for sludge application as a soil nutrient, and to help reduce
wind erosion. In addition, with a drier climate, the sludge msy be applied during
more months of the year. This might prove to be a severe problem in Clackamas County,
•where the climate is so much wetter.
Regarding both areas under consideration, The League bplieves that any con-
cerns expressed by the residents should be taken into consideration.
Energy use and operating expenses tend to point favorably toward Alternative A I.
With highways so clogged with traffic and truck accidents more prevalent, it seems
environmentally -unacceptable to have 39 round trips a day from the treatment plant
lagoon to the Canby area. This will only add more pollution to our already overloaded
airshed. The alternative transport means, barging up the Willamette, presents many
problems too: low water, meandering river, heavy river traffic and small boats.
The B.E.S.T. process might have many advantages in our fertilizer hungry world,
but at this time there seem to be too many unanswered questions involved in the process
not the least of which is the marketing problem. The companies already selling
fertilizer might put up stiff resistence to competition that cost the customer noth-
ing.
In conclusion, with 90% of the area's population connected to sewers in the year
2000, it behooves the City of Portland to plan immediately for the 90 tons per day
of sludge that will have to be disposed of. To make the land disposal sites last
even longer, we suggest that eveiy effort be made by EPS. regulation to cut down on
the amount of zinc, cadnrLum and other metals that is allowed by companies to be put into
the sewer system.
Leeanne G. MacColl
2620 S. W. Georgian Place
Portland, Ore. 97201
223-7661;
258
"To promote political responsibility through informed and active participation of citizens in tjovernment.
-------
Response to Comments from the League of Women Voters of
Portland - July 21, 1978
1. Comments noted.
259
-------
-------
has primary sludge trucked to the St. Johns landfill end secondary
sludge barged to Morrow County, neither of which is necessary. Both
oan "be composted right at the plant site. Even if composting is still
more expensive than barging it can easily be seen that the factors
that make composting expensive are likely to remain stable while the
cost of fuel for barging is likely to skyrocket.
The greater part of the typical wastewater treatment process
involves dewatering and settling of solids. Sewage ordinarily en-
ters the plant with about ifo- suspended solids. The methane digesters
require at least 5to 6fo solids for efficient operation. A large part
of the methane producing potential is now lost because of the low
solids content.
The biodegradable portion ( .putresables, paper, brush) of the
solid waste stream amounts to about ten times sewage solids. The adr-i
dition of the biodegradables to the sewage as it enters the plant
would accomplish the following^ solids content would be ideal for
the methane digesters, large amounts of gas would be produced (eqiv-
alent to cooking and hot water needs of 15000 homes), both primary
and secondary sewage treatment (the greater part of the process)would
be rendered unnecessary.
All of the regions biodegradable solid waste (about 70^ of the
total waste stream) could be handled in the space now occupied by
our sewage treatment facilities. Many additional digesters would
have to be built but should not require any more space than is now
used for primary and .secondary treatment.
Now of course we have much' more to dispose of, nevertheless
261
-------
the draft EIS estimates that potential users of free material would
take seven times what Portland is now producing. 0nC6 a,qain it is
important to consider the cost of fossil fuels in todays decisions.
Sewage sludge is much less concentrated than chemical fertilizer bo
it requires a lot nore to apply the same amount of nutrients. Even so
the rising cost of chemical farming will undoubtedly alter our present
attitudes towards organics. Besides organice are far better for our -
soil.
conjunction with the Portland School system establish urban farme
as a learning experience for our children. These farms should be in-
tensively managed, total about 2 to 3000 acres and be located in
Rivergate or as close as possible to the sevage plants. Two thou-
sand acres would provide the people of Portland with only about 2%
* 1
of their total diet, but a substantial part of the in season vege-
tables, and they would always be reasonably priced. Above all it
would be an invaluable experience for the kids.
Finally I would like to propose that the City of Portland in
Thank you.
Stan Kahn
722 SE 18
Port 97214
262
-------
Response to Comments from S. Kahn - August 9, 1978
1. Comments noted.
263
-------
1929 N. E. 10th "
Portland, Oregon 97212
June 19, 1978
Roger K. Mochnick Tfl/S itli3
201 KTfi Coordinator
US EPA Region X
1200 Sixth Ave.
Seattle Wash 98101
SUBJECT: EIS Sewage Sludge Disposl
City of Portland, Oregon
Dear Sirs:
The following comments on the Draft EIS Sewage Sludge
Disposal- City of Portland, Oregon are submitted.
Page 2k Rivergate Flood
The flood problem of the Rivergate Area has been
materially reduced by the improved control/ management
of upstream impoundments on the Columbia River System,
Possibility of a hundred year flood— as in the past —
can be more accurately predicted, controlled and managed
so that any great damage could almost be eliminated and
a similar statement should be included in the EIS.
Also, if closure of the Columbia Slough to naviggtion
is accomplished, interior flooding behind the present
Columbia River levees will be reduced.
Pages 3I4-I29 Rivergate Land Use Proposals.
As with any EIS, current and future planning and
land use conditions are in constant flux. This is true
264
-------
-Culham
page 2
of the Rivergate area and hinges on a recent action
and decision of the Portland City Council. It is
suggested that an n ADDENDUM" similar to the following
be prepared and included in the EIS.
" ADDENDUM; Since the preparation of the EIS,
the study by the City of Portland on dredging
and use of Columbia Slough for navigation has
been completed. Recent Council action accepted
the recommendation of the City Engineer NOT
to pursue any action to dredge the*slough,
but rather to close the mouth of the slough
to navigation and keep the slough for drainage
only.
This action is in concurrence with early
0
plans of the Port of Portland to close the
'sloough to naviggtion , and to further
fill and develop more industrial land in
the Rivergate area.
Also, the City of Portland and
the Metropolitan Service District are
actively pursing the issuance of a permit
by EPA and theCorps of Engineers to allow
expansion of St. John's Refuse Disposal
Uuidfill in the Rivergate area.
Both of these actions may provide
more acreage and an extended life expec-
tancy for sludge application both on
land filled with dredge spoil and the
Refuse disposal site."
265
-------
CULHAM
Page 3
Page 130 Aesthetics
The statement regarding the "remoteness" of Morrow county-
sites vhen discussing remoteness and aesthetics is some what
ndslea ding. The transport of sludge by any means across
1-80 N and the possible future development of areas along
1-80 because of increased agriculture- industrial use by
the reason the the PGE power plant and more irrigation
may materially change the "remoteness" characteristic of
the Morrow county sites within a short time.
GENERAL
It a pears that future planning by local government and
consideration of EPA and the Corps of Engineers of permits for
dredge disposal and expansion of St Johns Refuse /disposal site
may offer some additional factors to be considered in the
"NO ACTION ALTERNATIVE" for sludge disposal.
It also seems evident that a development plan for the
Morrow county disposal sites for sludge must include the
DISPOSAL concept as well as the land application and soil
improvement program for sludge.
This is necessary because a major upset of the sewage
treatment plant operation, changes in criteria for land loading
of sewage sludge or changes in local land use peripheral to
the land application areas may force a disposlprogram
for sludge on either a short term or lang term basis.
Consideration for sludge disposal could also include
a joint program with PGE disposal of certain ash and residue
from the coal-fired power plant.
266 Sincerd^^^ q
William B. Culham
-------
Response to Comments from W. B. Culham - June 19, 1978
1. Information included as suggested.
2. Comments noted.
3. Comments noted.
4. Comments noted.
267
-------
f
-j«KIT o
sr jin tin. \ DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
~" limit * I heGional office
\ illlllll c* ARCADE PLAZA BUILDING. 1321 SECOND AVENUE
~ «¦•** SEATTLE, WASHINGTON 98101
July 18, 1978
RPrinw y ,N REPLY Refer to:
Office of Community f\\ 10D M/S 317
Planning and Development '
Mr. Donald P. Dubois
Regional Administrator
U.S. Enviromental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Dubois:
We have reviewed the impact statement submitted with your June 12,
1978 letter.
The proposed project is to determine an acceptable sludge disposal
or reuse program for the City of Portland.
We find no constructive comments to offer on any of the proposed al-
ternatives. However, we do concur that no action alternative would
certainly be a short term solution and would not be acceptable in
meeting the future growth potentials of the .city.
Thank you for the opportunity to comment.
Sincerelj
2vX
;rt C. Seal fa,
Regional Director, CPD
JUL 24 1978
ENVIRONMENTAL EVALUATION
BRANCH
AREA OFFICES
Portland, Oregon • Seattle, Washington • Anchorage, Alaska • Boise, Idaho
Insuring Office
Spokane, Washington
268
-------
Response to Comments from the Department of Housing and Urban
Development - July 18/ 1978
1. Comment noted.
269
-------
m..
THE LAND USE RESEARCH INSTITUTE
821 N.W. Flanders, Portland, Oregon 97209 503-222-4333
August 4, 8
CARD OF DIRECTORS
ORG E D. WARD
<:su'!;pg Engineer,
-ctor
¦ VV>! (JAM J BAUER
..-Siii'i'iQ Engineer. Chicago, III.,
Di-'-'Jor
WID W HARPER
¦:iorn"y, Portland.
¦;-< ti.-f-y
."JENTiFlC ADVISORS
R THOMAS D. HINESLY
• .¦:! Geologist,
M,'et::;ty of Illinois
Mu S. EILIP
rcologist,
t(i Si.ii:> University
- 1\ V .ENCE G. GOI.UEKE
i.-'iologisl,
¦ '' r P, .-rke'CV
1 n r,-
•' -- u
Mr. Roger K. Mochnick, M/S 443 j
201 E.I.S. Coordinator .*
U.S. Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington 98101
1978 ¦
Re:
City of Portland, Draft E.I.S.
regarding sewage sludge disposal.
Dear Mr. Mochnick:
The following is to support verbal comments made by myself at
the public hearing held in Portland July 21, 1978 regarding the
draft environmental impact statement pertaining to sewage sludge
disposal alternatives available to the»City of Portland.
As discussed, the upriver barging and agricultural utilization
concept consistantly presented and recommended by The Land Use
Research Institute represents ten years of intensive investment
and research on the part of private enterprise. Upon reviewing
the draft E.I.S., it pleases us to note that this concept is
one of the prime sludge management alternatives recommended by
Portland's consultants. For this we are thankful and appreciate
the fact that barging and utilization will now be given full
consideration in any final decision making activities.
In summary, the Institute and it's membership wish to offer their
combined support for the barging and land application alterna-
tive. It is our belief that the coordinated efforts of the
numerous segments of industry that the Institute has assembled
for this purpose can reduce the final costs substantially over
those shown in the draft E.I.S. cost comparisons.
As a matter of record, it was noted that the draft E.I.S. failed
to include information presented by the Institute on behalf of
industry at either the Dec. 9, 1977 or the March 3, 1978 public
hearings on this subject. Because the information presented
does speak in direct support of alternative A-l, we ask again
270
A NON-PROFIT RESEARCH CORPORATION
-------
-2-
that it be included in the final E. I. S . "Copies of our Dec. 9, 1977 and
March 3, 1978 statements which were read into the record at the time
are attached.
Several members voiced surprise that this information was omitted from
the draft E.I.S. and strongly urged that it not be ignored at this time.
A majority of the technical information now available to the Institute
membership was assembled over the past ten years by the consulting engin-
eering firm of George D. Ward & Associates.
Funding for the longrange study was provided by an engineering retainer
from Tidewater Barge Lines plus the $1000 membership fees paid by the
Institute participants. An appreciable amount of information and experience
was also gained during almost three years and $100,000 worth of sand dune
stabilization research work conducted by George D. Ward & Associates
on the 50,000 acre, U.S. Navy Bombing Range at Boardman. During that -
project, liquid sewage sludge was barged by Tidewater from Portland to
Boardman where it was used successfully in establishing a healthy vegeta-
tive growth on massive, agriculturally destructive sand dunes. The pro-
ject was successful and also demonstrated that sewage sludge can play an
important role in preventing the loss by wind erosion of valuable agri-
cultural top soil.
Those who supported the cost of The Land Use Research Institutes extensive .
study of alternate A-l, include the following:
1. Tidewater Barge Lines
2. Land Reclamation Inc.
3. Pacific Carbide & Alloys
4. Domtac Chemicals
.5. Widing Transportation
6. R. M. Wade
7. Morrison Oil
8. Schulz Sanitary Service
9. Eudaly Bros. Excavating
10. Mud Cat, Inc.
11. W. J. Bauer, Consulting
En;:i nuers, Chicago
.Columbia River & it's tributaries
Operators of Portland Sanitary
Landfill
Lime sterilization
Line Sterilization
Sludge tank trucks ^
Irrigation equipment
Own land adjacent to North Portland
Harbor and hold valid dock permit.
Portland's largest septic tank
service organization.
Skilled and equipped to construct
lagoons and sludge dredging.
Manufacturers of sludge dredging
equipment.
Experienced in lagoon cleaning,
pumping and rail haul of liquid
sludge. Engineering News Record
attached.
In addition to the above, the Institute has made extensive contact with
the agricultural communities along the full length of the Oregon and Wash-
ington shores of the Columbia from Portland to Pasco and to a lesser extent
along the shores of the Snake River into Idaho. This has resulted in the
establishment of potential contract agreements with numerous agricultural
property owners amounting to many thousands of acres; far in excess of the
271
-------
area required to serve The City of Portland.
Efforts to develop a three state, regional sludge utilization concept are
continuing. The latest development has been an invitation by Dr. Joseph ,B.
Farrell, Chief of E.P.A-.'s Ultimate Disposal Section of the Environmental
Research Laboratory in Cincinnati to submit a grant application for a two
year sludge oriented research and development project. If awarded, it
would include the investigation of lime sterilization of sludge, barge
loading and off-loading methodology. The establishment of disposal research
sites at various upriver locations and an accurate cost analysis of all
aspects of sludge barging as compared to other known sludge hauling and
disposal alternatives.
It is anticipated that work on the E.P.A. funded research project could get
started in early 1979. If so, this would rr.ake the results available in
time for either consideration or immediate implementation at approximately
the same time as Portland's new digestors are completed and placed into
service.
In conclusion, we trust it is apparent that private enterprise has demon-
strated it's collective capability to properly receive, transport and
utilize the City of Portland's entire output of sewage sludge through the
year 2000.
Contract negotiations with willing land owners along the shores of the
Columbia are continuing. Barge modifications are also being planned by
Tidewater and several, upriver off-loading points have already been estab-
lished with dock construction underway at one site in Washington. For
added economy a study is now underway to establish return haul cargos for
full utilization of manpower and equipment.
This concludes the essence of my conim^nts at the July 21 public hearing.
I'd be pleased to answer any further questions you may have.
Respectfully submitted,
W-.rd, P.E.
27Z
-------
Response to Comments from the Land Use Research Institute -
August 1/ 1978
1. Comments noted. As requested by the city council on
September 27, 1978, the City of Portland will consider
proposals from private concerns for transportation and
disposal of sewage sludge.
273
-------
DEPARTMENT OF THE ARMY
PORTLAND DISTRICT. CORPS OF ENGINEERS
P. O. BOX J946
PORTLAND. OREGON 97208
NPPEN-PL-5
31 July 1978
Mr. Rodger Mochnick
EIS Coordinator
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, WA 98101
, r ^
Dear Mr. Mochnick:
Please refer to your 12 June 1978 letter to all interested agencies,
groups, and citizens for the review of the draft final Environmental
Impact Statement (EIS) entitled "Sewage Sludge Disposal for the City
of Portland, OR" (EPA 910/9-050). Since the Portland District
Corps of Engineers was responsible for the CRAG area 208 Sludge
Management Study, our office has reviewed your draft EIS. Our comments
are attached, ,
Thank you for the opportunity to review this draft EIS.
Sincerely yours
Incl
as
CF:
1. Mr. Terry Waldele, CRAG
2. Mr. John Vlastelicia, EPA Oregon Operations Office
3. Mr. Cowles Mallory, City of Portland
274
-------
COMMENTS ON SLUDGE EIS
a) Pg. 14, Figure 4: The names for the potential disposal areas for
Sandy, Estacada, Canby, and the Kellogg Region are labelled as "Disposal
Sites" which is not correct. The areas were identified in our 208
report as "Potential sludge disposal areas." The label of "site" is
misleading since the actual sites required for sludge disposal from
those municipalities would be only small portions of the areas shown.
Thus, it is recommended that the labelling on these areas be revised.
b) Pgs. 87-97: Marketing Analysis:
i) In general, the market analysis seems to be geared toward the fertilizer
benefits rather than soil conditioning properties of a dried sludge product.
Because it's nutrient value is relatively low, however, it seems that dried
sludge should have been analyzed primarily as a soil conditioner and
natural organic fertilizer. To quote Milorganite1s selling phrase: "It
can no longer be said that a pound of nitrogen is a pound of nitrogen
irrespective of source." Also, since the Milorganite people have con-
centrated their marketing efforts of golf courses, parks, horticultural
operations, and home-owners, it would seem that much of the effort should
be around those potential markets. If this is not appropriate, the report
should have summarized the reasons why.
ii) It would seem that the City itself could use much of the sludge on
its own golf courses and parks. This could offset city fertilizer costs.
>
iii) The large difference in sludge volumes between the potential specialty
product market in Table 15 and those in Table 16 for free material should
be discussed. ie. -- What do the potential prices represent? How did
the consultant arrive at these prices? How elastic is the demand with
price changes? Since Milorganite is sold in the area at a relatively
high price, it would be logical to assume that a Portland product could
be sold at a lesser price in larger volume.
iv) Table 17 shows a potential market of only 3,000 tons @ $30-$40/ton
for home and garden use of dried sludge as an organic fertilizer. How
much milorganite sells in the local area at $5,00 for a 50 lb. bag
($200.00/ton)?
v) There seem to be no conclusions in the Market Analysis. As a minimum,
the following two questions should be answered: Could the city sell this
product? What would be the cost of a marketing system? As was shown
in the 208 sludge study, the potential price of the dried product greatly
influenced the ranking or cost effectiveness of the sludge drying alternative.
275
-------
c) Pg. 104: on Table 18, indicates that the "short term" impacts of
the no-action alternative are essentially negligible. However, there
is no discussion of the potential serious long-term impacts of this
alternative. A discussion of this alternative similar to the others
on pgs. 81-84 would be very informative. Also, the potential huge
energy consumption and generation losses from additional irrigation
withdrawal from the John Day pool should be mentioned if land areas
not presently irrigated are to be put under irrigation due to sludge
applications.
d) Pg. 105, Energy Use: Somewhere in this section should be a comparison
or documentation of the energy use of drying sludge vs. manufacturing a
similar amount of commercial fertilizer.
e) Pg. 117, Odors: It is stated that barges will be inclosed to
eliminate odor problems. However, if a barge is loaded for any length
of time there may be methane gas production. This could be dangerous
if not vented from the barges since methane and air is an explosive
mixture.
f) Pg. 123, Sludge Conveyance Reliability: Mention should be made of
potential barge accidents and other unforeseen events which could close
the locks at a dam and disrupt all river traffic. Also, provisions must
be made for an annual 2-week lock maintenance on the Columbia River
Projects.
g) Pg. 125, paragraphs 2 and 3: The calculations which show the oxygen
depletion in the Columbia and Willamette Rivers'should be explained in
more detail since:
i) It's highly unlikely that a barge could spill its entire
load in 10 minutes. A slow seepage would be more reasonable.
ii) It is unlikely that effects of a complete barge dump in
the Columbia could be found one mile below the accident let
alone 5.5 to 6.5 days later downstream. If the spill occurred
in the main stream of the Columbia, the spill could move 300
miles or more in 5 to 6 days. A recent pilot dredging test on
in-water disposal of approximately 1000 cubic yards of Willamette
River material with a high immediate oxygen demand could not
be detected less than a mile downstream from the dumpsite. This
is evidently due to the huge dilution and mixing potential of
the Columbia River.
iii) You may want to note that the worst conditions for a spill
in the Portland harbor area would be during the Columbia River
freshet when the Willamette River flow may actually stop in the
harbor due to high water level in the Columbia.
h) Pg. 160, Barge or Truck Accidents: It is stated that the municipalities
of the Dalles, and Boardman withdraw water from the Columbia and should be
warned in case of a barge spill. The town, of Dallesport, not the Dalles,
withdraws water from Columbia. Boardman should be of no concern since
it is upstream from the proposed barge unloading facilities.
276
-------
Further, this section of the EIS states that Portland and Wilsonville
use the Willamette River as a source. Neither of these municipalities
presently use the Willamette River as a source. Several Washington
County purveyors have been recently considering the Willamette River
as a source but no firm decisions have been made.
Since both our 208 study, the city's 201 study and this draft EIS
showed that sludge disposal in the Northern Willamette Valley, Al-
ternative D, would be more expensive and have more serious environmental,
social, and institutional impacts than the other alternatives, it is assumed
that it will be dropped from further consideration. This leaves Alternative
A (barging to Boardman) and C (drying to a marketable product) for con-
sideration and project recommendation. However, with unanswered questions
on the market analysis study, it appears that recommending Alternative C
would be difficult.
-------
Response to Comments from the U. S. Army Corps of Engineers -
July 31, 1978
1. Corrections made as recommended.
2. The marketing analysis section in the Draft EIS was composed
of excerpts of a preliminary report. A summary of the
final marketing report is presented on pages 91-98.
The final report clearly states that the primary value of
the proposed dried sludge product would be as a soil
amendment. There were three general markets identified
and analyzed in the report: the home and garden market
consisting of private households; the specialty market
consisting of landscape contractors, wholesale nurseries,
public agencies and other urban commercial users; and the
commercial agricultural market. The demand in the first
two markets is primarily for a soil amendment, although
secondary markets for a base for organic fertilizers
and a potting soil ingredient for home and garden use
were also identified. No commercially feasible market was
found in commercial agriculture.
3. School districts, parks and public works department demand
is estimated and described in the final report. On a
commercial basis the demand is very low as very little
soil amendment is used and organic fertilizers require
too much additional labor in application because of their
low nutrient contents. If the product were provided free
these public agencies would be willing to use between
about 3,000 and 4,000 tons annually.
4. The final marketing report emphasizes the comparability
of sludge as a soil amendment with wood by-products.
Demand for a sludge as a soil amendment is a step-function
in that prices above about $7.50 per ton (June 1978 prices)
were not found to be generally competitive with wood
by-product prices, thus, captured a very small percentage
of the market, but at $6.75 to $7.50 per ton, demand was
substantially greater. Demand then apparently increases
very slowly at prices under $6.75 per ton until a price
of zero is approached, at which point another substantial
increase in demand occurs.
Milorganite is sold as a fertilizer (not a soil amendment)
in the specialty and home and garden markets and is placed
on the market at a relatively high price - even for a
fertilizer of its analysis. However, estimates of local
sales of Milorganite to these markets are not available
so it is difficult to compare estimates made in this
report to Milorganite's experience.
278
-------
5. Again, estimates of local Milorganite sales are not
readily available, but only 70,000 tons are sold annually
and it is known that the most active market for
Milorganite is in Florida citrus production. Current
sales of organic-based fertilizers in the local areas
are estimated at less than 1,000 tons annually. This
market is growing, but sludge alone is not likely to
capture a great percentage of that growth without forti-
fication. The Nu-Life Fertilizer Company of Tacoma, for
instance, uses Chicago's heat-dried sludge as a basis for
many of its organic-based fertilizer products. Portland
could compete in this market, but two of the major
northwestern fertilizer manufacturers making organic
products are closer to Seattle which is also considering
heat-drying its sludge. The 3,000-ton estimate is
conservative but realistic.
§. The marketing report clearly indicates there is sufficient
demand to absorb all potential heat-dried sludge production
by the City of Portland. Exact estimates of the potential
return to the city from a sludge marketing program were
not developed. Experience elsewhere indicates that returns
are likely to be negative during the early years when the
market is being developed and the product is gaining
recognition. Given appropriate development such a
program can produce positive net returns in later years
though these returns would never approach the sludge
drying costs. Marketing may still be desireable if it
minimizes total sludge disposal costs.
7. A discussion of the no-action alternative, similar to
discussions for Alternatives A-l, C-l and D-l, D-2,
is presented on pages 100-102. Discussion of the potentially
serious long-term impacts of the no-action alternative is
included in the section entitled Analysis of the Environmental
Impacts of the Alternatives.
Land areas on the Boeing property not currently in agri-
cultural use are planned for large-scale agricultural
activities in the near future. In terms of a particular
parcel of land, availability of sludge may cause a parcel
to go into agriculture sooner than it would otherwise,
or sludge availability may cause a parcel to go into
production in substitution for another piece of land.
Although sludge may assist agriculture through soil
stabilization and fertilization, it is probably not the
determining factor as to whether land goes into agriculture
or not. Therefore, no analysis was made of the energy
consumption or generation losses caused by additional
water withdrawal from the John Day Pool.
279
-------
8. The marketing study was not designed to develop the most
cost-effective means of developing a commercial fertilizer.
The goal and objective of the analysis was to find the
most cost-effective method of sludge reuse. In this case,
sludge reuse could supplement commercial fertilizer use,
but not replace it. Therefore, the analysis suggested is
not warranted.
9. Corrections made in text as suggested.
10. Additional information included as requested.
11. The analysis of oxygen depletion resulting from a sludge
spill in the Willamette or Columbia River was predicated
upon the worst conceivable hydrological situation in each
river, which may not be realistic, but provides the reader
with possible impacts under the worst river conditions.
It would be reasonable to assume that within a short
distance of even a massive sludge spill in the Columbia
River, dispersion would be so great as to render the
sludge undetectable. However, no study was conducted to
evaluate the hydrologic mixing and dispersion characteristics
of a spill in the Columbia River. Rapid dispersion was
assumed.
Additional information included as requested.
12. Corrections made as requested. Boardman is included in
the discussion of municipalities utilizing river water
because off-loading sites could be located upstream of
Boardman if sludge is utilized by agricultural concerns
east of the Boeing property.
13. Comments noted.
280
-------
k*
COMMENTS OF THE OREGON ENVIRONMENTAL COUNCIL ON THE DRAFT
EIS, SEWAGE SLUDGE DISPOSAL FOR THE CITY OF PORTLAND, OREGON '
August 3, ]978
The Oregon Environmental Council is a coalition of approximately
7 0 sportsman, planning, health, recreation and labor
organizations and 3000 environmentally concerned Oregonians.
After reading the DEIS we feel that the statement presents few
alternatives which are compatible with maintaining an
environment that is both safe and clean, long a concern of this
group. The alternatives are described quite thoroughly in
most respects. We feel, however, that the many questions which uO
arise are important enough to make us lend our support to the
no-action alternative until these matters are resolved.
1
3
f
1. Because of sludge's extreme toxicity, and because
a barge spill could occur either near or below the great blue
heron rookery located near ( page 33 )the Clackamas-Marion County
disposal site, studies should be made ascertaining the
effects of sludge on these birds. The herons would probably be
extremely sensitive to a spill on the river since they obtain
their water from the Willamette. It would be important, therefore, to
to know how long an accident at the near-by off-loading docks
would take to reach the rookery. Also, could the resulting
clean up be completed quickly enough to prevent damage at this
declared significant natural area? ,
2. Before considering marketing dried sludge as a fertilizer
in the Portland area ( PQQ6 73 ), one must consider that many
farmers would buy a cheap sludge-based fertilizer soley for
a high nitrogen yield without any concern for the potential
problems of heavy metals. So, would it be possible to label
heavy metal percentages on the package? What problems has
Milorganite had with this?
3. The sludge drying beds mentioned on page 83 for the
Morrow County site would probably emit odors, especially with
the high evaporative rate there. How would these odors be elim-
inatedj or at least controlled?
4. Since past "acceptable standards" for many heavy
metals have been later found to be unacceptable and constitute a
health hazard to humans, it is probable that the presently
acceptable standards ( e.g. as on page 138 ) will not be considered
safe throughout the twenty-year life of the project. As a result,
any disposal alternative that uses these wastes on lands for crops
or grazing is to be looked on skeptically. Consequently, one
must estimate what the safe future levels of these heavy metals,
[J5 (Tespecia,lly cadmium and zinc, will be throughout the lif e of the
'liipjjrQject .f^Jan these estimates be safely made?
2978
281
-------
5. The DEIS states on page ]56 that "use of sludge on
such crops as wheat, alfalfa and grass is considered acceptable
Wouldn't heavy-metal-laden grass concentrate heavy metals into
grazing cattle, thereby leading to humans getting high concentrations
in their milk or meat?
6. To judge how much heavy metals have built up in the
groundwater at the presently used Rivergate disposal sit£ Is
important in predicting seepage into groundwater elsewhere.
The DEIS states, on page 164, " there are no background data with
which to compare these heavy metal concentrations and interpret
the concentrations reported. " Couldn't these high, admittedly
abnormal heavy metal concentrations be compared to concentrations in
groundwater across the river? Probably there the features
would be similar to Rivergate, permitting a fair comparison.
If conditions were different across the Columbia River, then
a site across the Willamette, or even an unused area on the
Rivergate property surely must be available for comparison .
7. Why hasn't the percentage of zinc and cadmium
originating from the major industrial contributors of heavy
metals been determined ( page 131 )? When will they be measured?
Connected with this, the DEIS proposes putting more pressure
on industry to increase source control so as to limit their
input of heavy metals into the system. However, many firms prefer
to take the easier, and more economical alternative of paying
fines and doing as little as possible. So, how could regulatory
agencies put this pressure on? To what extent would this be
effective?
We appreciate the opportunity to submit these comments and
request that they be included in the final impact statement.
Oregon Environmental Council
2637 S.W. Water Ave
Portland, OR. 97201
Submitted to:
U.S. Environmental Protection .Agency
Region X
1200 Sixth Avenue
Seattle, WN 98101
L3C/s
282
\
-------
Response to Comments from the Oregon Environmental Council -
August 3, 1978
1. The great blue heron rookery mentioned in the Draft EIS
is located on the Clackamas River upstream from potential
off-loading sites on the Willamette River. Therefore
there would be no adverse effect on this rookery by a
sludge spill in the Willamette River.
2. Any large-scale use of dried sludge as a fertilizer by
private farmers would be under supervision of the Oregon
Department of Environmental Quality, which has set
limits on heavy metal loading to soils used for agri-
culture (Table 25). As far as is known, Milorganite has
had no problems relating to heavy metals.
3. Properly digested sludge should generate very little
odor in a drying bed. To minimize odor problems, drying
beds would be located away from developed areas. Winds
would disperse any odors quickly. Chemicals could also
be used to control odors, but were judged unnecessary.
4. It is possible that present "acceptable standards" for
heavy metal loadings may be found unacceptable in the
future. Therefore, those alternatives involving use of
sludge on agricultural land should be looked upon with
concern. Monitoring programs would provide additional
information on present safe loading rates on a site-
specific basis. However, there is no way to forecast
safe future levels of heavy metals.
5. Grasses are considered suitable crops for sludge application
because heavy metals do not accumulate in plant tissues.
Of greater concern is potential transmission of pathogens
to animals grazing on or feeding on vegetation that has been
fertilized with liquid sludge. The Oregon Department of
Environmental Quality has established safety measures,
including provisions to cleanse the vegetation through
irrigation or rainfall prior to use by cattle.
6. To adequately determine the effects of heavy metal seepage
from sludge disposal in the Rivergate area, a monitoring
program must be established providing background information
from deep wells located away from the disposal site as
well as from wells located within the disposal site. At
the present time, no studies of this nature are being
planned by the city or by the DEQ. No water quality data
could be found within the Rivergate area with which to
compare data collected from the disposal sites.
283
-------
7. Data on percentages of zinc and cadmium originating from
major industrial contributors were not included in the
Draft EIS because the City of Portland, until recently,
did not have equipment of proper sophistication to
accurately measure zinc and cadmium levels. The city is
currently measuring zinc and cadmium contributions on a
point source basis. Influent to the treatment plant has
also been analyzed for zinc and cadmium concentrations
(Edmonds, pers. comm.).
At the present time, the majority of industries contributing
heavy metals to the sewer system are in compliance with
regulatory standards. The source control program is,
for the most part, considered by the city to be effective
in controlling these heavy metal contributions (Edmonds,
pers. comm.).
284
-------
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
1220 S. W. Third Avenue, 16th Floor, Portland, Oregon 97204
August 15, 1978
Mr. Roger K. Mochnick, M/S 443
201 EIS Coordinator
U. S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Mochnick:
Thank you for the opportunity to review your draft environmental
impact statement "Sewage Sludge Disposal for the City of Portland
Oregon."
We have reviewed the document and submit the following comments for
your consideration.
The document represents the findings of a very thorough study and
presents all aspects pro and con on the subject. A good presentation
of unresolved issues is provided on page 173.
1. Pages 16 and 127 state mean annual precipitation for the Morrow
County Sites is five (5) to seven (7) inches. We could find no
weather stations in "Climate and Man" or "Temperature and Water
Balance for Oregon Weather Stations," Special Report 150, May
1963, Oregon Agricultural Experiment Station, Corvallis, Oregon,
that were less than seven and one-half (7^) inches for this area.
(Umatilla is 7.8", Arlington is 8.8", Ella (Morrow Co.) is 9.14",
Morgan (Morrow Co.) is 8.04".
2. Page 16. "The evapotranspiration rate exceeds forty (40) inches
in most years." According to Special Report 150 (see above),
Arlington and Umatilla rarely exceed thirty (30) inches. The
figure of forty (40) inches or more is from pan evaporation and
evaporation from soils plus transpiration from plants would be a
smaller figure.
3. Pages 148 and 156 - is a statement . . these soils are con-
sidered to be marginal for the production of wheat, grass and
alfalfa." Page 156 follows up with: "The use of sludge for
growing those crops would therefore represent a major benefit
in terms of increased productivity." Based on statements on
285
-------
RKMochnick
2
August 15, 1978
pages 165, 35 and 37, the latter would be true only if the soils
were irrigated, and under irrigation these soils, without sludge,
are not marginal for the production of wheat, grass and alfalfa.
4. Page 92, first paragraph. There is an inference that sludge could
be substituted for limestone because the sludge produced by the
B.E.S.T. process has a pH of 9.4 to 10.4, which is due to the use
of potassium hydroxide as a pretreat chemical. The use of this
type of sludge was for the Willamette Valley. Calcium would have
favorable effects other than amelioration of low pH. Some of
these favorable properties are not associated with potassium.
5. Concerning heavy metals, pages 35, 36, 37, 135, 136, 147, 161 and
165. The two most limiting constituents are zinc and cadmium
(page 161). The use of sewage sludge for growing root crops, such
as potatoes, is unacceptable (pages 35 and 147). A considerable
acreage is in a wheat/potato crop rotation. Alfalfa is grown in
a rotation with wheat (page 35). Pasture is also grown in a
rotation with alfalfa and wheat (page 35). If alfalfa and pas-
ture are ever in a rotation with wheat and potatoes, the amount
of acreage for sludge disposal may be quite limited. Is there a
known timespan that is acceptable for growing potatoes after a
sludge application on an earlier pasture or hay crop?
6. We found no discussion concerning the accumulation of heavy metals
in the soils receiving sludge application that would reflect the
variable of grazing versus harvesting of crops by other means.
We believe the heavy metals will accumulate at a faster rate,
other factors being equal, on grazed pasture than on land where
these elements in a harvested crop are removed from the land.
It should be possible to calculate zinc and cadmium budgets that
will reflect this difference.
If you have questions concerning these comments, please contact us.
Sincerely,
i_
State Conservationist
cc:
R. M. Davis, Administrator, SCS, Washington, DC
Director, Office of Federal Activities, EPA, Washington, DC
286
-------
Response to Comments from the USDA Soil Conservation Service -
August 15, 1978
1. Correction made in text as requested.
2. Correction made in text as requested.
3. Correction made in text as requested.
4. Comments noted. After further consideration of the B.E.S.T.
process, it appears that potassium hydroxide in dried
sludge may not be an appropriate substitute for calcium
carbonate.
5. Page 154 quotes from DEQ regulations that "no root crops
or low-growing fruit and vegetable crops which are edible
when raw should be grown on land fertilized with liquid
sludge for a period of 1 calendar year from date of
application".
6. No data are available to confirm this belief. Heavy metal
accumulations would most likely be related to site-
specific parameters such as crop type, weather conditions
and soil types and would therefore require detailed
analysis. A site-specific monitoring program would provide
information of this nature.
287
-------
CRAG
Columbia Region Association of Governments
527 S.W. Hall Street Portland, Oregon 97201 503/221-1646
July 7, 1978
RECEIVED
JUL 1 3 1978
EPA^~
Denton U Kent
E-ie< uiife Director
Regular Members
Clackamas County
Barlow
Canby
Estacada
Gladstone
Happy Valley
)ohr»sun City
l-ake Oswego
Milwauktr
Molalla
Oregon Oty
Rivernrove
Sandy
West l.jnn
Wilsonville
Multnomah County
C.resham
Maywood Park-
Portland
7 routdalf
Wood Village
Washington Cownfy
Hanks
Beaverton
C orndius
Durham
Ftirest (,n»ve
C .jston
Hillsbnro
King ( Uy
N'orth Plains
She/wood
T igard
Tualatin
Associate Members
Clark C ounty
Vancouver
5l Helens
Port of Portland
Tri Met
Fiaif of Oregon
Ex-Officio Member
State of Washington
Z
Mr. Roger K. Mochnick
"2 01" EIS Coordinator
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
SUBJECT: Draft EIS Sewage Sludge Disposal for the City
of Portland, Oregon
Dear Mr. Mochnick:
The Columbia Region Association of Governments (CRAG)
staff has reviewed the above referenced document and
provides the following comments for your consideration:
. The operation and maintenance cqst listed for the
BEST Sludge Drying System on table F-5 and F-8,
pages 217 and 220, respectively, are incorrect.
The appropriate cost should be $1,507,000 as shown
on page 216, not $1,362,200. As a result, the
total present worth of $26,573,800 for sludge
drying is incorrect.
. Alternative A (barging to Morrow County) should be
the favored alternative because the low cost, ease
of implementation, beneficial impact as a soil
conditioner and fertilizer outweigh the potential
adverse impact of sludge spills and the short-term
impacts of facility construction, assuming proper
care is taken in the construction and operation of
the facilities associated with this alternative.
. Alternative C (Sludge Drying System) should be
selected if a guaranteed market could be found
which would significantly reduce the annual operating
cost of the system. The BEST System appears to
have the lowest capital cost." However, potential -
problems associated with the mechanical drying
process, development of a market for the product,
and disposal of the product if no market can be
288
-------
Roger K. Mochnick
July 7, 1978
Page 2
developed indicate the potential revenue should be
significantly high to justify selection of this
alternative.
. Alternative D (Land Application in Willamette
Valley) is not recommended for consideration.
Previous studies by the City of Portland and CRAG
have rejected this alternative. The EIS identifies
several significant adverse impacts including
higher costs, institutional problems of dealing
with 50 to 100 land owners for sludge disposal,
aesthetic problems associated with a nine-acre
sludge storage lagoon, and increased truck traffic
with the associated air pollution and potential
for sludge spills in the City of Portland and
Clackamas County.
. The "No Action" Alternative is not acceptable
because of the short-term nature of this alternative
and the potential health problems with disposal
sites that are no longer available.
We encourage the Environmental Protection Agency to act
promptly in supporting Alternative A or C by offering
grant assistance to the City of Portland for construction
of the ultimate sludge disposal facilities. If you
have any questions regarding these comments, please
contact Dan Hodge of our staff.
Qi nporol \r
DUK:DH:be:03
5/9-10
cc: John Vlastelicia, EPA Oregon Operations
Cowles Mallory, City of Portland
289
-------
Response to Comments from the Columbia Region Association of
Governments - July 7, 1978
1. Corrections made as requested.
2. Comments noted.
290
-------
CH2M
55 H LL
engineers
planners
economists
scientists
21 July 1978
P1 1638.BO.90
Mr. Roger K. Mochnick
201 EIS Coordinator
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Subject: Draft EIS Sewage Sludge Disposal for
the City of Portland, Oregon
Dear Mr. Mochnick:
CH2M HILL, as consultant for Clackamas County, has reviewed
the draft EIS and is pleased to see that this report has
been revised since its preliminary form to better represent
what a North Willamette Valley alternative (D) probably
would look like. There still are a few minor points worth
commenting on.
• On page 166 the report indicates that there are
250,000 acres of suitable land in Clackamas
County for sludge application. It should be em-
phasized that this is 250,000 acres containing
suitable "soils" and that considering land use,
roads, forests, etc., these are considerably fewer
acres of land available for sludge application.
• The location of the Willamette River barge unload-
ing dock for Alternative D continues in this draft
report to be located just south of Oregon City.
Such a location would also infer that the storage
lagoon would also be nearby. Such a location would
tend to conflict with areas presently used and
projected for further use by the Clackamas County
plants. The unloading dock should probably be
2-
291
Portland Oil...200 S \V MaikH Stni't. 12th floor. Portland. Orison 97201 503/224-9190 TWX: 910/464-4720 Cable: CH2MHILL TELEX: 36-0103
-------
Mr. Roger K. Mochnick
Page Two
21 July 1978
P11638.BO.90
located further upstream in order to be closer
to the land that Portland should consider for sludg
application. Also, the lagoon was indicated as
2 being 9 acres in size which is drastically smal-
ler than the City's facility plan originally indi-
cated and undoubtedly much smaller than would be
required.
• Finally, Figure 7 has the Kellogg Creek plant mis-
sJ located and has omitted the Oak Lodge, Oregon City
and both West Linn plants.
Reading the EIS report it is now evident that from environmen
tal as well as economic reasons Alternative D should be re-
jected from further consideration. Also, as indicated in
our review of the preliminary draft (Letter 10 March 1973),
implementation of Alternative D would severely jeopardize
the existing, successful land disposal operations carried out
by the Oak Lodge and Oregon City plants as well as possible
proposed operations for the Kellogg Creek and Tri-City plants
Please contact us if you have any questions regarding these
comments.
Sincerely,
CH2M HILL, INC.
Randall C. Naef
Project Engineer
RCN/h
cc: David Abraham
Jeanette Norman
292
-------
Response to Comments from CH2M Hill - July 21, 1978
1. Correction made as requested.
2. Comment noted. The viability of Alternative D has been
substantially reduced since publication of the Draft EIS;
therefore, no attempt has been made to resize storage
lagoons or locate more appropriate barge off-loading
sites.
3. Corrections made as requested.
4. Comments noted.
293
-------
^JESdI) United States Department of the Interior
OFFICE OF THE SECRETARY
PACIFIC NORTHWEST REGION
500 N.E. Multnomah Street, Suite 1692, Portland, Oregon 97232
August 4, 1978
Mr. Roger K. Mochnick
201 EIS Coordinator
U. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
ER-78/540
WJ6 ?
Dear Mr. Mochnick:
This is in response to your request that the Department of the
Interior review and comment on the Draft Environmental Statement
for Sewage Sludge Disposal for the City of Portland, Oregon.
General Comments
Our review found that the draft statement, in general, adequately
discusses the impacts of the project. '
Specific Comments
Page 29, fourth paragraph. The target area of the U. S. Navy Bombing
Range, because it has been relatively undisturbed, contains many
examples of native grasses and forbs which are fast disappearing
elsewhere.
Page 31, Fishery Resources. Coho salmon should be included as a
species of major importance upstream of Portland.
Page 33, fourth paragraph. The Fish and Wildlife Service is currently
conducting a long-billed curlew nesting study in Eastern Oregon. The
Navy Bombing Range is the major study site.
Page 113, first paragraph. Fish hatcheries on or close to the main
stem Columbia in the area under consideration are Bonneville, Oxbow,
and Cascade hatcheries in Oregon and Spring Creek and Little White
Salmon hatcheries in Washington. The Washougal and Willard hatcheries
are some distance upstream on tributaries.
i
294
-------
Page 128, last paragraph. The environmental statement should clearly
indicate at least general plans for ground-water monitoring to accompany
each alternative involving land application or disposal. This is perr
haps implied by the discussion of monitoring required on some existing
projects by the Oregon Department of Environmental Quality, but monitor-
ing should be stipulated for the proposed action. Further, the state-
ment should address the possible avenues of remedial action to be taken
if contamination of ground water is detected. The potential for infiltra-
tion of contaminants from sludge in temporary storage lagoons—as under
alternatives D-l and D-2—should be addressed and mitigation proposed if
necessary. References to additional monitoring projects of the Oregon
DEQ are found on pages 138, 140, 163, and 164.
Page 151, second paragraph. Displaced wildlife species are considered
lost. Since adjacent habitats are normally at carrying capacity, intro-
duction of displaced animals means eventual loss of the additional numbers
of animals and, in extreme cases, reduction of carrying capacity.
Page 157, Mitigation Measures. It is suggested that this section include
mitigation for loss of wildlife habitat.
Page 165, third and fourth paragraphs. The Fish and Wildlife Service
believes that the target area portion of the U. S. Navy Bombing Range
should not be used for sludge disposal due to the importance of this
large acreage of native vegetation and the wildlife species dependent
upon it.
Page 167, Unavoidable Adverse Impacts—Table '
Construction. The permanent loss of wildlife and wildlife
habitat under alternatives A and D should be included in the
table.
Sludge Disposal. Wildlife habitat should be included under
alternative A since it is, in effect, lost as it is converted
to habitat used by few wildlife species.
Cultural Resources—Appendix E. Although an archeological survey has
been completed which adequately addresses the possible effect of the
pipelines and docks on cultural resources, the archeological values of
the selected disposal area should be investigated. The disposal of
sewage sludge may contaminate the site severely, limiting the scientific
value of potential archeological resources.
The procedure for the investigation should be determined in consultation
with the Oregon State Historic Preservation Officer and documented in the
final EIS. The procedure could, where appropriate, exclude significant
295
-------
archeological areas as unsuitable for sludge disposal. The State
Historic Preservation Officer for Oregon is Mr. David G. Talbot,
Superintendent, Oregon State Parks, 525 Trade Street SE, Salem,
Oregon 97310.
We appreciate the opportunity to review and comment on this document.
Sincerely yours
Charles S. Polityka
Regional Environmental Officer
296
-------
Response to Comments from the U. S. Department of the Interior -
August 4, 1978
1. Additional information and corrections included as requested.
2. The Environmental Protection Agency has determined that
a groundwater survey will be necessary prior to the
award of any Step 3 construction grant funds. The
"Preface" page i outlines EPA's requirements.
The viability of Alternative D has been substantially
reduced since publication of the Draft EIS? therefore,
no attempt has been made to study this alternative in
greater detail. In any event, it is likely that storage
lagoons would be sealed to prevent any leakage of sludge
contaminants to groundwater.
3. Corrections made as requested.
4. Because availability of sludge was not considered a
determining factor in agricultural expansion on Boeing
property, it was judged that regional losses of wildlife
habitat attributable to this project would be minimal.
Use of sludge to stabilize sand blows would possibly
create new wildlife habitat.
As stated in the Summary, proposed off-loading sites and
pipeline routes at Threemile and Sixmile Canyons have been
dropped from consideration due to significant wildlife
use of these areas.
5. Comments noted.
6. Corrections made as requested.
7. Comments noted.
297
-------
Public Statement of Paul S. McGough, Vice President - Product Development,
Resources Conservation Co., Seattle, Washington
Ladies and gentlemen, my name is Paul S. McGough. I am Vice President -
Product Development with Resources Conservation Co. RCC is the developer
of the B.E.S.T. sludge-drying system in the analysis of alternate sludge
disposal systems in the draft E.I.S.
Aside from some detailed corrections and comments to the draft which are
contained in the appendix to this statement, it is my belief that the
positive aspects of resource recovery by the beneficial use of sludge on
land should be emphasized.
A review of the EIS draft leads persons who are resource recovery-
oriented to commend both the City of Portland and the Environmental Pro-
tection Agency for the thorough effort made to explore means of beneficial
use of sludge on land.
Our efforts in support of the City of Portland have been to provide what
we believe to be a least-cost approach to dewatering and drying sludges,
putting them into a form that is usable as a bulk organic fertilizer.
Pilot tests conducted in the past year have proven that economical dewater-
ing and B.E.S.T. drying can be accomplished. B.E.S.T.-dried solids are
granular, pathogen-free and free-flowing. Handling and transporting these
solids present no environmental hazards.
The pilot tests also show that Portland sludges can be dried with minimal
environmental impact and can provide the residents in the Portland service
area a beneficial material.
298
-------
- 2 -
Although the marketing analysis in this draft is not complete, especially
the portion related to the value of product solids, we estimate that if
each resident of the City of Portland were provided the opportunity to
purchase a fifty pound bag of the product solids as an organic fertilizer,
an approximate 20 percent reduction of the city's operating and mainten-
ance cost of the entire sludge-handling system could be realized. Based
on information obtained from regional and national fertilizer distributors,
these products do have value and are in demand.
In any event, the solids marketing section included in the EIS draft should
be developed in significant depth to ascertain the basic value of the dry
solids and their most beneficial use. These recovered values to Portland
could then be reflected in the economic evaluation for final alternate
system selection. , »
This can be a great opportunity to establish a major milestone in promoting
the national goal of resource recovery while providing the City of Portland
an economical and environmentally sound method for sludge disposal.
299
-------
APPENDIX
page 86, 2nd paragraph, line 8 - change 0.3 percent to 3.0 percent,
page 90, last paragraph, first line, change "A B.E.S.T. process type..."
to read, "A dry "
page 91, second paragraph, should add that one blender's use of 3,000
tons per year is 20 percent of initial solids output at Portland.
page 105, fourth paragraph, change 47 to 9.6.
page 106, Air Emissions, second line, delete hot air.
page 107, first paragraph, should read..plus cooling water used in the "
page 108, second paragraph, last sentence on pelletizing should be deleted. ,
B.E.S.T. solids will not require pelletizing.
page 129 - Alternative "C„" Should read, "...odors would be most associated
with non-condensibles being vented. Also, deTete centrifuge and from
line 3.
page 130, Alternative "C„" This statement is incorrect. The B.E.S.T.
solids are in granular form. The Carver-Greenfield solids are in a
powder form, requiring pelletizing.
page 147, Alternative "C." It is not recommended that dry solids
be landfilled. This is not the best use for these solids.
page 154, third paragraph, line 3, question the 15 percent nitrogen
value. More likely five percent,,
page 211. Present cost for electrical energy is $0.0125/kWhr. Present
cost for thermal energy is $2.20/tef (actual gas).
page 216. EIS used 7 percent capital amortization versus 6 1/8 percent
in Portland study. Is this correct?
300
-------
P.O. BOX 3766. SEATTLE. WASHINGTON 98124
August 3, 1978
Ms. Alexandra Smith
Chief, Environmental Evaluation Branch
Region X EPA Headquarters
Seattle, Washington 98101
Dear Ms. Smith:
The attached pages document our official comments to the draft Environmental
Impact Statement related to Sewage Sludge Disposal for the City of Portland,
Oregon.
In addition to these detailed comments, we would like to add for your consid-
eration a concern we have with regard to the marketing section of the document.
The Environmental Protection Agency and other resource recovery-oriented
groups are stressing the recovery and reuse of materials that have end-use
value. Municipal sewage sludge is certainly such a material. The current
draft EIS contends that the market for Portland sludges is the "local area."
We do not concur in this position. Many of the citjes that are currently
drying and marketing their sludges are distributing the products outside the
local area, and current indications are that the demand exceeds supply. Fur-
ther, the products have sufficient value to sustain high transportation charges
to get them to their ultimate markets. This is a current condition. As natural
gas feedstocks become more scarce and thus more expensive, the market demand and
hence price for organic fertilizers will significantly increase.
We would therefore strongly recommend that the market report be modified to
consider the use of Portland sludge outside the local area.
I would like to take this opportunity to commend the persons from your office
for the excellent manner in which this evaluation has been conducted. The
City of Portland, Region X'and the nation as a whole are better served because
of a job so well done.
If you should have any questions concerning comments contained herein or about
our process, please feel free to call me at any time.
Paul^S. McGoug/
Vice President - Product
Development
Attachments
301
-------
ATTACHMENT
Page 86, second paragraph - The potassium level of B.E.S.T. dried solids
would be 3.0% due to the use of KOH pretreat
as compared with 0.3% for solids dried by
conventional methods.
Page 90, last paragraph - "A B.E.S.T. process type" should be changed
to read "A dry" as this paragraph applies to
dry solids produced by any method. Recognition
should be given to B.E.S.T. solids' higher
potassium level.
Page 91, second paragraph - Reference should be made to the fact that
3,000 tons is 20% of Portland's annual output
and thus represents a substantial commitment
for disposal of dry solicis.
Page 105, fourth paragraph- The B.E.S.T. process requires 9.6 kWh/ton-
not 47 kWh/ton.
Page 106, Air Emissions Delete the words "hot air" as the B.E.S.T.
process does not dry by using the "hot air"
method.
Page 107, first paragraph - Add the adjective "cooling" to water in
the first sentence.
Page 108, second paragraph- Delete references to pelletizing as B.E.S.T.
solids do not require pelletizing. They are
in a granular form as they come from the dryer.
302
-------
9
Page 129
Alternative "C". The first sentence should read, "...odors
would be most associated with the noncondensibles being
vented." Delete reference to centrifuge from line 3.
Page 130 -
Alternative "C". This statement is incorrect. The B.E.S.T.
solids are in granular form while the Carver-Greenfield
solids are in a powder form (requiring pelletizing). There
is a distinct difference in appearance and in form.
Page 147 -
Alternative "C". While dry solids can be landfilled, this is
not a recommended use.
Page 154, Third Paragraph - The 15 percent reference to nitrogen value is
very high. A five percent figure would be more plausible.
Page 211 - The present cost for electrical energy is $0.0125/kWhr. The
present cost for thermal energy is $2.20/tcf (natural gas).
303
-------
RESOURCES CONSERVATION CO.
P.O. BOX 3766. SEATTLE. WASHINGTON 98124
August 7, 1978
Ms. Alexandra Smith
Chief. Environmental Evaluation Branch
Region X EPA Headquarters
Seattle, Washington 98101
Dear Ms. Smith:
In addition to those comments sent you in my letter dated 3 August, 1978,
please add the following:
Page 73 - Third paragraph - Alternative C - Blended Diqested Sludqe
Drying for Fertilizer Production.
/ +
First sentence should read
and dewatered using belt filter presses.
Fourth paragraph should be deleted. This was not a
recommended alternative.
15
Page 79 - Only one "C" (B.E.S.T.) alternative was proposed, which
was C no subscript. All others should be deleted.
Page 80 - Narrative description of C* should replace narrative
description for C and C* and C2 should be deleted.
Page 85 - Figure 11 - Schematic Diagram for Alternative C1.
Incorrect. Should be replaced with attached flow diagram.
Very truly yours,
/ (o
17
Paul^5. McGoifgh
Vice President - Product
Development -
PSM/jm
Attachment
304
Resources Conservation Co. is owned by affiliates of Reading & Bares Offshore Drilling Company and "Pie Boeing Company.
-------
SCHEMATIC DIAGRAM
FOR ALTERNATIVE C
305
-------
Response to Comments from the Resource Conservation Company -
July 21, 1978
1. Comments noted.
2. Corrections made as requested.'
3. This statement refers to both B.E.S.T. and Carver-Greenfield
solids being similar in appearance to many soil conditioners.
The text has been corrected to elucidate this point.
4. Comment noted.
5. Comment noted.
6. The unit cost values used in the Draft EIS (electrical
energy at $0.01/Kwh and fuel at $1.90/tcf) are the same
as those used in the Facility Plan. These unit values
were not altered in the interest of consistency.
7. The 7 percent interest rate used in the Draft EIS was to
establish the estimated costs to the city, and is based
on the rate that many bonds have been sold recently.
In other words, it is a typical value.
The 6 1/8 percent rate used in the Facility Plan is
mandated by the EPA for determining the Present Worth
Cost. This rate is now 6 5/8 percent, which was the rate
used in the Draft EIS. The Present Worth Cost does not
include any funding and is a measure of the cost to
society. However, the local costs do include funding
and assure that the city will borrow the local share
through bonding or other similar method. The typical
rate for municipal borrowing is 7 percent.
8. Comments noted.
9. Corrections made as requested.
10. See Response 3.
11. Comment noted.
12. Comment noted.
13. See Response 6.
14. Corrections made as requested.
15. The alternatives presented in the EIS are not and were
not represented as recommended alternatives. They represent
only the alternative sludge systems that were considered
during the course of study for both the Facility Plan
and the Draft EIS.
306
-------
The specific alternative referred to by Mr. Paul S.
McGough is described on page 238 of the Facility Plan
and was considered during the facility planning study.
16. See Comment 15. Additionally, Alternative C-2 is described
on page 250 of the Facility Plan. It too, was one of the
many alternatives considered in this study.
17. Figure and text corrected as requested.
307
-------
Arthur Forsyth Company
2035 Southwest 58th
Portland. Ore3on 97221
(503)297-3121
f fi'
August 2, 1978
Roger K. Mochnick, M/5443
201 EIS Coordinator
U.S. Environmental Protection Agency, Region X
1200 Sixth Ave.
Seattle, WA 98101
Subject: Response to Draft
EIS Sewage Sludge
Disposal for the City
of Portland, OR.
Dear Mr. Mochnick:
Enclosed are comments and questions from Dehydro-Tech
Corporation regarding references in the Draft EIS to
their Carver Greenfield process. Also we have included
a copy of the L.A. City-LAOMA Pilot Plant Study and
copies of equipment lists, capital costs and economics
for Digested and Undigested sludge plants. This has
been developed for Bergen County, New Jersey.
In addition, we have included a list of kludge plants
which show a history of operation.
We appreciate the opportunity to present the attached
information.
TT «_ _ . . 1 __
RJN/dw
Enc.
cc:Mr. C. Greenfield - Dehydro-Tech
308
-------
REFERENCES TO ENVIRONMENTAL IMPACT STATEMENT
--DRAFT OF E.P.A.-JUNE 1978--
1. With reference to Alternative III - CI Carver-Greenfield Process,
we can establish Capital and O&M costs for the Portland operations
similar to those we developed and described in our letter of
October 14, 1976, with attachments of Capital and O&M costs. We
do not know what Portland requires. Perhaps they are interested
in obtaining LAOMA's view of costs.
2. The schematic diagram for Alternative C-l - Figure 11 is entirely
workable for the C-G Process as well as Figure 12 marked "Schematic
Diagram for Carver-Greenfield Process Alternative. The Carver-
Greenfield Process can also utilize vacuum filtration sludge
which is shown in attachments sent to Portland on October 14, 1976.
2. Under the caption on page 86 of the report marked Carver-
Greenfield Process, reference is made that the manufacturer
claims that jthe water removed is virtually "distilled" in quality
and "that considerable evidence exists to support the contrary".
We do not fully understand this reference, but other than the
water containing dissolved volatile organics the water with
regards to salts and heavy metal content is of distilled grade.
We have had samples of distilled water from our process that
shows C.O.D. 's as low as 100 to 200. However, if sludges are
septic or badly decomposed they can have values of up to 2000
or even higher. Our data indicates that a 1000 C.O.D. is typical.
We further wish to emphasize that this water returned to the
treatment plant is rapidly biologically oxidized without any
significant treatment plant load. This can be verified by LAOMA.
Further, such treatment can be utilized to produce a high quanity
organic free and mineral free water equivalent to distilled water.
We are enclosing the following references:
1. Los Angeles report
2. Dr. Parrels letter report
Further to the discussion of the Carver-Greenfield alternative on
page 86, reference is made as follows: "After removal of the
remaining oil, a portion of the dry solids are pyrolyzed to provide
energy for the multi-effect evaporator". This is certainly true,
however, in our economic studies described in our October 14, 1976
letter we did not pyrolyze any solids but assumed sufficient oil
could be extracted by the process to pi>ovide the fuel and thereby
the steam for the evaporator system. If we pyrolyze the dry solids
the electrical energy costs would be zero and a substantial
electrical energy quantity would be generated. We are enclosing
data for a plant of 43.5 tons of digested sludge and 75 tons per
day of undigested sludge showing the energy produced
309
-------
On page 87, a Cost Analysis caption is referred to for the
Carver-Greenfield Process. Here3 again} we are perplexed by the
electrical generating equipment installation since no reference
has been given for pyroly sis gas turbine or steam turbine for
generating electricity or credit given for electrical energy
produced.
--also see reference to energy requirements of the Carver-
Greenfield Process on page 105.
On pjage 107 under the caption Recycled Water, the Carver-
Greenfield Process is referred to having oil remaining in the
recycled water (back to the treatment plant). Utilizing a
coales cer this oil is recovered and what remains is negligible.
The water is clear and bright.
On page 108 (top of page) we note the following: "The Carver-
Greenfield Process has also had a short history of pilot plant
application with no full experience handling sewage sludges."
We are enclosing a list of plants which does describe a history
of successful operating plants particularly Barsheys Fukuchiyama
and Coors.
On page 177 (on footnotes) reference is made to a San ^Francisco
report of November 1977 on Carver-Greenfield Process. We are
writing for a copy of this report. We wonder if the economics
shown on page 218 and 219 are derived from this report.
310
-------
Response to Comments from the Arthur Forsyth Company -
August 2, 1978
1. Comment noted.
2. Comment noted.
3. The information regarding the impurity of the water was
based on the San Francisco wastewater solids study.
Also, by virtue of the comments in this letter, the water
is contaminated and therefore could not be considered
"distilled".
The results of the pilot plant work at LAOMA and the
letter of October 14, 197 6, which is constantly referred
to, were not available to the EIS consultant. We
have no argument with the concentration of contaminants
in the recycled water or that they are biodegradable. We
are only trying to describe the process in relatively
simple terms.
4. The electrical generating equipment is proposed for inclusion
in several of the alternatives and is to be operated
from the digester gas. It has nothing to do with the
Carver-Greenfield process.
5. See Comment 4.
6. Comment noted.
7. The intent of the passage referred to was, "no full scale
experience handling municipal sewage sludges". The
Coors plant is a brewery waste. We are not familiar with
the other two installations mentioned.
8. Comment noted."
311
-------
Date
Received
Table 33
Public Hearing Testimony
Speakers
1 FEDERAL POLICY
ENERGY
SLUDGE MARKET
i AGRICULTURE
1 GROUNDWATER
! SLUDGE TRANSPORTATION/SPILLS
SOILS
! WATER QUALITY
AESTHETICS
LAND USE
SLUDGE PROCESSING
VEGETATION
DRINKING WATER
SLUDGE COMPOSITION
SECONDARY IMPACTS
FISH AND WILDLIFE
SLUDGE APPLICATION
ALTERNATIVES
SLUDGE DISPOSAL
HISTORIC PRESERVATION
SLUDGE REUSE
METEOROLOGY
FLOOD HAZARD
CONSTRUCTION IMPACTS
STATE PERMITS
DISPOSAL SITES
7/21
Paul S. McGough
X
X
X
Leeanne 6. MacColl
X
X
X
X
X
X
George D. Ward
X
X
X
X
X
X
X
X
X
7/20
Glenn Ward
X
X
X
X
X
1
•
•
-
1
-------
Public Hearing Summary
On July 20 and 21, 1978, the EPA held public hearings
on the Draft EIS for the proposed City of Portland sewage
sludge disposal system. The July 20 hearing, held in
Boardman's high school, was attended by five people, while
the July 21 hearing, conducted at Portland's city hall,was
attended by about 20 people. Because of the costs involved,
we have not reproduced the document for this Final EIS. A
table is provided, however, which lists the speakers and the
specific areas in which they were most concerned. The
public hearing record is available for review at EPA's Oregon
Operations Office in Portland and EPA's Region 10 Office in
Seattle, Washington.
Following is a summary of the speakers' remarks at the
two hearings:
The July 20 hearing in Boardman, Oregon:
Mr. Glenn Ward of the Oregon Department of Fish and Wildlife,
was the only public participant at the hearing, and his remarks
were made during the question and answer period. His
questions and comments were primarily concerned with potential
wildlife displacement and perturbation caused by the project,
in particular the effect of an off-loading dock at Threemile
Canyon near Boardman, on a population of Caspian terns and
ring-billed gulls nesting there. As a result of Mr. Ward's
reservations on the Threemile Canyon dock site, EPA has
subsequently withdrawn that site from consideration.
The July 21 hearing in Portland, Oregon:
Mr. Paul S. McGough, vice president of Product Development
for Resources Conservation Company (RCC), discussed sludge
recovery and marketing for use as a bulk, organic fertilizer.
Mr. McGough explained that pilot tests had proven the effectiveness
of the B.E.S.T. process developed by RCC in producing an
environmentally acceptable, indeed desirable product. He
endorsed a reassessment of the marketing analysis, in particular
the basic value and market demand of the dry solids and their
impact on the economic evaluation for final alternative system
selection.
Ms. Leanne G. MacCall, speaking for the League of Women
Voters of Portland, recommended Alternative A-l based on the
following factors: 1) favorable land availability, climate
for sludge application, and opportunity to enhance soil
conservation in the Boardman area; 2) the economic and envir-
onmental unacceptability of alternative schemes. Ms. MacCall
also suggested that EPA move to reduce the amount of heavy
ir.etals incoming to the sewer system from industry to the
fullest extent possible.
313
-------
Mr. George D. Ward, a consulting engineer representing the
Land Use Research Institute, endorsed sludge conservation and
utilization, especially with regard to upriver barging. Mr. Ward
favored the interstate shipment of sludge to areas of need,
indicating that the application of European methods of sludge
concentration will brighten the prospects for its long-range
transportation and will impact true barge economy. Ward
recommends that the dispersement of sludge not be confined to
a single disposal site, but be made available to those areas
that need such material. On behalf of the Institute, Mr. Ward
supported the City of Portland's objective, stressing upriver
barging and agricultural utilization on a not-for-profit and
not-for-cost basis. Ward also resubmitted two documents
and added a third statement outlining the Institute's
position and philosophy.
A brief question, and answer period followed the speaker's
presentation. Mr. McGough asked Mr. Bernhard, an economist
for Gruen Gruen + Associates, the following questions:
1) if the value of product solids had been treated as a study
topic; 2) if demand for it outstripped supply; and 3) if sale
of the product solids versus a give-away program had been
considered? Mr. Bernhard responded that product solid value
had been discussed and that demand did exceed the potential
output of sludge. He added that in considering just the free
distribution of material, that this effectively lowered the
"uncertainty" as to the ability to get rid of it.
EPA wishes to thank each of the participants at the public
hearing for expressing their views and concerns. Additional
information as a result of the hearing has been added to this
Final EIS.
314
------- |