United States Region 10
Environmental Protection 1200 Sixth Avenue
Agency Seattle WA 98101
Water July 1979 EPA - 10 - Wa - City & Co Spokane - CSO - 79
Environmental Final
Impact Statement
City of Spokane
Combined Sewer Overflow
Abatement Project
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FINAL ENVIRONMENTAL IMPACT STATEMENT
City of Spokane, Washington
Combined Sewer Overflow
Abatement Project
Prepared By:
U. S. Environmental Protection Agency
Region X
Seattle, Washington
With Technical Assistance From:
Jones & Stokes Associates, Inc.
2321 P Street
Sacramento, CA 95816
In Association With:
Culp-Wesner-Culp
fficial:
is '
rional Administrator
sgional Admin
JUL 3
Date
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TABLE OF CONTENTS
Page
Table of Contents i
List of Figures iii
Summary iv
CHAPTER 1 - INTRODUCTION 1
History and Purpose of Proposed Project 1
Purpose and Content of the Final EIS 1
CHAPTER 2 - SUMMARY OF PROPOSED ACTION 3
Sewer Separation 3
Project Timing and Funding 3
Relationship of Proposed Action to
Spokane's NPDES Permit Requirements 6
Mitigation of Proposed Action Impacts 6
CHAPTER 3 - GENERAL RESPONSES TO COMMENTS 9
Introduction 9
Wastewater Regionalization at the
Spokane Treatment Plant 9
Stormwater Treatment 10
Export of Wastewater to Crab Creek 12
Phasing of the Proposed Action 13
CHAPTER 4 - RESPONSES TO SPECIFIC COMMENTS 15
Introduction 15
Written Comments 15
U. S. Department of Agriculture,
Soil Conservation Service 17
U. S. Department of Army, Corps
of Engineers 20
U. S. Department of Housing and
Urban Development 22
U. S. Department of the Interior 26
U. S. Department of Transportation -
Coast Guard 30
Advisory Council on Historic Preservation 33
Washington Department of Ecology 36
Washington Department of Fisheries 38
Washington Department of Game 41
Washington Office of Archeology and
Historic Preservation 43
Washington Office of Financial Management 46
Washington State Parks and Recreation
Commission 50
Spokane Regional Planning Conference 54
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Spokane County Engineers 57
Spokane County Health District 61
City of Spokane Finance Department 65
City of Spokane Department of Public Works 6 7
City of Spokane Plan Commission 69
City of Spokane Public Utilities 75
City of Spokane Traffic Engineering
Department 78
Bovay Engineering, Inc. 85
Jake Klicker 90
Oral Comments 91
Roger James 91
James Schasre 91
Robert Smith 91
BIBLIOGRAPHY 93
TRANSCRIPTS OF PUBLIC HEARINGS ON DRAFT EIS 95
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List of Figures
Page
Figure 2-1 - Proposed Action - Phase 1 4
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SUMMARY
FINAL ENVIRONMENTAL STATEMENT — CITY OF SPOKANE
COMBINED SEWER OVERFLOW ABATEMENT PROJECT
Environmental Protection Agency
Region 10
120 0 Sixth Avenue
Seattle, Washington 9 8101
1. Type of Statement: Draft ( ) Final ( x )
2. Type of Action: Administrative ( x ) Legislative ( )
3. Description of the Action:
The waste water conveyance system of the City of Spokane
currently discharges untreated sewage to the Spokane River
with almost every rainfall or snowmelt. This happens because
the city conveyance and collection system carries both raw
sewage and stormwater, and the pipes in the system are too
small to carry the entire flow of sewage and stormwater to
the sewage treatment plant. To relieve the flooding problems
which would be caused by pipes overflowing during such conditions,
the combined sewage and stormwater or melt-water is discharged
directly to the Spokane River with no treatment. Such occurrences
are commonly referred to as a Combined Sewer Overflow or CSO.
Currently in Spokane during a rainstorm which would cause
a CSO to occur, some of the flow in the conveyance system
is treated by the City's advanced waste treatment plant,
some is discharged as a CSO directly to the river prior to
reaching any type of treatment facility. The system overflows
directly into the river at more than 30 points throughout
the city. CSO's contain raw sewage and therefore can cause
public health hazards and other water pollution and aesthetic
problems. The goal of the city's proposal is to remove the
stormwater from the sewage collection system so that the
sewage conveyance system will not overflow and discharge
untreated sewage to the Spokane River.
On March 5, 1979, the Environmental Protection Agency
(EPA) released a draft Environmental Impact Statement (EIS)
on the city's facility plan proposal to control and abate
CSO's. All of the alternatives in the city's facility plan
plus several others from outside sources were evaluated in
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the draft EIS. A number of public meetings were held during
the preparation of the draft EIS and public hearings were
held on April 19, 1979 although the agency accepted comments
after that date. Comments and EPA's responses to these
comments are included in this final EIS.
4. The preferred Alternative:
The preferred alternative is Alternative 3, construction
of a separate stormwater conveyance system. This would
separate stormwater from sewage; the sewage would continue
to be conveyed to the city's waste treatment plant but would
no longer enter the river untreated. The stormwater would
receive no treatment prior to discharge to the river.
To facilitate planning and funding of this alternative,
the proposed plan has been divided into two phases. Phase I
would commence this year and would involve eventual construc-
tion of a storm sewer system in the two drainage basins
which contribute the largest of the city's CSO's. Phase II,
separation of stormwater and sewage flows in other areas of
the city, would not commence until Phase I has been completed
and the results evaluated. Future city and county facility
planning would also be necessary prior to detailed desing
of Phase II. EPA will provide 75% and the State 15% of the
grant eleigible costs in Phase I. The city will provide the
remaining needed Phase I funds.
The major impacts of Phase I include construction of
about 120 miles of pipeline and removal of an estimated 84%
of the current annual volume of CSO to the Spokane River.
Disruption of traffic patterns could be a significant impact
during construction, however the city is committed to carrying
out construction in a manner to minimize such impacts. The
actual plans for such mitigation will be developed during the
design stage of this project. Removal of raw sewage from the
flows directly entering the river should reduce harmful
pathogenic material in the Spokane River and should improve
the aesthetical enjoyment of the river. The state will
require monitoring to determine the effectiveness of Phase I
and, with the city, will develop a schedule for future phases
of the project.
Removal of storm water from the treatment plant in Phase I
and II would allow the city to treat more sewage than it could
otherwise treat. This could allow the regionalization of
the plant. Use of the City of Spokane facility as a regional
facility will be evaluated at the appropriate state and local
levels. Decisions concerning timing and manner of regionali-
zation require more detailed design information than is currently
available. Information refined and developed during desigh
of Phase I will be used in the regionalization evaluation.
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5. Additional Alternatives Considered:
A variety of approaches which could control and abate
the CSO problem were evaluated for varying degrees of
control of CSO's. Some of these alternatives were originally
evaluated by the city in their facility play while others
were proposed later by private citizens.
The storage basin concepts (Alternative 1, the Klicker
Plan and several of the combination alternatives) would
still allow CSO's to occur, although not as frequently as
present. The storage basins would retain some of the combined
storinwater and sewage instead of directly discharging to the
river. The combined stormwater and sewage in the storage
basins would be gradually released back into the existing
conveyance system for eventual treatment at the city's
facility. As a result, neither the conveyance system nor
the plant would have the capacity to function as a regional
facility. In addition, the treatment of a relatively dilute
influent at a phosphorous removal facility is an inefficient
use of that facility.
Another approach investigated by the city was small
satellite treatment plants located throughout the city. CSO's
would receive primary treatment and chlorination at the satel-
lite facilities and would be discharged directly to the river.
Primary treatment of sewage would likely cause water quality
violations. The effectiveness of chlorination under these
circumstances is unknown. At the larger overflow points,
it could be extremely difficult to adequately disinfect the
large volumes of water that would have to be treated in high
runoff situations. Proper mixing and contact time may not
be available in the small satellite facilities. Also, the
capital and operation and maintenance costs are considerably
higher than with some of the other options.
A complete wastewater and stormwater export plan, the
Latenser plan, was considered. The system would have potentially
significant environmental impacts on the receiving stream
and would violate state water quality guidelines and policy.
This plan is also the most costly of the alternatives. Impacts
on the receiving water would include changing an intermittent
stream to a perennial stream, possible contamination of ground
water, possible contamination of drinking water supplies and
possible adverse impacts on the downstream fisheries.
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6. List of Agencies and Individuals that commented on the Draft EIS:
Written Comments
Federal
U. S. Department of Agriculture, Soil Conservation Service
U. S. Department of Army, Corps of Engineers
U. S. Department of Housing and Urban Development
U. S. Department of the Interior, Office of the Secretary
U. S. Department of Transportation, Coast Guard
Advisory Council on Historic Preservation
State
Washington Department of Ecology
Washington Department of Fisheries
Washington Department of Game
Washington Office of Archeology and Historic Preservation
Washington Office of Financial Management
Washington State Parks and Recreation Commission
Local
Spokane Regional Planning Conference
Spokane County Engineers
Spokane County Health District
Spokane City Finance Department
Spokane City Public Works Department
Spokane City Plan Commission
Spokane City Public Utilities
Spokane City Traffic Engineering Department
Individuals
Bovay Engineers
Jake Klicker
Oral Comments
Roger James - Spokane City Public Utilities
James Schasre - Lake Spokane Environmental Association
Robert Smith - Bovay Engineers
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7. List of Preparers of the Final EIS:
Jones and Stokes Associates, Inc.
Dr. Charles Hazel
Michael Rushton
Culp/Wesner/Culp
Dr. Robert Gumerman, P.E.
8. The following agencies and individuals were sent
copies of the final EIS:
FEDERAL AGENCIES
U. S. Department of Defense
U. S. Department of Housing & Urban Development
U. S. Department of Agriculture
U. S. Department of the Interior
U. S. Department of Health, Education, and Welfare
U. S. Department of Transportation
National Oceanic & Atmospheric Administration
Advisory Council on Historic Preservation
STATE AGENCIES
State of Washington Department of Fisheries
State of Washington Department of Game
State of Washington Office of Archaelogical and Historical
Preservation
State of Washington Department of Ecology
State of Washington Office of Financial Management
Washington State Parks & Recreation Commission
LOCAL AGENCIES
Spokane County Engineering Office
Spokane County Health District
Spokane County Planning Commission
Spokane Traffic Engineering Office
Spokane Planning, Programming, and Community
Development Department
Spokane Regional Planning Conference
Mayor of Spokane
Spokane City Manager
Spokane City Engineer
INDIVIDUALS AND OTHER GROUPS
Spokane Daily Chronical
Gonzaga Environmental Law Caucus
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League of Women Voters
Bovay Engineers
Spokane Public Library
We the People
Spokesman Review
National Wildlife Federation
Washington Archaeological Research
Dan Neal
James A. Schasre
Carl Maxey
Bob Eisenbart
Ray Aoltero
Jake Klicker
Larry Esvelt
William Dunmire
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Chapter 1
INTRODUCTION
History and Purpose of Proposed Project
The City of Spokane has applied to the State of Washington
and the federal government for grant funds to design and
construct improvements to its wastewater system. The city
recently constructed a new advanced waste treatment plant
on the Spokane River, but its combined sanitary and stormwater
collection system is not sufficiently sized to convey peak
wastewater and storm flows to the plant. As a result, un-
treated combined sewer overflows (CSOs) are discharged to
the Spokane River 80 to 110 times a year. The continuation
of CSOs is contrary to requirements of the city's National
Pollutant Discharge Elimination System (NPDES) permit, and
creates a public health threat to persons using the river.
The Washington Department of Ecology (DOE) which administers
NPDES permits, has ordered Spokane to eliminate CSOs. The
grant funds, made available through the Federal Water Pollution
Control Act (FWPCA, PL 92-500) and its successor, the Clean
Water Act of 1977 (PL 95-217), are being sought to design
and construct wastewater system improvements capable of bringing
the city into compliance with its NPDES permit and relieving the
public health threat.
Spokane initiated action in this regard by preparing
a facilities plan for wastewater system improvements. This
planning effort, completed in 1977, was funded in part by
state and federal grants. In order to comply with the man-
dates of the National Environmental Policy Act (NEPA), the
U. S. Environmental Protection Agency (EPA) was required
to prepare an environmental impact statement (EIS) on the
project before allocating grant monies to project design
and construction. The EIS was begun in May 1978 and the
Draft EIS was distributed for public review in January 1979.
Two public hearings on the draft were subsequently held in
Spokane on April 4, 1979. The EIS evaluated the project
proposed by the city and a variety of alternatives developed
in the planning process.
Purpose and Content of the Final EIS
This Final EIS has been prepared to respond to comments
and discuss environmental issues raised with regard to the
Draft EIS, as required by NEPA and its implementing guidelines.
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Recent changes to the Council on Environmental Quality (CEQ)
guidelines for preparing EISs allow the Final EIS to take
several forms. The Draft EIS can be revised in its entirety
to reflect project changes and/or public comment, or a supple-
mental document may be prepared that includes only comments,
responses to comments and changes in the Draft EIS. Because
it is felt that comment on the Spokane CSO Draft EIS did
not raise substantive new issues or create major changes
in the approach to solving the CSO problem, this Final EIS
has been prepared as a supplement to the Draft EIS.
This introduction is followed by a summary of the proposed
action and a number of issue-oriented statements that respond
to comments on the project's major environmental impacts.
A separate section responds to specific comments that could
not be readily categorized into general topics. All letters
of comment are included and transcripts of the public hearings
are attached at the back of the report.
Copies of the full Draft EIS may be obtained by: writing
to Mr. Roger Mochnick, U. S. Environmental Protectipn Agency,
Region Xf 1200 Sixth Avenue, Seattle, Washington 98101; or
contacting Mr. Dan Robison, Director of Environmental Programs
City Hall, Room 303, Spokane Washington 99201. Copies of
the report are also on file at the main branch of the Spokane
City Library, West 906 Main in Spokane.
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Chapter 2
SUMMARY OF PROPOSED ACTION
Sewer Separation
The proposed project to abate the sewer overflow problem
is to construct new storm sewer lines throughout the city.
These new lines will separate storm runoff from sanitary
sewerage and thereby reduce the hydraulic overloading
of existing lines. After construction, stormwater will flow
directly to the river rather than through the wastewater
treatment plant, and mainly sanitary sewage will flow through
the treatment plant.
The construction is expected to occur in two phases.
Phase 1 will include about 120 miles of pipeline construction
in the northern one-third of the city (see Figure 2-1). This
will eliminate the two largest CSOs, at Meenach Drive and
Hollywood. The city estimates about 84 percent of the current
annual CSO in Spokane comes from these two overflow points.
It will take about 5 years to complete Phase 1 construction.
The remaining 100 miles of new pipe will be installed in
following years. The exact time frame and location of sub-
sequent construction has not been established; the Phase 2
project will be reevaluated after the Phase 1 improvements
are completed and evaluated. At the appropriate time, the
Phase 2 project will receive additional engineering, economic
and environmental analysis as part of the planning process.
DOE will reevaluate the entire CSO project in terms of continued
commitment of federal and state funds at the completion of
Phase 1 (see their letter of comment in Chapter 4).
Project Timing and Funding
The sewer separation project has been divided into two
phases because funding is not immediately available for the
entire effort. This initial planning effort has sought to
remedy the public health threat created by overflows and
at the same time assess the Spokane treatment plant's ability
to function as a regional wastewater facility. Phase 1 of
the proposed action should result in an improvement in waste-
water contamination of the Spokane River, and at the same
time it starts the process of separating storm flows from
the sanitary wastewater conveyance and treatment system.
This will eventually free capacity in the system for transport
and treatment of additional wastewater sources.
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Fl GURE 2-1
PROPOSED ACTION-PHASE 1
-1-E1GEZ N D —
CITY LIMITS
PHASE 1 SEPARATE
SEWER CONSTRUCTION
AREA
MEENACH DR. OVERFLOW
DRAINAGE AREA
15 HOLLYWOOD OVERFLOW
DRAINAGE AREA
MILES
SOURCE from SPOKANE CITY DEPARTMENT
OF PUBLIC WORKS, 1977, EXHIBITS
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Step I of the construction grants process consists of
facilities planning. In this' project, the facilities planning
process considered the scope and nature of the CSO problem/
a variety of approaches which could be used for relieving
this problem, and the manner in which EPA could participate.
The proposed action is the approach judged to be the most
suitable for this project. The magnitude and extent of the
CSOs were estimated by the city in their facilities plan.
These figures will be reevaluated as detailed design begins.
Any decision concerning the scope of Phase 2 and any final
decisions on regionalization of treatment for areas not currently
served by the city system will be subject to that reevaluation.
Step II in the process of implementation will be design of
the facilities. According to the state priority list, grant
funds are available for this in fiscal year 1979. Funds
for Step III, actual construction of facilities, will be avail-
able in fiscal years 1980 through 1983.
The Draft EIS provided a relatively detailed explanation
of how Phase 1 costs were developed and allocated to federal,
state and local entities. The allocation of Phases 1 and 2
costs between the EPA, the state and the city was based on
EPA rules for funding of multipurpose projects, which are
defined as projects which solve more than just a water quality
problem. In the City of Spokane project, the storm sewers
would, in addition to solving the CSO problem, also solve
local sewer backup problems, drainage problems, and allow
regionalization of sewage treatment and disposal. Based
upon the allocation rules for multipurpose projects, the
Draft EIS presented a possible allocation of Phase 1 and
Phase 2 costs between EPA, the State of Washington, and
the City of Spokane. This allocation is presented in the
following table.
SUMMARY OF OBSTRUCTION COST SHARING*-PROPOSED ACTICN
Total Construction State of City of
Cost EPA Washington Spokane
Phase 1 $24,980,000 $18,740,000 $3,750,000 $2,490,000
Phase 2 39,070,000 23,430,000 4,680,000 10,960,000
Total $64,050,000 $42,170,000 $8,430,000 $13,450,000
* Allocations for Phase 1 were made assuning 75 percent federal funding,
15 percent state funding and 10 percent local funding because this first
phase was determined to be 100 percent eligible for grant funding. The
entire project was determined to be 87.8 percent grant fundable; this
accounts for the less than 75 percent federal participation in Phase 2.
It is important to note that Phase 2 sharing is only speculative at
this time because grant fund availability and priority for grant money
distribution is not kncwn more than 1 year in advance.
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The timing and funding for Phase 2 has not been developed
in detail because the availability of federal and state grant
money cannot be determined far enough in advance. It is
estimated that. Phase 1 construction will not be complete
for approximately 5 years, and grant allocations are not
established for more than 2 to 3 years in advance. Therefore,
a specific time frame and cost allocation cannot be predicted
at this time. In the interim, the effectiveness of Phase 1
construction can be monitored and more planning can be conducted
to clarify the effect of subsequent sewer separation on inter-
ceptor and treatment plant capacity. Proposed regional 201
planning can also further explore the timing and extent of
tying unsewered county areas into the city wastewater system.
Relationship of Proposed Action to
Spokane's NPDES Permit Requirements
The Washington DOE, which has issued and is responsible
for enforcing the city's waste discharge permit, has agreed
that sewer separation "is the most desirable option for abating
the problem of combined sewer overflows in Spokane" (see
their letter of comment on the EIS in Chapter 4). Also,
they remain committed to ensuring that all CSOs are eliminated
regardless of the availability of federal and state grants.
However, they are not committed to funding Phase 2 of the
separation at this time because of the uncertainty of grant
money in the future. The DOE indicates in their comments
on the Draft EIS that a schedule for sewer separation must
be developed. This schedule would become a part of the city's
NPDES permit.
Mitigation of Proposed Action Impacts
Many of the proposed project's potential impacts can
be reduced or eliminated by some mitigative action. Efforts
should be made by the city to minimize short-term construction
problems by adopting some of the following construction practices;
fugitive dust should be controlled by watering disturbed
surfaces, especially during windy periods; excavation, pipe-
laying and backfilling should occur in a continuous sequence,
avoiding long, open ditches and exposed spoil piles; excava-
tion along or across major traffic corridors should be planned
well in advance with the city traffic department and police
so that lane closures and blocking of access do not result
in major traffic congestion or create unnecessary safety
hazards; citizens should be notified prior to any utility
disruptions (gas, electricity, water) that might be necessary;
construction in the city's main commercial areas should be
scheduled to avoid peak business periods (e.g., major holidays)
whenever possible.
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Once a system of separate storm sewerjs is in operation,
stormwater runoff will be flowing directly to the Spokane
River without treatment. This will reduce hydraulic overloading
of the treatment plant and avoid costly treatment of nonsanitary
flows, but this runoff will contain a variety of materials
washed from yards, streets, and various paved areas. There
are a variety of measures which could be taken by the city
to help reduce the introduction of these types of materials.
This includes more frequent street cleaning, dry weather
flushing of catch basins, improved litter "control, screening
of storm outfall points, diversion of runoff for percolation
and recharge, use of porous asphalt in new construction areas,
improved control over used oil disposal, and investigation
of alternative deicing methods. EPA encourages the city
to consider such measures since presently there are no treat-
ment requirements for stormwater runoff. However, it is
possible that federal treatment requirements may be established
at some future date. This may include issuance of a general
NPDES permit for stormwater discharges and required implementa-
tion of certain Best Management Practices (BMPs). Currently
EPA and DOE encourage voluntary adoption of control practices.
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Chapter 3
GENERAL RESPONSES TO COMMENTS
Introduction
The following pages restate and/or augment discussions
of major environmental issues presented in the Draft EIS.
The material has been kept as brief as possible while re-
sponding to some of the more prevalent questions* raised on
the Draft EIS. Only those issues stimulating significant
comment or requiring additional clarification are included.
Individual comments requiring less response are included
in the following chapter.
Wastewater Reqionalization at the
Spokane Treatment Plant
It was intended that this EIS on Spokane's CSO abatement
plans would evaluate the technical and economic feasibility
of using the Spokane treatment plant as a regional wastewater
treatment facility. Each of the CSO control alternatives
was analyzed in this regard. It was not intended that the
precise timing of regionalization would be determined, nor
would it be decided which outlying areas might be first connected
to the plant. An analysis of data presented in the city's
CSO facilities plan (Spokane City Department of Public Works,
1977) and information obtained from other wastewater planning
documents (U. S. Department of Army, Corps of Engineers, 1976;
Kennedy Engineers, Inc., 1978 and 1978a; Esvelt and Saxton-
Bovay Engineers, Inc., 1972; Bovay Engineers, Inc., 1973
and 1977) suggest that the city's plan to construct separate
storm sewers would eventually eliminate all CSOs, remedy
local sewer backup and flooding, and free capacity in the
city interceptor and treatment plant for service to presently
unsewered areas. The other alternatives considered would
reduce or eliminate CSOs but would not be as effective at
reducing stormwater flows in the city's interceptor system.
Therefore, they would not be as amenable to future regionali-
zation schemes as the proposed project.
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Separate sewers constructed in the Hollywood and Meenach
drainage areas during Phase 1 will remove stormwater from
the existing sanitary sewer system. Should treatment capacity
become available as a result of Phase 1, regionalization
possibilities could be explored at the appropriate state
and local government levels. Before any such available capacity
can be used to service new areas, DOE requires that a schedule
for complete separation be developed (see DOE letter in Chapter 4)
At that time it would be possible to contemplate regionalization
but an expansion of the service area would involve several
important trade-offs. Even though there may be sufficient
dry weather capacity in both the interceptors and the treat-
ment plant, during storm conditions (80-100 days per year)
there would continue to be insufficient capacity in the secondary
treatment and phosphorus removal facilities during most storms.
As an example, if sewer separation reduced stormwater flows
by 7-8 mgd and a new service area expansion took on 3-4 mgd
of sanitary flows, there would only be a net reduction of
3-4 mgd in water diverted through the stormwater treatment
system. Therefore, flows from newly-annexed regions would
directly contribute to continued bypassing of flows through
the stormwater treatment system, which provides only primary
treatment and chlorination prior to river discharge. This
must be balanced against the potential groundwater quality and
public health benefits of sewering outlying areas that now
rely on on-site waste disposal. It must also be weighed
against the fact that the two stormwater clarifiers must
be made available for conversion to secondary clarifiers
before the ultimate planned capacity of the treatment plant
can be utilized.
The decision to expand Spokane's service area prior
to complete stormwater separation (Phase 2) will be made
by DOE and the appropriate local agencies. Prior to making
that decision, it would be valuable to obtain further information
on the amount of stormwater that may remain in the sanitary
sewer system even after Phase 2 is completed.
Stormwater Treatment
The proposed CSO control action includes construction
of a separate storm sewer system throughout the city, with
discharge of all collected stormwater runoff directly to
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the Spokane River without the benefit of treatment. This
has led to several concerned responses to the Draft EIS.
The primary concern is over impact on water quality.
Data collected for the stormwater discharge analysis
were obtained primarily from city treatment plant staff. The
measurements were taken in existing Spokane stormwater facilities.
To make comparisons of existing and post-project impact on
the river, the water quality parameters listed in Table B-10
of the Draft EIS were applied to the flow estimates recorded
in Table B-ll. The proposed action (Alternative 3) and the
other alternatives were compared to the existing situation
(no action) by totalling the pollutant inputs from each of
the flow components. The results of the analysis are presented
on pages 98 to 106 of the Draft EIS. The proposed action
would reduce flows through the treatment plant, reduce CSOs
and increase direct stormwater runoff to the river.
The stormwater runoff can contain a variety of undesirable
substances as noted in Table B-l of the Draft EIS. Our analysis
indicated that suspended solids would show the most significant
increase under the proposed action. With an average suspended
solids content of 172 mg/1 and a projected storm flow of
5,120 mgd, approximately 2,800 tons of suspended solids would
reach the river through stormwater outfalls. This compares
to a total of 1,720 tons being discharged by the city through
its present wastewater system. This analysis considers only
the point-source discharges to the river; direct runoff that
is not carried in the wastewater system has not been measured.
There are insufficient data to analyze some of the other
potentially harmful stormwater components such as oil, salts
metals and pesticides. With an increase in untreated
direct runoff, it is likely that more of these deleterious
materials will reach the river. However, the city could
mitigate this problem by implementing a variety of control
practices for urban runoff. Screening of all stormwater
outfalls, more vigorous street cleaning efforts and paving
of dirt roads are logical first steps toward reducing stormwater
discharge impacts on water quality. This can be combined
with a variety of other actions including but not limited
to the following: dry weather flushing of storm drain catch-
ment basins, investigation of different deicing techniques,
diversion of storm flows to percolation/groundwater recharge
basins, tighter control over used oil disposal, and initiation
of a public education program to keep toxic materials used
at home out of the storm drain system.
It is possible that there will eventually be federal
or state treatment requirements for stormwater discharges,
but at this time EPA and DOE are simply encouraging adoption
of suitable control measures. If treatment requirements
do become a reality, the separated stormwater and sanitary
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wastewater systems•should facilitate treatment. Without
implementation of control practices, stormwater discharges
will carry an unnecessarily large amount of suspended solids,
debris and a variety of chemical compounds into the river;
this will be especially true when storms follow an extended
dry period.
Export of Wastewater to Crab Creek
The Latenser Plan for CSO control, analyzed in the Draft
EIS, calls for export of all Spokane wastewater from the
Spokane River drainage basin. The wastewater would be given
secondary treatment and piped to upper Crab Creek, where
it would be discharged to the natural stream bed for transport
to farmland in the Odessa area. This plan is not being pursued
by the City of Spokane or EPA for a variety of reasons, some
financial and some strictly environmental.
The financial implications were presented in Chapters 2 and 4
of the Draft EIS. The Latenser Plan presents both the highest
capital cost and highest average annual cost of all the alter-
natives considered. The city's share of construction costs
are estimated to be about $68 million; this is more than
the entire anticipated cost of both phases of the proposed
action.
The environmental implications of the Latenser Plan
are also significant. First, the storage and feed-back method
of controlling CSOs does not completley eliminate the dis-
charge of untreated sanitary wastes to the Spokane River.
Due to the sizing of storage facilities, CSOs would still
occur about once a year. Second, all stormwater entering
the Spokane collector system would still be funneled through
the treatment plant; this eliminates chances of turning the
Spokane system into a regional wastewater facility.
Use of Crab Creek as a conveyance for secondary effluent
poses some serious water quality and public health questions.
The dry season discharge of effluent to Crab Creek would
not only violate state water quality guidelines and policy,
it could create a serious hazard to the stream's fishery
and public use of the stream. This includes potential ground-
water contamination where Crab Creek flow becomes subterranean,
downstream from Odessa. These concerns were discussed in
Chapter 4 of the Draft EIS and are reiterated in letters
of comment from the U. S. Soil Conservation Service and the
Washington Department of Game.
Finally, construction of the open 50 million gallon
CSO storage reservoir envisioned in Riverside State Park
(across the river from the treatment plant) would have several
12
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significant conflicts. The planned site is on state park
property that is planned for use as an equestrian center
beginning in the summer of 1979. As such, the open reservoir
would not be acceptable to the Washington State Parks and
Recreation Commission (see their letter of comment on the
Draft EIS).' Also, this area of Riverside State Park contains
potentially significant historic and archeological resources
in the form of Indian encampments and Fort George Wright
military trash dumps.
Phasing of the Proposed Action
As stated in Chapter 2, the proposed action was divided
into two phases because there are not sufficient state and
federal grant funds available to finance the entire project
at this time. Phase 1 is expected to receive 75 percent
federal, 15 percent state and 10 percent local funding. Sewer
separation in the Hollywood and Meenach drainage areas
is estimated to cut annual CSOs in Spokane by about 84 percent.
Phase 2 timing and funding will receive further evaluation
after Phase 1 has been completed and analyzed. The Phase 2
planning should be conducted after more information is made
available on the effectiveness of the planned sewer separation
in other parts of the city. Additional areawide 201 planning
for unincorporated areas surrounding Spokane should also
be completed by the end of Phase 1; this should aid in developing
a schedule for Phase 2 separation and eventual connection
of outlying areas to the city system.
Because the initiation of Phase 2 CSO control is at
least 5 years in the future, it is expected that additional
engineering, economic and environmental evaluation will be
warranted before design of the project is undertaken. Additional
public input into Phase 2 planning will also be sought prior
to any final action. Funding and scheduling of Phase 2 cannot
be determined until Phase 1 is complete and a reevaluation
has occurred. Both EPA and DOE are unable to commit specific
funding levels to Phase 2 because it is impossible to determine
the overall level of funding that will be available to these
agencies 5 years from now.
13
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Chapter 4
RESPONSES TO SPECIFIC COMMENTS
Introduction
The following pages are devoted to responding to individual
comments received on the Draft EIS. Individual letters are
included and the comments in each letter have been given
numbers. Responses, numbered to correspond to the comments,
immediately follow each letter. Oral comments received at
the EIS public hearings are also included in this chapter.
Only those oral comments requiring a response are included.
Each comment is followed by a response. For a complete version
of the oral testimony see the attached public hearing transcripts.
Written Comments
15
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
Room 360, U.S. Courthouse, Spokane, Washington 99201
March 20, 1979
Donald P. Dubois
Regional Administrator
U.S. Environmental Protection Agency
Region 10
Seattle, IVA 98101
Dear Mr. Dubois:
The Soil Conservation Service has reviewed the draft environmental impact
statement for City of Spokane Combined Sewer Overflow Abatement Project.
Our comments are applicable to the "Latenser Plan" alternative only.
1. We believe the draft environmental impact statement should address
action to be taken following construction of the pipe from the treatment
plant to Crab Creek regarding reestablishment of vegetation. Disturbed
soils are susceptible to both wind and water erosion and protection
should be assured.
2. The draft environmental impact statement does not appear to address the
impact of the flow of effluent down Crab Creek. Sections of the creek
contain porous soils which may allow substantial seepage into surrounding
ground water.
3. We believe the draft environmental impact statement should address the
potential impact of irrigating the land near Odessa with the effluent.
Thank you for the opportunity to review this draft environmental impact
statement. If we can be of further assistance, feel free to contact our
office.
Sincerely
Galen S. Bridge
State Conservationist
16
RECEIVED
M.Ai? 2 6 1S70
-------
U. S. Department of Agriculture/ Soil Conservation Service
1. As noted in Chapter 2 of this report, the proposed CSO
control action does not include export of wastewater to Crab
Creek. Therefore, the project should not affect Crab Creek
or the surrounding agricultural land. If this export scheme
were to be implemented, steps would have to be taken to protect
disturbed areas from soil erosion. This would undoubtedly
include regrading, disposal of excess spoil and revegetation.
Contact with the Soil Conservation Service would be necessary
to identify any additional control techniques that have proved •
to be effective in the area.
The potential for contamination of groundwater and erosion
of irrigated areas was discussed briefly in the Draft EIS
on pages 133 and 134. Additional analysis is not deemed
necessary at this time because the Latenser CSO control option
is not being proposed for action.
17
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NPSEN-PL-ER
DEPARTMENT OF THE ARMY
SEATTLE DISTRICT. CORPS OF ENGINEERS
P.O. BOX C-3755
SEATTLE. WASHINGTON 98124
& 3 WAR 1373
Roger K. Mochnick, M/S 443
201 EIS Coordinator
U.S. Environmental Protection
Agency, Region X
1200 Sixth Avenue
Seattle, Washington 98101
11
u va
26
i
Dear Mr. Mochnick:
We have reviewed the draft environmental impact statement (EIS) for the
City of Spokane Combined Sewer Overflow Project, Spokane, Washington,
with respect to the U.S. Army Corps of Engineers' areas of responsibility
for flood control, navigation, hydropower, and regulatory functions. We
have the following comments:
a. Chapter 3, titled "Laws, Rules and Policies Affecting the CSO
Abatement Project," should include the following statement:
"A Department of the Army permit may be required for the dis-
charge of fill in and/or on wetlands adjacent to waters of the
United States under the provisions of Section 404 of the Clean
Water Act as implemented by 33 CFR, Part 323."
b. Page 206, section titled "Flooding:"
(1) The report referred to in the second paragraph is now completed.
«3 (2) The EIS should address the impacts of the proposal and the
alternatives on flooding. In addition, no aggravation of flooding should
be generated.
18
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NPSEN-PL-ER
Roger K. Mochnick., M/S 443
Thank you for the opportunity to comment on this statement. If you have
any questions, please feel free to contact Dr. Steven F. Dice, telephone
(206) 764-3624, of my staff.
Sincerely yours,
SIDNEY I'MUTSON, P.E. ' ' "
Asst. Enoinsering DMeion
19
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U. S. Department of Army, Corps of Engineers
1. The statement included under a. in the Corps of Engineers
letter is acknowledged and incorporated into the Final EIS.
2. Completion of the Corps of Engineers report on flooding
in Spokane is acknowledged.
3. The impact of the proposed project and its alternatives
on local street and basement flooding is described on pages
115-117 of the Draft EIS. None of the alternatives would
have a significant effect on flooding along the Spokane River
or Hangman Creek. The amount of stormwater either stored
or passed directly to the Spokane River by the CSO projects
is insignificant compared to the river's flood flows. There
are no structures planned that would encroach on the river
floodplain and thereby increase the threat of flooding in the
vicinity.
20
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
ARCADE PLAZA 8UILDING, 1321 SECOND AVENUE
SEATTLE, WASHINGTON 98101
April 10, 1979
REGION X
Office of Community
Planning & Development
IN REPLY REFER TO:
10G
Mr. Roger K. Mochnick
201 EIS Coordinator, M/S 443
U.S. Environmental Protection
Agency, Region X
1200 Sixth Avenue
Seattle, Washington 98101
I
2s
3
Dear Mr. Mochnick:
Re: Draft Environmental Impact Statement
Combined Sewer Overflow - City of Spokane
We have reviewed the statement submitted with Mr. Dubois'
February 20 letter.
Following are our comments:
1) We suggest the impact in the sole source aquifer be
noted under each alternative. Specifically, wouldn't
a no action alternative have a high potential for
impacting the aquifer in the future?
2) Under the National Urban Policy EPA projects should be
planned to minimize or prevent urban sprawl. Shouldn't
local governments be alerted to this policy so that
appropriate future plans can be made in regards to
regionalization of treatment facilities?
3) Will relocation plans be prepared to assist the residents
in Peaceful Valley that may be affected by this proposed
Your consideration of the above in the final statement will
action?
Director, Regional Office
of CPD
21
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U. S. Department of Housing and Urban Development
1. The regionalization discussion in the Draft EIS (pages
158 to 170) states that only Alternative 3 (proposed action)
is capable of making Spokane wastewater service available
to outlying areas. Therefore, only Alternative 3 can have
a positive influence on wastewater contamination of the aquifer.
By eventually providing wastewater service to currently unsewered
areas of the county, on-site disposal systems can be removed
from land overlying the aquifer. As growth continues in
these suburban areas, the importance of this sewering will
increase. If any of the other Spokane CSO options were imple-
mented, including "no-action", removal of on-site disposal
systems would be left to other facilities planning action
by the county or other appropriate agency. There would definitely
be the potential for increased impact on the aquifer if no-
action is taken.
2. The local and regional planning agencies of the Spokane
area have been contacted and have taken part in the Spokane
CSO planning effort. They should therefore be aware of the
implications of regionalization in terms of future growth
in the area. There is considerable effort now underway to
coordinate city and county development plans, especially
with regard to wastewater treatment service.
As indicated in the comment, the National Urban Policy
discourages continued urban sprawl. Regionalization of waste-
water treatment service through the Spokane facilities should
encourage infill in those outlying areas connected to the
system.
3. Residents in Peaceful Valley would not be displaced
by the proposed action, therefore no relocation plans are
proposed. Only if storage or satellite treatment were imple-
mented would there be residential displacement. If storage
or satellite treatment facilities were to be placed in the
Peaceful Valley area, the city would have some obligation
to aid in relocation efforts.
22
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United States Department of the Interior
OFFICE OF THE SECRETARY
PACIFIC NORTHWEST REGION
500 N.E. Multnomah Street, Suite 1 692, Portland, Oregon 972ii h 1 3" , ' " "• ;
... fjl
Uvi "lijl
April 18, 1979 APR IQ 1379 L~J'
ER-79/189 E'iViiifs&icurtt -¦
Mr. Roger K. Mochnick
201 EIS Coordinator
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
We have reviewed the draft environmental statement for Spokane
Combined Sewer Overflow Project, Spokane County, Washington. The
following comments are provided for your consideration when pre-
paring the final document.
Analysis of the effects of the project on ground water should in-
clude assessing the significance of reduced local recharge of
ground water from septic tanks and other onsite wastewater dis-
posal systems.
The DES does not discuss mineral resources such as sand and gravel.
This lack of discussion may mean there are no impacts or it may
be an oversight. Sand and gravel deposits would be impacted if
pipelines, storage facilities, or treatment plants were to be con-
structed across them. Construction would require supplies of sand
and gravel which would probably be mined from nearby deposits.
One feature that might be considered is use of mined-out sand or
gravel pits for storage or treatment facilities.
Despite the foregoing comments, mineral involvement and impacts are
not expected to be of major importance in the choice of alternatives.
On page 5, damages caused by installation are mentioned, but the
statement fails to specify adverse environmental impacts. In
Chapter 6 Affected Environment and Appendix A on page 233, the
setting and relative degree of project impacts are treated, but
relationships of those effects on biota are ignored. The state-
ment fails to discuss the types of habitat and dependent wildlife
which will be damaged or destroyed, or what will be done to miti-
gate those losses. Significant fish and wildlife resources exist
in the project area of impact.
23
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A main function of the new plant is described as phosphorus removal.
Beneficial uses of the Spokane River that would be enhanced by re-
duced phosphorus loading with resultant algae reduction are fish and
wildlife. In view of this emphasis on nutrient removal as a major
project objective for water quality enhancement, it is difficult to
reconcile lack of planning coordination with construction of the up-
river Liberty Lake wastewater treatment facility which does not plan
to have phosphorus removal.
As stated on page 208, the reach upstream from Millwood, to be impacted
by the Liberty Lake facility, is rated by the Washington Department of
Game as one of the top ten unique ecosystems in Spokane County. Yet
the only protection provided by the Liberty Lake project for the
unique natural trout fishery is dechlorination. Anticipated heavy
phosphorus loading under low flows would severely degrade this aquatic
ecosystem and reduce the benefits of the proposed project.
Considering the wide area and diversity of values stated as being
served by the project, the document should discuss relationships of
those upstream impacts to the project function and design.
Regionalization aspects of waste treatment are described on pages 166-170,
but that discussion fails to address the immediacy of Liberty Lake and
other upriver developments as related to Spokane River water quality.
The principal concern of this Department's National Park Service re-
lating to this project is the effect upon water quality in the Spokane
Arm of Lake Roosevelt. Water quality in the Arm, of course, is gov-
erned largely by the quality of the Spokane River which feeds the Arm
via Long Lake and Little Falls reservoirs.
As has been noted in the draft statement (page 125), the Spokane Arm
portion of the Coulee Dam National Recreation Area receives intensive
water recreation use by the public each year. Public use here, as
measured by statistics on the numbers of swimmers and boats launched
at our two largest developed sites on the Arm, has been increasing at
a greater annual rate than it has in most other parts of the National
Recreation Area. A visitor survey conducted by the National Park
Service last summer showed that over half of the visitors using the
Spokane Arm are from the city of Spokane or its surrounding communities.
The draft statement (page 125) suggests that water pollution in the
Spokane Arm is not now discouraging visitor use. We believe that
presumption is untrue. We have recently conducted several public
workshops in communities surrounding Lake Roosevelt to obtain citizen
input for a General Management Plan for the National Recreation Area,
and in the course of these workshops a number of citizens expressed
a deep concern over water pollution in the Spokane Arm. Written com-
ments elicited from our visitor survey last summer exhibited a deep
concern over the health aspects of swimming in the Spokane Arm.
24
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Furthermore, our information from qualified biologists is that the
toxic Anabaena algal blooms that occurred in the Spokane Arm last
summer are the direct result of unnaturally high amounts of nutrients
in the water. It is our belief that storm sewer discharge from the
city of Spokane into the Spokane River is a major source of this
nutrient pollution into Lake Roosevelt.
On page 206, under Biological Resources, the bald eagle should be
treated as a species designated as threatened in the State of Washington
under the Federal Endangered Species Act.
Thank you for the opportunity to review this 'document.
Sincerely yours,
Charles S. Polityka
Regional Environmental Officer
25
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U. S. Department of the Interior
1. According to the U. S. Geological Survey (Open File
Report 77-829, 1978) the Spokane Valley-Rathdrum Prairie
aquifer has not shown a long-term change in storage over
the past 50 years. Discharge and recharge are essentially
equal. This equilibrium has persisted in spite of an estimated
net industrial and agricultural pumping loss to the aquifer
of 175 cubic feet per second, (cfs) and a 64 cfs loss from
existing sewer collection systems. If all of the estimated
11.5 MGD of wastewater generated in Spokane Valley by 1990
were collected in sewers and transported to Spokane for treat-
ment, this would be a net loss of only 17.8 cfs. Therefore,
it appears unlikely that elimination of on-site wastewater
disposal systems in the Spokane area will cause a significant
change in recharge of the aquifer. It will, however, reduce
the threat of public health hazards being created by waste-
water contamination of the aquifer.
2. The proposed CSO control action will require construction
of about 220 miles of new storm sewers. Nearly all of this
construction will occur in existing rights-of-way. Therefore,
it is unlikely that the project will affect the development
of sand and gravel resources. There are extensive sand and
gravel deposits in the Spokane area including developed pits
near Felts Field and Riverside State Park. There are also
extensive deposits in undeveloped areas. Because it does
not appear that mineral resources will be significantly affected
by the proposed action, this subject area was not discussed
in the Draft EIS. This is in keeping with the new CEQ guidelines
for EIS preparation, which encourage consideration of only
the significant environmental issues.
3. Chapter 6 of the Draft EIS presents a summarization
of the environmental setting data reviewed in preparation
of the Spokane CSO impact analysis. Our review of biological
data included discussions with local Washington Department
of Game officials and field surveys of all proposed construction
sites. Our analysis indicated that loss of vegetation and
wildlife disturbance would not be a significant factor, especially
for the proposed project which is limited primarily to construction
within existing rights-of-way. Therefore, biological impacts
were not discussed in detail.
It should be noted, however, that the noise and increased
human activity associated with construction will disturb
wildlife frequenting the Spokane urban area. This includes
a large number of bird species and a variety of rodents and
small mammals. If any of the storage options or satellite
treatment were selected for CSO control, construction of
storage basins or satellite plants at sites 9B and 16B (see
Figure 2-3 in the Draft EIS) would remove relatively undisturbed
wildlife habitat. Site 9B contains grassland and scattered
26
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pines while site 16B contains a mixture of pines and bankside
deciduous trees and shrubs. This would require relocation of
those species utilizing the habitat. No rare or endangered
species are expected to be affected. However, it would be
desirable from a wildlife standpoint to relocate these
two storage/satellite treatment sites to already- disturbed
areas if storage or satellite treatment were selected for
implementation.
4. The potential for and environmental implications of
wastewater service regionalization are discussed on pages
158 to 170 of the Draft EIS. This analysis is somewhat restricted
because the project being analyzed seeks primarily to control
CSOs. There is no new plant under consideration in this
project. The effect of the CSO control strategy on Spokane
treatment plant capacity was determined to be only a peripheral
issue to the main project objective - reduce public health
threats in the Spokane River by eliminating discharge of
untreated wastes to the river.
The impact analysis indicates that CSO control does
not have a major effect on nutrient loadings in the river>
it would, however, have a significant impact on contamination
of the river with pathogenic organisms. Therefore, a detailed
analysis of nutrient inputs and conditions up and down the
length of the Spokane River was not undertaken. Such an
analysis was considered beyond the requirements of the CSO
issue. This EIS was considered an inappropriate vehicle
for discussing broader regionalization plans of the entire
area. As such plans are developed by the appropriate agencies,
the public and other agencies will be afforded an opportunity
to participate.
5. The Draft EIS suggests on page 125 that CSOs from the
City of Spokane are apparently not discouraging visitor use
in the Spokane Arm of Roosevelt Lake. This did not intend
to indicate water pollution in general was not affecting
visitor use of the lake. The fact that park planning and
public surveys suggest water quality is a concern at the
lake is important to pollution control planning along the
entire Spokane River.
Opinions received from users of the Spokane River near
Spokane contain similar feelings about river pollution. The
findings of numerous personal interviews are included in
pages 118 to 125 of the Draft EIS. However, it is important
to reiterate the EISs findings on the source of pollution.
Data compiled from numerous sources suggest that Spokane's
CSOs contribute only about 1 percent of the total annual phosphorus
and nitrogen reaching Long Lake. This low nutrient input
is not likely to be the cause of recent algal blooms in Long
Lake and the Spokane arm of Roosevelt Lake. There are numerous
sources of pollution affecting the Spokane River and CSOs
are only a small factor.
27
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6. Reference to the threatened status of the bald eagles
is acknowledged and included as part of the Final EIS.
28
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DEPARTMENT OF TRANSPORTATION
915 SECOND AVE.
SEATTLE. WASH. 98174
phone 206 442-7523
16476
DPL79-261
2 3 MAS i973
Mr. Donald P. Dubois
Regional Administrator
U. S. Environmental Protection Agency
Region 10
Seattle, WA 98101
Dear Mr. Dubois:
We have reviewed your draft environmental impact statement
of January 1979 addressing the City of Spokane Combined
Sewer Overflow Abatement Project. We have no comments.
Thank you for the opportunity to review the document.
Sincerely
MCHARD F. MALM
Captain, U. S. Coast Guard
Chief of Staff
Thirteenth Coast Guard District
29
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U. S. Department of Transportation - Coast Guard
1. No response is required.
30
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Advisory
Council On
Historic
Preservation
1522 K Street NVV.
VX&shington D.C.
20005
Jleply to: P. O. Box 23®35 _
Deaver, Colorado
rw
k,_
! I!
APR 20
. .
1979
April 16, 1979
Mr. Roger K. Mochnick, M/S 443
201 EIS Coordinator
Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
Thank you for your request of February 21, 1979,ifor comments
on the draft environmental statement (DES) for the City of
Spokane Combined Sewer Overflow Abatement Project. Pursuant
to Section 102(2)(C) of the National Environmental Policy Act of
1969 and the Council's regulations for the "Protection of
Historic and Cultural Properties" (36 CFR Part 800), we have
determined that your DES mentions properties of cultural and/or
historical significance; however, we need more information in
order to evaluate the effects of the undertaking on these
resources. Please furnish additional data indicating:
Compliance with Section 106 of the National Historic Preservation
Act of 1966 (16 U.S.C. Sec. 470f, as amended, 90 Stat. 1320).
The environmental statement must demonstrate that either of the
following conditions exists:
1. No properties included in or that may be eligible for
inclusion in the National Register of Historic Places are
located within the area of environmental impact, and the
undertaking will not affect any such property. In making
this determination, the Council requires:
—evidence that you have consulted the latest edition of the
National Register (Federal Register, February 6, 1979, and its
monthly supplements);
31
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Page 2
Mr. Roger K. Mochnick
City of Spokane
April 16, 1979
•i* —evidence of an effort to ensure the identification of properties
eligible for inclusion in the National Register, including evidence
of contact with the State Historic Preservation Officer, whose
comments should be included in the final environmental statement.
The State Historic Preservation Officer for Washington is Louis Guzzo.
2. Properties included in or that may be eligible for inclusion
in the National Register of Historic Places are located within the
area of environmental impact, and the undertaking will or will not
affect any such property. In cases where there will be an effect,
the final environmental impact statement should contain evidence
of compliance with Section 106 of the National Historic Preservation
Act through the Council's regulations for the "Protection of Historic
and Cultural Properties" (36 CFR Part 800).
Should you have any questions, please call Brit Allan Storey at
(303) 234-4946, an FTS number.
Sincerely,
Louis
Chief,4" Western Office
of Review and Compliance
32
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Advisory Council on Historic Preservation
1. As requested, the latest update of the National Register
of Historic Places (Federal Register, February 6, 197 9) was
consulted to determine if properties of historic significance
might be affected by the proposed action. The February 6
listing (and its latest monthly supplement, June 5, 197 9)
included several more historic spots in Spokane, but the
proposed storm sewer construction project will not adversely
affect any of the properties. All storm sewer construction
will be conducted in existing rights-of-way. Some properties
will suffer temporary access problems, but this will last
only as long as construction and is not deemed significant.
In order to verify the status of historic and archeological
resources in the Spokane area, the Washington Archeological
Research Center in Pullman, Washington was contacted a second
time. No new archeological site information was reported
through that contact. The Washington State Historic Preservation
Office was also contacted. Its letter of comment is included
in this chapter.
As stated in the Draft EIS, all pipeline construction
in the vicinity of the Spokane River should be closely monitored
for possible discovery of unrecorded archeological sites.
Surface reconnaissance in urbanized areas is not effective
at locating archeological material, and lands bordering the
river should be considered archeologically sensitive. The
city's recently prepared historic landmarks survey (Keller,
n.d.) should also be consulted when it is made available
for public review.
33
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STATE OF
WASHINGTON
Dixy Lee Ray
Governor
DEPARTMENT OF ECOLOGY
Olympia, Washington 9S504 206/753-2800
Mail Stop PV-11
April 19, 1979
Mr. Roger K. Mochnick
201 EIS Coordinator
Lf. S. Environmental Protection
Agency - Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
Thank you for providing us with review copies of your draft environmental
impact statement for the proposed "City of Spokane, Combined Sewer Over-
flow Abatement Project."
Your impact statement has been reviewed by Department of Ecology staff in
Olympia and in our Eastern Regional Office in Spokane. We wish to offer
the following comments for your consideration in preparation of the final
environmental impact statement.
1. We agree that the construction of separate storm sewers is the most
desirable option for abating the problem of combined sewer overflows
in Spokane.
2. The DOE is committed to insuring the correction of all combined
sewer overflows by the City of Spokane regardless of the availability
of state and federal funds for this purpose.
In addition, a schedule for sewer separation must be developed prior
to significant expansion of the sewer service area.
3. The DOE is not committed to funding Phase II of the Spokane CSO
project. At the conclusion of Phase I (approximately five years
hence), DOE will reevaluate the entire CSO project in terms of our
continued committment of federal and state grant funds. Phase II
will be rated and ranked relative to the other projects on the
fiscal year's priority list. The Phase I funding allocation is:
EPA (75%) = $20,085,000
DOE (15%) = 4,017,000
City of Spokane (10%) = 2,678,000
TOTAL $26,780,000
4. The EIS states, with regard to the Hollywood and Meenach drainage
areas, "Separation of stormwater in these two drainage areas would
remove approximately 84% of the CSO that now flows into the
Spokane River each year. This can be accomplished for approximately
39% of the total construction cost of Alternative 3."
34
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Mr. R. K. Mochnick
April 19, 1979
Page two
These figures are quoted in several sections of the EIS.
Obviously they are important in determining the boundaries of
the Phase I project area and the level of grant participation
in the project. However, we are unsure of the validity of storm
flow data used to develop these percentages. Information should
be obtained which can verify the validity of these estimated
removal percentages.
5. Page 39 — It is possible that at some future-date there may be
federal requirements developed which will require treatment of
stormwater discharges. At the very least, it appears that EPA
is promulgating regulations which would require the^issuance of
a general National Pollutant Discharge Elimination System permit
to cover stormwater discharges. This general permit may require
that some combination of Best Management Practices (BMP) be
implemented.
6. Page 190 -- It is widely recognized that separation of storm
sewers will free capacity at the treatment plant and allow for
expansion of the sewer service area. This section in the EIS
points out that Phase I separation removes only a minimum amount
of storm flows at the treatment plant. We believe it is extremely
important that everyone concerned with the project understand that
significant expansion of the sewer service area cannot occur until
Phase II separation is undertaken.
In conclusion, we feel that a further breakdown in the EIS of Phase II
into subphases based on hydraulic integrity, water quality impact, and
contribution toward freeing excess capacity at the city sewage treatment
plant, would be very helpful. Subphasing of Phase II will allow better
decisions on the funds available each year during the Phase II CSO time
frame and will insure the best possible combination of federal, state,
and local funding.
Should you have questions concerning these comments or any other phase of
our involvement in this proposal, please contact Mr. Claude Sappington of
our Eastern Regional Office in Spokane at (509) 456-2926.
John F. Spencer
Assistant Director
Office of Water Programs
JFS:as
cc: Claude Sappington, Eastern Region
Myron Saikewicz, Water Programs
Dennis Lundblad, Comprehensive Management
35
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Washington Department of Ecology
1. No response required.
2. These comments have been considered in preparing the
general response entitled Phasing of the Proposed Action
(Chapter 3). It is recognized that the DOE funding alloca-
tion amounts are higher than those included in Table 5-3
of the Draft EIS and page of the Final EIS because the
DOE numbers contain additional design and engineering costs
not added into the original construction cost estimates.
3. The data used to predict an 84 percent removal of annual
CSO volume were taken from the Facilities Planning Report for
Sewer Overflow Abatement (Text) prepared Dy tne Spokane city
Department of Public Works (1977). Table 1 (page 7) of the
Text volume lists all combined sewer overflow points and
their average frequency, duration and volume of discharge.
The city's data had been taken with only minor modification
from the Spokane Wastewater Study prepared for the city in
1972 by Esvelt and Saxton/Bovay Engineers, Inc. To our know-
ledge, no other comprehensive survey of CSOs has been under-
taken. It is our understanding that the Esvelt and Saxton/Bovay
figures are based on calculations, using drainage basin acreage,
weir capacities and climatic data. No systematic program
of field measurements was conducted. The data are therefore
only estimates and should be considered as such. These numbers
will be refined in the design stage of the project to more
accurately reflect the current overflow situation.
4. This comment has been considered in preparing the general
response entitled Stormwater Treatment (Chapter 3).
5. These comments have been considered in preparing the
general response entitled Phasing of the Proposed Action
(Chapter 3).
36
-------
STATE OF
WASHINGTON
Dixy Lee Ray
Governor
DEPARTMENT OF FISHERIES
115 General Administration Building, Olympia, Washington 98504 206/753-6600
February 23, 1979
Mr. Roger K. Mochnick
201 EIS Coordinator
U.S. EPA, Region X
1200 6th Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
The Washington Department of Fisheries has reviewed the above referenced
document. Since the proposal does not appear to involve direct or indirect
impacts upon resources under this Departments jurisdiction, we' do not wish
to make any comment at this time.
Thank you for the opportunity to review and comment.
Sincerely,
Draft EIS for City of Spokane
Combined Sewer Outfall Abatement
Spokane County WRIA T-54-57
mr
37
-------
Washington Department of Fisheries
1. No response required.
38
-------
STATE OF
WASHINGTON
DEPARTMENT OF GAME
600 North Capitol Way/Olympia, Washington 98504 206/753-5700
Dixy Lee Ray
Governor
April 13, 1979
Mr. Donald Dubois
Regional Administrator
U. S. Environmental Protection Agency
Region 10
Seattle, Washington 98101
1 s
»«»
ENVIRONMENTAL IMPACT STATEMENT:
City of Spokane Combined Sewer Oveflow
Abatement Project, Spokane County
Dear Mr. Dubois:
Your document has been reviewed by our staff as re-
quested; our comments follow.
We recognize the need to control combined sewer over-
flow for reasons concerning public health, recreation,
aesthetics, and economics. We must, however, raise ob-
jections to any abatement alternative which would compro-
mise water quality components affecting fish in either the
Spokane River, Long Lake, or Crab Creek. In addition to
the brown trout fishery mentioned in the EIS, there is a
significant wild rainbow trout population in Crab Creek,
providing a quality fishery. Rainbow trout are more sensi-
tive than brown trout to decreases in dissolved oxygen, or
increases in water temperature.
Therefore, Alternative #1 is the only abatement plan
we are supportive of. Alternative #3 would allow untreated
stormwater runoff to enter the river. This water can be ex-
pected to contain cadmium, lead, mercury, arsenic, asbestos,
petrochemicals and other toxic substances, as stated in the
EIS. Fecal coliform levels as high as 11,000 MPN per 100 ml
have been measured in Spokane stormwater, as mentioned on
page 112 of the EIS. Alternative #3 does not incorporate any
controlls against accidental spills into storm drains.
Alternative #3 may accelerate sewering of the Spokane
Valley. It has been suggested, however, that interceptor
lines large enough to accommodate projected wastewater flows
will be larger than existing city lines, which could create
a major bottleneck resulting in more overflows or back ups.
RECEIVED HFSHifTS
APR 1 7 'c79
Or'fiC? Or
REGIONAL t'.D",SI.JTRATQR
r,PR u U 1979
n pa-pis
39
-------
Page 2
April 13, 1979
The U. S. Army Corps of Engineers Study (1976) prepared
by Kennedy-Tudor Consulting Engineers omits mention of two
fish species: Kokanee (Oncornhynchus nerka) occur in both
Long Lake and Little Falls impoundments. And, a substantial
wild eastern brook trout (Salvelinus fontinalis) population
occurs in all of the Spokane River, especially above Upriver
Dam, and in the Little Spokane River.
In summary, we feel Alternative #1, or anyNother alternative
plan which would provide for storage lagoons where stormwater
runoff can be collected and treated at a later date, provides the
most comprehensive solution to the CSO problem. Such a system
would appear to be the only alternative which would not simply
relocate the problem or replace one set of pollutants with
another.
Thank you for the opportunity to review your document. We
hope our comments are helpful.
Sincerely,
THE DEPARTMENT OF GAME
"^Douglass A. Pineo, Applieii Ecologist
Habitat Management Division
DPrmjf
40
-------
Washington Department of Game
1. These comments are considered in the general response
entitled Export of Wastewater to Crab Creek (Chapter 3).
2. These comments are considered in the general response
entitled Stormwater Treatment (Chapter 3).
3. If interceptor sewers are constructed in Spokane Valley
to convey wastewater to the Spokane treatment plant, they
will not be sized so that hydraulic overloading of city inter-
ceptors would occur. Connections would be made to city lines
with sufficient capacity or a new interceptor through the
city would be necessary.
4. These comments are acknowledged and made a part of the
Final EIS.
41
-------
June 26, 1979
Ms. Deborah Kirk
Environmental Protection Agency
Region 10
1200 Sixth Avenue M/S 443
Seattle, Washington 98101
RECEIVED
Jj'/ 2 8 1979
PPVFIS
Dear Deborah:
As per our previous conversation, I have the following comments regarding
the Draft Environmental Impact Statement for the City of Spokane Combined
Sewer Overflow Abatement Project.
The document exhibits a well considered concern for the cultural environment.
The only changes I would recommend concern the publication of site locations.
On page 177, the Draft states that the cultural resources report by Hartman
and Robbins is available for public review at offices in Spokane and Seattle.
Please be advised that site locational data are exempted from public disclosure
under both federal and state law. The limitation of access to locational data
is one of the most important protective measures available for archaeological
resources. I would suggest that you delete that statement from the Final EIS
and advise those offices with copies of the report to ensure its security
except on a' need-to-know basis. I also suggest that portions of the Draft which
refer to specific site locations be amended for the same reasons.
I concur with the recommendation for professional testing and/or monitoring
of high potential areas prior to or during construction. Those areas where
sites have been identified within the project area should be professionally
evaluated to determine anticipated impacts and to provide alternatives for
mitigation of impact. If sites are within the area of project impact, it will
be necessary to obtain a determination of eligibility for the National Register
of Historic Places and the comnents of the President's Advisory Council on
Historic Preservation. In that event, this office will be pleased to assist
in the necessary procedures.
Sincerely,
JEANNE M. WELCH, Deputy State
Historic Preservation Officer
Sheila Stump, Archaeologist
md
42
-------
Washington Office of Archeology and Historic Preservation
1. The Draft EIS should be modified to indicate that all
site .location data are not available for general public review.
Only the report narrative is available. Maps and locational
descriptions are confidential. Anyone desiring site location
information should contact the Washington Office of Archeology
and Historic Preservation. Because this Final EIS does not
include a reprinting of the entire Draft EIS, it is not necessary
to delete the discussions of specific sites contained in
the Draft.
2. As indicated in the response to comments from the Advisory
Council on Historic Preservation, no known historic or arch-
eological sites will be significantly impacted by the proposed
sewer separation construction. This includes sites listed
on the National Register of Historic Places.
43
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STATE OF
J|) WASHINGTON
Dixy Leo Ray
G-'uernor
OFFICE OF FINANCIAL MANAGEMENT
Hou« Office Buiiding, Oiympia, Washington 93504 206/753-5450
Onn C. Smith. Director
April 26, 1979
Mr. Roger K. Moc'nnick
201 EIS Coordinator
U.S. Environmental Protection
Agency - Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
Review of the Draft Environmental Impact Statement for the City of
Spokane Combined Sewer Overflow Project has been completed by agencies
of the State of Washington. The review was coordinated by the Office of
Financial Management as the designated state clearinghouse.
Comments were received from the Washington State Parks and Recreation
Commission and Department of Ecology. While it is understood that the
Environmental Protection Agency (EPA) will respond directly to the
enclosed comments, the agencies have identified several significant
issues which are highlighted below for your consideration in evaluating
the proposed project.
The State Parks and Recreation Commission comments are directed to the
Latenser Plan alternative. Under the Latenser Plan, a pipeline and open
storage reservoir would be constructed in Riverside State Park. In the
discussion of the Long-Term Effects of New Facilities on Adjacent Land
Uses on page 176, it is noted that the reservoir proposed under the
Latenser Plan "would eliminate future recreation development in that
vicinity". In view of the Commission's plans to develop an equestrian
area at Fort George Wright in Riverside State Park, it is recommended
that the Latenser Plan be withdrawn from further consideration as a
possible alternative to the proposed project.
The Department of Ecology concurs with EPA's decision to propose construc-
tion of separate storm sewers as the most desirable option for abating
the combined sewer overflows in the City of Spokane. The proposed
action consists of two major phases, the first being construction of
separate storm sewers in the Meenach and Hollywood drainage areas with
the second phase providing separate storm sewers for the remainder of
the City of Spokane.
RECEIVED
KM 1 1979
44
EPA-Cic;
-------
Mr. Roger K. Mocnnick
-2-
April 26, 1979
The funding allocation for Phase 1 assumes federal-(75 percent), state
(15 percent), and local (10 percent) cost sharing of construction costs.
While a Phase 2 allocation is included in the discussion of Construction
Costs and Cost Sharing of the proposed action, it is noted that Phase 2
is only speculative at this time. The Department reiterates that the
state is not committed to funding Phase 2 of the project. State participa
tion in Phase 2 would be subject to a detailed evaluation of the Spokane
project at the conclusion of Phase 1. The Department of Ecology (DOE)
would reevaluate the entire project in terms of continuing funding
support at that time and the Phase 2 project would be rated and ranked
relative to other projects on the fiscal year's priority.^list.
The Department also notes that significant expansion of the sewer service
area cannot occur until a schedule for sewer separation is developed and
the Phase 2 separation is undertaken. The Department concludes that a
further breakdown of Phase 2 into subphases would be very helpful in
considering future funding for the Phase 2 project.
Thank you for the opportunity to review the draft statement. We hope
you will find these comments useful in your consideration of this proposal
\
Sincerely
Thomas A. Mahar
Assistant Director
TAM:de
enclosures
45
-------
Washington Office of Financial Management
1. The letter from the Washington Office of Financial Management
summarizes the comments received from other state agencies.
The reader is referred to responses to comments from the
Washington Department of Ecology and the Washington State
Parks and Recreation Commission for information on the Office
of Financial Management concerns.
46
-------
WASHINGTON STATE PARKS AND RECREATION COMMISSION
TO:
FROM:
SUBJECT:
MEMORANDUM
March 7, 1979
Mike Mills, Policy Analysis Division
Office of Financial Management
IN REPLY REFER TO:
35-2650-1320
Draft EIS - City of
Spokane - Combined
Sewer Overflow -
Abatement Project
(E-1571) /
David W. Heiser, E.P., Chief
Environmental Coordination
Draf- EIS - City of Spokane - Combined Sewer Overflow
Abatement Project
The staff of the Washington State Parks and Recreation Commission has reviewed
the above noted document and has the following comments:
/ Page 7, Latenser Plan, Disruptions Caused by Construction Activities
An equestrian area at Fort George Wright in Riverside State Park will
be constructed with the first stage in the summer of 1979. Construction
of sewage facilities would disrupt equestrian use.
Page 73, Latenser Plan, Public/Semi-Public Facilities - Southeast Spokane
The storage bin, if constructed after the summer of 1979, would be
constructed within a developed operating state park equestrian area.
Page 175, Latenser Plan, Long-Term Effects of New Facilities on
Adjacent Land Uses.
The open reservoir in Riverside State Park, if within Fort George Wright,
would interfere with and be detrimental to an existing developed and
utilized equestrian area if the sewerage facility is contemplated to be
built after the summer of 1979. This would not be acceptable to the
State Parks and Recreation Commission because they plan to develop the
area for equestrian use in the summer of 1979.
I have enclosed a copy of the staged development plan for the Equestrian Area.
Mr. Mike ?.ush~on of Jones & Stokes Associates, Inc. was previously contacted
concerning the Latenser Plan. A copy of that letter is enclosed for your
information.
Thank you for the opportunity to comment on this EIS.
DWH/PJP:jc
Enclosures
47
-------
IA -
J;
STATE OF
WASHINGTON
Dixy Lee Ray
Governor
WASHINGTON STATE PARKS AND RECREATION COMMISSION
7150 Ceanwater Lane, Olympta, Washington 93504 206/753.5755
March 2, 1979
35-774-0555
35-774-0720
Riverside State Park •- Fort
George Wright Equestrian Area
Sewage Treatment Plant
Preliminary DEIS - Overflow
Abatement
Mr. Mike Rush ton
Jonas & Stokes Associates, Inc.
2321 P Street
Sacramento, California 95816
Da a r^rTRus h to n:
Last November you sent me a packet of data relating to the DEIS which I had
expected to receive long before now. Several things have happened since you
wrote to me: my father was in the hospital for several months prior to passing
away in early February and our regional staff have been preparing plans for
development of the Fort George Wright area. Those plans are-now being finalized
and I have enclosed a copy for your use. •
On tha question of the deed restrictions tnat relate to non-recreational use
of the land, I offer the following observations:
1. When the property was leased to Washington State Parks and Recreation
Commission in 1963 there existed a number of outstanding easements of
record across the property.
2. These include Washington Water Power, Salt Lake Pipeline Company,
Pacific Northwest Bell, Great Northern Railway Company and the U.S.
Government.
3. "For a period of twenty (20) years from the date of this conveyance,
the property shall be continuously used and maintained as and for
public park and public recreational area purposes, in accordance with
the approved plan of utilization ..."
From the above restriction, I draw the conclusion that we have no authority
to grant any easements for this property (such as the Latenser Plan) until
1983. It would still be a matter of some considerable controversy, since
t;~.e property has been dedicated to equestrian use since the early 60's.
48
-------
Mr. Mike Rushton -2- March 2, 1979
For the above reasons, I feel that the Latenser Plan is not viable at this
1ocaticn. If another site can be located, it might well be viable.
Thank you for the opportunity to provide this input. Please send me a copy
of tne DEIS when available. Thanks!
Sincerely,
David W. Heiser, E.P., Chief
Environmental Coordination
DWH:jc
Enclcsure
49
-------
Washington State Parks and Recreation Commission
1. Plans for the Riverside State Park equestrian area were
received after publication of the Draft EISj therefore, reference
to those plans was not included in the document. The land
use conflict between the Latenser Plan storage reservoir
and the equestrian area is a significant impact and is acknow-
ledged in this Final EIS. Current plans do not include imple-
mentation of the Latenser Plan, so the land use conflict should
be avoided.
50
-------
March 12, 1979
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:
Please find comments attached received from the Transportation Study Division of
the Conference commencing review of the draft Environmental Impact Statement, "City
of Spokane Combined Sewer Overflow Abatement Project." I believe the comments to be
self-explanatory.
Thank you for the opportunity to review this statement.
Sincerely yours,
SPOKANE REGIONAL PLANNING CONFERENCE
jfce M. Urcia, Director
JMU:11
Enc. (1)
cc: Robert Vaughan
. r.
¦2
"¦* v..».
51
ADDRESS REPLY TO: SPOKANE REGIONAL PLANNING CONFERENCE, ROOM 353, CITY HALL, SPOKANE, WASHINGTON 99201
-------
March 6, 1979
Mr. Jose M. Urcia
C0nf-2rer.cs Director
Room 353 City Hall
Spokane, Washington.99201
Dear Mr. Urcia:
The Conference Transportation Study has reviewed the draft Environmental Impact
Statement, titled "City of Spokane Combined Sewer Overflow Abatement Project".
Our review comments are related to transportation and air quality planning.
This document describes seven major alternatives to abate the combined sewer over-
flows at over 30 points in the City of Spokane. At the present time, the, trunk
sewer system is unable to transport all of the sanitary waste water and storm runoff
to the sewage treatment plant.
These alternatives are:
1. Build 14 underground storage basins.
2. Build 14 small underground treatment plants.
3. Construct a storm sewer system of 220 miles to separate sanitary waste water
from storm runoff.
4. Klicket Plan of smaller underground storage basins with surface lagoons.
5. Latenser Plan of a large open storage reservior in Riverside State Park
where storm water is held for later treatment. Effluent from the Spokane
sewer treatment plant would be discharged into the Crab Creek drainage basin.
6. Use a combination of 1 and 3.
7. No action
None of the alternatives will significantly affect ambient air quality nor interfer
with the air quality implementation plan control strategies. During construction,
temporary dust problems may be a problem in select areas; proper measures to hold
dust down should be utilized.
It appears from this document that proposal number 3 may be the selected alternative.
Alternative Number 3 will, during construction over an 8 to 10 year period, affect
up to 220 miles of city streets. Most of the major arterials will be influenced
by construction, either in the arterial right of way or by crossing the arterial. A
number of major central business district streets will be affected such as River-
side, Sprague, Lincoln, Monroe, Spokane Falls Blvd. and First.
52
v rrv SPOvjAiV? rv AW«v
-------
Mr. Jose M. Urcia
March 6, 1979
Page 2
Some of the construction impact on traffic should be able to be reduced by-
avoiding having the routes closed during peak hours. The impact in the central
business district could probably be reduced by construction periods operating 24
hours a day, thus shortening the time the streets will be torn up.
Very truly yours,
Robert A. Vaughan, P.E.
Transportation Study Director
RAV/em
53
-------
Spokane Regional Planning Conference
1. It is imperative that nuisance dust be kept to a minimum
along pipeline construction corridors, especially in residential
areas. The city should ensure that frequent watering of
disturbed areas and compaction and resurfacing of completed
pipeline routes be a requirement of the construction contract.
2. Mitigation of other construction-related impacts are
discussed on pages 75 to 89 of the Draft EIS. Maintaining
through-access on roads in construction zones is desirable,
but 24-hour construction periods would probably violate the
Washington Environmental Noise Control Ordinance. It restricts
construction noise between 10:00 p.m. and 7:00 a.m.
54
-------
s§3P jo:kscsctj G '.'DirssTirTi'
OFFICE OF
COUNTY ENGINEER
ROBERT S. TURNER
COUNTY ENGINEER
S3>OIHCAT>rE , V'VASH3W.TO.Y 09201
5?0"A,NS CCI'NTV iOUi£
April 18, 1979
Roger K. Mochnick M/S 443
201 EIS Coordinator
U.S. Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, WA 98101
SUBJECT: EIS - City of Spokane
CSO Project
Dear Sir:
The project being reviewed is the "City of Spokane Combined Sewer'Overflow
Abatement Project" and is properly titled being a project intended to stop
overflow at the points of interception. The EIS deals with the project
as if it were a project to accomplish complete separation of sanitary and
storm waste waters. In actual fact, the project proposes to reduce, not
eliminate, storm waters from the combined system. Overflows can be stopped
at the point of interception, but storm and other non-sanitary sewage
flows will continue to flow through the system and to reach the central
plant. This failure to recognize the difference between overflow abatement
and separation most directly affects the EIS discussion of regionalization.
These discussions assume that completion of phases 1 & 2 of Alternative 3
will effect complete separation, thus providing interceptor and plant
capacity to accommodate extra-City flows. This is an erroneous assumption.
Major additional expenditures beyond those projected for phases 1 & 2
would be necessary to accomplish the necessary degree of separation to
achieve the results assumed; in fact, achieving full separation as the
EIS seems to assume may well be an impossible task.
The writers and reviewers of the EIS statement are referred to Appendix A
of the North Spokane Facilities Plan which addresses the subject in consider-
able detail. This Facilities Plan also points out that there are ways to
connect North Spokane to the city treatment plant without waiting for the
complete separation as is inferred by the CSO-EIS, although this will
involve giving priority for full treatment to the North Spokane flow.
A
IU)
20 1$$
- u,
v'
55
-------
Roqer Mochnick
April 18, 1979
Page 2
These comments are'not intended to be negative to the proposed City project.
The project is honestly titled and would accomplish the intention of stop-
ping overflows. There is, however, a general misconception abroad that
the project will go beyond this to accomplish full separation. The EIS
report had an opportunity, perhaps even an obligation, to correct this
misconception and did not.
Very Truly\yours,
' Kl/i On
kobert S. Turner
County Engineer
56
-------
Spokane County Engineers
1. These comments have been considered in preparing the
general response entitled Wastewater Reqionalization at the
Spokane Treatment Plant (Chapter 3).
57
-------
Spoken
Health
March 29, 1979
Wesr 1101 College Avenue Spokane. Washington 99201
!313 # 3 3 !1'*
Roger K. Machnick, '201' EIS Coordinator
U.S. Environmental Protection Agency, Region X
1200 Sixth Avenue, Mail Stop 443
Seattle, Washington 98101
RECEIVED
APR 5 197S
rpA.-tq
Dear Mr. Mochnick:
The Spokane County Health District has reviewed the EIS "Draft" for the City of
Spokane combined sewer overflow abatement project. Transmitted herein are our
comments:
1. It is of interest that in the Goals and Constraints Section, it is stated,
"The DOE must insure that the selected project is capable of complying with
the city's NPDES permit, which calls for eventual elimination of all CS0 to
the river." Also, in the Necessity for and Purpose of the Environmental Impact
Statement. it is stated, "In the selection of a combined sewer overflow abate-
ment plan, it is the intent of NEPA that alternatives be evaluated and a plan
be selected on the basis of all environmental considerations, not just monetary
costs." The authors proceed, primarily due to monetary costs, to recommend
Alternative 3, which does not remove all CSO, and does not efficiently remo\'e
effects on the river.
2. On page 9, it is stated, "Only the Latenser Plan would be likely to create
significant improvement in water quality in the Spokane River and Long Lake."
3. On page 10, Alternative 3 is said to be able to improve groundwater quality
condition in the Spokane Valley - Rathdrura Prairie Aquifer indirectly by
allowing eventual sewering of Spokane Valley residences, and this could
eliminate "septic tank contamination" of this sole-source aquifer. Some
observations are in order here:
a. No study we are aware of has shown "septic tank contamination" of the
aquifer. (Perhaps you mean on-site sewage disposal, not septic tanks.)
On the other hand, the current '208' study, as well as other data, show
increased population and man's activities increase pollution. As such,
sewering the valley will encourage more population and hence more pollution.
b. Adding more sewage to the STP will add more pollution to the river.
c. The additional capacity needed at the STP to handle the total valley sewage
will take further monetary investment.
4. On pa^e 10, it is stated, "The Klicker sub-option would best remedy the over-
flow health hazard by eliminating all overflows." This is in opposition to
selection, of Alternative 3.
Administration
Clinic
456-0630 Personal Healrh
456-3640 Viral Srarisncs
456-3613 Environmental Health 456-6040
456-3670 Labororoty 456-3667
58
-------
March 29, 1979
Roger K. Mochnick
Page 2
5. On page 10, it is stated, "Health hazards and aesthetic problems associated
with sewer backups would be. most effectively eliminated by new storm sewers
(Alternative 3)."
6. On page 13, it states that Alternative 3 would reduce energy consumption.
7. Alternative 3 would create a large savings in chemicals.
8. On page 17, the Latenser Plan would allow abandonment of the alum and ferric
chloride use, a net savings of $452,700 annually.
9. On page 19, it is stated, "... a first step in efforts to make the Spokane
plant a regional treatment plant, a regionalization which would produce a
substantial cost savings for wastewater treatment for the Spokane Valley ..."
This statement is in direct opposition to data prepared by URS as part of the
'208' study. The URS study shows essentially the same cost to use the STP as
to use the new treatment facility.
10. The discussion on page 31 explaining why only 15 basins and not 24 would be
utilized in the recommended Alternative 3 indicates the CSO would not be
solved by this plan while it could be by both the Klicker and Latenser Plans.
The above are enough items to support our conclusions. We believe that, contrary
to the stated goals and intent, the recommendation to use Alternative 3 is strictly
based on Tionetary consideration. We believe the Latenser Plan has far and above,
the most environmentally sound advantages. The difficulties of reuse of water
and export to Crab Creek are real, but not insurmountable. In fact, this idea is
being explored by EPA as "THE" method of waste disposal for the future. If the
benefits of reuse of the water and added nutrients for crops and cleanup of the
river are adequately evaluated, we believe this is the alternative of choice.
Even considering monetary effect, let's compare:
(The city population is 132,000 or based on 3.2 people per home, approximately
55,000 residences.)
ALTERNATIVE 3: Construction cost - $ 64,050,000 O&M - $152,930
LATENSER PLAN: Construction cost - $105,645,400 O&M - $587,900*
*Hovever, this eliminates $452,700 of now expended funds on alum and ferric chloride,
A comparison cost to John Doe Citizen for "NO" financial assistance from anyone:
a. Construction cost spread over 10 years
ALTERNATIVE 3-per person - $ 352.00 total » $ 35.20 per year » $ 2.93 per month
per residence - $1165.00 total - $116.50 per year « $ 9.71 per month
LATENSER PLAN-per person - $ 580.00 total = $ 58.00 per year =¦ $ 4.83 per month
per residence - $1921.00 total = $192.10 per year ¦ $16.00 per conth
b. 0&M cost
ALTERNATIVE 3-per person -
per residence -
LATENSER PLAN-per person -
per residence -
$
.84
per
year =*
$
.07
per
month
$
2.78
per
year *
$
.23
per
month
$
3.23
per
year »
$
.27
per
month
s
10.61
per
year -
$
.88
per
month
59
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March 29, 1979
Roger K. Mochnick
Page 3
c. O&M reduction by saved chemical
LATENSF.R PLAN - per person - =* $ .74 per year = $.6425 per month
per residence - = $ 2.46 per year - $.205 per month
d. Total unaided cost per residence for 10 years equals
ALTERNATIVE 3 - $ 9.94 per month
LATENSER PLAN - $15.38 per month
LATENSER, LOITER 0&M - $16.20 per month
Considering the overall benefits from this and the possibility of revenue from the
reuse of the water, the Latenser Plan would rank best from our viewpoint.
Sincerely,
ENVIRONMENTAL HEALTH DIVISION
v
Edward M. Pickett, R.S., M.P.H.
Director of Environmental Health
ciaf
60
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Spokane County Health District
1. Alternative 3 is planned to make a significant reduction
in CSOs, which create a health hazard in the Spokane River.
This does not include stormwater overflows, just CSOs.
Selection of a staged Alternative 3 as the recommended action
was not made "primarily due to monetary costs". Several
of the alternatives were lower in cost (see pages 14 and
15 in the Draft EIS). Alternative 3 provides a viable means
of reducing CSOs (a health problem in the Spokane River)
and eventually sewering areas over the Spokane Valley aquifer
that now use on-site disposal systems (a public health threat
to Spokane's sole source of domestic water).
2. The water quality discussion on page 9 refers to chemical
quality only. Changes in bacterial and other pathogenic
organism contamination of the river is discussed on page 10
as a public health consideration.
3. Use of the term "septic tank" was inappropriate; "on-
site sewage disposal" more properly describes the various
wastewater disposal systems that are used by individual dwelling
units or commercial/industrial developments that are not
part of a central sewage collection system. The recently
released Spokane Aquifer Cause and Effect Report (Esvelt,
1978) concludes that "there is a risk of bacteriological
degradation of the aquifer which accompanies current and
future development over and adjacent to the aquifer. The
risk of contamination will increase with additional population
growth". This indicates that present wastewater disposal
practices over the aquifer are a threat to aquifer water
quality. Most wastewater disposed of over the aquifer is
passed through on-site systems.
It is agreed that continued development over the aquifer
increases the risk of aquifer contamination; this will be
especially true if on-site systems continue to be the main
form of wastewater treatment and disposal. Construction
of sewers may stimulate additional development, but in the
absence of sewers, the use of on-site systems proliferates.
Wastewater reaching the Spokane River from the Spokane
plant has been treated to remove contaminants; waste-
water reaching the aquifer from on-site disposal systems
has only been filtered by the soil mantle.
4. The Klicker Plan would best eliminate the CSO-related
health hazard in the Spokane River, but it is not capable
of adequately meeting the other two project objectives -
controlling sewer backup and flooding problems, and maintaining
the option of using the Spokane plant as a regional wastewater
facility. Alternative 3 could accomplish these objectives
and would only be slightly less effective at reducing health
hazards in the Spokane River.
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5. No response required.
6. The financial comparison of regionalization and construction
of a new wastewater treatment plant in Spokane Valley utilized
data in the U. S. Department of Army, Corps of Engineers
(1976) Metropolitan Spokane study and treatment plant con-
struction costs taken from EPA cost curves (U. S. Environ-
mental Protection Agency, 1978). The recently-prepared URS
data were not available at the time the Draft EIS was being
compiled. It is not known whether the URS comparison was
developed using the same treatment plant size and treatment
level assumptions used to prepare the costs in Table 5-2
of the Draft EIS.
7. Alternative 3 does not include use of storage basins.
The discussion on page 31 relates to storage and satellite
treatment alternatives only.
8. The numbers are essentially correct for the approach
utilized. However, an error is evident in the $16.20 per
month figure for "Latenser, Lower O&M". This number
should actually be $16.67 per month using the numbers contained
in the County Health District letter.
An approach which would more accurately reflect the
actual costs involved would be to amortize the capital cost,
an approach which would take into account interest charges.
Amortizing capital costs over a 10-year period at 8 percent
would make the "total unaided cost per residence for 10 years"
as follows:
Alternative 3 = $14.6 9 per month
Latenser Plan = $24.74 per month
Latenser, Lower O&M = $24.53 per month
Thus, when interest charges are included in the calculations,
the Latenser Plan is less favorable than shown in the County
Health District letter.
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DEPARTMENT OF PUBLIC WORKS & UTILITIES
GLEN A. YAKE, P.E.
ASSISTANT CITY MANAGER - ENGINEERING
ROGER JAMES, P.E.
DIRECTOR OF PUBLIC UTILITIES
April 17, 1979
U.S. Environmental Protection Agency'
1200 Sixth Avenue M/S 443
Seattle, Washington 98101
Ladies and Gentlemen:
Following receipt of the Draft Environmental Impact Statement
on the City of Spokane Combined Sewer Overflow Project, we sent
copies of it to a number of interested local agencies in the City
of Spokane for their review and comments. It was our hope that we
could take the comments and consolidate them into an overall City
comment, however, due to the critical involvement of key City
personnel in important legal matters and court appearances it has
not been possible for us to effect this consolidation. Instead
we will send you the material which we have collected and hope that
you have an opportunity to read it and incorporate it into the
final draft.
Very truly yours,
Roger James, P.E.
Director Public Utilities
RJ:ajg
End .
63
RECEIVED
"PR 1 S 1979
^PA-PIS
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MEMORANDUM
March 16, 1979
TO: Roger James, Director of Public Utilities
. I
/
I I
FROM: Victor G. Cole, Manager - Finance u
SU3JECT: Draft Environmental Impact Statement - Combined
Sewer Overflow Abatement Project
I have been examining the Draft Environmental Impact Statement for the
Combined Sewer Overflow Abatement Project and find that the cost alternates
probably should be updated prior to final adoption.
Some of the material is out of date, 1977 cost figures having been used.
Some of the material apparently may have been developed without a full
understanding of certain of the property tax laws. The table on the
limitation of indebtedness, for example, is one that should be brought up
to date to more correctly reflect the City's financial position. The
alternatives of property tax values have not given consideration to increased
valuation, changes in millage levies, and the effect of the 106% lid law.
The study mentions a combined water-sewer-refuse-utility tax of 6%, when,in
fact, the sewer utility tax is 9-3%- The impact of tax rates is not under-
stood by this office because the assumptions built into the construction of
the impact tables do not appear to be sufficiently explained. It is the
conclusion of this office that, while the differences may not be substantial
to the overall conclusions, readers of this environmental impact statements
are likely to arrive at erroneous opinions as to the ability of the City to
finance the project.
If the Environmental Protection Agency should agree that revisions ought to
be made and is willing to send its people to Spokane for the two or three
days that might be necessary to make the suggested revisions, this office
would be quite willing to set aside the time to work with the EPA representa-
tives accordingly.
Dept. of PU3LJC UTILITIES
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City of Spokane Finance Department
1. The estimated user charge increases and ad valorem taxation
increases presented on pages 142 to 154 of the Draft EIS
were prepared to indicate the general range of increases
that might be expected as a result of the alternatives. The
analysis was not intended to present exact data; it sought
mainly to show relative differences between alternatives
for comparative purposes. An update of the city's financial
position is not deemed necessary for this alternatives comparison.
We concur that the figures used are now out of date.
The user cost and ad valorem taxation estimates adequately
illustrated the magnitude of the potential financial impact
of Spokane sewer system users. It is believed that the magnitude
of the anticipated user cost increases included in the Draft
EIS are well within the level of accuracy expected from facilities
planning. The specific means of collecting local funds and
allocating local costs are to be determined by the city.
Early indications were that the city would pay local costs
through adjustments in user charges.
2. Reference to a 6 percent sewer user tax should be modified
to reflect the current 9.3 percent sewer utility tax. The
important point is that this tax was not included in estimates
of sewer user charge increases that might result from the
various alternatives (Table 4-15, page 151 of the Draft EIS).
In order to develop the estimated ad valorem tax increases,
the local equivalent annual cost of each alternative was
evenly distributed to all property in the city; a total assessed
valuation of $1,835,660,452 was assumed. An estimated increase
per $1,000 of assessed value was calculated. These estimated
rate increases were then applied to several typical properties
(one residential and one industrial) to indicate the magnitude
of the annual increase in a typical tax bill that the tax
rate increases would generate.
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INTER-OFFICE MEMO
April 2, 1979
TO: John Swanson - Director Public Works
FROM: Brad Blegen - Construction Engineer
SUBJECT: Overflow Study Environmental Impact Statement (EIS) Comments
I have reviewed the EIS and have concluded that it is a very well
written document. The author(s) seem to have an excellent understanding
of the information presented in our report and also an excellent under-
standing of our sewer and treatment systems. I think the EIS presents
a favorable outlook towards our proposed storm sewer solution for solving
overflows and will be a very helpful document for the City in proceeding
with the program. I feel the information presented in the EIS is factual
with no significant errors detected.
From our standpoint probably the most important pages in the report
are 184, 185 & 186. Table 5-1 indicates that our proposed storm sewer
(multi purpose) project ($6.81 million) is only slightly more costly than
the proposed EPA storage basin (1 overflow/year) project when a credit is
given for regionalization ($6.18 million). The reason the credit calculated
in the EIS is larger than what we calculated earler in our report is because
of new Valley STP costs available to the authors of the EIS.. Apparently we
will be funded (75% Fed. & 15% State) for Phase 1, and I believe these new
cost figures indicate that we should rightfully be eligible for substantial
amounts of state and federal funding assistance for Phase 2 if a regional-
ized approach is pursued. The EIS indicates that Phase 2 funding is too
far in the future to be committed now. Phase 2 funding will probably not
be resolved until a Valley sewage plan is developed.
One point I thought was interesting is on page 13 it is stated that
th.e storm sewer alternate (Alternate 3) would provide annual cost savings
to the City for electricity ($65,835) and chemicals ($132,600). If these
savings were really realized they would more than offset O&M costs on the
storm sewer system.
In conclusion probably the most important point made on the EIS is
that construction of Phase 1 storm sewers solves 84% of the overflow
problems for 39% of the total cost involved. It is a major step for
solving many backup and drainage problems and is the first step for
regionalization of the Spokane Metro area sewage system. Future funding
of Phase 2 will depend on results of more in depth regionalization studies.
/s/Brad
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City of Spokane Department of Public Works
1. No response required.
67
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CTTTvJF 5PUK'AlNt. WAOnilNVj I vjIN
CITY PLAN COMMISSION
309 City Hatl
RICHARD H. BARRETT, President
VAUGHN P. CALL, A.I.P.
Manager — Planning
E. T. CLEGG. A.I.P.
Planning Director
March 8, 1979
r;
t
i
u
MAR 1?.
fir. Roger K. Mochnick, N/S 443
201 EIS Coordinator
Eiv/i.v^v
VALUATiOrl
U.S. Environmental Protection
Agency, Region X
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Mochnick:
RE: EIS, City of Spokane Combined Sewer Overflow
Abatement Project
/ | We have reviewed the above Environmental Impact State-
I ment and find it has fully discussed this project.
Thank you for the < J~— -
ETC:GOZ:elt
68
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City of Spokane Plan Commission
1. No response required.
69
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CITY OF SPOKANE. WASHINGTON
DEPARTMENT OF PUBLIC WORKS & UTILITIES
GLEN A. YAKE, P.E.
ASSISTANT CITY MANAGER - ENGINEERING
ROGER JAMES, P.E.
DIRECTOR OF PUBLIC UTILITIES
April 3, 1979
MEMORANDUM
To: Glen A. Yake - Manager-Engineering
From: Roger James - Director Public Utilities
I
3
t
/
Subject: EIS on the Combined Overflow Abatement Project
These are my notes after reviewing this project.
Page 1, first paragraph, I do not interpret the NDDES permit
as did the author. The City is simply not in violation of its waste
discharge permit at this time.
Page 5, fourth paragraph, we find a number of descriptive
locations in the report which we have difficulty locating. For
example, "Bridge Street", "East Town", Riverton Street", "Cedar
Street Fire Station", "Spokane Branch Library", and "Rockwood Park
Clinic". One can guess what the author means, but certainly with
no degree of certainty.
Page 20, first paragraph, once again how does one say something,
we fail to see the reasoning behind the statement that we cannot
accept any sewage from outside the City until Phase II of the CSO
program is completed. We think that the truthfulness of this state-
ment depends entirely on the assumptions made and that these assump-
tions should be stated.
Page 39, third paragraph, Mr. Latenser always claimed that the
trunk sewer in Jackson and Cleveland Ave, that is the big fifth ward
sewer, was underloaded. I suppose that if one says this enough times
some people will believe that to be true, nevertheless, we must state
that it is a totally false statement.
Page 51, second paragraph, we believe that this discussion is
misleading, the EPA guidelines provide for determining the most cost-
effective solution by an arbitrary means which cannot and should not
be compared with costs shown in the Facility Plan. It seems to us
that what the EPA sees fit to label a multipurpose plan is actually
a multiple effect plan in which a system designed to correct the over-
flow problem just coincidently also corrects certain other situations.
70
RECEIVED
-PR 1 S 1973
GPA-FIs
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Page 98, first paragraph, first let us correct a few facts.
The City began to dump sev/age into the river in 1890. Its studies
relating to sewage treatment commenced in 1913. The City has been
actively pushing ahead since that time.
We believe that the Long Lake Dam was one of the last ones on
the river to be built. However, most dams have undergone extensive
rebuilding in recent years.
We believe that the amount of water removed from the river for
irrigation or other beneficial use has actually decreased markedly
in recent years.
While State and Federal agencies are Johnny-come-latelys in this
area the City has been an active party in trying to clean up the
river for over 60 years. Four times the City went to the voters and
four times, because of active opposition by the media and lackluster
support from the State, the issues were overwhelmingly defeated.
The City was successful in attempt number five in 1946 and has pur-
sued the program quite vigorously since that time.
Page 188, Table 5-3, the understanding left with the City by
Senator Magnuson was that 75% federal funding, and 15% state funding,
would be available for Phase I of this project. Following completion
of Phase I a period of testing would ensue. If necessary all or
portions of Phase II would follow utilizing whatever federal and state
funds were then available.
It is the City's position that the material on page 188, lower
one half of the page, could be interpreted to mean that the City has
agreed to proceed with Phase II even if no federal and state funds are
available. This is definitely not the City's understanding.
Page 149, fifth paragraph, and page 152, first paragraph, we
categorically reject the statements herein contained.
The City is under orders from the DOE and through them from EPA
to act on the storm sewer program. The required increases in sewer
rates and/or tax rates are imminent, they could easily occur this year.
On the other hand local groups such as the 208 Committee have not
even concluded. As of now that sewering in the valley is necessary,
the 208 report will be out in May 1979 and of course will be subject
to final hearings.
Insofar as the Spokane Valley is concerned we know of no funds to
even officially study this area, Any project is, in our opinion, far
enough down the line to allow an industry to build a plant in the
valley and amortize it before sewer costs would be forthcoming.
This seems to us like a deliberate attempt to mislead.
2
71
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Page 38, a number of pages following page 38 discuss in some
detail financing abilities of the City of Spokane particularly as
they relate to the ability of the City to proceed without the
availability of federal and state grants.
We have asked Mr. Cole to comment on these pages since we feel
they are based entirely on old figures and on interpretations of
state law which are contrary to our general understanding of the
state laws. He believe that the entire pages should be either totally
redone or that they should simply be labeled as inaccurate and there-
fore of no value to anyone who studies the report. We believe that
Mr. Cole's report will reinforce this opinion.
I think these are pretty much the ideas which I have come for-
ward with, I have asked other people in the City to study certain
sections of this report and hope to have reports from them before
the day (April 3) is over.
RJ:ajg
3
72
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CITY OF SPOKANE. WASHINGTON
DEPARTMENT OF PUBLIC WORKS & UTILITIES
GLEN A. Y AKE, P.E.
ASSISTANT CITY MANAGER • ENGINEERING
ROGER JAMES, P.E.
DIRECTOR OF PUBLIC UTILITIES
April 17, 1979
MEMORANDUM
To: Glen A. Yake - Manager-Engineering
From: Roger James - Director Public Utilities
Subject: Further Comments on the Environmental Impact^Statement (EIS)
on Combined Overflow Abatement Project
Since the publication of the EIS the City has on a number of occasions
been advised that the report states that the City system will not handle
flows from the County without increasing the overflow to the river. The
statements seem to indicate that this will be true until both Phase I and
Phase II of the project are completed. We fail to find this statement in
the EIS, but in view of its persistence feel that it is necessary for us
to comment upon it.
The City studies show:
1. The entire North Spokane area can be discharged to the Hollywood
system without increasing the volume of overflow to the Spokane River.
2. Considerable sewage from North Spokane could be added to the
Cochran Avenue system without increased overflows. The extent to which
this can be done depends upon exactly how it is designed and constructed.
The theory behind this statement is that if the material could be dis-
charged to an existing facility, such as the Lidgerwood Lagoon, it could
then be pumped into the City system during dry weather periods and at off
peak hours.
We believe that the following statement pretty well covers the
position regarding sewer service East of the City:
"If we can assume the following:
A. The sewers in the Southwest portion of the City are separated
(this is the area South of the River and generally East of Perry Street).
B. All sanitary sewage from this area and from the Spokane Valley
is transported to either Mallon and Perry or Trent and Erie.
C. Phase I of the Spokane Combined Sewer Overflow Project is completed.
73
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D. The North Spokane area is sewered and connected as outlined
under either 1 or 2 above."
It is our feeling that if the conditions listed herein are met,
overflows to the river will not increase during the period that the
rest of the Phase II Project is being completed.
RJ:ajg
2
74
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City of Spokane Public Utilities
1. Recent discussions with Mr. Claude Sappington of DOE
indicate that Spokane is in technical violation of its waste
discharge permit because the CSO abatement project schedule
stipulated in the latest modification to the permit has not
been met.. A new schedule for compliance will be developed
once the EIS process is completed.
2. No response required.
3. This comment has been considered in preparing the general
response entitled Wastewater Regionalization at the Spokane
Treatment Plant (Chapter 3).
4. No response required, as the Latenser Plan is no longer
being considered.
5. EPA guidelines and program management memoranda have
been developed to assist in allocation of federal funds to
local public works projects. The cost comparison and cost
allocation methodology of PRM 75-34 and PRM 77-4 are intended
to clearly indicate the most economic means of achieving
the legal mandates of the federal Clean Water Act. The act
requires control and eventual elimination of discharge of
pollutants to the nation's waterways. All local plans to
achieve this goal must be compared with the least-cost means
of achieving the goal. In Spokane's case the most inexpensive
means of controlling the pollution (CSOs) would be construction
of storage basins sized for the 1-year frequency storm. The
proposed action (Alternative 3) is more expensive than this
storage option an<3 seeks to solve more than just the CSO
problem with the extra expense. In order to comply with
its guidelines, EPA must assign this extra expense to the
local entity, thereby reserving federal funds for just the
water pollution control purpose they were originally allocated.
6. The comments are acknowledged and incorporated into
the Final EIS.
7. All decisions on the nature of and funding for Phase 2
will be made after Phase 1 results are analyzed. DOE will
have primary responsibility for determining Phase 2 requirements.
8. The information on pages 14 9 and 152 is not intended
to be misleading. It simply provides a rough estimate of
the effects of allocating local share project cost on a property
tax (ad valorem tax) basis. The exact means of distributing
the increased local costs would be left up to the city. If
payment through property taxation is not desirable, user
charges or some other procedure may be used. The ad valorem
taxation figures simply provide a second means of comparing
the various alternatives. EPA requires only that the cost
allocation be equitable.
75
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Spokane County is seeking to study wastewater treatment
possiblities in the Spokane Valley area through a regional
201 planning effort. Application has been made for a grant
to fund this planning; a grant award is expected in July.
9. Refer to the Spokane City Finance Department letter
for responses to these comments.
10. These comments have been considered in preparing the
general response entitled Wastewater Regionalization at the
Spokane Treatment Plant (Chapter 3) .
76
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April J+, 1979
MEMORANDUM
TO: Roger James, Director Public Utilities
FROM B. J. Schmitz, Traffic Engineering Director
SUBJECT: ENVIRONMENTAL IMPACT STATEMENT CITY OF SPOKANE
COMBINED SEWER OVERFLOW ABATEMENT PROJECT
We have reviewed the E.I.S. for the Combined Sewer
Overflow Abatement Project and are very concerned
with the effect that construction of recommended
Alternate 3 will have upon vehicle travel.
This Department will be intensely interested in
having input during design stages in order to
avoid proposals that would create critical traffic
conditions during construction.
bjs mrs
77
Dept. ol PUBLIC UTILITIES
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City of Spokane Traffic Engineering Department
1. Because the proposed action will be constructed under
the direction of the city, it is assumed that the Public
Utilities and Traffic Engineering Departments will consult
on traffic control problems. Every effort should be made
to minimize serious traffic safety hazards and traffic
disruptions. Several potential mitigation measures have
been suggested in the text of the Draft EIS (page 89); these
and other mitigations should be thoroughly explored prior
to start of construction.
78
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ilZZl! BCVAY EWGIiMESHS, ![NJC.
ii HOUSTON • SPOKANE • BATON ROUGE
1- :V;caJ!LJ Austin • alSuOuebque • Washington 0. C.
BOVAY
April 3, 1979
Mr. Roger Jaines, P.E.
Director of Public Utilities
North 221 Wall Street
Spokane, Washington 99201
Re: CSO Abatement E>S Comments
Dear Mr. James:
We have examined the final draft Environmental Impact Statement for
the Sewer Overflow Abatement project and enclose our initial comments for your
review. We will continue to review the document and keep you informed of any
additional comments we feel are significant- Please feel free to include any
of the notes in your written comments being submitted to EPA.
Si ncerely,
BOVAY ENGINEERS, INC.
Robert E. Smith, P.E.
RES: er
Enclosure
Dept. of PUBLIC UTi'-lTl^S
79
PROFESSIONAL ENGINEERS AND PLANNERS
EAST 808 SPAAGue AVENUE SPOKANE. WASHINGTON 99702 TEL 509 838-4111
-------
COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
PREPARED FOR
CITY OF SPOKANE
COMBINED SEWER OVERFLOW ABATEMENT PROJECT
Pages 1 and 2 - It seems to be a gray area whether or not the City is
in violation of its NPDES permit as evidenced by the conflicting statements 1)
The City's NPDES permit specified cleanup of all CSO's by 4une 30, 1977 (is this
true?) and 2) "... NPDES permit, which calls for eventual elimination of all CSO
to the river."
Page 5 - Eastown? Should this be Northtown?
Page 6, Table 1-1 - Eastown? Same as for comment on page 5.
Page 7 - "construction is planned for most of the major streets in the
downtown area." Is this true? Figure 4-2 shows less than 50 percent.
Chapter 1
Page 9 - There seems to be conflicting data in the report to support
the statement, "Suspended solids loading would be increased by over 160 percent
due to direct discharge of stormwater runoff."
Page 10 - States that the Klicker suboption would best remedy the over-
flow health hazard by eliminating all overflows. No plan will eliminate all
overflows because the overflow depends upon the intensity of the storm and no
basin can be designed to handle the maximum possible storm.
Page 12 - Alternative 3 would eliminate sanitary wastewater related debris
Page 13 - The costs for chemical savings and for additional costs is
probably off by a factor of 2 because of recent and anticipated price increases.
The statement that Alternative 3 would create a large savings in chemicals is
definitely correct.
Page 16, Table 1-6 - Why does storage under Alternative No. 1 and storage
under the Klicker Plan have such a wide variance, i.e., $94.10 vs. $30.38?
Page 19 - The last paragraph says Phase I would eliminate 84 percent of
Spokane's CSO but would probably not result in discernible change in Spokane River
water quality. However, the same paragraph says that Phase I would eliminate the
two largest sources of untreated wastewater discharge. How can water quality not
improve if this is true? This conflicts with page 29-which says, "The constituents
K[u)
379 Lyj
: UTILITIES
80
4/3/79
Depf. of PUSH
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in the CSO which are of particular importance are pathogenic organisms and solid
materials of sewage origin."
Would like to see backup data that says Phase 2 is absolutely necessary
to function as a regional facility.
The total construction cost in the report for Phase 1, $24,980,000 is
1 ow.
Is the statenent correct that the north central and southern region would
not be relieved of the sewer backup problems, and that those areas are the most
severe?
Page 20 - Is it correct that separation in the Hollywood and Cochran
areas will not allow annexation of flows from north Spokane?
Stormwater Overflows - Chapter 2
Page 24 - Average daily flow for 1978 was 36.2 MGD.
Page 34 - The second paragraph is incorrect. The re-evaluation by the
City did not result in a decision to size basins for one overflow per year. The
one overflow per year criteria was dictated by the EPA.
We have not seen any discussion of future energy costs for pumping all
the stored water
Page 36 - Further review of O&M costs will show that the estimated annual
0&M costs for all alternatives is greater than the O&M costs for separation. It
therefore becomes apparent that with excessive inflation in power and chemical
costs that the City is being asked to fund an ever increasing O&M burden.
Page 37 - On the satellite treatment plants there is absolutely no
guarantee that future regulations will not require secondary treatment. In every
case there will not be land available. However, in the case of Cochran (Meenach)
and Hollywood storm separation, there would be space available for primary treatment
of stormwater.
Page 41 - Is the Fort Wright Bridge structurally sound enough to carry
a 110-in pipe flowing full?
Page 60 to 63 - In most cases we are .talking about acquisition of public/
private land. This would be extremely difficult at best.
Page 67 to 72 - It is recognized that storm sewer construction will
disrupt many areas; however, the overriding point is that it can be scheduled in
such a manner that only one recreational area or one semipublic facility is
impacted at a time. The report currently leads one to believe that streets around
all parks would be torn up at the same time.
81
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Page 75 - Mitigation measures for construction impacts. This is a good
discussion, i.e., the limiting of construction to two continguous blocks, the
appointing of a contractor's construction coordinator and the use of the off season
when constructing facilities near parks and recreation areas. The preceding dis-
cussion which ends on page 90 concerning construction disruption seems to be
objective and a good presentation of the subject.
Pages 92 and 93 - It appears that the report is based on the old
generally accepted, 1/3, 1/3, 1/3 to determine labor payroll costs.
Page 94 - We concur with the emphasis on Garland Avenue.
Page 101, Table 4-5 - Again we would like to seeNthe assumptions, data,
calculations, etc., supporting the 160 percent increase in suspended solids loads
to the Spokane River. Table B-10 shows stormwater runoff S.S. at 138-207 mg/1
based on analyses of stormwater by treatment plant staff. I think clarification
is needed as to whether this is combined stormwater or stormwater runoff. Sanitary
sewage S.S. are generally at least 70 mg/1 yet we show a range in Table 2-1 of
20 - 210 mg/1 for CS0 suspended solids which is lower than either of its constituents.
How can this be? Table B-10 is inconsistent with Table 2-1 for CS0 suspended solids
and BOD.
Page 113 - Sediments from Hangman Creek and upstream areas would also
mask the effect of CS0 suspended solids at low flow periods.
Page 138 - Note: Costs are based on 1978. We are already looking at
1980 costs or two years of escalation on the project.
Page 145, Table 4-11 - Shows $9.5 million available for indebtedness on
Councilmanic Bonds. Since this statement was as of September 31, 1977, it does
not include the pavilion.
Page 154, Table 4-17 - As shown in several areas of the report separate
storm sewers at $190 is again much cheaper than any other alternative except No. 4,
Klicker Storage Sub-option, at $117.
Page 156 - All the energy figures in the report are based on present
costs and are not escalated. This should be noted whenever 0&M costs are considered
as increases in energy costs are projected to be quite significant over the next
20-50 years.
Page 157 - When discussing chemical costs it should be noted that the
price of alum went up 50 percent last year and such increases in the future with
all chemicals should be a significant concern.
Page 160 - The draft by Kennedy Engineers suggesting that phosphorus
removal units at the treatment plant cannot properly treat flows beyond 57 mgd
without expansion may or may not be true. Conversion of stormwater clarifiers
only to Secondary clarifiers requires pump and piping'modifications'but not
additional basins.
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Chapter 5 - Proposed Action
Page 182, Figure 5-1 - Note that the area between A and Maple, Rowan
and Garland is not proposed for storm sewer separation.
Page 185, first paragraph - EIS implies allocation of Phase I-costs
between Federal, State and local entities has been firmly established. This is
not necessarily true.
Third paragraph - About 120 miles of storm sewer will be installed for
Phase I, not 90.
2^1 ^a9e 187, second paragraph - After Phase I, suspended solids loading
3 would increase 15 percent annually, compared to the total iN63 percent for Phase
I and II. If Phase I removes 84 percent of the CSO, these SS percentages appear
to be inconsistent.
1
Page 188 - States that downstream coliform concentrations would be
much lower with Alternative No. 3.
Page 188, third paragraph - Is it true that there are much fewer sewer
backups in the Hollywood and Cochran drainages?
Page 188, fourth paragraph - Last sentence is unnecessary as- it is
restated in the footnote to Table 5-3.
Table 5-3 - Numbers are correct if 87.8 percent total eligibility is
correct.
Page 189, 0&M - Add to paragraph, "0&M costs for Alternative No. 3 are
I substantially lower than any of the other alternatives."
37
Page 190 - Talks about sewer rates wherein the only increase in user
charges would be that required to finance 0&M and to raise the 10 percent share.
Depending upon the City's cash position and the present fund surplus, there may
not Le a need to increase rates for th°- next ten years.
Page 191 - Table 5-4 - Shows an increase in user charges and probably
can best be analyzed by the City accounting department.
. Pages 190-192 - Says Phase II must be implemented before significant
3/ j interceptor capacity is freed. Should have calculations and backup data in EIS
to support this as it is a' significant item.
3*1
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Chapter 6 - Affected Environment
Page 201 - Near the bottom of the page it infers that chlorine discharged
from the sewage treatment plant may be partially responsible for low summer concen-
trations of total coliforms.
Page 204, Hangman Creek - Last sentence in the first paragraph is a
questionable statement. Should say, "The small flows from this nutrient-rich
stream may not significantly influence Spokane River quality." (or, eliminate
sentence).
Page 211, Table 6-5 - Gives some current and projected population figures.
Increases for the City of Spokane average around 3 percent and those for the county
average around 5 percent. The City's is about right, but the county looks low.
Page 217 - States the largest single source of suspended particulates
is unpaved roads. A lot of the roads on the northeast area could very well be
paved under the storm sewer project.
Page 219 - Starts the bibliography. Bovay Engineers is listed as
completing the Report on Additions and Modifications in 1978. This is incorrect--
it's 1973.
Page 220 - There are certainly a lot of reports, etc., prepared on the
Spokane area and to date the only one thing that has been done is building the
treatment plant.
Page 227 - It is worthy to note that Ken Lauzen, Bob Kussman, Richard
Thiel, and Norm Sievartson, the people who know something about the Spokane area,
were evidently not contacted regarding this report.
Page 240 - Shows significant impacts based for Alternative No. 3 because
the streets will be torn up. Again, there are ways of minimizing the impacts.
Page 245 - Shows the storm sewer impacts on parks. In general they are
significant but can be mitigated.
Page 247 - Construction activity on semipublic/public facilities. Same
comment. These impacts can be minimized.
Page 252, Footnote No. 7 - Seventy-five percent suspended solids removal
for primary treatment sounds quite high. What is this number based on?
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Bovay Engineering, Inc.
1. The city's original NPDES permit did require elimination
of all CSOs by June 30, 1977. However, when this schedule
could not be met, DOE issued several modifications to the
permit schedule. These modifications state that DOE will •
not initiate enforcement action against Spokane for failure
to achieve the June 30 clean-up deadline as long as they
comply with new schedules included in the modification orders.
The latest order (Docket No. DE 77-335, first amendment)
required elimination of dry weather CSO from three discharge
points by February 16, 1978, and full compliance with the
treatment plant total phosphorus effluent limitation by
February 1, 1978. The latest time schedule for full CSO
control (Docket No. DE 77-833) required that plans and speci-
fications for the Meenach and Hollywood CSO corrections be
submitted no later than April 30, 197 9. This schedule is
under appeal by the city.
2. The Eastown commercial area is located on the southwest
corner of Havana and Sprague at the city's eastern edge.
The reference should not be to Northtown.
3. As indicated in Figure 4-2 of the Draft EIS, all down-
town streets except Stevens and Howard will face some dis-
ruption from storm sewer construction. Some of the streets
will only be crossed by the new pipelines, but this will
nonetheless cause traffic delays and disruptions.
4. This comment is considered in the general response entitled
Stormwater Treatment (Chapter 3).
5. The storage basins and surface lagoons planned in the
Klicker Alternative were to be sized to accommodate stormwater
flows in excess of those expected from the 25-year frequency
storm. While it is true that a CSO could still occur, statistically
it would be less than once every 25 years.
6. No response required.
7. The chemical costs were based on prices being paid by
Spokane as of September 1978. They have undoubtedly increased
since that date.
8. Alternative 1 (25-year storage) includes $28.9 million
of construction for relief sewers to correct sewer backup
problems. This cost would be borne totally by the city and
would therefore be reflected in user cost increases. The
Klicker sewer backup control strategy (gate valves and on-
site storage) would cost only $1 million. As a result, the
city's share of Alternative 1 construction cost would be
$36.2 million while its share of the Klicker Plan would be
only $6.9 million. This accounts for the extreme difference
in user charges shown in Table 1-6 of the Draft EIS.
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9. Throughout the Draft EIS, discussions of bacterial and
viral contamination of the river and its public health implications
have been separated from other water quality considerations
(e.g., nutrients, suspended solids, BOD). The statement
on page 19 of the Draft EIS refers to water quality exclusive
of the pathogenic organism question. Data analyzed in the
EIS indicate that CSOs contribute generally less than 1 percent
of the river's load of nutrients and suspended solids; there-
fore, elimination of the estimated 84 percent of the CSO
would probably have little effect on these water quality
parameters. From a public health standpoint, however, the
84 percent CSO elimination (pathogenic organisms and solid
materials of sewage origin) would be significant because
of the reduced health risk.
10. This comment was considered in preparing the general
response entitled Wastewater Regionalization at the Spokane
Treatment Plant (Chapter 3).
11. The Phase 1 construction cost fiqures are based on data
presented in the city's CSO facilities plan (Spokane City
Department of Public Works, 1977), and utilized the same
unit costs presented in that report. The facilities plan
estimates were made in 1977, so may be slightly low due to
inflation over the past 2 years.
12. The statement is consistent with backup location and
severity information supplied by the Spokane City Department
of Public Works.
13. This comment was considered in preparing the general
response entitled Wastewater Regionalization at the Spokane
Treatment Plant (Chapter 3).
14. The 39 MGD average daily flow estimate was based on
data from January to June 1978.
15. It was not intended to indicate that the city concluded
basins should be sized to allow one overflow per year. This
was an EPA determination.
16. No energy cost estimates were made for pumping from
storage in either the city or Klicker storage plans.
17. The proposed action is presently stormwater separation;
therefore, the city is not being asked to fund an ever-increasing
O&M burden.
18. No response required.
19. The structural integrity of the Fort Wright Bridge was
not analyzed in the EIS; the Latenser Alternative is no longer
being considered, so the question does not warrant further
investigation.
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20. The potential acquisition problems are recognized and
have been considered in selecting the proposed action.
21. It is stated at numerous points in the report that Phase 1
construction would be spread over a 5-year period and that
individual sites would be affected for only a 2- to 3-week
period. There was no intent to indicate all parks would
be affected simultaneously.
22. No response required.
23. These comments are responded to, in part, in the general
response entitled Stormwater Treatment (Chapter 3). It has
been verified that the data reported as stormwater quality
was indeed obtained from stormwater (not CSO) measurements.
Total suspended solids and BOD quality listed in Table 2-1
is transposed; BOD should be listed at 20-210 mg/1 and total
suspended solids should be 76-220 mg/1.
24. We concur with this assessment.
25. No response required.
26. Refer to the Spokane City Finance Department letter
for response to this comment.
27. No response required.
28. Future increases in energy and chemical costs are acknow-
ledged and have been considered in selecting the proposed
action.
29. No attempt has been made to verify Kennedy Engineers
suggestion. The phosphorus removal capability should be
thoroughly investigated prior to any regionalization efforts
that might result from sewer separation.
30. The funding allocation for Phase 1 has not been finalized,
but it is felt that it will be very similar to that identified
in the Draft EIS.
31. The revised estimate is acknowledged.
32. Phase 1 would reduce CSO by 84 percent, but total storm-
water separation would increase direct stormwater runoff
to the river by over 5 billion gallons per year. This accounts
for the large increase in suspended solids loading to the
river (see Tables B-10 and B-ll of the Draft EIS).
33. No response required.
34. This statement is supported by sewer backup location
and frequency information supplied by the Spokane City Depart-
ment of Public Works.
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35. No response required.
36. The statement is accurate, but not needed in the Phase 1
impact analysis.
37. No response required.
38. See Spokane City' Finance Department letter for additional
comments on user charges.
39. This comment was considered in preparing the general
response entitled Wastewater Reqionalization at the Spokane
Treatment Plant (Chapter 3).
40. There has been no field study to determine whether
treatment plant chlorine residual is affecting downstream
bacterial levels, but this possibility is suggested by the
coliform sampling data presented in the metropolitan Spokane
report (U. S. Department of Army, Corps of Engineers, 1976).
41. Qualifying the statement about Hangman Creek's influence
on Spokane River water quality is problably warranted in
light of the relatively limited data available on Hangman
Creek quality.
42. The population projections presented in Table 6-5 were
developed in 1975 by the Spokane City Plan Commission. It
is possible that the county numbers are low when the rapid
growth of the last 2 or 3 years is considered.
4 3. No response required.
44. The typographical error in the BIBLIOGRAPHY is acknowledged;
the correct date is 1973.
45. No response required.
46. Ken Lauzen played a major role in compiling data for
and preparing the Draft EIS; he is listed on page 227 under
U. S. Environmental Protection Agency, Olympia, Washington.
47. No response required.
48. The suspended solids removal estimate is based on manu-
facturer's literature for the type of treatment used by the
city in its cost estimates.
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1 >
- J
RECEIVED
-PR 1 3 1979
r"1-* \ ^
r\ ;i~ n ^ /-:•« q k 3 .-N'n . . T « V} >¦* -
-1 -1
ir.i~ r.~t
--v^.'"3'v'"Z.Y f,h? of -i~S-?.V3 brr "huxD.ci.j.'.*"-" 3^ J- of*
*V^-3 •~'3Tr,32? t»hon "V^s of* v^*t5-*r^ 7,;?r'-*r>>'>+,
"'ro-'ect as outlined in the flicker plan.
I request that you rake -an analv3is of costs for such a combination.
- base I in the "Torth portion of the City T-?ill than handle 8^i of se:-ra?;e presently
discharged. Klicksr plan storage tanks and lagoons '-n.il handle 16/5.
Costs of cleaning such storage should be reasonable. The concrete floors of
stors-e should be sloped so thst a ''s^rtnklin^ s"*sterv' rd.?v.l olaar. autcritically.
The •'sprinklers'' "ould thrc-r a stream of vater nlT.o^t fire hoso size, the "?t*r
broker, up slightly, and rotate vcrv slo-.rly. -loasles similar to those i^sed in
the hu-o automatic irrigation svntens that irrigate a §0 acre cirle of land
If th~se T*ere turned or -rhile the last of the storr. "rater was .irainin~ out there
^ " l*1 tt 1-1 c^ -anins ^ e ft to b^ d one •
C-" co"r*:o the storage tanks en be desirrned so that lots of labor is necessarv,
'"lit o-r proiectier.s should not be base? on ooorlv designed storare.
'•his should "not affect reTionalisation of s w':e nrobl^ns• The Valley can still
he hooked on to the 1'orth 3luff intercept. It has a hu^e circumference and the
sli~ht additional floTT should rrake coTTjarativ,',lv sTnall difference. Possibly it
would be necessary to purm this line downhill during a storm. However this seers
to be a *nost remote possibility,*, but the figures aren't presently available to
ne to cuote.
It T.i»ht be r.ec;ss«»ry to purrc a swill anount cf this Valley sewage into the -'orth
Bluff intercept as there is an -area -iast of division Ct that will not ~ravitv
flo-'.
Obviously the p-ipin~ and pupps necessary for re^rionaliaation are chargeable to
future plans to hook up to our treatment Plant. There is no reason for the City
to pa" e::tra nw for our -ewa^e Abatemrt product. If they hook on, and this
is stil an en^n function, thQ'"' should rav then.
As far is plant earacitv is concerned "it arrears obvious that the plant c*n handl?
r e ¦ - i o p a 1 i ^ ati c n as storr volur.e '-"ill be onlT* lb> of previous calculations. -e she1.
lb"1 e to trickle this in at ^i^ht von flow is TO.j to ¦ un-1ar dav time flev*•
•N..* •"> ¦
-«o 1
XT n.*. \c:
-ore efficient o^eration than nor!a?.l fluct'^-tions.
89
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Jake Klicker
1. Mr. Klicker has requested that costs be developed for a new
alternative. This alternative would use storm sewers in
certain areas in the northwest portion of the city, and the
Klicker concept of covered and open storage basins to control
CSO in the remainder of the city. Storm sewers would be
constructed for drainage areas 12 and 15 (see Figure 1 in
this report), which is the identical area for construction
of the Phase 1 storm sewers in Alternative 3 of the Draft
EIS. Construction of these storm sewers would eliminate
the need for the large reservoir at Bridge Street proposed
in the earlier Klicker Plan as well as pipelines to connect
this large reservoir to existing interceptors. Other than
these changes, this new alternative is identical to the Klicker
Storage Suboption described on pages 34 to 36 of the Draft
EIS.
The cost for this new alternative would be as follows:
Total Construction Cost $55,042,970
O&M Cost 245,370 per year
Average Annual Cost 5(, 638'; 4 90 per year
These costs can be compared with the costs for other alternatives,
which are presented in Table 1-4, page 14 of the Draft EIS.
When the costs are compared, it should be noted that the
average annual cost for Mr. Klicker's new alternative is
less than the average annual cost for Alternative 3, which
is the proposed project. This comparison should be tempered,
however, by the fact that Phase 2 (of Alternative 3) costs
are only speculative at present. There will be a reevaluation
of CSO control after the results of Phase 1 separation have
been analyzed. Mr. Klicker's proposed Phase 2 approach could
also be evaluated at that time.
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Oral Comments
The following oral comments were received at the Draft
EIS public hearing held in the City of Spokane on April 4,
197 9. The comments are briefly summarized; for a complete
version of the testimony see the hearing transcript attached
at the back of this report.
Roger James
Mr. James indicated that the figures and discussions
of user charges presented in the Draft EIS should be revised,
as they are out of date and inappropriate. This comment
was considered in preparing the response to the Spokane City
Finance Department's letter in the preceding section of this
chapter.
James Schasre
Mr. Schasre asked if the stormwater collected by new
separate storm sewers would be treated prior to discharge
to the Spokane River. Mr. Burd of EPA/ Mr. James of Spokane
City Utilities, and Mr. Arnquist of DOE all made oral responses
at the time of the question. The general response was that
there are currently no plans or requirements for treatment
of stormwater discharges, and none is foreseen in the near
future.
Robert Smith
Mr. Smith pointed out that water quality data in Tables 2-1
and B-10 of the Draft EIS were inconsistent. BOD and suspended
solids numbers were in conflict. A check of the report text
found that BOD and suspended solids numbers in Table 2-1
had been transposed. This transposition is acknowledged
and corrected to read: BOD - 20-210 mg/1 and Total Suspended
Solids - 76-220 mg/1.
Mr. Smith also questioned whether data reported in Table B-10
as stormwater quality was not in fact CSO quality. A check
of the data and its source verified that it was stormwater
quality.
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BIBLIOGRAPHY
References
Bovay Engineers, Inc. 1973. City of Spokane, Washington
report on additions and modifications to the wastewater
treatment plant. 3 vols.
1977. Preliminary draft, facilities planning
report for sewer overflow abatement supplement -
construction grant allocation analysis. Prepared for
City of Spokane Dept. of Public Works.
Esvelt and Saxton-Bovay Engineers, Inc. 1972. Action plan
for better wastewater control - advanced waste treatment,
high river water quality, better environment. Prepared
for the city of Spokane.
Esvelt, Larry A. 1978. Spokane aquifer cause and effect
report - summary report of '208' water quality results and
cause and effect relationships for water quality in the
Spokane Rathdrum aquifer. Prepared for Spokane County
Engineers.
Keller, S. [n.d.] Historic landmarks survey: a report and
site inventory of Spokane's historic resources. Un-
published report, prepared for the Spokane City Plan
Commission.
Kennedy Engineers, Inc. 1978. Preliminary draft facilities
plan - North Spokane suburban area sewerage system. Pre-
pared for Spokane County.
1978a. Rough draft amendment to the North Spokane
facilities plan. Prepared for the Spokane County Engi-
neers .
1979. North Spokane wastewater facilities plan.
Prepared for Spokane County Engineers.
Spokane City. Department of Public Works. 1977. Facilities
planning report for sewer overflow abatement. 5 vols:
text, exhibits, back-up data, appendices and supplement.
U. S. Army Corps of Engineers. 1976. Metropolitan Spokane
region water resources study. Summary report, technical
report and 11 appendices. Prepared by Kennedy-Tudor
Consulting Engineers.
U. S. Environmental Protection Agency. 1978. Construction
costs for municipal wastewater treatment plants: 197 3-
1977. Office of Water Program Operations, Washington,
D. C. 43019-77-013. MCD-37.
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TRANSCRIPTS OF PUBLIC HEARINGS
ON DRAFT EIS
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BEFOPE THE UNITED STATES
F.NVmOJi'lLNTAL PROTECTION AGENCY
REGION 10
h PUBLIC HEARING
ON
AVAILABILITY OF AN f:NVI RON MENTAL IMPACT STATEMENT
COMBINED SEWER OVERFLOW ABATEMENT PROJECT
CITY OF SPOKANE, WASHINGTON
BEFORE
MICHELLE COYLE
liEMilNf; CTFICEU
2:30 P.M.
APRIL 4, 1979
COUNTY HEALTH DISTRICT OFFICES
ROOM 140, W. 1101 COLLEGE
SIOKAtlE. WASHINGTON
CAROL I. DEWEY
LuiCI At|«(hi< In
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Speaker'•
Michelle Coylc
Robert Bard
Charlca Hazel
Robert Gumserman
Mike Ilushton
Roger Jaatas
Jiiiea Schasre
I 11 ii PlHfl*'
SfOKANL *** !>• UN*i I ON M203
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2»30 P.M., April 4, 1979
MS. CGYLEt I would like to convene this
hearing on Environmental Protection A^anoy'a Draft
Environmental Itipaot report or EIS for the City of Spokane
CcanbiiteJ Scuur Overflow Abatement Project.
Lot the record indicate that this meeting la taking
place at 2i35 in the afternoon at tha County Health
district Office, Itocra 140, Uest 1101 College, Spokane.
I would like to welcoioe you all hare. I appreciate
your attending and taking your tine to caao and share your
opinions with ua. X realize that many of the iasucs which
will be disuujaed this afternoon will be of direct
concern to you.
My nanus iu IIichclle Coylo, and I cm an attornoy with
tho Of.iicd of liejior.ul Counsel, Environmental Protection
.lyoncy, .
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subject o£ this hearing discusses onvjroiuaental impact
of tho propui
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the City of Spokane, who will give a brief statement, as
well.
¦fittor the statuwenta of these three individuals,
oral presentations will be made in the following orderi
Ir there &r o any federal government representatives in tlie
audience who wish to make a statement, they will 90 first 1
then state representativej, county representatives, city
representatives, and then individuals and citizen groups.
As of this moacnt, z do not have any requests for making a
statcuent from anyone other than those seated here at tho
head table, so if you do wish to make a presentation. Jet
nic know.
If anyone needs to loave early, pleasa let tlichalene
hard, who is seated at the table by the entrance to this
roan, knew, so I ccji give you an opportunity to speak.
Follcuinj the presentation of the testimony, in Part
2 of the agenda, we will have a discuseion-and-question
period. Questionu may be asked of the panel sitting here
at the table, through me. The panel may have to ask their
various associates in the audience to answer tha mora
technical que&tlons.
i.a Hearing Officer, I reserve the right to limit
discussion as such nay be necessary. Since this is an
inforual hearing, no cross-examination is really ncceusacy
or appropr late. Au already utaLcJ, please auk your
CAIIOI I l>l Wl V
, ,4m,.
. l«»n y«.Mi
...(i com:
1 questions of tho panel tlirough me, ar.il tli,/ t;Lll ficJ.J
2 them or field tho question to the i>rotjjr r,;:LLon.
3 Presentations, sinco so few people havo notified me that
4 they would like to make a prasentacion, could Lj .13 Jou j
5 as IS to 20 minutes. Written material Uiould Lo ieit uivl.
6 me following your presentation, if you havo it, or aunt
7 to Mr. Mochnick at tho address I noted earlier. You at-i
8 under no obligation to submit written uatccial, but a
9 written account helps ua keep our records in ccii-.r .aid
10 makes it easier for the individual making tin.- t ir^njcr ip t.
11 Written material must be submitted before tno deadline of
12 April 19, and I believe the release of the filial
U Enviromaental Impact Statement is actiadulu J tor ajiproMi-
I* mately aix to ei>iht veela following tho uloju or tha
15 caament period.
16 A record is being made by the court ro^oi t^r, ;u.
Carol Dcwcy, and, th^refo^e, I ask that you clear ly state
your name and ad-'ll
CAROl. L. I>t wt y
'• Mil/ I'l M**V
WOtlAhl W«'.IM4T.ION WMJ
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1 as Ei'A'a Seattle Kejional Office.
' Ara there i.ny questions about the procedure to Le
* folltued?
Seeing none., let ma introduce He. Burd, who will iuoka
* Clio tirut inLrcductory communco.
}Ul. Boitui I would like to spend a few minutes
to ruviuw the rationale we want tlirough at EPA in making
tha duelsIon to prepare an Environmental Impact Statement
9 on the City of Spokane's plan to control cor«bined sewer
10 cverflcva. and, by tha way, 1 hope everyone has picked up
' the handout that is available. It does hava a definition
of what combined overflows are, in case you ara unfamiliar
uith the term and tha probleics it jaay create.
basically, we felt that an Environmental Xispact
Statement on tho City's facilities plan for tha combined
uower over £ 1c*j project would provide a greater public
i-v/arcneou of tha issues that are involved with this
project, and aloo greater public participation in tha
decision-inking process as to what would be tha best of
the alternata solutions in solving coabinad-sewer-overflw
problems.
Vic felt this particular project In Spokane was a
proper project.
There were a number of alternatives that needed to
be considered, quite a number of alternatives, which
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CAROL I. OCWEV
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eventually were reduced to buuically j>„vc_.i in I ho [ikll
Environmental Impact Statement. Uo tliOLjh'c there wcrj
significant economic iauues involved \/ith this pt:oji.ut,
economic issues that the citizens of Spok wjuld Lu
very much interested in and would b&cJMe, hopefully, .ioru
familiar with through the preparation of an Lnvirunmcntul
Irapaat Stateijent.
Wo also felt that there wero major c:.vir„:u..firital
issues to bo dealt with hero. There ujc tho ip.pact o£
controlling, or not controlling, cc»..),ir.c j a<->.-R£ c/uirllc./u
on water quality in the Spokane River
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Lpokaiu County, i.'c thought all thc:;o i3suem vera very
important, and suno rjoi.ibota or thu public iil tho ilpokane
crca aoU'jlit greater public involv^oiit than had been,
Lhey felt, available up to that time.
So, bjjiiJ Git their interest, and, Mr. Hazel.
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lit. lUtJ.HLt lly name is Charles Ilancl. I
represent Jones U Stokes Associates, the prime contractor
lot tho preparation o£ tho Environmental Impact Statcmont.
CAKOL I. OI WEV
JIMMil MA rflilK.ll 'U W'l
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I would like to introduce two ot n;y ajiioci utoa who
were principally irtvolvod in tho preparation or. the docu-
ment, Hike Rualiton 2ind l; abort Gura.Tjnv.jii. 1'licy will be
making a short presentation of so.ua cf Liu kiiy material in
the document, in the EIS, and will ba u/aiiablo to i;n,iwr
technical quostions later on.
To add soraowhat to tha purpo3Q and scope of thu EIS
given by Mr. Burd, I would like to indicate that the
Draft Environmental Impact Statement 13 a composite ot
information and data that was locally avallabia gathered
from various agencies and Individuals in the area and
sorted, analyzod and ovaluated and interpreted to prepare
the EIS. State EPA ro'julationa and other fetors havu,
naturally, affected some of these iiitorprut.itioiu and ute
of data.
The Draft EIS presents results and conclusions derived
from tho data end discussions we have gathered together in
the workshops that were held and presented in a way which
we beliovo point out the key issues and key data available
relating to these issues, and, hopefully, present it in a
way which is understandable and organised, uo perilous can
use it so thoy understand the project.
With that, I wish to introduce again Iliice Rush ton,
who will makes a short presentation of su.iu o£ tho roatori alo
in tho EIS, and he will bo followed by Holiert Uiuauemian.
CAROL L. DCWCY
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bob is first. I had it backwards.
Mil. otKttliSiti-MU i In the City's Facilities Plan,
there wore three alternatives which vers mentioned, and
tlieac oru cn thin slide, labeled as Alternatives 1, 2 and
3.
Sinoa the City's Facilities Plan, there vera two
plans which were formulated by private citizens. These
arc called the KlicV.er and Latcnscr Plana, and an alterna-
tive which vas developed in the course o£ the BIS process
is hare labeled cs tha Cc*ubination concept, and, as required
by federal law, a ao-act ion alternative. Vihat wo are going
to do new ia go through a description of these one at a
t iiao.
Alternative 1 is a concept that uses underground
storage basins to score the waste water flow and than
gradually put it back into the interceptor, and it is
conveyed to the treatment plants for tiubsequent treatment.
In the City's Facilities Plan, the underground
storage basins were sized so there would bo ons overflow
event on the average of every 25 years. A subsequent
analysis by the City and EPA and also as a portion of this
EIS process showed the cost effective size for a storage
basin was such that there would bo one overflow event
overy year. So the CIS process looked at Alternative 1,
storage bo3in concept, ucing two different sizes. One
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would allow pn overflow ovent every 25 yoaru, and Um
smaller size would allow an overflow event onuo every
year. The alternatives looked at storage butiina located
at 14 different locations.
Another part of Alternative 1 and Alternative 2 ia
relief sewers. V.e would have to look at the project
objectives, one of the project objectives being to
eliminate combined se^er overflow, stor;;Rjat-ir overflow,
which the storsgo basins do, and the second ia to solve
basement flooding and drainage problems, and this iu
accomplished "with relief sewers.
So Alternative 1 is storage basins i-ilus relief aowota.
Alternative 2 ha3 what i3 called satellite truiit.uuttt
plants, and these arc located at the uar.-.j lujatiuiiu as U13
underground storage basins, at 14 different locations.
The satellite treatment plants provide a lw level o£
treatment cuapared to what is provided by the City's
treatment plant, called priority treatment, aid it is
mainly a process of sediDentation, with the addition of
ahlorine.
As I stated. Alternative 2 also requires relief
sewers, about 55 miloo of relief sewcts, to i.olve baueiaent
flooding and urban drainage problems.
Alternative 2, as it ia presented in the EIS, ia
idontical to Alternative 2 in the City's I'aeil i l ieo Plan,
CAROL L. DEWEY
C.„»< fl'-.KMf.M I."
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and allows one overflew every 25 years.
AXl'uriiutlvc 3 is construction of storm sewers. The
viciy the cewer system Is set up new in the City of Spokane,
or a principal portion of it, ami leads to tha problem we
arc facing now, the storm water and sanitary waste aru
conveyed in ono sewer. Alternative 3 would construct now
storm scweru to oe.jregate these flows, and the existing
system would than be used to convey sanitary waste, and
thu now eybtcia would convey stora water, which would then
go directly to the river.
There are 220 miles of storm sewers which would be
required, and like I said, these would convey storm water
directly to the river, and, depending upon the tima of the
year and intensity o£ the storm, which is used to calculate
how auch runoff there would be, there would be somewhere
betweon CO and 110 days that storm water would be conveyed
to thu river.
Alternative 3, which is called the Klicker plan, is
really a sub-option of Alternative 1, which uses storage.
The Klicker Plan uses underground storage basins which are
sized to contain all flows which would occur once evory
five years. When a storm producing a greater amount of
precipitation and runoff than this occurred, the storage
basins would overflow into open lagoons which would ho
located adjacent to the storage basins, and these lagoons
CAROL l. OEWEY
Cv» ho/»*-<•• <<•£
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would then contain any flex* in excesn ci tlu; five-year
storm event.
As in Alternative 1, the flcus fraa i;toraga b-aiiiu
and open lagoons would then, following the ccuiati cn cL;
the stoma, bo put back into the interceptor and cowv^yed
to tho treatment plant for treatment.
Another factor which differentiate:: the Klicl.cr
Plan froa Alternative 1 is a large storaje lagoon located
betweon Bridge Street and tho Sjiokano River. cu.J this
storage basin would also have a portion which is clewed
and underground and another portion which ia open ui.J at
ground level.
The Latenser Flan uses a combination cl: flow rerout-
ing and storago in a large open storagci bacin which la
across tho river frcia tha treatment plant, in Kiverjida
State Park. This open storage basin would contain all o£
the flew during a storin which would nom.ally b_- tliu CJO,
end then, when the storm passes, this flew would Lc
directed into the treatnent plant. As diffeientiatcd frc*u
all those alternatives, the treatment concept is different.
In the Latenser Plan, all the advanced ua3te water
treatment at the tertiary facility would be abandoned
end only secondary treatment would be provided. The
effluent frcta the secondary treatment plant would be
exported using a pipeline and a balancing rejervoir to a
CAROL L. DEWEY
CcN.il RvpoiUrt H>t t
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l-u/.'ii utation in the Crab Citel; drdinaje basin, and it
would tluw down Ortib Creek a distance and be collected
uiiJ utilised for t>jricultural irrigation.
The Combination Concept, which was developed as a
pert ion ol the J-lb process, tried to cou.bine, solely on
a colI initially tho bunt features of storage i.nd
stor.i m-.eta and dividing the 15 different drainage
LljIiis within the City, It looked at oach one of theso
on a jobt biuia to determine whether storajs basins or
stoi."i;i uuverci were morj cojt effective. Tho conclusion of
this Vi,j tlul in iive areas storm sewers were the moat
cost effective, ai.d In 10 areas storage basins were the
uost cost effective technique.
Tho Mo-action alternative, which is required to be
analyzed, would consist basically of doing nothing other
than trotting wastewater as it comes down the interceptors
into the existing treatment facility. There would still bt>
CSO and still be a stornrwater plant. The UPDES would
continue to be violated because of the existence of the
storiM/ater plant and existence of CSO and the objective
of the tl£> to proiuota or to leave open the option for
rationalization would not be wet.
Costing out of this analysis, which looked at cost
and aluo locked at environmental and cost to society or
social is thu apparent Loot project alternative.
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Tho apparent beat project alturniilive, or tno pii^o^ed
project, is actually what'u called a i-h^i-i i or oiviuion
of what was previously called itlternative J, winch la tin.
construction of stonu eeuora. Tim pli.u..a li.,vu t=n
divided into two, Phaco I and 1'hasu II, and lure we &«;<;
what is a propound project in the nuUh norlhucat
portions of the City.
Tho proposed action in Phaae I clininotus ut.pro,.in.utoI,
65 percent of the overflew and only 3j percent of thj
total atom fcuwer cost la expended in puriuiuinj this,
and this is how thatse I ut,x actually dofin-J, as Hut
portion of Alternative 3 vthich was ogjI directive at the
present time.
This would involve the construction ci uLaut 'j0
miles of storu sewers in tl.e construction ^rio.i, which
would take between thres end five yearu, and e detailed
schedule has not been formulated at thin Liu:.
Phase II, which isn't shown herj, is oonaLruction
of storia seuors in the remainder of tao City, this
would solve the remaining 15 to 16 percent ot the uvur-
flou and would require approximately 61 percent ot the
remainder of the cojt of Alternative J.
Phase II is a necessary component of thia alternative
to allow full compliance vith the Id'DU^ program and alao
to keep open the option lor uao of tho City'u tcontnunt
CAIIOL I . Dl WI Y
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pl&nt tot trucjic.tiili.sdtl.uii,
VI.e project, in addition to being coat effective,
wi s divided into Phase I and rhaae II b3cause at the
incii.c"',t tl.ic there is insufficient federal and state
'jriint funding to Carry out the entire Alternative 3,
whereas Phase I couicl bo fundt-J at the present tirca.
In a later part of this presentation, we will
discuss the probable c.-oat-3harin1 «ia
downstream from the City, the stormwatcr Uoutmcut plant
which io locutod at the uame point, iiiuJ then r;cii.L»i nod
cower overflows that oociir at numerous poiutu within the
CAROL L. DEWEY
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City.
The raujor purainctera we are looking at here are
nitrogen ji;d phoapliorouu, mainly because thoua are the
olci.enta oil thu uaatcwatur which pertain to the
utrifixation of the river.
'ilii.i ij another bar graph indicating the City's
current loading to the river compared to measurements
ox nitrogen and phosphorous wade at the head ol Long
l.ul.a in the year 1970, and you can oee hero that
approximately 2,030 tons of nitrojon pi.a^od into Long
Lake in 10 78, ia measured at the pciut at the hee^l o£ tha
lii/.d •
'ihti second bar indicates an approximation of what
the City is contributing to the rivor in terms of CJG,
sittuvaer plant discharge and advance wastewater
t£Co>..n^itt discharge.
Phase I construction will reduce the umaller
iac£t,..oi.t her*, the CiiO increment, by approximately 04
percouc in volurae, end it will also reduce the stonn-
water itiflou to the treatment plant by approximately
ond-juartcr.
This results in approximately a throe percent
reduction in tha City's nitrogen leads and a five percent
reduction in the City's phoophorous loads to the river.
1 uio talking about only the nidJlc bar here. Phuue I
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04 porcsnt ot the cnnual volume of CSO to the river.
Vhitf will to a major reduction in bacterial and viral
contamination tlicit reaches tho rivar, benefiting, of
couruti, the use cf tha river throughout the year. However,
period CwO events. will continue to occur frwn the othor
25 ovcrflow points that aro not controlled by Phase I.
thJau II, vhen it is completed, would eliminate tho
remainder of the sruallor overflows in the City.
finally, the influence of the project on the
rcgionalization potential of the treatment plant. If
storuwator flcwa through the wastewater treatment plant
ucu eliminated, the plant has a capacity o£ serving a
tauch larger area than the City ot Spokane. The plant
has now uD average dry weather flow capacity of about
40 million gallons a day, and the present dry weather
11 ou'i through that plant are approximately 23 million J
yailcr.o a day. llcv-ovor, on an annual basis, the plant
is new treating about 11 million gallons a day of etorm-
water that is diverted through the combined newer eysteu
to the treatuent plant.
So, by eliminating stormwater overflows to the
pliuit, thoie la ii olzadblQ increase in capacity at that
treatment plant.
Plume I will reduce the stormwater flows through
the plant by about 25 percent. That's in Phase I. Phase
CAROL L. OFWt*
'.Hi/nun'
<»*.<. m j 2 i u poU r.t i..1
also that a mho uxpanaicn of phobphorous-roi.oval cai^bility
will have to ijo along with this ucdif icctici. oi cl~*ifierj>
but that hasn't been djvtlop^d to aiiy jrcr.t detail yet,
as to how extenuivo th.it would be.
I think I will turn it back to tcl> to lal'». ^Lov.t
costs.
I1R. GU/C-ilirjiAi;i This chart the
tha apparent beut proje ct alternative, cl t!.e jj: J
project, for Phase I, Phaue II, a:id tho total cut.
Phai,o I, tho totul construction* co^t ya rwutjr.ly
25 million dollars, and for l'haiia II, it iu 3J i.-illit-n
dollars, to give a total con u true ti or, coi.t ot CI trillion
dollars. That's if lh^ projoct vuro „L tl,^
CAROL L. OEWEY
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' present tii.Kj.
2 New. tha jJ location o£ the project cojtu between
3 10.*Vi, tha Stale of I'aihiri'jton, and tho City yovcrned
4 by a very cu:.[j1cx i^ci.ula which allocates the coat for a
5 u.uiti-j>ui."t-'s>iJ project, which this is, between pollution-
6 C'jiutol lectures and drainage features.
I looking at the total coat or 64 million dollars
S it it v.-mu Cwii&tructed today and utilising this fortaula,
» the project dj we have calculated it iu OS. 7 percent
10 eligible tor utatc and federal funding.
II When it Is divided into rhaao I cud Phase II. the
12 im.dinj lor l'h^oo I is 100 percent eligible for feucrc.1
13 fimJiri.j. 100 percent eli'jible, whan it io translated,
I* means that 75 pjcccnt of the coat id paid by tho federal
15 ijo7u£n„t.iit, la percent by the state and 24 percent by the
" City, is shown in this chart.
17 At the prc^ont time, the funding for Phase II ccnnot
" be Jcteraiiiied, since thoro ia no taoney allocated by tho
" ttatc and federal 'jov-jrr.ir.enta lit the preaont time for
20 funding frtu y;ara subsequent to about 1931, and Pheae
" II would be constructed Lci.icwhat after lSul.
22 'i'hc tr^nulution of the City's eharo of the
2* construction and tho operation and iaaintenar.ee of this
24 project is thuun at the boLtcra lit re, and it could be
limit- r.lLl:-;r of two weye, or a co;ubiiiation of theao two
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mi ayu.
Tho first viay th.it is ^h'^/n is ta Ji._. tuo
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proposed I'hdsc I project, tha construction iinpucte cro
lo.'oli/.uJ to tk£ area proviouuly ihaun on the map and in
the handout. The CSO, Ca.abinevl Scwcr Overflows, will
continue to discharge from 25 locations along the river,
anJ, therefore, Phase J of the project will only partly
aba to the pollutants going into tho river.
About 16 percent of the original volume of CS
ovarflcM would still enter the rivar. Sevm* backup and
str.73 per
year.
IlR. Gl'MMSUTi/UI: l'cr connection.
MS. COYUJi Mr. Jijraua.
MR. JiVMEji Ro'jtr jaiacs, the Director of
Utilities with tha City of Spokane, uiid i wcuia u->y ^
couple things before 1 start.
number one, it ia a rejl plejuuru for i..o to be liure
today to represent the City ajid to participate in thia
very important mooting, and. secondly, J vould aljo euy
that the assignment uhich you have giv^n nw to prejjnt
at the meeting today has ptetty well butn ccvttit froi
ray original as3ignucnt and tul): e littlo bit, br iefly ofid
rather quickly, about no.ao of the historical ^oint^ in
the development of this uystc.n and so;.\c u£ the thi.'ijs
that are perhaps not too well Known to Liai.y ct the
people in the audience today. I will try to rcn throujh
these quite rapidly.
It might be of interest to knew that, the first
sewers in the City of Spokane were constructed ar.J
placed into operation in 1C00. They verc in t!w oroa
just west of tho downtown business district. 'Jhe swar
system in tjie downtown area uua built Jurir.j '-li- iOJO's.
CAROL L. DEWEY
C'».«< me ,
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litjj£ ocnctiuction hau continued rathur evenly throughout
all oc the yeaca silica that tine, and up until about 1940,
about U.o bajjtaii.nj of U'orld V.ar IX, all cc-.jcra
constructed within the City were ccubincd sewers, incanimj
that u«:y nut only carried away sanitary aowayo frotn
co:aaaxcj.al, industrial, institutions, but also
carried stoi. .(*.-< tor flora catch bujinu and soof drainu
and tuiu typo o£ tiling. Jtll of them, with tho exception
c£ .ione o£ tha very few firut built, wore of the coiubinud
ctuor variety.
The wily of dpokane has a long history cf iiltircct
in 3c..'u'je treatment, and 1 think uayba some people ara
not !iu«.ra of that. It might bo interesting to knew that
the City beyan seriously considering building sewage
tre-tuaiit lr. 1013. iho city developed a number of
proju-i-ja tor providir.g ucwayj treatment over fcho yearn
vitli U.o help of their consulting engineer, a ficia which
was cat that tine located in Chicago, Illinois.
On four cjccioionc before 1,'orld War II, vq presented
ccoprclicr.^ive plans to the voters of the City of Spokane
for ccua^e treatment facilities for tlio City, and I might
say we wcro rathor liorrcndously defeated at the polls in
every attciapt to do this, but eoir.e very concentrated
efforts bsi'a to do it.
finally, in 1916, the fifth presentation van mado.
CAROL L. DEWEV
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fiNloLul government to do £JUiu:thing about thin coiubinod-
ov^rflc/j proble.-c and puruue it to that objective.
They J id apply tor a Stop 1 9 rant to do the original
planning £oc thin project. The planning wa3 done with
engineers f ro.n our own Puolic l.oiks Department and the
facility l'lan was prepared by the,a.
1. great many different ideas weiu considered
in solving tliia problem, and tho three listed first on
the showing there a few minutes ago vera the three which
wo decided vera worthy of aoiue additional study; that ie,
ths Gtoraja basin concept plan, one involving statisti-
cally one overflew each 25 years. Theao were very largo
b^sin:; to be constructed at various points along the
&pokcui£ ltivur. Tli&y are tn expensive operation, because,
or courts, as you realise, they lave to bs very large, in
tlie flrut place. 'ihon, in the second place, they have to
fcs equipped with e*tre®ely large puiops because when they
till up they have to be pumped back into the system, ready
lor the next rain. You really have to get that material
out of there in a hurry, and because they are in tha
congested areas o£ the City and because of the possible
concern i.r.d nuluanco arising from them, aorae very
elaborate plaits have to be included to clean theji and put
the,* in shape so they will not be a nuisance.
lie investigated, secondly, what they have referred
CAROL I. DEWEV
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to as Galcllitc-treati.1Mit-pl1.111l: concept wln.ee Wu wu,.M
build email, automatic pltir.ts at liheue v..iiou:i oull.;Ui
and they would go on line whenever luatcrial otjrud tu
overflew; and run only during the overflow p^ricJ.
And, finally, this process of at'.-cr atjijutiua,
in which we bade what ia essentially a branvi-n<-u
ayotsm over the entire City, disconnected U.c c-^toli
basins end roof drains £rc.-r< the existing j^icr, ami
tied thcia into ths ntu one, and ua^d the i 11 ;vj !,o.cr
exclusively for sanitary sewers.
The cost of these has been mentioned liclor.;. o.ir
figures vers about 64 million dollars for thi s>:wee-
deparation concept, which was by far the iio^t ij'.e>.;<<-Tisive
and moat coat effective of the thro- pl^r. j \j.i i nv-iiti juitj
The part which has been designed 1, which
included souething better than a-thirJ ci l:-.a city
tha north end, ve estimated it would cost 24
uiillion. These figures were based on tht conc.pt of
talcing enough storr-water out of the sy.ii.L,.i so Lhu ten
would not overflow.
fica/ever, we did come up with the cOi;t ol
eight million dollurs which would bo »neet!u ,.;xy vote it
rioccusary that we ectually remove til of Ll.u utcmiwat«r
from the towere, and not just enough to Keep thu::i trr.in
overflowing. Via estimate J another eight r.Lllici) iiollurs
CAROL L. DEWEY
Cttoat fiu/Mtt 1*1 yii
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vould be inquired to ticcoiuplitli that purpose, iini this
v..s thi plan thi.t Sit: wont to the State of V.'oaliington
vltii.
I would just briefly on tho luatter of cojto.
V.c h.A'tf been rtvitv;i.vj the £n\'irc>miicntal Impact
Ututeuu-i-.t, uita, frankly — and I don't uean to say this
in a uerrGjjjtory but, frankly, vie teal tin; aittire
chapter relating to costs and charges for services should
really bt LCJoi.3 bcCjuso the figures are out-of-data and
b«. cause we think they are bated on assumptions which are
timely not in accordance with Washington State lav end
would not be possible. So we will bo filing a statement
later on in that, attempting to point out why we beliovc
ll.cuo thinjH to be true.
Vh-J City ii, atu.ious to proceed with this project
and to yjt it underway as beet we can. Our figures
i:>di<:<>i4 that the dry-woathcr tlow run* about 20 million
gallons pur day. Wt can provide the complete advanced
wastewater treatment to sewage at the rate of about 77
•tillion gallons a day. We can treat all of the sewage
which gats into the interceptor, souewhere around s rate
of 125 million gallons a day, either at the present time,
we can treat the 77 million with the complete advanced
vastevater treatment, ar.d the balance of tha 125 Million,
~U>ut -1U million, would receive primary treatment and
CAROL L. DtWCV
*. Hit (1 Ml' f
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disinfection. The project, wj think, h^ti U:.m t.ither
carefully worked out. We are prepared lo jiuv; :ih.;.jd
with it as coon aj tho neco^nary atopr. ot tilv; L'j i.nd
thy financing can be worked out. Wo aic very Im^py to
have the people in the iitA and thu othsxu h>; ro t o.i ,y
to talk to the citizeiia of Spokane reyardi :i j this
project. We think it is a good projGot, tl.u hot>o we
can get underway rati,or shortly.
Thank you very much.
KS. COYLKi liou, hopefully, yoinj into ps,rt
two of our agenda, there aru several c^loycua
in the audience this afternoon, but I under l t;:nd th-iy
are not prepared to raake .iny cocunenlu ot i|ij3 t>oi111, but
would be willing to answer quotations. ijono ot
individuals ere Daooruh Kirl:, who ia I'rojejt Oi.iicc.-r o.i
tho Iinvironruonta 1 Impact Statement, Mr. K..-n who
is the Project Engineer with respect to thiu project.
In the event vo have queiitionc. and tlu^y .;re the!
individuals who are best qualified to anawcr, they would
be willing to do go.
We also have several representatives from the State,
two individuals frora the State who, igain, would be
willing to field questions if they arirc, Mr. John
Arnquiat and Mr. Claude Sappington.
There nay be other representatives here. I am not
CAHOL L. OEWLV
I1IUK
SfOKANt WVJHM
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aware of anyone li^ra being fro:u the County, lie. Dobratz.
if i.ny queatic'iifl arl ta you might ba able to handle, I
liopo you will be willing to help us out.
Aside from Kc. Junes, I buliova Mr. Yaka has laft
thu twwl.
l)R. J/CiESi Mr. Bladen is in the back tow
there.
lis. COYLEj Mr. Blagcn may be able to anuwer
qutiutioiia.
/no there any questions at this point from individual:
in the audience? I haven't received any cards suggesting
that there Right bit.
S!U-?
MH. SOUAJI-Et Gentlemen. lay nana iu Jaineu
licliaiico. I an hero as Psfcuident c£ Lako Spokane
i.nviro.'i:.iontal Association.
we atii int trail ted in this EI3 report in a lot of
respcctu. Ons particular facet of it th.it we aro
vitally interested in is what kind of treatment, if any,
iu contemplated lor the'storm sev;er overflew before it is
dunked into the rivor? Jn other words, iu it going to be
collected directly iron the various basins, together with
all the debris normally found on the streot and the nalt
truu the winter and so oil end ao forth, dumped dlroctly
into tho river, or is it going to be treated in ucttio
carol i. otwtt
liHuihcWmt mc
'j -j tot »1 *uti
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fashion? If it ia going to U» truc.ti.-a, wo t.(.uUi Ji).« to
know what the cout of that would b•¦..>
given as to what the cout of that: treatment mijlit ue.
MS. CuVLlit K.r. llurJ?
hR. BUI Hr. Jaiaeu iaay be able to an^v/i.r
better than I aw, but the project doo.ui't, as f^r ct 1
kaow, contuuplate treatment of tton.r./.itor Ui..c ia
separated fruu the combined .i<.wur and tii
B'Jl-ol ately .
I think it Ehould be pointed out thai tii-i'-- iu
considerable difference in the character J jtioj, t;^;
quality of tha ccxubiried sewer overfly.. that js t-L.: nr.i^ly
discharged into tha river and tho characteristics ol
the separated stomvator. Oonibinud aov.er ovtrfl^ h_j
a much greater pollution load, in terms oi o< jauic:
solids, in'terms of bacteria. Storwwutcr a
leuer contribution of thoac pollutants that I liu.ilc »;c.
are most concerned al'Out in the Spokane Eiv-.r o.iJ i.:mg
Lake. Certainly, there Lie soma, as you iii.Uc.it:>., u.t:
Btormwater washing off of streets, parking lot-j, ooe,;
carry along with it tha dobri3 and dir.- ^nJ oth .r things,
oil froci automobiles, that oro on the" attest j juj ticking
lots} but, again, tho pollution Ick.u fro:.. th-t uouicu is
considerably leua than that from cuubiuud a ever overflow,
and hopefully thurj will be prograaid in the City uikl
CAHOL L. DEWEY
fiv>l M|KI>(*> htf
:i MO/PIHHV
SfOftANC KAMMNGION 9920)
(MM) 44« •«*,?
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County that perhaps will more efficiently remove some
ot the debriB from the streets ami parking lots so even
lei-s tit that luutcriLl would bo carried aion-j in the
storm* a tor.
113. C.tiVi^i Mr. Jd.nau, da you have anything to
aJ U?
M«t. JAlliids I yucca 1 would kind o£ echo a cine
or the things Mr. BurJ has said.
There is no contemplation at this time oi a
treatment tor the separated atormwuter. it is our
conaidurod' opinion that it' trcatucnt o£ atorniwater bocomta
a necoesity, that the typa of treatment which would have
to be provided cor the storciwater would be considerably
djif<-rent from the typo of treatment which ia provided for
sanitary, domestic uouagc, and, therefore, it is our
feeling and our jud>nent that, it' we are required at some
tiu.o to ti^at the storuwutcr, that it would be neceissary
to separc-tu it before it could be treated, and so wu feel
that, even if this is a future outlook, that this is a
stup in the rioht direction, and a step which, in our
opinion, would be necessary in order to accomplish that
kind of treatment. I'his is our feeling.
We did some studies in connection with our Facilitioa
Plan, and undoubtedly will do more on the possible effects
of uiui-h.tr-jinj Lhu htoii.iw.itor directly to the river, and
CAHOL L Ol WL y
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at least as a result of Uu utudics thut v.* wo
ciiu.a to tlie conclusion — and I i.u ti.ic tl.ut Lhe nVA
i»nd tho DOE at that tine oonci;rreJ in tiiiu Jttoifcion —
that treatment under the preacnt guidu].i»o:i \i<*a not
conuidcrcd to be necoueary.
Thank you.
113. COYLiii /iny other questions ar.yr.r.i. might
have?
KIl. &C11ASKK: I believe the Diili ccnJiicU-1
toiiie studies along the linen of tlivj rju .uti I jujt a^k'o.
I would like to hear wlwt tho DOE haa conoluJe-l in that
regard, for the record.
MR. ARUUUIljTs My name is Joha n-iti ist, ^n-i I
ara with tha Department of Ecology here in una, jr.,]
basically the an..\JC.ru that lioo and Koj..r js'Jt
fctonnwator treatment are shared by th_' Dep.. ..
Ecology. At this tii;:e, \tion
project. The City iu engaged in the proct.-iu ot making
CAROL l OEWtV
i>GHA(ll WAMWtf.ll.UVJW
P*i| 44«»4»f 37
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tho election. The Oiigincering firm which designed the
si.va.ju treatment pl.mt, and which, in all probability,
will work with uu on tho separation project. Is rat'ru-
bented l.cru ii> tliu iiuJiencc by ilr. Bo it Smith, and I
think I would at lc-a-it like to havu people knew who he
is, it they tic.'ii't kucM who ho id. lia in here, it anyone
wisl-.uu to talk to hi:a, Mr. Loh Smith from Uuvuy Engineers
hurts in Spokunb, \»u;;hington.
MS. COVLU; It there arc no questions —
Mr. limit hV
Hit. smith; I have one question. Hovera1
places in tha report, we talked about the increased
suspenJjd solid load by storm s«iwor separation, aj.»< 1
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at the present time.
MR. SIIITUI I don't doubt Hut1. !><>
increase* of cooic sect in Mineral t*.• jr iii, i 1 l\ ;l t yL o
of thing. I au vonJer I jucu3, It tiuii w.i.-i
clarifiod.
I alco wanted to Kncr*i, you have gut a iooc;u>L<; ct
number ai* that the tre.itiaiiiit pi jilt provjci-J data
on storiDMQter runoff. J oin v/onderiinj if Lliot shouldn't
bo clarified, to wake sure that i/aa .-.toi; iw-it-ur runoff
snd not combined cower overflow.
UK. GWUltWi/j;: \i» v/ill ciariry Lh..i.
MR. SMITlit I don't know wharo tlii-y V'Oiild h;vo
gotten a Samplo of purely storiiA'&ter runoff t'> niiiko u.-
an analysis.
lill. CUtSOWia> That ves infor..iatlon tutnlithcd
by the City, and it wao indicated it for iitcirni'.'titer
runoff.
IlR. JAMBSt I think, Mr. Smith, «r. i-lijcn
can help you with that question because Iv- ij familiar
with what you are talking about. He will talk t.> you
afterward, or now, or whenever you ujnt him to.
MR. QI^.GE:!s I would lik<3 i>i»•/ Ci\t coitai'.nt
now. We did take a few samples of iitormwnter runoff.
MS. C(JYI.£i Any other quo;;tioiu; oi. coinir.eiits
by any othor raprcn&ntativen hare?
CAIIOL L OI WI V
!, •,»../mow
CtfOKAM *»0J
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I ati'jht hjvo ij.ic question of Jir. nurd.
If I Vvcj-'o a citizen o£ this City of Spokane, I would
pfooii.'jly In- v.ry concerned about tha economic alterna-
tive, the ejcnc...iau of the alternatives proposed, and
I UUi<-vo X/j vicii: alzi-uaainy tliia uiflior, that the
propound option is tliJ second wo at coat effective, not
the utofct cost eii:c._tive.
\iluU rationale could you givi mo for justifying
thi.t u.Jlaalion?
Kit. UUllDi El'A regulations &nd the law gener-
ally rc.iJiro the selection of the least-cost alternative
unl^-ia thc.ce arc other factors, particularly environmen-
tal £^tora, that ijuuld justify going through a aomeuhat
more crnuntive altcriiativa.
In tliu ca&a hure, the proposed reco:nmt»-nded alterna-
tive is the second least costly, but va feel it hus scou
oijvircrji:jntal advantages over the strictly least-costly
alternative, plus it has tha advantage of allowing
regionaliz^tlon of sewage facility in the area ao that
additional ucwage from Spokane County could be received
by the City savage treatment plant.
Tnat, in ltaulf, by the way, could cortainly lead,
and probably would lead, to additional environmental
advantage, to htvc tha regional, rather then multiple,
trcut.iK-'iit pljntu around tlie County. This la o cjhu whera
caholl orwiv
SfMWA'll r\ * l 11 Ji T/.-Ul
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there are soma definite en^iroiu cntjI _JvaiiL.,jod, _i.u
the institutional adv^nta.je ot regional i>je trisuii^nt
plants that overrides tUo legist-costly -jLlernative, ;3
I think would justify the second-lejut-oujtiy alteviw.tivc.
MS. COYiXt finy other tjuout ion„Y
If not, for the rucord, I vould liU.; to ';ivc to our
reporter a copy of the Uotico of thii» public hiurin,,
and Affidavit of Publication, uliicli I would jivu to you
after the meeting ic clo.io.l.
If there are no further quc-jtioiu or tl.^n
this meeting is idjourncj aL 3;'!0.
Thank Jou for caning. 1 appreciate it.
(iluari.Hj is coi.ciuJed.)
CAHOL l. otwtr
< ,H»! I„ tut f
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SI'CtfAM. H»]
4M 144/
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£S£IIEI£in
court raporter, I hereby certify that
thi.u transcript is a true and accurate record
oi. Uiu facte, uuttcra and proceeding of the
Meeting hold on Wednesday, i.pril 4, 1979.
.(,<< ¦ ¦
C„KOL L,. DtWE'/
IXattla, Washington
A|)ril 16, 1979
CAROL L. DEWEV
S 'xWJKIml
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CHANGES IM FOnn AMD SUDSTANCE
TJD EE MADE IN FOREGOING TIUUSCRIVT
PAGE LINE CHANGES IN FORM AND SUBSTANCE AND REASONS
THEREFOn:
CERTIFICATE
I, MICHELLE COYLE, Hearing Officer, do hereby certify
that the foregoing is a true and correct transcript of the
public hearing held on Wednesday, April 4, 1979, at 2:30 in
the afternoon.
MICHELLE COYI-E, Hearing Officer
Environmental Protection Agency
CAROL L. OEWEV
Co.ifl Hnftflu' l'K
S MOM'LHIIV
SPOKANC, «VA'.M7
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'floliCO (ll I'ulllii Hearing
oil and Av.i ) I .i!>11 > f y of
Aii Envii'Okiih'mLu 1 fuipait Statement
for llie Combined Sewer Over} low Abatement 1'iojrct
for the City of Spokane, Washington
Notice is hereby given of public hearings to he lield by the environmental
Protection Agency, Region 10 (Ll'A) on the City of Spokane's application to
El'A for grant assistance in the abatement of combined sewer overt lows. I he
hearings will he held an April 4, 1979, al ?:30 p.m. in the County Health
District Offices, Room 140, W. 1101 College, and at 7: i(J p.m. at the
Sliadle Park High School Auditorium, N. 4327 Ash.
The purpose of this hearing is to allow all interested parties an opportunity
to express their views and furnish specific d.Ha on matters pertinent tu the
proposed action. Detailed information on the project is found in El'A's
Draft fnvironniental Impact Statement. This document is on file and available
for public inspection at the City of Spokane Library, U. 906 Main. Copies
of the Draft Environmental Impact Statement can he obtained by lequesl Iiomi
EPA, 1200 Sixth Avenue, Seattle, UA 9R101, AITII: MS 443.
Public participation is encouraged by CPA. Exhibits, written statements, and
other documentary evidence relating to the environmental impact ot the
proposed action can be submitted prior to the hearing. Anyone who has
additional comments after attending the hearing may submit couinents, exhibits,
and evidence by April 19, 1970. Conments should be sent to EPA, 1200 Sixth
Avenue, Seattle, WA 98101, ATTN: HS 443.
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BEFORE THE UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 10
A PUBLIC HEARING
AVAILABILITY OF AN ENVIRONMENTAL IMPACT STATEMENT
COMBINED SEWER OVERFLOW ABATEMENT PROJECT
CITY OF SPOKANE, WASHINGTON
BEFORE
MICHELLE COYLE
HEARING OFFICER
7:30 P.M.
APRIL 4, 1979
S1IADLE PARK HIGH SCHOOL AUDITORIUM
NORTH 4327 ASH
SPOKANE, WASHINGTON
CAROL L OEWEY
s iMji fttmf
WOXAriE v«iliMOM Wtil
lull
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It-iJ I*^
1-"
1 4, 1//V
Hti. COYIX; Let the- record ii.jic
ut w
it
ia now OiOO p.ia., and wo ciro here il th; i
Ui..-
ic i tl i. 1 X iiiiVC'
until April 19, 1971) to submit thuir ui-itt
',1a
cui.a.c.iC.i to
Ll'A, Uojdr Uoclinick, c.ite o£ tho El'A ke-,io
Aial
Oi ricw.
itggion 10, Scuttle, Ha^liin-jton, 9ulGl.
(Ilairinj iJi
cc:;
cludeJ.)
CAROL L DEWEV
Ctoutt htlKt'lut M
S SlO/PtfWtf'
SPOftANC WAi.M«KjlOU M303
l*49| Ml •«*!
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As court reporter, I hotoby certify that
this tr„n^cri^t is a true unci accurate record
oi tl.o fjcto, matters and proceedings or the
hold oil l/ii>!neud• i. y ¦ ' ' 1
C-dit/k L.
JJeiittle, WiiChincjton
/.pii! 16, 1379
CAHOl I Of.WtT
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IS
CHANGES III FOPM AND SUBSTANCE
TO BE MADE IH rOnECOItlG TPAMSCHIPT
PACE LINE CHANGES IN FORM AMD SUUSTAMCE AND HEASOJIS
THEREFOR:
CERTIFICATE
I, MICHELLE COYLE. Hearing Officer, do hereby certify
that the foregoing is a true and correct transcript of the
public hearing held on Wednesday, April 4, 1979, at 7:30 in
the evening.
MICHELLE COYLE, Hearing Officer
Knvironnontal Protection Agency
CAROL L. OCWtY
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Notice of I'lililit llc.irimj
011 and Availability of
An Environmental Impact Statement
for the Combined Sewer Overflow Abatement Project
for the City of Spokane, Washington
Notice is hereby given of public hearings to be held by the Envi ronwental
Protection Agency, Region 10 (EPA) on the City of Spokane's application to
EPA for grant assistance in the abatement of combined sewer overflows. The
hearings will be held on April 4, 1979, at 2:30 p.m. in the County Health
District Offices, Room 140, W. 1101 College, and at 7:30 p.m. at the
Shadle Park High School Auditorium, II. 4327 Ash.
The purpose of this hearing is to allow all interested parties an opportunity
to express their views and furnish specific data on nutters pertinent to the
proposed action. Detailed information on the project is found in EPA's
Draft Environmental impact Statement. This document is on file and available
for public inspection at the City of Spokane Library, W. 906 Main. Copies
of the Draft Environmental Impact Statement can be obtained by request from
EPA, 1200 Sixth Avenue, Seattle, UA 98101, ATTN: MS 443.
Public participation is encouraged by EPA. Exhibits, written statements, and
other documentary evidence relating to the environmental impact of the
proposed action can be submitted prior to the hearing. Anyone who has
additional comments after attending the hearing may submit comments, exhibits,
and evidence by April 19, 1979. Coimients should be sent to EPA, 1200 Sixth
Avenue. Seattle, UA 98101, ATTN: HS 443.
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