EPA 910/9-80-074 United States Region 10
Environmental Protection 1200 Sixth Avenue
Agency Seattle WA 98101
Water EPA-10-OR-Deschutes-Bend-WWTW-80
<&ERA Environmental Final
Impact
Statement
Sewage Effluent
Disposal for the
City of Bend, Oregon
-------
FINAL ENVIRONMENTAL IMPACT STATEMENT
SEWAGE EFFLUENT DISPOSAL FOR
THE CITY OF BEND, OREGON
Prepared by
U.S. Environmental Protection Agency
Region 10
Seattle, Washington 98101
With Technical Assistance from
Jones & Stokes Associates, Inc.
2321 P Street
Sacramento, California 95816
Regional Administrator
1 2 OEC 1980
Date
-------
TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY 1
Chapter 1 - INTRODUCTION 5
History of the Project 5
The Study Area 9
Chapter 2 - EFFLUENT DISPOSAL ALTERNATIVES 13
Projects Evaluated 13
Chapter 3 - ALTERNATIVES ACCEPTABLE TO EPA 21
Introduction 21
Discharge to the North Unit Main Canal 21
Evaportation and Infiltration Through the
Soil Mantle 25
Chapter 4 - COMMENTS AND RESPONSES TO .THE DRAFT EIS 41
Letters of Comment 41
Public Hearing Summary 88
Chapter 5 - COMMENTS AND RESPONSES TO THE FINDING
OF NO SIGNIFICANT IMPACT (FNSI) AND
SUPPLEMENTAL FNSI 91
Letters of Comment 91
Public Hearing Summary - June 9, 1980 FNSI 101
Chapter 6 - LIST OF PREPARERS OF FEIS 103
Chapter 7 - BIBLIOGRAPHY 105
References 105
Personal Communications 106
Chapter 8 - APPENDIX 10 7
i
-------
LIST OF TABLES
Table
Page
2-1 Summary of Effluent Disposal Alternatives
Evaluated for the City of Bend and Their
Current Status as Ultimate and/or Interim
Disposal Methods 14
3-1 Impacts Associated with Discharge of
Effluent to the North Unit Main Canal
and Potential Mitigation Measures 23
3-2 Groundwater Constituents and Their Proposed
Sampling Frequency - Background Monitoring
Program 32
3-3 Impacts Associated with Discharge of Effluent
to Infiltration Ponds and Potential Miti-
gation Measures 38
4-1 Summary of Letters of Comment on the City
of Bend Draft EIS 42
4-2 Summary of Public Hearing Testimony for the
City of Bend Draft EIS 90
LIST OF FIGURES
Figure
1-1
1-2
2-1
3-1
3-2
3-3
3-4
3-5
3-6
Diagram of a Typical Domestic Sewage
Disposal System in the Bend Area
The Study Area
Treatment Plant Locations and Proposed
Effluent Disposal Areas (Sites C & E)
Location of Interim Infiltration Pond -
Site E
Design of the Interim Effluent Infiltration
Facility
Approximate Monitoring Well Locations
Typical Deep Monitoring Well
Typical Intermediate Monitoring Well
Typical Shallow Monitoring Well
Page
6
10
16
27
28
33
34
35
36
i i
-------
EXECUTIVE SUMMARY
ENVIRONMENTAL IMPACT STATEMENT
Draft ( )
Final ( x )
Prepared by: U. S. Environmental Protection Agency
1200 Sixth Avenue, Region 10
Seattle, WA 98101
Type of Action: Administrative
The City of Bend, Oregon applied to the Oregon Department
of Environmental Quality (DEQ) and the Environmental Protection
Agency (EPA) in 1977 for grant funds to construct a new 6 MGD
wastewater treatment plant at a site approximately 4 miles
northeast of the City. Treated sewage effluent was to be
discharged to a drill hole near the plant. In 1977 sewage
collection and treatment was being provided for about 10 per-
cent of the City's population while most residents were on
septic tanks discharging to lava sink holes or drill holes.
Sewage discharge into holes in the rock structure was declared
a potential public health hazard by the DEQ because of the
potential for contamination of domestic water supply wells.
Regulations adopted by DEQ to prohibit the use of waste dis-
posal wells after 1980 prompted the City to study alternative
methods of effluent disposal.
The City's application for federal funds to construct
a 6 MGD wastewater treatment and disposal facility was re-
viewed by EPA. During such reviews, the National Environmental
Policy Act (NEPA) requires EPA to assess the environmental
effects of the proposed project. If significant adverse
environmental impacts are likely to result, EPA must prepare
an Environmental Impact Statement (EIS). During the NEPA
assessment, EPA concluded that no significant impacts would
result from the construction and operation of the proposed
new wastewater treatment plant. The proposed method of effluent
disposal, however, was found to have the potential to signi-
ficantly affect groundwater resources used for domestic water
supply, thus an EIS was required for the disposal facility.
A grant offer to construct the wastewater treatment
plant was approved by DEQ and EPA, and the plant will be
operating in late 1980 or early 1981. Since the treatment
plant will be operational before final selection of a long-
term effluent disposal system, an interim project using surface
infiltration was subsequently funded by EPA to accommodate
initial operation of the plant.
1
-------
The use of drill holes, lava tubes, or fractured rock
as a means of wastewater disposal, such as originally pro-
posed by the City, was found by EPA to have potentially sig-
nificant, long-term adverse impacts on regional groundwater
resources that supply domestic and agricultural users. EPA
based its conclusions on information contained in the Draft
EIS. In addition, the Clean Water Act, administered by EPA,
requires the agency to protect from degradation, groundwater
systems that are now or can be used for domestic supply.
As a result of EPA's decision to prepare an EIS, numerous
effluent disposal methods were identified in facilities plan
reports (Design Definition Memoranda) prepared by Bend Engineering
Consultants (1977a). These reports included effluent disposal
methods previously identified by Stevens, Thompson and Runyan,
Inc., in the City's original facilities plan dated September
1976. The effluent disposal alternatives were fully evaluated
by EPA in the Draft EIS which was distributed for public
review and comment in September 1979.
In the process of developing the EIS, EPA reduced the
number of effluent disposal alternatives to the following
six:
1.
Discharge
to
drill holes or fractured rock.
2.
Discharge
to
infiltration ponds.
3.
Discharge
to
the Deschutes River.
4.
Discharge
to
sealed evapotranspiration ponds.
5.
Land application by spray irrigation.
6.
Discharge
to
the North Unit Main Canal.
These alternatives were selected for detailed evaluation
in the Draft EIS; other identified alternatives were eliminated
from detailed evaluation on the basis of cost and feasibility.
The purpose of the Final EIS is to present to the public,
EPA's position on disposal of treated wastewater from the
newly constructed Bend wastewater treatment plant. In its
evaluation of the six alternatives listed above, EPA concluded
that discharge to the North Unit Main Canal would be the
most environmentally sound method of effluent disposal. This
alternative is also one of the least costly methods evaluated.
As ia result of numerous meetings between EPA, DEQ, the City
of Bend, and the North Unit Irrigation District, it was realized,
however, that many institutional constraints precluded imple-
mentation of this alternative at this time. Because the
2
-------
City's new treatment plant was nearing completion, and the
City had committed to a financial plan for the wastewater
system, the City proposed to EPA an interim alternative for
effluent disposal. The interim alternative could be opera-
tional at the time of plant start-up.
After incorporating EPA-suggested modifications to this
interim effluent disposal system, a finding of no significant
impact was released by EPA, and the City proceeded to design
and later construct the interim disposal facility. This
facility has an estimated capacity of 2.5 MGD. It is located
less than 1 mile from the new treatment plant on land leased
from the U. S. Bureau of Land Management (BLM) for 3 years.
This interim facility is conceptually the same as the infil-
tration alternative evaluated in the Draft EIS and described
in this Final EIS.
In providing financial assistance, EPA is requiring
the City to conduct extensive groundwater monitoring during
operation of the interim facility to determine its effective-
ness and its potential for incorporation into the ultimate
effluent disposal solution. Because of the short-term lease
arrangement with BLM and the limited capacity of the interim
facility, it is important that the City continue to pursue
their ultimate effluent disposal solution. Such activities
must include: 1) further efforts toward negotiating an agree-
ment with the North Unit Irrigation District for utiliza-
tion of the treated effluent for agricultural purposes in
this limited water supply area, 2) encouragement by the City
to ranchers and farmers to use the reclaimed wastewater,
3) coordination and provision for effluent reuse on a sea-
sonal basis through the use of holding facilities, and 4)
consideration of modifying the interim facility to a size
capable of handling the projected 20-year effluent flow of
6 MGD.
The use of BLM land is a major consideration in the
City's choice of future actions. The 440-acre site of the
interim project was leased by the City from BLM for $330
for a period of 3 years. The lease has several general and
specific stipulations. One very confining stipulation re-
quires the City to notify the BLM by September 24, 1982 if
the interim project will be a part of the permanent 20-year
disposal project. If not, the land must be rehabilitated
by the end of the third and final year of the lease. Also,
the lease may not be extended or renewed as an interim dis-
posal project.
3
-------
The EPA will prepare an environmental report consistent
with NEPA and CEQ guidelines on the permanent project applied
for by the City of Bend. This NEPA report will then be
available to the BLM for their use relative to any land use
permits and land leases required by the City of Bend.
4
-------
Chapter 1
Introduction
-------
Chapter 1
INTRODUCTION
History of the Project
In 1970 the City of Bend constructed a sewage collection
and treatment plant designed to serve a population of 20,000.
At that time the urban area population was 19,150. By 197 4
the urban population had grown to 25,690 and is projected
to be 60,000 by the year 2000.
The existing wastewater treatment plant was designed
to produce an average sewage flow of approximately 2 MGD.
The facility provides secondary treatment (activated sludge
process) and discharges disinfected effluent into a lava
sink hole on the plant site. The plant presently treats
and discharges an average sewage flow of 0.5 MGD.
Five other wastewater treatment and disposal facilities
are operated in the study area. They are small units serving
apartment complexes and industries, and most are approved for
interim use until a regional sewage system becomes available.
The majority of domestic wastes are disposed of through
septic tanks discharging to lava sink holes or drill holes
(Figure 1-1). Approximately 6,000 to 7,000 of these waste
disposal wells are currently utilized in the Bend area. This
method of disposal is necessary because the soil overburden
is generally less than 12 inches deep, which does not provide
sufficient surface leaching.
These several thousand waste disposal wells create a
potential for contamination of domestic well water supplies,
and thus are a public health hazard. A study done by the
Federal Water Quality Administration entitled Liquid Waste
Disposal in Lava Terrane of Central Oregon concluded that
a continued discharge of septic tank wastes to drill holes
posed a potential hazard to the quality of the groundwater
(Sceva 1968). Subsequently, DEQ promulgated regulations
prohibiting the construction of additional lava sink holes
for disposal of inadequately treated wastes in the Bend urban
area after January 1975 and prohibiting their use beyond
January 1980.
5
-------
DISPOSAL
FIGURE I -1. DIAGRAM OF A TYPICAL
DOMESTIC SEWAGE DISPOSAL SYSTEM
IN THE BEND AREA
SOURCE: SCEVA , 1968
6
-------
As a result of these regulations and a formal requirement
issued to the City by DEQ, on September 5, 1975 as part of the
waste discharge permit, the City of Bend initiated a study to
determine the proper treatment and disposal of sanitary wastes
for the Bend urban area. A report entitled Sewerage Facilities
Plan, City of Bend, Oregon was prepared for the city in
September 1976 by Stevens, Thompson & Runyan, Inc. and Tenneson
Engineering Corporation. In this document the recommended plan
called for expansion of the existing wastewater treatment
facility to a capacity of 6.0 mgd. Approximately 150,000
linear feet of collector and interceptor sewers would be
installed, and disposal of treated effluent would be through
year-round spray irrigation on approximately 600 acres located
about 3 miles north of the treatment plant.
In 1977, the City of Bend applied to the EPA for 75
percent funding of their proposed sewerage facilities plan
under the Construction Grants Program authorized by the
Federal Water Pollution Control Act Amendments of 1972
(PL 92-500). After review of the City's facility plan,
the EPA determined that the proposed project did not consti-
tute a significant impact and therefore did not require an
EIS. An April 5, 1977, the EPA released a Negative Declara-
tion announcing its preliminary decision not to prepare an
EIS. This decision was based on the fact that the proposed
project conformed with the City's local land use plan and
with statewide planning goals and guidelines. The City's
proposed project to sewer the entire City of Bend would also
be necessary to comply with state water quality requlations.
On July 8, 1977, upon completion of the 15-day comment
period on the Negative Declaration, EPA awarded a Step II
grant to the City of Bend for design of the proposed project.
After reevaluation of the proposed project, however, the
City decided to reject the plan approved by EPA and instead
proposed to construct a new secondary wastewater treatment
plant at a site on BLM land approximately 4 miles northeast
of the existing facility. The effluent would be filtered,
disinfected and discharged year-round to the subsurface via
drill holes or lava tubes or cracks on the new site as an
interim measure with a permanent disposal method to be applied
for at a later date. The existing treatment plant and dis-
posal site would be abandoned.
The City applied to the EPA for this relocated new facility
in Amendment Number One to the Sewerage Facilities Plan (BECON
1977b), contending that a comparative cost analysis of the
treatment alternatives showed the total cost was essentially
the same for either alternative. The City also contended
that major environmental impacts would occur if the existing
plant was expanded. Among these nuisance impacts were noise
and odor problems relating to recent residential developments
around the existing facility.
7
-------
To review costs associated with the two treatment plants
and relocation to the new site, the EPA contracted Brown and
Caldwell Engineers to perform an independent cost comparison
analysis._ The Brown and Caldwell analysis reported that
construction of the new plant would be as cost-effective as
expansion of the existing plant. As a result, on April 5,
1978, the EPA issued a Negative Declaration for design and
construction of the new wastewater treatment plant, and
collector and interceptor sewers. However, the EPA decided
to prepare an EIS on the ultimate means of effluent disposal
because the City's hewly proposed project contained signi-
ficant changes in the method of effluent disposal.
The City's new treatment plant was scheduled for com-
pletion and start-up in late 1980. It was recognized that
the EIS process and selection of a permanent effluent dis-
posal alternative might not be completed before plant start-
up; therefore, emphasis was changed by the City and EPA to
evaluating and selecting an interim effluent disposal alter-
native. The City had received approval from DEQ for use
of subsurface disposal (defined as a drill hole) as an interim
method of effluent disposal. The EPA would approve interim
use of a drill hole only if it was found to be environmentally
acceptable, and if rxo other method of disposal was available.
After release of the Draft EIS (October 1979) and the
EPA public hearing, several meetings were held, with the Ci y
of Bend, DEQ and EPA to discuss interim effluent disposal
alternatives. As a result of these meetings, the City s
consultant, BECON, prepared Design Definition Memorandum
No. 11, Subsurface Effluent Disposal FeasibilityJ^nvef^?at '
dated December 1979. In Memorandum No. 11, the city Vf
commended the design and construction of a surface infiltra-
tion-overflow pond for interim effluent disposal along with
an extensive wastewater monitoring program. In this alter-
native effluent would be discharged into a pond on Site E
for soil infiltration and evaporation. The size of the in-
filtration area would be 80-100 acres. Construction of the
pond would include the removal of soils to underlying basalt
rock near the center of the pond. The rock would be fractured
by explosives to depths on the order of 20-25 feet. The
excavated and fractured rock area would be surrounded by
a berm so that water would only flow into this area after
the pond has filled to overflow capacity.
The EPA viewed this alternative as nearly the same as
drill hole and lava tube disposal. In the viewpoint of EPA
it is advantageous to use the wastewater treatment and dis-
infection capabilities of soil filtration. Consequently
subsurface disposal should rely on filtration through a mini-
mum of 3 feet of soil. EPA conditionally approved the soil
8
-------
infiltration alternative by excluding the overflow features,
clearing of the clay overburden near the center of the natural
depression, and fracturing rock. EPA's conditional approval
was based on a number of concerns that needed to be satisfied
prior to a decision to provide grant assistance for the con-
struction of the proposed interim effluent disposal project.
These additional EPA concerns were addressed by BECON in
a February 1980 report entitled Environmental Information
Document, Effluent Containment Pond and Ground Water Monitoring
Systems.
On June 9, 1980, the EPA released a Finding of No Signifi-
cant Impact (FNSI) on the interim effluent disposal facility
described above. However, during the 30-day comment period
on the FNSI, additional information was developed regarding the
proposed disposal facility. This information was made avail-
able for public review on August 15, 1980 in a Supplemental
FNSI. Based on the Supplemental FNSI, the June 9, 1980
Environmental Assessment and FNSI and public comments, the EPA
made a final decision in September 1980, that an EIS for
the proposed interim effluent disposal facility would not be
prepared.
During the same period, the BLM prepared an Environmental
Assessment of the proposed interim effluent disposal facility,
which would be located on BLM land. The BLM also concluded
that an EIS would not be required for the proposed facility.
Subsequently, the BLM issued a three-year lease for use of 440
acres for the interim effluent disposal facility and monitor-
ing well system. On September 30, 1980, the EPA awarded
the City of Bend a Step III construction grant to begin con-
struction of the interim effluent disposal facility and moni-
toring well system. The projected date for completion of
construction is January 1981.
A decision has not been made on a permanent effluent
disposal facility. This Final EIS is a special purpose docu-
ment which identifies the actions taken by EPA to date and
subsequent action to be taken by the City for the ultimate
effluent disposal facility. The City was awarded an EPA
grant to construct, operate and monitor the interim disposal
project. The information gained is expected to allow the
City to apply to EPA for a grant to construct a permanent
facility.
The Study Area
The study area, extending from the City of Bend and its
surrounding urban area north to the Madras area, is located in
Deschutes and Jefferson Counties in west-central Oregon
(Figure 1-2). The area is characterized by gently rolling
high desert terrain, bisected by the deep canyons of the
9
-------
FIGURE 1-2. THE STUDY AREA
10
-------
Deschutes River and its major tributaries. Elevations vary
from approximately 3,600 feet at Bend to 2,200 feet at Madras.
Site E, shown in Figure 1-2, lies northeast of Bend and is the
location of the new wastewater treatment plant.
The Bend-Madras area is characterized by a semi-arid
climate. Annual rainfall averages 10-12 inches, with the
majority falling in winter as rain or snow. Summers are
typically hot and dry. Freezing temperatures, however, can
occur during any month of the year.
Geologic formations in the study area are primarily of
volcanic origin. Lava tubes or caves, formed when molten
lava flowed out beneath a cooled and hardened crust, occur
throughout the area. Overlying soils are most commonly a
sandy loam, and range in depth from several inches to greater
than 10 feet.
The major source of surface water in the study area is
the Deschutes River and major tributaries, such as the Crooked
and Metolius Rivers. During the irrigation season, April
through October, almost the entire flow of the Deschutes
River is diverted at Bend into six irrigation canal systems,
which support crops such as alfalfa, wheat, peppermint and
potatoes. Agriculture, including livestock grazing, is the
major land use in the study area.
Groundwater is the primary source of drinking water in
the study area. The regional water table lies at a depth of
500-600 feet at Bend and between 200-300 feet at Redmond and
Madras. Perched groundwater also occurs at various locations.
Groundwater flow is believed to travel in a northerly and
northwesterly direction (Sceva 1968).
11
-------
Chapter 2
Effluent Disposal Alternatives
-------
Chapter 2
EFFLUENT DISPOSAL ALTERNATIVES
Projects Evaluated
The purpose of the EIS is to assist the City of Bend
in selecting an environmentally-sound and cost-effective
solution for the disposal of effluent from the new 6 MGD
wastewater treatment plant in accordance with EPA construction
grant regulations. This project must be planned to accommo-
date the City's needs for a 20-year period. A number of
effluent disposal options were evaluated for the Bend waste-
water treatment plant. This chapter summarizes all alter-
natives considered by the City's consulting engineers (STR
initially and later BECON) and by EPA. Reasons for rejection
or acceptance of the various alternatives are also given.
Table 2-1 summarizes this information.
STR Alternatives
In the facilities plan developed by Stevens, Thompson and
Runyan, Inc. (STR 1976), four options were evaluated for
the disposal of effluent from expansion of wastewater treat-
ment facilities at the former treatment plant. These four
alternatives are described briefly below.
Year-round Drill Hole Disposal. Under this alternative,
effluent would be discharged to drill holes on a continuous
basis. The treatment level considered was advanced secondary,
using activated sludge followed by clarification and filtra-
tion and finally, disinfection using chlorine. Although
the facilities plan indicates treatment for nitrogen control
as well, the treatment systems finally reported did not
include this additional level of treatment.
Combination of Drill Hole and Irrigation Canal Discharge.
Effluent disposal would be to the North Unit Main Canal during
the summer months and to drill holes during the winter months
when the canal was not utilized. Treatment for discharge to
the irrigation canal would be secondary treatment followed by
chlorine disinfection. Treatment for drill hole disposal would
be secondary, followed by filtration and chlorine disinfection.
Combination of Disposal to the Irrigation Canal and
Deschutes River. Secondarily treated (activated sludge) and
disinfected effluent would be discharged to the North Unit
Main Canal during the summer months and to the Deschutes River
during the winter months.
13
-------
EFFLUENT DISCHARGE
ALTERNATIVES EVALUATED
Table 2-1. Summary of Effluent Disposal Alternatives Evaluated for the
City of Bend and Their Current Status as Ultimate
and/or Interim Disposal Methods
FACILITIES
PLAN
AUTHOR STATUS AS ULTIMATE SOLUTION STATUS AS INTERIM SOLUTION
Drill hole - Site C
Drill hole - HUM Canal
NUM Canal - Deschutes River
Spray irrigation - Site C
Drill hole - Site E
Infiltration ponds
Deschutes River
Evaporation ponds
Spray irrigation - Site E
NUM Canal
STR Rejected due to potential
groundwater contamination
STR Rejected due to potential
groundwater contamination
STR Rejected due to high cost
STR Rejected due to uncertain
reliability
BECON Rejected due to potential
groundwater contamination
EPA/BECON Potentially acceptable in
total or as a component of
a total system
EPA Rejected due to public health
risks, impacts on fisheries
and high cost
EPA Rejected due to high cost
BECON Rejected due to high cost
EPA Preferred alternative
NA
NA
NA
NA
Rejected due to potential
groundwater contamination
Conditionally accepted
NA
NA
NA
Unimplementable due to unresolved
institutional and legal restraints
No action
Not acceptable
NA
*NA - not applicable
-------
Land Application of Effluent by Spray Irrigation. Second-
arily treated (activated sludge) and disinfected effluent would
be used to irrigate crops at alternate sites on a year-round
basis. For this option, three different sites were evaluated
as three separate effluent disposal alternatives. No temporary
storage reservoir is mentioned as being included in these
options. The three sites would be under control of the City.
The STR report recommended land application by spray
irrigation on Site C as the most environmentally sound alterna-
tive (Figure 2-1). The remaining alternatives were rejected for
varying reasons as shown in Table 2-1.
As previously stated, the City retained BECON to implement
the facilities plan. After more detailed site evaluation
by BECON (Design Definition Memorandum No. 5), Site C was
found unsuitable for land application of effluent on the
basis of high cost. After relocation of the treatment plant
to Site E (Figure 2-1) and further analyses of the land appli-
cation alternative, BECON recommended that a subsurface eff-
luent disposal method be provided on an interim basis, with
a final or ultimate disposal method to be selected at a later
date.
Alternatives Evaluated in the Draft EIS
The six effluent disposal options that were considered
potentially suitable for the new wastewater treatment plant
are evaluated in the EPA Draft EIS, Sewage Effluent Disposal
for the City of Bend, Oregon (October 1979). These alter-
native effluent disposal plans were described by the City's
engineer, BECON, and/or by EPA. The Council on Environmental
Quality (CEQ) guidelines for EIS preparation authorizes EPA
to evaluate in an EIS effluent disposal alternatives offered
by the City and alternatives of their own choice. Imple-
mentation of one of the alternative projects is, however,
the City's responsibility and if EPA grant funds are to be
used, the City must apply to EPA for funding.
The Draft EIS alternatives evaluated were:
1. Subsurface disposal via drill holes or fractured rock;
2. Subsurface disposal through the soil mantle;
3. Discharge to the Deschutes River;
4. Discharge to sealed evapotranspiration ponds;
5. Land application by spray irrigation;
6. Discharge to the North Unit Main Canal; and
7. No action to implement a permanent disposal facility.
15
-------
CTl
FIGURE 2-1. TREATMENT PLANT LOCATIONS & PROPOSED
EFFLUENT DISPOSAL AREAS (SITES C & E)
W'
BEND
\ AIRPORT
ABANDONED
CITY TREATMENT PLANT
BEtNIO
NEW TREATMENT PLANT
-------
Subsurface Disposal via Drill Holes or Fractured Rock.
This alternative involved year-round conveyance of effluent
by pipeline to a series of drill holes or fractured rock
basins on Site E. Effluent would receive secondary treatment,
chlorine disinfection, and sand filtration prior to discharge
to the disposal basin.
Subsurface Disposal Through The Soil Mantle. This
alternative involved year-round conveyance of effluent by
pipeline to an 85-acre infiltration pond at a site approxi-
mately 2 miles northeast of the new treatment plant. Effluent
discharged to the pond would filter through a minimum of
3 feet of soil before entering underlying rock formations.
The infiltration pond alternative presented in the Draft
EIS was later modified by BECON. The pond site was moved
to a location closer to the new treatment plant and the pond
size was expanded to 160 acres.
Discharge to the Deschutes River. Treated wastewater under
this alternative would have been pumped through a 6.7 mile
pipeline to the Deschutes River on a year-round basis. Effluent
would have been discharged downstream of the Bend diversion dam.
The treatment system included sand filtration and chlorine
disinfection.
Discharge to Sealed Evapotranspiration Ponds. This
alternative was considered in the Draft EIS at the request of
a local citizen, Mr. Gordon Priday. The Priday alternative
involved construction of a series of sealed ponds interconnected
by a small canal system. Each pond would have been constructed
and managed to establish wildlife habitat. Approximately 1,270
acres of ponds were needed to evaporate the effluent. A 35-
acre infiltration pond was included in this alternative as a
backup for peak flow and cold season use.
Land Application by Spray Irrigation. Under this alterna-
tive, effluent would have received secondary treatment, then
would have been pumped to either center-pivot or fixed-head
(solid-set) irrigation units for spraying onto the land. Spray
irrigation required 1,350 acres to accommodate a treatment plant
capacity of 6 mgd. Effluent would have been applied to a cover
crop such as reed canary grass, fescue, orchard grass or meadow
foxtail.
Discharge to the North Unit Main Canal. This alternative
was based on year-round discharge of treated wastewater to the
irrigation canal. Because the North Unit Main Canal operates
only during the irrigation season, roughly April through
October, modifications to year-round canal discharge were in-
cluded under this alternative. Options considered in combination
with summer discharge to the canal were:
17
-------
1. Discharge to an infiltration pond ;
2. Discharge to the Deschutes River; and
3. Discharge to storage reservoirs
No action to Implement a Permanent Disposal Facility,
The no-action alternative in this case is the interim 2.5 MGD
disposal facility and monitoring program designed to meet
two main objectives: 1) receive effluent from initial opera-
tions of the new 6 MGD wastewater plant, and 2) provide data
that can be used in the design of a 20-year, 6 MGD project.
This interim disposal project is the same as the Subsurface
Disposal Through the Soil Mantle alternative described above
except that the size of the facility needed to take 6 MGD
is presently undetermined. The no-action or interim disposal
project will provide pilot plant operations data important
to the selection of a permanent 20-year project.
Alternative Evaluation Summary
The effluent disposal alternatives listed above were
evaluated by the EPA as potential ultimate and/or interim
effluent disposal options. Analyses of potential impacts
described in Chapter 6 of the Draft EIS (October 1979) led
to rejection of several alternatives for reasons shown in
Table 2-1. Subsurface Effluent Disposal via Drill Hn]oc
°r.Kr!°?Ured R°°S YuS rejected as b°th an ultimate and interim
method because of the potential for contamination of ground-
water; Discharge to the Deschutes River was rejected due to
potential adverse impacts on fisheries resources public
health risks and costs; Discharge to Sealed Evapotranspiration
and Land Application ^SpfI7^rriqation/whlVh Enth
required large acreage, were rejected due to their high cost
and usage of_large areas of public land. Subsurface Disoosal
Through the Soil Mantle and Discharge to the Nor-eh rmit EL ^ '
Canal were deemed environmentally-sound and cost-effective
and therefore, potentially acceptable to EPA as ultimate
effluent disposal alternatives.
. , Subsurface Disposal Through the Soil Mantle has been
implemented as an interim effluent disposal project coupled
with groundwater monitoring to determine: 1) treatment/disposal
effects on subsurface resources and 2) the pond capacity
(acreage) needed for long-term (20 years) effluent disposal.
Soil infiltration disposal could also be used either as an
ultimate solution or in combination with irrigation season
discharge to the North Unit Main Canal to provide winter
season and emergency effluent disposal.
18
-------
Reuse of treated effluent is encouraged by federal agencies.
Section 201 (d) of the Federal Water Pollution Control Act Amend-
ments states: "The Administrator (EPA) shall encourage waste
treatment management which results in the construction of
revenue-producing facilities providing for ... the recycling of
potential sewage pollutants through the production of agricul-
ture, silviculture, or aquaculture products For this
reason, in combination with an evaluation of all other potential
impacts, the EPA selects discharge of effluent to the North
Unit Main Canal as the environmentally preferred alternative.
The effluent can be considered a long-term water resource of
considerable value in an agricultural area where water can often
be in short supply. EPA encourages the City of Bend to take
further steps toward negotiating an agreement with the North
Unit Irrigation District for use of treated effluent in agri-
cultural irrigation. In addition, the City should encourage
farmers and ranchers in the vicinity of the treatment plant
to seasonally use the reclaimed wastewater. Holding ponds
could be provided for this type of use.
19
-------
Chapter 3
Alternatives Acceptable to EPA
-------
Chapter 3
ALTERNATIVES ACCEPTABLE TO EPA
Introduction
The environmental impact analysis reported in the Draft
EIS, coupled with comments submitted at the EPA public hearing
and by letter, causes the EPA to find two methods of effluent
disposal environmentally acceptable and cost-effective for
EPA grant funding: 1) discharge to the North Unit Main Canal
for reuse in crop irrigation, and 2) evaporation and infiltra-
tion through the soil mantle. Evaporation/infiltration can
be coupled with a system providing storage and conveyance
to nearby farmers and ranchers for agricultural reuse. These
effluent disposal methods may be used in combination to pro-
vide year-round and/or emergency services. If EPA grants
are to be offered, the City of Bend must apply to EPA for
funds to implement an environmentally acceptable and cost-
effective effluent disposal project. The implementation
of either or both options as the permanent (20-year) disposal
project is presently held in abeyance until certain technical
and institutional matters are resolved. These issues, which
are discussed in detail in the following sections, should
be resolved before September 1982.
Discharge to the North Unit Main Canal
Alternative Description
This alternative is based on year-round discharge of
treated wastewater to the irrigation canal. Due to the
location of the treatment plant, which is scheduled for start-
up in late 1980, and the principal use of canal water for
irrigation, the North Unit Main Canal was considered more
appropriate for effluent disposal than other canal systems
in the Bend area. Effluent would undergo secondary treatment
followed by chlorine disinfection and filtration prior to
discharge.
The effluent would be pumped through a short forcemain
and discharged directly to the canal. The effluent flow
rate would average approximately 9 cubic feet per second
(cfs) at full use of the plant.
21
-------
Because the North Unit Main Cartal operates only during
the irrigation season, roughly April through October, a modi-
fication to year-round canal discharge or provisions for
storage would need to be included under this alternative.
Impacts of Canal Effluent Discharge and Feasible Mitigation
Measures
Short-term and long-term impacts of effluent disposal
to the North Unit Main Canal were addressed in the Draft
EIS (October 1979) . Table 3-1 summarizes the impacts and
potential mitigation measures. Potential adverse impacts
relate to: 1) public health risks to Madras residents that
use canal water for domestic purposes in summer, 2) increased
aquatic plant growth in the canal, and 3) addition of nu-
trients to Haystack Reservoir that may affect eutrophication
rates. Mitigation measures for public health risks include
the construction of water wells for the City of Madras, moni-
toring of water quality at the Madras water treatment plant,
and acceptance of liability by the City of Bend for potential
public health hazards. To mitigate increases in aquatic
plant growth in the canal, the City of Bend could pay in-
creased maintenance costs to the irrigation district, or
the treatment process could be upgraded to remove nuisance
nutrients. Accelerated eutrophication of Haystack Reservoir
also could be mitigated by upgrading the treatment process,
or by selectively scheduling the filling of the reservoir.
Impacts associated with winter discharge to the canal,
such as ice-buildups, potential groundwater contamination
and interference with canal maintenance schedules, could
be avoided by discharging effluent to infiltration ponds
during the nonirrigation season.
In comparison to other alternatives evaluated in the
Draft EIS, the impacts associated with effluent disposal
to the North Unit Main Canal can be considered as trade-offs.
For example, discharge of effluent to the canal vs. effluent
discharge to the subsurface lessens the potential for signi-
ficant groundwater impacts. Large acreage needs and high
costs of disposal are avoided by chosing canal discharge
over spray irrigation or discharge to sealed evaporation
ponds. Canal discharge vs. discharge to the Deschutes River
avoids adverse impacts to the fishery, domestic water users,
and the City of Redmond, which also uses Deschutes River
water for domestic uses.
22
-------
Table 3-1. Impacts Associated with Discharge of Effluent to the
North Unit Main Canal and Potential Mitigation Measures
Impact Category
Impact Description
Potential Mitigation Measure
Groundwater
Effluent discharged in winter
is not expected to proceed a
great distance down the canal
before entering the ground.
There would be a risk of
groundwater contamination of
shallow aquifers near the
canal.
Discharge of effluent to stor-
age or infiltration ponds ir.
winter. Explore subsurface
conditions; monitor effluent
flow in subsurface.
Surface Waters
Increased nutrient input to
canal could cause added eutro-
phic conditions in Haystack
Reservoir.
Add treatment processes to ra-
move nutrients. Selectively
schedule reservoir filling.
Public Health
Potential health risk to resi-
dents of Madras using canal
water for domestic purposes
in summer.
Monitor water quality in Madras
water treatment plant; con-
struct new water wells for
summer use.
Fisheries
Chlorine concentrations in the
canal system could adversely
impact fish in the canal and
Haystack Reservoir.
Dechlorination of effluent
at the treatment plant.
Eutrophication of Haystack
Reservoir could reduce dis-
solved oxygen concentrations.
Add treatment processes to
remove nutrients. Aerate
reservoir.
Aesthetics
Adverse visual impact of in-
creased aquatic plant growth
and algae in canal and reser-
voir.
Add treatment processes to re-
move nutrients. Implement
chemical treatment and mechani-
cal harvesting.
Secondary Costs
Increased maintenance costs to
control increased aquatic
plant growth.
City of Bend pays increased
maintenance costs.
Potential ice buildups due to
winter flow in canal; structural
maintenance costs.
Discharge of effluent to stor-
age or infiltration ponds in
winter; City of Bend pay increa-
sed maintenance costs.
Liability insurance costs.
City of Bend assumes liability
associated with effluent dis-
posal.
Potential secondary economic
impact on resorts at Haystack
Reservoir due to increased eu-
trophication.
Add treatment processes to re-
move nutrients. Use alterna-
tive methods of operations.
23
-------
Implementation Problems
Although discharge of effluent to the North Unit Main
Canal is an environmentally acceptable alternative to the
EPA, this alternative is not implementable at this time be-
cause it is not acceptable to the managers and customers
of the irrigation district. Moreover, the City of Bend has
not applied to EPA, DEQ, and the North Unit Irrigation District
to implement this disposal option. The North Unit Irrigation
District has outlined the following major institutional and
legal constraints on acceptance of effluent discharged to
the canal during the irrigation season:
1. The addition of effluent nutrients (i.e., nitrogen
and phosphorus) to the canal could result in in-
creased aquatic plant growth thereby requiring
the district to increase the use of herbicides in
their maintenance program.
2. Effluent flow in the canal in winter would inter-
fere with canal maintenance normally scheduled
during the winter months when the canal is dry.
3. Effluent flow in the canal in winter could cause
ice buildups that could damage canal structure.
4. Present easements allow water to flow in the canal
through private property only during the irrigation
season (April through October). Property might
have to be condemned to allow effluent to flow
through the canal in winter.
5. Undiluted effluent flow in the canal outside the
irrigation season could contaminate groundwater.
6. Liability insurance would be required to protect
the North Unit Irrigation District against claims
regarding diseases contracted by people coming
in contact with canal water containing effluent.
Setting limits on liability insurance would be
difficult under present law.
7. There is a potential for adverse psychological
effects regarding use of effluent on food crops
grown in the irrigation district.
As stated previously, discharge of effluent to the North
Unit Main Canal is considered to be an environmentally acceptable
alternative to EPA. The EPA urges the City of Bend to continue
negotiations with the North Unit Irrigation District to resolve
present legal and institutional constraints. This alternative
24
-------
could be implemented only if the City successfully negotiates
an agreement with the irrigation district to discharge effluent
into the canal. The interim effluent disposal alternative
presently under construction has the potential for solving
some of the implementation problems associated with discharge
to the canal. This topic is discussed in Chapter 1.
Evaporation and Infiltration
Through the Soil Mantle
Introduction
The evaporation/infiltration pond alternative described
in the Draft EIS (October 1979) involved piping effluent
approximately 2 miles northeast of the new treatment plant
to an 85-acre natural depression. Subsequent revisions of
the Draft EIS alternative prepared by BECON in consultation
with the EPA and BLM resulted in relocation of the evaporation/
infiltration pond to a site less than 1 mile east of the
treatment plant. The size of the pond also was increased
to 160 acres due to possible differences in soil percolation
rates between the two pond sites.
The revised evaporation/infiltration pond alternative
was selected by the City of Bend for interim effluent dis-
posal and subsequently funded by EPA. Infiltration of eff-
luent through the soil mantle provides additional soils
treatment and may achieve best practicable wastewater treatment
(BPWT) objectives of EPA. For this reason, infiltration
is reviewed favorably by the EPA as the interim disposal
alternative and, therefore, may become a part of the per-
manent disposal facility. The EPA, however, is concerned
about the long-term environmental consequences of this alter-
native and will require further evaluation of the interim
disposal facility before determining its potential use as
part of the permanent disposal facility. Operation of the
interim facility will also provide data to determine the
size of infiltration ponds necessary to accommodate a 6 MGD
flow. To implement this alternative as a permanent disposal
facility, the City of Bend must apply to the EPA for appro-
priate grant funding.
The following sections describe: 1) the process by
which infiltration was selected as the interim disposal method,
2) the design of the disposal facilities, and 3) impacts
and mitigation measures associated with this alternative.
25
-------
Alternatives Evaluated
In Design Definition Memorandum No. 11, BECON (197 9)
evaluated six interim effluent disposal alternatives. These
were :
A. Subsurface disposal to basalts above pumice deposits;
B. Subsurface disposal to a void zone at the 215-240
foot depth;
C. Subsurface disposal to artificially fractured
basalts beneath the pumice deposit;
D. Surface infiltration - evaporation through the
existing soil mantle with overflow to adjacent
basins;
E. Combined surface infiltration through the soil
mantle and subsurface percolation through frac-
tured basalt;
F. Surface infiltration - overflow pond and centralized
overflow percolation zone through fractured basalt.
These alternatives are described in greater detail in
Appendix A, Chapter 8 j (June 9, 1980 Finding of No Significant
Impact).
After several meetings between the City and EPA, the
EPA selected a modified version of BECON Alternative F for
implementation as an interim project. This project, which is
similar to the infiltration pond alternative presented in the
Draft EIS (October 1979), is described below.
Infiltration Pond
The infiltration pond will receive secondarily treated
and disinfected effluent from the new wastewater treatment
plant. The pond will be located within a 470-acre tract
of land northeast of the treatment plant (Figure 3-1). The
infiltration pond will be approximately 160 acres and be
developed by diking lower boundaries of a natural depression.
At maximum capacity, the pond will have a maximum depth of
approximately 25 feet with an average depth between 10-12 feet.
Its disposal capacity is estimated to be 2.5 MGD.
Figure 3-2 shows the proposed design for the infiltration
pond. Construction of the pond will require 5,000 linear feet
of dike, utilizing approximately 60,000 cubic yards of soil
26
-------
to
-J
FIGURE 3-1. LOCATION OF INTERIM
INFILTRATION POND -SITE E
-------
FIGURE 3-2. DESIGN OF THE INTERIM
EFFLUENT INFILTRATION FACILITY
-------
that will be excavated from the pond site. Remaining soils for
percolation will be a minimum of 3-5 feet. The dikes will be
a maximum height of 15 feet, tapering to zero, as necessary
dike height is matched with existing topography. The dikes will
be 10 feet wide at the top with 2:1 side slopes riprapped with
rock excavated or blasted from the pond site (BECON 1980b).
Dikes will be constructed with an impermeable core to prevent
effluent seeps. The infiltration pond will be divided into
several alternate basins or cells for intermittent flooding and
drying, and for maintenance purposes. Such provisions will
assure that natural sealing of the pond bottom is prevented.
During design of the infiltration pond facility, potential
leakage areas (fractured basalt in the pond bottom) will be
identified and an appraisal made of their likelihood for exces-
sive leakage. Those areas judged to be highly susceptible to
seepage will be sealed. Other potential leakage sources will
be identified and monitored during operation of the facility
and inspected during maintenance periods.
The pond area will be cleared of trees, brush and any
other vegetative matter. This material will be removed from
the site and disposed of. The top 6 inches of soil will be
scarified to improve percolation. The buffer area surrounding
the infiltration pond will be left in its existing natural
state.
The outfall line from the wastewater treatment plant,
which will follow natural contours,j will convey effluent by
gravity to the outfall structure in the infiltration pond.
The outfall line will either be an open channel or a buried
pipeline, depending on final design.
For maintenance, a road will be constructed around the
pond perimeter. The road will be approximately 12-14 feet
wide and will be graded and surfaced with cinders.
A 4-strand barbed wire fence will be constructed around
the 470-acre lease area. Maintenance access will be provided
at McGrath Road and at fence corners.
A Pacific Power and Light Company transmission line (69kv),
which currently crosses through the infiltration pond site,
will be relocated so that it will extend along the northwesterly
and northerly side of the pond.
It is estimated that construction of the infiltration pond
will be completed in January 1981 (Carnahan pers. comm.).
29
-------
Infiltration Pond Maintenance
Maintenance of the infiltration pond and surrounding lease
area will be provided by the City of Bend, under direct super-
vision of the wastewater treatment plant superintendent. The
lease area will be inspected a minimum of three times per week
by plant operating personnel. Any necessary maintenance
services will be provided by these personnel or by the City
Maintenance Department.
During tri-weekly inspections, dikes will be inspected for
integrity and potential erosion. The outfall line will be
inspected for any blockages to effluent flow.
The maintenance road will be graded periodically to assure
adequate access to the lease areas. Fences will be repaired as
necessary.
The power transmission line will be maintained by the
Pacific Power and Light Company as part of their regular
program of surveillance and upkeep.
Infiltration Pond - Percolation Rates
To size the infiltration pond and determine acceptable
effluent application rates, BECON (1979) performed percolation
tests on Site "E" basin soils. A percolation test was conducted
on a 1-acre plot in the area where the infiltration pond will be
located. Water from the North Unit Main Canal was pumped to the
1-acre pond continuously for 5 days to allow a reasonable degree
of soil saturation before any measurements were made. Based on
this test, a percolation rate of 100 gallons per minute (gpm)
of clear water per acre was established. The effluent applica-
tion rate was then calculated to 0.30 gpd/ft on the basis of
criteria foij septic system design (BECON 1980a) . The value
0.30 gpd/ft corresponds to an effluent percolation rate of
approximately .44 feet per day.
Soil types within the infiltration pond were sampled by
BECON (1980a) and found to vary with depth. Silty sands and
medium-to-fine sands were encountered to depths of 9 feet. Clay
soils as thick as 6 feet were found approximately 6 feet below
the surface at the center of the Site E basin. Soils ranged in
depth from approximately 4-15 feet within the basin (BECON 1979).
According to BECON (1980a), soils encountered within the infil-
tration basin are of adequate grain size, cellular nature and
thickness to provide effective percolation rates.
30
-------
Groundwater Monitoring Program
A groundwater monitoring system was developed by BECON
(1980b) to accomplish several goals:
1. To establish a data base for comparison purposes in
the future;
2. To track effluent migration below the site; and
3. To compare groundwater quality below the infiltration
pond site with established drinking water standards.
To establish background water quality prior to effluent
disposal, a number of constituents of groundwater that are most
closely associated with effluent will be measured at periodic
intervals. These constituents and their sampling frequency are
shown in Table 3-2. Data will be analyzed on a continuous
basis and the program revised where needed. Background water
quality sampling began in existing wells in February 1980 and
will be continued through March 1981.
To monitor effluent migration as well as water quality below
the infiltration site, a monitoring well system will be
sequentially constructed around the disposal site. Initially,
five monitoring wells will be constructed. Each well will be
ten inches in diameter and totally encased. Two wells will be
drilled to a depth of approximately 600 feet and the remaining
three to a depth of approximately 75 feet. Additional wells
will be drilled to varying depths after the infiltration pond is
in operation and an estimate of subterranean migration can be
made. The approximate locations of monitoring wells are shown
in Figure 3-3. Included are existing domestic wells for which
historic data are available, additional domestic wells with no
historic quality data and two wells to be constructed specifi-
cally for monitoring purposes.
Figures 3-4, 3-5 and 3-6 show the cross-section of a typical
deep (±500 feet) well, intermediate (±250 feet) well and shallow
(±75 feet) well. Deep wells will be drilled into the water
table and will have submersible pumps installed for water quality
sampling. Intermediate wells will penetrate the cavernous zone.
Shallow wells will extend only into the pumice/ash bed layer.
Intermediate and shallow wells will act as "dry wells" used to
monitor any subterranean effluent flow. If flow is discovered
in a dry well, a pump will be lowered into the well for sampling.
Monitoring wells will not be supplied with permanent elec-
trical power connection; a portable generator will be used to
operate the pumps for sampling purposes. The surface apparatus
for each well will be covered by a concrete box attached to a
concrete slab and covered with a locked lid. Perpetual mainten-
ance will be provided for all monitoring wells (BECON 1980b).
31
-------
Table 3-2. Groundwater Constituents and Their Proposed Sampling
Frequency - Background Monitoring Program
CONSTITUENT
pH
Temperature
Total Coliform
Fecal Coliform
BOD5
Total Solids
Volatile Solids
Total P
O-PO4
NO3-N
NH3-N
Conductance
Alkalinity
Ca
CI
Cu
Fl
Hardness
Fe
Mn
Mg
Si
Na
Arsenic
Barium
Cadmium
Chrcmium
Lead
Mercury
Selenium
Silver
Lindane
Methoxychlor
2,4-D
Toxaphene
Endrin
2,4,5,TP (Silvex)
1980
SAMPLING FREQUENCY
2/month
1/month
1/month
1/3 months
1/3 months
1981
SAMPLING FRSPUENCY
2/month
1/2 months
1/2 months
3/year
3/year
SOURCE: BECON, February 29, 1980 letter to DBQ.
32
-------
u>
u>
A
N
I
-L. EGEND -
S - SHALLOW WE LL
I - INTERMEDIATE WELL
D - DEEP WELL
SOURCE'- BECON, 1980b
INTERIM 3?,
INFILTRATION o®
POND
( EXISTING)
FIGURE 3-3. APPROXIMATE MONITORING WELL LOCATIONS
-------
-------
II'XV'W
Rs
I-• I." '
M
10' TO 40' CAVERNOUS
1U IU W Z0NE
1/4" STEEL PLATE
REMOVABLE LOCKED
CAPPED 3
GALV. PIPE
CAPPED I 1/2" GALV. PIPE
MONOLITHIC POUR
WELLHOUSE ^4 REBAR
12" O.C. VERT. 6. HORIZ.;
FLOOR: 4' X 4' INTERIOR
AIRLINE - 1/4 " GALV. P I PE
INSTALLED TO 2' FROM
BOTTOM
GAGE TO READ
IN FEET OF —
WATER /
3 TALL
CLAMP
CONCRETE GROUT FULL
DEPTH TO GRAVEL PACK
MIN. 10 WELL BORE
FULL DEPTH
BASALT
CASING 6 5/8" O.D. X 1/4"
WALL
SOURCE' BECON,1980b
FACTORY PERFORATIONS
GRAVEL PACK FULL WIDTH
OF CAVERNOUS ZONE
FIGURE 3-5. TYPICAL INTERMEDIATE
MONITORING WELL
35
-------
1/4" STEEL PLATE
REMOVABLE , LOCKED
CAPPED 3
6ALV. PIPE
CAPPED 1 1/2 GALV.
PI PE
MONOLITHIC POUR
WELLHOUSE ¦"* 4
REBAR, 12" O.C. VERT.
& HORIZ. FLOOR'-
4'X 4' INTERIOR
AIRLINE - 1/4" GALV. PIPE
INSTALLED TO 2' FROM
BOTTOM
_ CASING 6 5/8" O.D. X 1/4"
WALL
FACTORY PERFORATIONS
GRAVEL PACK FULL WIDTH
OF POROUS ZONE
SOURCE BECON, 1980b
FIGURE 3-6. TYPICAL
MONITORING WELL
36
-------
Drilling and well installation operations are anticipated
to begin in November or December 19S0. Water samples from deep
wells will provide additional site-specific baseline data for
existing groundwater conditions, to be included in the ground-
water data collection program initiated in February 1980.
Monitoring wells will be located near existing roads,
whenever possible, to minimize the need to construct access
roads.
Management of the monitoring well system will be the respon-
sibility of the City of Bend as part of the wastewater collection
and treatment facilities.
Impacts of Infiltration Pond Disposal and Mitigation Measures
Short-term and long-term impacts of effluent disposal
to infiltration ponds were addressed in the Draft EIS (October
1979). Table 3-3 summarizes major adverse impacts and potential
mitigation measures. The adverse impact of greatest significance
is potential groundwater contamination and the associated
public health risk. Soils encountered by BECON (1980a) on
the infiltration pond site, however, are judged to have good
pollutant removal qualities. Grain size, fines content and
thickness are adequate to provide substantial surface area
for percolation. The cellular nature of volcanic or pumice
materials found in the soils will also provide additional
surface area for effluent contact, further increasing pollu-
tant removal.
Soil infiltration-percolation studies have shown high
removal efficiencies for pollutants such as BOD, suspended
solids, viruses and bacteria. Removal efficiencies of other
pollutants such as nitrogen, phosphorus and stable organic
compounds, however, vary considerably with soil characteristics
and management practices (Pound and Crites 1973). Actual
pollutant removal efficiencies for soils within the infil-
tration pond should be determined through the proposed
effluent and groundwater monitoring program. Using adequate
monitoring data, a confirmed rate of transfer of substances
from the effluent to groundwater can be calculated.
Adverse impacts associated with effluent discharge to
infiltration ponds would be lessened by combining winter
and emergency use of this alternative with summer discharge
of effluent to the North Unit Main Canal. Effluent flow
to the infiltration ponds would be approximately 870 million
gallons annually, or 40 percent of the total effluent dis-
charged per year.
37
-------
Table 3-3. Impacts Associated With Discharge of Effluent to
Infiltration Ponds and Potential Mitigation Measures
Impact Category
Impact Description
Potential Mitigation Measure
Groundwater
Some effluent contaminants may
not be filtered out in soil
mantle and therefore may reach
groundwater supplies.
Monitor groundwater below in-
filtration site* upgrade treat-
ment process or apply source
control and oretreatment mea-
sures .
Public Health
Archeological and
Historical Re-
sources
Potential health risk to resi-
dents using groundwater sup-
plies for domestic uses.
Inundation of .25 miles of the
Prineville-Bend wagon road.
Disturbance to archeological
sites.
Monitor groundwater below in-
filtration pond site and in
nearby domestic wells; upgrade
treatment process.
Map, describe and photograph
sites; minimize ground distur-
bance. '
Wildlife and
Vegetation
Loss of vegetation and seden-
tary wildlife.
Confine construction activities
to as small an area as possible.
38
-------
The No-Action Alternative
The no-action alternative is the 160-acre interim effluent
disposal project which is designed to have an effluent dis-
posal capacity of about 2.5 MGD. The EPA considers the
interim evaporation/infiltration pond to be potentially accep-
table as part of the permanent 6 MGD effluent disposal facility.
The EPA is concerned, however, about the sizing of the pond
for a 6 MGD capacity and possible long-term adverse impacts
on groundwater. Therefore, EPA has required the City of
Bend to monitor groundwater quality and subsurface flow be-
neath the interim ponds. The interim project will serve
in effect as a pilot project. Monitoring and operational
data should provide the additional information needed by
the City to determine if evaporation/infiltration is suitable
as a long-term disposal method. The interim project is ex-
pected to operate for a term not to exceed 3 years.
The interim disposal facility is located on BLM land;
consequently, the City of Bend must comply with conditions
outlined in their lease agreement. According to the BLM
lease (September 24, 1980), the City of Bend may use the
interim infiltration pond site for a period of 3 years. At
the end of the second lease year, the city must decide, based
on available operational and groundwater monitoring data,
if the interim infiltration pond will become part of the
permanent effluent disposal facility and notify BLM of their
decision. At about the same time, the city must apply to
the EPA for grant funding to construct a permanent effluent
disposal facility. The EPA will utilize information provided
to them by the city to evaluate the proposed project as re-
quired under the NEPA.
39
-------
Chapter 4
Comments and Responses to the
Draft EIS
-------
Chapter 4
COMMENTS AND RESPONSES TO THE DRAFT EIS
Letters of Comment
This section contains letters of comment from agencies and
organizations on the Draft EIS for the City of Bend. Those
letters which commented directly upon the Draft EIS have been
reproduced in this section. Wherever a response is required by
EPA to the letter, a response page follows that letter.
Table 4-1 /is a listing of the comment letters received
during the 45-day review period, including a general category
listing of their contents. Comment categories are shown in an
attempt to indicate those aspects of the proposed project about
which the commenters were most interested and concerned. This
may serve to direct the reader to those sections of the document
which he or she may wish to restudy.
The EPA wishes to express its appreciation to all comment-
ing agencies and organizations for the time and effort spent in
reviewing the Draft EIS. All comments were fully considered
prior to formulating the EPA's recommended proposed action.
41
-------
Table 4-1.
1. Jefferson County Pomona Grange #32,
Madras, Oregon
2. Avion Water Company, Bend,
Oregon
3. Advisory Council on Historic
Preservation, Washington, DC
4. State of Oregon Aeronautics Division,
Salem, Oregon
5. League of Women Voters of Deschutes
County, Bend, Oregon
6. Oregon Environmental Council,
Portland, Oregon
7. Water Resources Department, Salem,
Oregon
8. U. S. Department of the Interior, Office
of the Secretary, Portland, Oregon
9. Oregon Department of Fish and
Wildlife
10. Department of Land Conservation and
Development
11. Law Offices of Rodriguez, Glenn and
Wilkinson, Madras, Oregon
12. City of Redmond, Deschutes County,
Oregon
13. U. S. Department of Agriculture, Soil
Conservation Service, Portland, Oregon
14. Department of Environmental Quality,
Portland, Oregon
Summary of Letters of Comment on the
City of Bend Draft EIS
w
u
H
Eh
Eh
U
2
U
H
<
O
M
S
H
K
o
a
u
Eh
w
Eh
a;
<
w
w
V)
x
M
Eh
<
Cm
H
Eh
<
05
z
W
H
E
M
U
W
<
§
CO
S. 2
J
w
M
Eh
J
Q
«
U O
M
Q
0
w
<
0<
2
w
V)
2
J
>
M M
CQ
OS
O
Eh
3
O
O
M
H
O Eh
<
<
*-1
<
u
H
o
H
E-<
O
J
<
w
Cj
L>
D
<
sc
u
<
<4
2
o a
32
u
2
in
<
Eh
Eh
M
os
w w
J
o
D
Ua
Q
W
Q
a:
2C
w
S w
<
Q
OS
Eh
o
H
2
O
<
O
u
tn
Eh
u w
o
PS
Q
o
<
w
W
O
w
H
PS tt
w
H
>h
o
cn
w
J
>
tc
fc.
a:
in
<
< a
CQ
3
U
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x x
X
X
X X
X
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
PACIFIC NORTHWEST REGION
500 N.E. Multnomah Street, Suite 1692, Portland, Oregon 97232
December 5, 1979
ER-79/1013
Mr. Roger K. Mochnick
Acting Chief
Environmental Protection Agency
1200 Sixth Avenue
RECEIVED
VS.C 1 0 1979
rr
Seattle, Washington 98101
Dear Mr. Mochnick:
Thank you for the opportunity to review and comment on the draft
environmental statement for Sewage Effluent Disposal for the City
of Bend, Oregon.
General Comments
Field investigations underway by Geological Survey indicate that an
interpretation of the hydrogeologic system differing from that pre-
sented in the environmental statement warrants serious consideration.
The Geological Survey interpretation suggests that the conclusion
that "It is likely no signicant amount of effluent discharged to the
subsurface would enter the deep artesian aquifer" is open to some
question and that additional coverage should be given to potential
groundwater contamination and alternative disposal methods.
The draft statement is inadequate in its consideration of historic
and archaelogical resources which could be impacted by project con-
struction. Some further consideration should have been given also
to downstream effects of effluent discharge on recreational resources.
Specific Comments
Pages 1-5. Summary
Disposal to Drill Holes. As stated, the major adverse impact
associated with subsurface disposal to drill holes would be the
potential for groundwater contamination. In the event of domestic
well water contamination by this alternative, additional mitiga-
tion measures could be replacement of the contaminated deep
aquifer or alternative water source with a piped distribution at
43
-------
City expense, or direct compensation or payment to the affected
owners to case out the contaminated aquifer and deepen the wells
or redrill in a new location into a safe aquifer.
Disposal by Infiltration Ponds. We suggest that the reduced
potential for groundwater contamination should be listed as a
favorable and not a major adverse impact of subsurface disposal
via infiltration ponds. As noted on page 80, removal of B.O.D.
and bacteria is estimated to be greater than 98 percent in in-
filtration ponds. According to page 44, the development of in-
filtration ponds would require only 85 acres which is consider-
ably less than that required for the evapotranspiration pond
alternative (1,305 acres) or spray irrigation alternative (1,350
acres); hence, this would seem to be only a moderate land
commitment.
It might also be helpful to the reviewer to have highlighted in
the summary some of the significant information from pp. 90-92
regarding the relative effectiveness of infiltration ponds in
providing a greater degree of disinfection of water compared to
other proposed alternatives.
Disposal by Evapotranspiration Ponds. We recommend that mention
be made of the major impact of the solids removal problem from the
evapotranspiration ponds which are sealed with bentonite.
Disposal by Spray Irrigation. Major adverse impacts noted, such as
large land commitment and significant loss of vegetation and as-
sociated wildlife, are apparently based on the assumption that all
the irrigation will be on newly developed land and not on land that
is already farmed. Even if this were the case, the loss of vege-
tation would be a short term effect with the resultant irrigated
crop being more luxuriant and better ground cover than the original
cover. Under average conditions 6mgd effluent water would be suf-
ficient to irrigate 600 acres; however, as spray irrigation is more
efficieit, the report estimates 1,150 acres can be irrigated; but
this land requirement may be reduced by using crops requiring large
quantities of water, such as alfalfa.
The economical return from this irrigated land has not been mentioned.
If irrigation by conventional gravity laterals were feasible in this
area, this would likely, result in a reduced investment cost.
No Action Alternative. It might be useful to reviewers to have the
information on the Summary section that the Oregon Department of
Environmental Quality placed a ban on construction of additional
sink holes in the Bend urban area for disposal of inadequately
treated wastes and prohibited their use beyond January 1980.
44
-------
Page 3, Table A. Vegetation and odors adverse impacts for the North
Unit Main Canal should be shown with at least moderate impact (0) and
not negligible impact to be consistent with the rest of the report.
The increased B.O.D., nutrients, and higher water temperature of the
sewage effluent is bound to result in accelerated growth along the
canal and in Haystack Reservoir, and would pose a problem. Similarly,
any odors associated with the sewage effluent would be spread by the
canal over a wide area.
Page 38, Table 3-2. We suggest that individual measurements be given
for ammonia and nitrates since they are both important measurements
of pollution and effectiveness of the sewage treatment. Note the ef-
fects of ammonia listed on pages 99 and 100 which point out that the
presence of ammonia, which has an affinity to oxygen, will result in
a reduction in dissolved oxygen and is toxic to aquatic life. Accord-
ing to page 100, the allowable concentration of ammonia at discharge
point in the mixing zone is about 1.2 mg/1. The separate measurement
of nitrogen in groundwater over 10 mg/1 measured as nitrogen can cause
"blue baby" (see page 89) and, hence, should be measured separately.
With a measured total nitrogen level of 13 mg/1, both the above para-
meters for ammonia and nitrate may have been exceeded, so prompt dilu-
tion would be essential.
Page 68. According to the discussion of "Reliability," over half of
the nation's treatment facilities do not meet EPA's secondary treatment
standards either because of operation and maintenance deficiencies or
design deficiencies. Given this high probability of treatment plant
failure, it is our suggestion that (particularly in the Deschutes
River and North Unit Canal disposal alternatives) the potential impacts
associated with possible failure be fully discussed in order that the
reviewer may understand the range of impacts for each of the alterna-
tives in a comparative manner.
Page 70, paragraph 1. Because correct interpretation of the hydro-
geologic system is crucial to evaluation of the waste-effluent dis-
posal problem, we suggest an additional alternative explanation for
the system described. The system, as described from data obtained
from the Forest Service well, is one that has been encountered during
data collection throughout the Bend-Redmond area, and it appears to
be the normal situation rather than a unique occurrence. Wells com-
monly tap water at some depth in the subsurface, but upon increasing
the depth of the well, the water level in the well decreases in altitude.
This situation of falling water level with increased depth of well pene-
tration is one that characterizes recharge areas in groundwater flow
systems. In reference to the right-hand part of the groundwater flow
diagram (figure 6-2, page 76), the shallow water levels may represent
perched groundwater bodies located above the regional flow system, but
it is doubtful that this is true in most of the cases found in the area.
45
-------
The principal source of recharge causing apparent flow-system anomalies
probably is water lost to the subsurface from irrigation canals and,
more importantly, from excess irrigation water applied to fields during
flood irrigation. Recharge to the subsurface from flood irrigation and
from canals in the heavily irrigated area between Bend and Redmond has
caused a buildup of water levels as irregular ridges and mounds that
cannot be easily contoured and which tend to mask the directions of
local groundwater flow. Irrigation has been practiced in the area since
the early 1900's, but it is not known yet whether this irregular ground-
water mound is continuing to build up.
Page 71, paragraph 4. The last sentence speculates that there probably
is no downward movement from the shallow zone into a deep underlying
artesian aquifer system at the Forest Service well. Evidence already
mentioned, however, suggests that there is a strong vertical downward
component of groundwater flow at the Forest Service well and at other
wells, including the city of Bend supply wells mentioned on page 70,
paragraph 3.
If the alternative explanation of the groundwater1 flow system presented
here is correct in part, it suggests that groundwater flow is much more
complicated than that depicted in the draft statement and that the
directions of movement of effluent in the subsurface probably will be
more difficult to predict than expected.
Page 72, paragraph 5. Sentence 4 implies that lateral movement of ground-
water in the regional groundwater flow system may be small. When evidence
from all wells is considered, it becomes apparent that the regional flow
system is a highly productive water-bearing unit. A few dozen large-
capacity wells have been developed in the Bend-Redmond area during the
past 15 years; most have specific capacities in excess of 50 gallons per
minute per foot of drawdown, and their reported yields range from about
500 to over 5,000 gallons per minute. To our knowledge, in most cases
where the depth of a well has not been a consideration, there have been
few, if any, unsuccessful large-capacity wells drilled in the Bend-
Redmond area. Paragraph 1 on page 80 is a similar type of statement
that probably cannot be substantiated.
Page 78. item 3. The statement that "It is likely that no significant
amount of effluent discharged to the subsurface would enter the deep
artesian aquifer system" is too strong based on evidence at the Forest
Service well, for example, and should be modified to indicate greater
uncertainty.
Page 100. The residual presence of chlorine in the treated waste water
will cause a proble® for both alternatives of discharging to the Deschutes
River or to the North Unit Main Canal since aquatic plants suffer from
chlorine toxicity at levels greater than 0.003 mg/l, which would be ex-
ceeded; hence, dechl°rination of the effluent is necessary.
46
-------
Page 103. The draft statement refers to the adverse aesthetic effects
of effluent disposal in the Deschutes River. The draft statement should
be expanded to include possible impacts to Billy Chinook Reservoir and
Cove Palisades State Park. The reservoir lies downstream of Bend, and
the potential for reduction of water quality exists. Further downstream,
the Deschutes River has been designated as a "State Scenic Waterway."
Any possible impacts on the river at this point should be investigated
and described.
Pages 103-105. Although the document mentions two historic roads cutting
through Site E, as well as "a number of archeological sites containing
cultural material" which occur on Site E, it does not appear that either
full evaluation of the significance of these resources or an assessment
of potential project effects on them has been carried out. It is also
apparent from the discussion that there has been no attempt to identify
and evaluate historic or archeological resources that might be impacted
by:
(1) land disturbance associated with drill hole discharge on
Site E;
(2) infiltration pond and connecting gravity pipeline construc-
tion (see figure 4-1);
(3) forcemain and pumping construction for river discharge (see
figure 4-2);
(4) pipeline canal and evapotranspiration pond construction;
(.5) irrigation system and storage reservoir construction; and
(6) forcemain construction to the North Unit Main canal.
We found no indication in the draft statement that the Oregon State
Historic Preservation Officer has been consulted.
The draft statement should document completed or intended compliance
with 36 DFR 800, as amended (Federal Register, January 30, 1979) in
regard to required consultation with the State Historic Preservation
Officer. These requirements include consultation on: the need for and
type of surveys to identify eligible historic and archeological proper-
ties, survey boundaries, application of National Register criteria to
identified properties, determination of effect of the proposal on
National Register or eligible properties, and other 36 DFR 800.4
procedures if such properties will be affected.
47
-------
Page 115, paragraph 4. Sentence 3 downplays possible vertical movement
in the regional flow system, and also should be modified. This statement
implies the "deep artesian zone" is not hydrologically connected to over-
lying saturated zones. We consider that implication to be false.
Sincerely yours,
V:
Charles S. Polityka f 1
Regional Environmental Officer
48
-------
Response to Comments from the U. S. Department of the Interior,
Office of the Secretary, December 5, 1979
1. The City of Bend will utilize all available sources of
information, including the Geological Survey, in eva-
luating the environmental impacts of interim effluent
disposal via infiltration on underlying groundwater
systems.
2. As a condition of grant funding for an ultimate effluent
disposal method, EPA will require a survey of archeo-
logical and historical resources commensurate with state
and federal regulations.
3. Comment noted. Discharge of effluent to the Deschutes River
has been dropped from consideration as an ultimate method
of effluent disposal.
4. Comments noted. This alternative has been dropped from
consideration as an ultimate method of effluent disposal.
5. In Table A, page 3 of the DEIS, the potential for impacts
on groundwater from disposal of effluent via infiltration
ponds is indicated as a moderately adverse impact.
6. Comments noted. Additional information on the relative
effectiveness of infiltration ponds in providing disin-
fection of effluent should be produced by the interim
effluent disposal monitoring program.
7. Comments noted. These alternatives have been dropped from
consideration as ultimate methods of effluent disposal.
8. Comments noted.
9. Comments noted. If discharge to the North Unit Main
Canal is reevaluated as an ultimate method of effluent
disposal, discharge facilities should include an infil-
tration pond or storage reservoir to accommodate winter
effluent flow and emergency needs.
10. Comments noted. See response to comment #1.
11. Comments noted. Discharge of effluent to the Deschutes
River has been dropped from consideration as an ultimate
method of effluent disposal. If discharge to the North
Unit Main Canal is reevaluated as an ultimate method of
effluent disposal, the impacts of residual chlorine on
aquatic life will be investigated in greater detail.
Impacts could also be mitigated through dechlorination
of the effluent.
49
-------
12. Comment noted. See response to comment #3.
13. Historic roads, as well as any archeological and cultural
resources identified in the project area, were evaluated
with respect to their eligibility for inclusion on the
National Register of Historic Dlaces. One historic road
in the study area, the Meeks Trail, which has been placed
on the National Register, would not be impacted by any
alternative of effluent disposal. A 100% archeological
and historical survey was conducted on the proposed project
site for interim infiltration ponds. No resources were
found to be eligible for inclusion on the National Register.
As a grant condition for funding an ultimate effluent dis-
posal method, the Environmental Protection Agency will
request an appropriate survey of archeological and his-
torical resources for any land area not previously sur-
veyed. The State Historic Preservation Office has and
will be consulted on all archeological/historical in-
vestigations .
14. Comments noted.
50
-------
State of Oregon Aeronautics Division
3040 25th STREET S.E.. SALEM, OREGON 97310 PHONE 378-4880
October 30, 197^CEIVED
r:ov 5 1979
FPA.rrir;
Mr. Roger Mochnick, M/S443
Acting Chief
U.S. Environmental Protection
Agency, Region X
1200 Sixth Avenue
Seattle, WA 98155
Dear Mr. Mochnick:
The Oregon Aeronautics Division and the Department of Transportation
have jointly reviewed the recently published document entitled Sewage
Effluent Disposal for the City of Bend, Oregon and find a significant
omission. The issue of potential collisions of birds and airborne
aircraft has not been discussed. National studies have proven that
water bodies can attract birds which hover at low elevations in the way
of aircraft during take-off or landings. The proposed Sewage Effluent
Disposal area to be located close to Bend's Municipal Airport lies under
the flight path of most aircraft traveling to or from this airport. The
Bend Municipal Airport is considered essential to the State and National
System of airports. We suggest all precautions should be taken to
protect the investment in this valuable facility as well as to ensure
safety of the pilots and general public using it.
It is, therefore, our recommendation that this document be revised to
include the issue of the potential bird strike hazard and an analysis of
mitigation measures available to eliminate the conflict between birds
and aircraft.
Sincerely,
PAUL E. BURKET
Aeronautics Administrator
CS:PEB:seh
51
A DIVISION OF THE DEPARTMENT OF TRANSPORTATION
A MtMBM OP THC NATIONAL ASSOCIATION OP STATI AVIATION OmCIAL*
-------
Response to Comments from the State of Oregon Aeronautics
Division
1. The issue of the potential bird strike hazard related to
use of infiltration or evaporation ponds for effluent
disposal and suggested mitigation measures were discussed
on pages 56, 92 and 95 of the Draft EIS.
It is understood that the Bend Airport expansion will not
be designed to accommodate turbojet aircraft, therefore, any
facilities attracting bird life should not be located within
5,000 feet of the airport runway unless provisions are made to
prevent bird strike hazards (Deirtpsey pers. comm.). No open
water facilities will be located within 5,000 feet of the air-
port runway.
The potential for bird strike hazards in relation to the
infiltration pond facility has been coordinated with the
Deschutes County Planning Department. Aquatic vegetation will
be controlled within the infiltration pond to minimize attrac-
tion of water-associated birds.
52
-------
Advisory lhis respm!e ** rot r«t
-------
Page 2
Mr. Roger K. Mochnick
Sewage Effluent Disposal, City of Bend
November 2, 1979
1. No properties included in or that may be eligible
for inclusion in the National Register 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 the agency has consulted the latest edition
of the National Register (Federal Register, February 6, 1979
and its monthly supplements);
—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.
2. Properties included in or that may be eligible for
inclusion in the National Register 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 statement should contain
evidence of compliance with Section 106 of the National
Historic Preservation Act through the Council's regulations,
"Protection of Historic and Cultural Properties".
Should you have any questions, please call Brit Allan Storey
at (303) 23^-^-9^6, an FTS number.
Sincerely,
Chiefs Western Office
of Review and Compliance
54
-------
Response to Comments from the Advisory Council on Historic
Preservation, November 2, 1979
1. The U. S. Bureau of Land Management (BLM) has negotiated
a land lease with the City of Bend for the site of the
interim infiltration pond. As a part of this process a
100% archeological survey of the project area was conduc-
ted. The survey concluded that there were no archeological
or historical sites eligible for inclusion in the National
Register of Historic Places on the proposed project site.
The State Historic Preservation Office (SHPO) has concurred
with this conclusion.
When an ultimate effluent disposal option is chosen,
a professional archeologist will conduct an archeological
and historical survey of the proposed disposal site as a
condition of grant funding by EPA.
55
-------
mm wmm ©ww
60813 PARRELL ROAD
BEND, OREGON 97701
TELEPHONE (503) 382-5342
December 4, 1979
Avion Water Company, Inc. Concern and Comments Regarding
Sewage Effluent Disposal for the City of Bend, Oregon.
Avion Water Company is very concerned about the method of sewage
effluent disposal to be employed by the City of Bend, since underground
water contamination could adversely affect over 3»100 Avion Water Company
household customers.
Avion Water Company, in the event of contamination, would hold
liable all parties involved for:
1. The public health of Avion's customers.
2. The expense of interim service to provide safe drinking water.
3. The cost of developing new sources.
4. Any additional operating expenses resultant from contamination;
for example, any required additional pumping depth and sizing, and the
additional replacement cost of oversizing equipment to compensate for
the afepth.
5. Any operating loss nnd any loss of profit to Avion stockholders.
AVION WATER COMPANY, INC
Paul C. Ramsay
President
PCR:em
56
-------
Response to Comments from the Avion Water Company, December 4,
1979
1. Comments noted.
57
-------
r
LEAGUE of WOMEN VOTERS of DESCHUTES COUNTY
December 1979
League of Women Voters
of Deschutes County
P.O. Box 6^53
Bend, Oregon
EPA Hearing on the Draft EIS for Sewage Effluent Disposal For The City Of Bend, Oregon
The League Of Women Voters of Deschutes County, after reviewing
the EPA Environmental Impact Study concerning sewage disposal for the
City of Bend, supports the use of Evapotranspiration Ponds or Land Appli-
cation by Spray Irrigation as acceptable alternatives. We do not support
the use of drill holes.
We favor the Evapotranspiration Ponds used as a treatment process
as the preferred method. The three factors leading to this choice were
the mitigation measures which are specific and obtainable, the treatment
reliability of this alternative, and that it is a year round system.
The user costs initially look higher than the other methods; however,
we urge that the Evapotranspiration Ponds be considered for additional
funding as suggested in the EIS because of possible qualification as
"innovative or alternative technologies". League feels that the wetlands
created through the Evpaotranspiration Ponds alternative would create a
habitat type near Bend that currently does not exist in comparable acfceage.
League also feels it fits in with the environmental nature of the community.
The Land Application by Spray Irrigation, alternative is our second
choice. To reuse treated water in a productive manner is certainly prefer-
able to any irretreviable disposal method. We feel that adequate health
and sanitary standards will be maintained if used with the DEQ proposed
policy for land irrigation aid disposal of treated sewage as outlined in
the BIS.
We do not support the use of subsurface disposal via drill holes.
There are unknown factors involved that do not begin to guarentee safe
Received
0 1979
rp
BEND, OREGON 97701
-------
health standards* The most significant of these i3 the groundwater contamin-
ation potential. Although this alternative is much leas costly to the user
now, it could become the most costly in the long run if we have to start
cleaning up the water later.
We urge the adoption of the Evapotranspiration Ponds as Bend's
treatment method. The League feels this best fits the needs and desires
of our community.
V X W;/1! ^
Ann Flree, President
59
-------
Response to Comments from the League of r„Tomen Voters of Deschutes
County, December 4, 1979.
1. Comments noted.
60
-------
December 4, 1979
Environmental Protection Agency,
Hearing in Bend High School, in C Hall.
Jefferson County Pomona Grange #32, voted to send a letter to this
meeting in protest to putting the sewer effuenet into the North Unit
Irrigation Canal.
Pomona Grange represents three granges, and has over 150 members.
Haystack Grange and Mud Springs Grange are in the North Unit Irrigation
project.
It seems unreasonable for this meeting to be in the City of Bend. The
people of North Unit Irrigation live in Jefferson County, and no direct
publication was issued.
North Unit Irrigation is not the dumping ground for Bend, Oregon.
DEQ Policy has been to allow pasture grass raised with this effluent of
sewer ponds. North Unit would be ruined for raising potatoes, wheat,
and mint.
Where is the Environmental Protection Agency Impact Study on putting the
iffluent in North Unit Irrigation District.
Maste
N
61
-------
Response to Comments from the Jefferson County Pomona Grange
#32, December 4, 1979
1. Although effluent disposal to the North Unit Main Canal
(NUMC) is considered by the Environmental Protection
Agency to be the environmentally preferred alternative,
it is recognized that canal disposal is not feasible at
this time due to concerns raised in your letter as well
as by the North Unit Irrigation District and others. As
an interim measure, the Environmental Protection Agency
has selected the infiltration pond alternative for
effluent disposal. Monitoring wells will be constructed
in conjunction with this disposal option. Information
from these wells will assist the City of Bend in deter-
mining the impacts of infiltration on groundwater. In
the event that infiltration is found to be unsafe en-
vironmentally as an ultimate disposal option, the other
disposal methods will be reevaluated.
62
-------
Alternative FUTURES Tigard
AMEP.CAN INSTITUTE OF ARCHITECTS
Peruana Chapter
AMERICAN SOCIETY Or LANDSCAPE
ARCHITECTS
Oregon Cnaotrr
ASSOCIATION OP nopthwest steelhe aoers
ASSOCIATION OF OREGON RECYCLERS
AiJDubON SOC/ETV
C«n»'f» Oreoor, Ccvd! '3 Poniard. Salem
6A-. /.HEA ENVIRONMENTAL COUNCIL
Coos 8a f
bring
CENTRAL CASCADES CONSERVATION COUNCIL
CHfcMEKETANS Sa-em
CITIZENS FOR A BETTER GOVERNMENT
Cl WENS FOP A CLE.AN ENVIRONMENT
CLATSOP ENVIRONMENTAL COUNCIL
CONCERNED COZENS FOR AlR PURITY
Eugene
OEPENO£RS OF WJLOHFE
ECO ALLIANCE Guivaiiis
ENVIRONMENTAL ACTlON CLUB
Parkrose Htgn School
EUGENE FUTURE POWER COMMITTEE
EUGENE NATURAL HISTORY SOCiETY
GARDEN CluQS c( Ce<2ar m,h Co^aiM.
f/cM'^r Ne'iai©ni Bay Sc^ppooso
GRANT COUNTY CONSERVA hONISTS
HE A L.. A^aiea
LANO AIR. WATER Eugene
-E AGUE OF WOMEN VOTERS
Cfc'Vfai Lar.e C«>cs County
McKE NZiE GUARDIANS Blue River
NOftTM/.fST TNVlRONMENTAL DEFENSE
CENTER
OBSIDIANS Eurjone
1 CiOC F RiENDS OF OREGON
OREGON ASSOCIATION OF RAH WAY
PASSENGERS
OREGON BASS AND PANFlCH CLUB
OPf OONIANS COOPERATING TO PROTECT
WHALES
OREGON Ff OERation OF GARDEN CLUBS
OREGON GUIDES ANDPACKERS
OREGON high DESERT STUDYGROUP
OREGON LUNG ASSOCIATION
Port i and Saiem
OREGON NORDIC CLUB
OREGON NURSES ASSOCIATION
OREGON PARK & RECREATION SOCIETY
Eugena
OREGON ROADSIDE COUNCIL
OREGON SHORES CONSERVATION COALITION
OSPIRG
PLANNED PARENTHOOD ASSOCIATION INC
Portland
PORTLAND ADVOCATES OF WHOE»i«£33
PORTLAND PECYCUNG TEAM. INC
Pr.CREATiONAL EQUIPMENT. INC
SANTIAM ALPINE CLUB
SaieTi
SIERRA CLUB
Oregon Chapter
Co'urrb>a Group Pcriiand
Kiamair-Grojp K:ama»h Fans
Many River# Group. Eugene
Ma'y s Pf-ak Group C"rvdll»s
Mt jt;Mer$on Group. Salem
Rt-cjue Valley Group Ashland
SOLV
SPENCER BUTTE IMPROVEMENT ASSOCIATION
STEAMBOATERS
SURViVALCENTER
University o< Oregon
THE TOWN FORUM INC
Collage Grove
TRAILS CLUD OF OREGON
UMPOUA WILDERNESS DEFENDERS
WESTERN RlVEH GuJDES ASSOCIATION. 1NC
WICLAME rTE nlVER GREEN WAY ASSOCIATION
1
RECEIVED
DEC 1 0 1979
OREGON ENVIRONMENTAL COUNCIL
2637 S W WATER AVENUE. PORTLAND. OHEC.ON 97201 / PHONE £03/222- 1C63
December 7, 1979
To: Roger Mochnick, M/S 44 3
Acting Chief
U.S. Environmental Protection Agency,
Region X
1200 Sixth Avenue
Seattle, Wash. 98101
From: Bruce Merrick for Oregon Environmental Council
In compliance with your request concerning the Draft
EIS-SEwage Effluent Disposal for the City of Bend,
Oregon, The Oregon Environmental Council submits the
following comments and suggestions for your consideration:
All of the alternatives listed in the Draft EIS
involve:
a)Significant to moderate environmental impact;
b)Significant cost to taxpayers and residents;
c)Significant energy consumption.
We realize the "No Action Alternative" is out of
the question. Therefore we would like to comment as
follows:
1)Subsurface disposal.
Comment
This alternative definitely is hazardous with
no consideration to future generations.
2)Discharge to the Deschutes River
Comment
This alternative would require the effluent to
meet drinking water standardsas the water will be used
for human consumption for municipal water supplies for
Madras and Redmond, by fishermen and recreationalists.
3)Discharge to Evaporation Ponds
Comment
This alternative will result in stagnation of
land and soil pollution. It makes no attempt to re-
cycle water and creates a possible health hazard due
to airborne bacteria.
4)Land Application via Spray Irrigation
Comment
With the establishment of a broad enough base,
this alternative can make use of the water but still
presents a possible health hazard. It is also a very
costly alternative.
63
-------
OEC - Bend Sewage Draft EIS -2-
5)Establishment of Wildlife Marsh Area
Comment
Good intentions, but aside from aesthetics there is no': real
advantage over the other alternatives. No direct profit from water
recycling. A large lanci area is involved. There are possible health
hazards again,though the hazards are remote if filtration is used.
General Comments
The study does not single out any one Alternative as being more
advantageous than any one of the others. Therefore OEC suggests
the following:
1)Sewage should be treated with active anaerobic digestion,
generating methane.
2)Solids should be removed by settling^ana filtration. Effluent
may then be distilled at 400 F in an efficient system (i.e. in-
coming effluent used as a condensatejin an evaporator of sufficient
capacity, the system being insulated to minimize heat^ loss.)
Evaporation may be accomplished with the aid of solar and methane
heat. The condensate may then be mildly chlorinated, monitored, and
released to the North Unit Irrigation Canal (summer) and to the Des-
chutes River (winter).
3)All removed solids might then be sold to the agriculture
fertilizer industry to help defray costs oft,the sewage treatment
system.
4)As there are efficient solar stills in operation, producing
safe drinking water from sea water at. Rocky Point in Baja, Calif.,
and in Saudi Arabia,this technology may be applied' to effluent
treatment. Such treatment would provide for two valuable resources
while using the sewage efficiently.
64
-------
Response to Comments from the Oregon Environmental Council,
December 7, 1979
1. Comments noted.
2. The Environmental Protection Agency has approved interim
disposal of effluent via infiltration ponds. An ultimate
disposal option has not been selected at this time.
65
-------
Executive Department
INTERGOVERNMENTAL RELATIONS DIVISION
ROOM 306, STATE LIBRARY BLDG., SALEM, OREGON 97310
December 7, 19 79
RECEIVED
r-12 1979
rp <\ r-tr*
Roger Mochnick, M/S 44 3
Acting Chief
U.S. Environmental Protection Agency
Region 1
120 0 Sixth Avenue
Seattle, WA. 9 8101
SEWAGE EFFLUENT DISPOSAL FOR BEND, OREGON
PNRS 7910 4 540
Thank you for submitting your draft Environmental Impact
Statement for State of Oregon review and comment.
Your draft was referred to the appropriate state agencies.
The Departxnents of Land Conservation and Development, Fish
and Wildlife offered the enclosed comments which should be
adressed in preparation of your final Environmental Impact
Statement.
We will expect to receive copies of the final statements
as required by Council of Environmental Quality Guidelines.
a tor
KW: cb
Enclosures
66
AN EQUAL OPPORTUNITY EMPLOYER
-------
OREGON PROJECT NOTIFICATION AND REVIEW SYSTEM
STATE CLEARINGHOUSE
Intergovernmental Relations Division
306 State Library Building, Salem, Oregont 97310
Phone Number: 378-3732
P-NJLS 5LT.JL I J. 1 R V If.
Project >': , . . Rnturn llnte:
ENVIRONMENTAL IMPACT REVIEW PROCEDURES
If you cannot respond by the above return date, please
call to arrange an extension at least one week prior to the
review date.
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( ) This project has no significant environmental impact.
(X ) The environmental impact is adequately described.
( ) We suggest that the following points be considered in the
preparation of a Final Environmental Impact Statement.
( ) No comment.
Remarks
Agency ^ ^ ^ A . V W v ^ By >u
rf 7/,.. jL
67 Cental management section 11/29/79
-------
PNRS 7910-4-540
The Oregon Department of Fish and Wildlife has reviewed the sewage effluent
disposal for the City of Rend, Oregon, draft environmental statement, and
has the following comments.
The draft discusses several alternatives for effluent discharge. The
department's preferred alternative would be the development of a series
of sealed ponds that would provide enhanced wildlife habitat. We
recognize, however, that the excessive cost estimates for this proposal
are beyond the available funding limits.
The department also favors development of infiltration ponds. Some
changes in wildlife use would be expected from this proposal; however,
the changes are regarded as beneficial.
Discharge of effluent into the Deschutes River is unacceptable. During
the low flow period, nutrient levels in the discharge could cause
growth of undesirable quantities of algae or other aquatic vegetation
in the river. Discharge of effluent into the North Unit Canal is not
an acceptable alternative. Summer discharge would add additional
nutrients, which have an impact on water quality in haystack Reservoir.
Water quality problems have previously been noted in Haystack Reservoir,
where nuisance algae blooms and low dissolved oxygen levels have Impacted
fish production. Additional nutrients added to this:impoundment would
aggravate the existing problems.
Subsurface disposal of effluent into drilled disposaj wells has no
identified adverse impact on fish and wildlife. Theiuncertainty of
the ultimate disposition of this material would make,this alternative
questionable.
Land application by spray irrigation would commit large quantities of
land to a single use. This development would have some adverse impacts
on existing wildlife populations.
-------
Response to Comments from the Oregon Department of Fish and
Wildlife, November 23, 1979
1. Comments noted.
69
-------
OREGON PROJECT NOTIFICATIO*" AND REVIEW SYSTEM
STATE CLEARINGHOUSE ? ° ,'L
PFPAF; "-'i r;F . . - '
.lAi ,, , . intergovernmental Relations Division
AMD DuUXO^QM'tate Library Building, Salem, Oregon, 97310
Phone Number: 378-3732
/
• • i
-• *»
. i
rv v.
I J . • '
P_.N...R s c. T.A J !' R F .VJ.f. w
r
Projrect >• f J -I Return Date:
"av,r'Vi
ENVIRONMENTAL IMPACT REVIEW PROCEDURES
If you cannot respond by the above return date, please
call to arrange an extension at least one week prior to the
review date.
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( ) This project has no significant environmental impact.
( ) The environmental impact is adequately described.
( X) We suggest that the following points be considered in the
preparation of a Final Environmental Impact Statement.
( ) No comment.
Remarks
The EIS report did an adequate job of identifying the six alternatives
for sewage afluent disposal for the City of Bend. Before a final
alternative is selected it must be compared with the Deschutes County
Comprehensive Plan to ensure that the alternative is in compliance
with their comprehensive plan. Any discussion of adoption of a
final alternative should be closely coordinated with the Deschutes
County Board of Commissioners.
Agency S~
70
-------
Response to Comments from the Oregon State Land Conservation and
Development Commission, November 23, 1979
1. The proposed site plan for interim effluent disposal via
infiltration ponds was reviewed by the Deschutes County
Planning Department and County Board of Commissioners.
They concluded that the site plan was generally consistent
with the Deschutes County Year 2000 Comprehensive Plan.
Complete approval of the project was granted by Deschutes
County, subject to a number of conditions. Selection of an
ultimate disposal method, whether it is an expansion of the
infiltration pond or a new alternative, will be subject to
the County's Site Plan Review process.
71
-------
CITY OF REDMOND
DESCHUTES COUNTY, OREGON 4 = s south seventh street
PHONE 548-2140
REDMOND. OREGON 97756
December 5, 19 79
Mr. Roger K. Nbchniok, EIS Coordinator ^ECPM/c-
Environmental Evaluation Branch ^ Vc&
Environmental Protection Agency 1 1 in
1200 Sixth Avenue, M/S 443 >97i
Seattle, WA 98101 rn'
Dear Roger:
I was very nuch impressed with the hearing on the Environmental Impact
Statement concerning the sever effluent disposal for the City of Bend, which
was held at the Bend High School on Decerrber 4, 1979.
I further thought that all of the questions relevant to the issue were
answered. Under the circumstances, I appreciated the fact that the hearings
officer allowed considerable latitude for discussion of issues not immediately
related to the subject.
I would like very nuch to have the following statement included in the
official record as the postion of the City of Redmond on this matter.
THE FOLLOWING IS THE PRESENT POSITION OF THE CITY OF REDMOND
CONCERNING THE METHOD OF SEWER EFFLUENT DISPOSAL FROM THE
TREATMENT PLANT NOW BEING CONSTRUCTED BY THE CITY OF BEND.
While the City of Redmcnd enthusiastically supports the Bend sewer project,
it is also very concerned about the continued purity of the water supply in
Central Oregon. 1tie City of Redmcnd is, therefore, strongly opposed to any
permanent system of treated sewage effluent disposal which is designed to
introduce into the earth or into the Deschutes River upstream of the City of
Redmcnd's water collection points, any voter which does not neet State and
Federal standards for drinkabilitv.
The City is not opposed to the City of Bend's proposal for tenporary
percolating/evaporating ponds, so long as they are reviewed within three years.
We do oppose any system of disposing of untreated sewage into individual dry
walls.
The City of Redmcnd has no preference among the other alternative
permanent methods of sewage effluent disposal which do not violate the above
criteria.
Sincerely,
SSJ:lj
72
-------
Response to Comments from the City of Redmond, December 5y 1979
1. Comments noted.
73
-------
Water Resources Department
MILL CREEK OFFICE PARK
555 13th STREET N.E., SALEM, OREGON 97310
PHONE 378-845 5
TO:
FROM:
Roger K. Mochnick
Environmental Protection Agency
DATE:
December 7, 1979
Kent Mathiot
¦ (
-f 111 rtf-;: s
SUBJECT: Bend Effluent Disposal Project.
We have reviewed the draft environmental statement on the sewage
effluent disposal project for the City of Bend, and are submitting
the following comments for your consideration.
The report presents an adequate general description of each of the
disposal options under consideration. However, the information
contained in the report does not provide answers to many of the
basic environmental protection questions associated with the
disposal project, and additional work needs to be carried out
before an ultimate disposal method is selected.
Especially lacking is quantitative information to support the
statements on the hydrogeologic characteristics of the study
area. Specifically, additional information is needed to support
statements concerning'(1) the lateral extent and susceptibility
to contamination of the deeper "artesian" aquifer, (2) the
suggested low productivity of the regional aquifer, (3) the
ground water flow direction in the immediate area of the
disposal site, and (4) the location, production capabilities,
and hydrogeologic characteristics of any perched aquifers
near the disposal site. The need for this additional infor-
mation is supported by several statements in the draft report
that address the lack of existing detailed hydrogeologic
information, and stress the potential variability of hydro-
geologic conditions from site to site.
The information presented on the infiltration and percolation
characteristics of the soil materials at the proposed evapo-
percolation pond site is encouraging, and was evidently
developed through actual testing at the proposed site. This
preliminary data should be expanded by providing additional
detailed information on the lateral extent, thickness,
textural characteristics, and cation exchange capacity of
the soil materials in the disposal area. Such information
is necessary to properly evaluate the evapo-percolation
option. Similar effluent treatment capability information
should be developed for the various sedimentary interflow
deposits.
74
-------
-2-
The draft statement should be accepted as the environmental
statement for an interim disposal program. The interim
permit should be issued only if an evapo-percolation system
is used, and then, only if surface materials at the disposal
site are not removed and the underlying basalts are not
artificially fractured.
Funding should be provided to support additional research into
the subsurface and wildlife habitat disposal options. This
research should concentrate on methods of lowering the cost
of the wildlife habitat option, and on obtaining the above
mentioned information necessary for evaluation the various
subsurface disposal proposals. Any subsurface disposal
program chosen as an ultimate disposal method should utilize
the natural treatment characteristics of the soil and
underlying sedimentary materials, and maximize the separation
distance between the lowest point of the disposal zone and
the underlying water table. This additional research should
also consider options involving combinations of evaporation
and evapo-percolation systems.
cla
75
-------
Response to Comments from the Oregon State Water Resources
Department, December 7, 1979
1. A document entitled Design Definition Memorandum No. 11,
Subsurface Effluent Disposal Feasibility Investigation
prepared by Bend Engineering Consultants (December 1979)
provides additional quantitative information regarding
hydrogeologic and soil characteristics of the study area.
EPA has stated, however, that they would approve interim
and/or ultimate use of a drill hole only if it was found
to be environmentally acceptable in the Draft EIS and
if no other method of disposal was available.
Subsurface effluent disposal by infiltration, as described
in Chapter 3 of this document, will allow effluent to
percolate through 3-5 feet of soil before entering the
subsurface. A monitoring well system will be established
to document movement of the effluent plume and determine
groundwater quality.
2. Comments noted.
76
-------
LAW OFFICES
RODRIGUEZ, GLENN & WILKINSON
Sumner C. Rodriguez
David C. Glenn
Douglas R. Wilkinson
Edward E. Sites
406 Sth Street
Madras, Oregon 97741
Telephone 475-2272
Area Code 503
December 10, 1979
RECEIVED
12 J 979
P~ri ^. r->«
Roger Mochnick, M/S 443
Acting Chief
U. S. Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington 98101
Re: Comments on Draft Environmental Statement.
Dear Mr. Mochnick:
I am forwarding you a copy of the letter which I have sent to the City of Bend in
respect to the proposal for the North Unit Canal. Please consider this as comments
on the Environmental Impact Statement and include it in your records for the review
and comment period.
Douglas R. Wilkinson
DHW/af
enc.
cc: Bob Wagner
North Unit Irrigation District
Sincerely
77
-------
LAW OFFICES
RODRIGUEZ, GLENN & WILKINSON
406 5th Street
Sumner C Rodriauez Madras. Oregon 97741 Telephone 4lb 2212
aumner u Moonguez Area Code bl)3
David C. Glenn
Douglas R. Wilkinson
Edward E. Sites
December 10, 1979
-thur R. Johnson
Ci t^Manager
City mNBend
p. 0. BoxMJl
Bend, OregonS^701
Re: Interim Effluent Disposal of Treated Water
from the City of Bend, Oregon to the North
Unit Irrigation District Canal near Bend, Oregon.
Dear Art:
The North Unit Irrigation District Board of Directors is adamantly opposed to the dumping
of Effluent into the North Unit Canal on an interim basis. There arc numerous problems
which are insurmountable before the summer of 1980 when the City of Bend sewer project is
supposed to be on line.
The following is a list of some of the problems that have been brought up by the Board,
however it is not intended to be all inclusive. A proposal to dump effluent in the North
Unit canal will require careful study and I am sure there will be more problems that show
up.
1 There is a problem of increased servitude on the land over which the district's
laments run. Arguably in the summer the effluent could be ronsidered i r r.
-------
Arthur O. Johnson
December 10, 1979
page 2
4. As you are well aware, there have been many instances when there have been
failures of treatment facilities along the Willamette River and untreated
sewage has been discharged to the river. No one has been able to adequately
explain how the City of Bend will be able to insure their system will never
fail.
5. The increased weed problem has been addressed, but the effects of the nitrates
on the present herbicide is really unknown. Charles Kissel of Magna Corp.
has indicated to the Board that the nitrates that would be in the treated
effluent could work on a catalytic level in causing the herbicide to dissipate.
If this were to occur then more herbicide would be required and there is a
chance that amounts in excess of 15 p.p.m. may be required to control the
increased weed problem.
6. Along the same lines Mr. Kissel indicated there may also be a problem with
sulfates that could cause damage to pumps and piping in the way of increased
corrosion. This matter also .apparently lias not been studied.
7. The Board is especially concerned about the organochlorides that arc created
in the treatment process. These chemicals are toxic and do not dissipate.
Because the water will be used on some food crops there is a possibility that
they could become a part of the food chain much as D. D. T.
8. At present there is a potential for low head hydro projects on the main canal
at the Crooked River. This would mean water would be diverted year around
and in the winter months it would be dumped directly to the Crooked River
after going through the turbine. This would mean that the effluent would be
going directly into a river. It is the Boards, understanding that E. P. A. has
a policy that would not allow the effluent to be dumped into the Deschutes River
and this merely would be an avoidance device with respect to that policy.
9. Until such project is in operation the canal would not have water diverted in
it during the winter. There are problems of ice and increased maintenance
on the canal that would be caused from this, but the main problem is what effect
would this have in concentrating chemicals along the floor of the canal. It
appears they might become quite concentrated and when the first water comes
through in the spring there would be a very heavy concentration of those chemicals
flushed through the whole system.
10. Another problem that involves the winter discharge is the potential sub-surfac6
contamination. As you know there is extensive loss in the floor of the main
canal and by allowing it to run some 8 miles down the canal before it goes into
the ground appears to be just bringing the effluent that much closer to Jefferson
County and creating a potential for contaminating the Deschutes Valley Water
District's source at Opal Springs.
11. The phycological effect on food crops is virtually unknown. There is great
concern by the District of a P. c. B. scare or a Cranberry scare. If such a
thing were to happen it could have a devastating effect on the Jefferson County
economy and it is doubtful that any liability insurance would cover any damages.
It is unclear how you can educate the public concerning the effluent, to prevent
this.
12 At full capacity the discharge of the treatment plant will only provide a
negligible increase to the irrigating capabilities of the District. Accordingly
allowing effluent to be dumped in the canal it would appear that the district
is receiving no benefits only a lot of problems.
79
-------
Arthur O. Johnson
December 10, 1979
paqv 5
As I indicated above, this list is not all inclusive, as one studies the; proposal, one-
becomes aware of more problems. Accordingly the Board wants to make it clear that undiar
no circumstances will they consider allowing effluent to be placed in the canal durinq
1980. At the present time the Board feels that the above problems nr<> of hucIi maqni t u
-------
Response to Comments from Rodriguez, Glenn and Wilkinson, Law
Offices, December 10, 1979
1. Comments noted.
81
-------
United States
Department otf
Agriculture
Soil
Conservation
Service
1220 s.w. Third Avenue
16th Floor
Portland, Oregon 97204
December 12, 1979
Mr. Roger Mochnick, M/S 443
KcCEIVED
1 •' 1979
Acting Chief r^/.
U. S. Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
The Soil Conservation Service has reviewed the Draft Environmental Impact
Statement, Sewage Effluent Disposal for the City of Bend, Oregon. We offer
the following comments:
Page 20 - Range and Endangered or Threatened Species. Are there any
threatened or endangered plant species that wDuld be effected by the
alternatives.
Also, the EIS should state if any prime agricultural land, wetlands,
or flood plains are effected by the alternatives.
We appreciate the opportunity to review and comment on this draft.
Sincerely,
GUY WC NUTT
State Conservationist
cc:
Administrator, SCS, USDA, Washington, D.C. 20013
82
-------
Response to Comments from the U. S. Department of Agriculture,
Soil Conservation Service, December 12, 1979
1. No rare and endangered or threatened plant species were
found in the project area.
2. No prime agricultural land, wetlands or floodplains would
be impacted by any of the DEIS alternatives, including
interim disposal of effluent by infiltration.
83
-------
VICTOR ATIYEH
GOVFRNOR
Department of Environmental Quality
522 SOUTHWEST 5TH AVE. PORTLAND, OREGON
MAILING ADDRESS: P.O. BOX 1760, PORTLAND, OREGON 97207
December 7, 1979
Mr. Roger K. Mochnick, EIS Coordinator
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue, M/S 443
Seattle, WA 98101
"r *" 1 -
1 < 19/9
TP'N r-,_
Dear Mr. Mochnick:
The Department of Environmental Quality has the following comments on the
draft EIS for Sewage Effluent Disposal for the city of Bend, Oregon:
1. These first comments are editorial in nature:
a. Page 1, third line; change Disinfection to Disinfected.
b. Page 1, third paragraph, second sentence; add the phrase "for
disposal of raw sewage" between wells and after.
c. Page 28, paragraph 1; Rimrock West is a community sewerage system
which has been omitted.
d. Page 30, third paragraph intimates that present sewage treatment
plant does not provide secondary treatment. That, of course,
is wrong.
e. Page 40, paragraph entitled Year-round Drill Hole Disposal.
Here the proposed treatment level is called secondary but what
the report describes is more than secondary. It should be called
advanced secondary or tertiary.
f. Page 57, fourth paragraph; states that Oregon must develop a
UIC program. That is not true. EPA can develop one if the state
elects not to.
g. Page 59, paragraph entitled Permit Requirements should indicate
that Oregon administers the NPDES program in Oregon, not EPA.
h. Page 68, Reliability. The report compares the proposed treatment
plant to other secondary treatment facilities when indeed the
proposed plant is more than secondary and therefore would be
much more reliable.
84
-------
Mr. Roger K. Mochnick
December 7, 1979
Page 2
i. Page 82, second paragraph; OAR-44-045 was recently modified.
j. Page 83, first paragraph; last sentence should include
filtration in the definition of Redmond's water system.
k. Page 85; fourth paragraph should include filtration as a unit
process in the Madras water treatment process.
2. The remaining comments are philosophical or technical:
a. On page 88, paragraph 5; the report declares that effluent going
to the North Unit Canal would cause Haystack Reservoir to become
eutrophic. Isn't Haystack Reservoir already eutrophic?
Where is the basis of scientific fact? What percentage increase
in phosphorus would occur? How does this compare with Crooked
River water currently pumped into the canal? We feel the authors
need to do more homework on this item.
b. On page 99, paragraph 4, and page 100, paragraph 4; the report
refers to a fishery in the North Unit Canal. There may be some
fish that get through the screens and take up residence in the
canal but there is no recognized fishery.
c. On page 98; the report identifies nitrates as a possible health
hazard to Madras residents if effluent goes to the canal. What
concentrations of nitrates will occur? What percentage increase
will that be over existing levels? How does that compare with
drinking water standards?
d. On page 99,, last paragraph; the report discusses deleterious
increases in ammonia if discharged to the Deschutes. What
magnitude of increase is anticipated? Where are the facts?
e. On page 100, last paragraph; the report again tells of
accelerated eutrophication of Haystack Reservoir. The report
should contain analytical data and be more factual if it is going
to contain such statements.
f. On page 111, fourth paragraph; the report includes an estimate
from the Bureau of Reclamation that Bend effluent would double
or triple the aquatic weed control problem in the canal. Without
some scientific basis to back up such a statement, it should
not be in the report.
g. On page 113, third paragraph; the report stated that if effluent
were discharged to the Deschutes River domestic use could be
prohibited. That is a bold statement to make without any
technical data to back it up.
85
-------
Mr. Roger K. Mochnick
December 7, 1979
Page 3
h. On page 115, last paragraph; the report states that nitrate
removal would be necessary if discharge was to the Deschutes
River. Where is the data?
i. On page 116, last paragraph; the report suggests that advanced
waste treatment should proceed land irrigation. That is not
normally true, especially in an area as remote as the proposed
plant site.
j. On page 117, paragraphs 4 and 5; the report discusses mitigation
of public health risks associated with sewage effluent in the
canal. The risks are blown out of proportion.
The report should recognize the sewage effluent as a resource rather than
strictly a public health hazard. The Department predicts that regardless
of what disposal method is initially used, eventually it will be put to
beneficial use, especially during summer months.
We agree with the premise that the potential for groundwater contamination
is greatest with continued use of raw sewage drain holes; therefore, it
would seem appropriate for the report to state that regardless of what
ultimate disposal means is finally adopted, it should not preclude the
use of interim temporary subsurface disposal until ultimate disposal can
be implemented.
Thank you for the opportunity to review the draft EIS.
Sincerely,
William H. Young
Director
CKA:le
WL0312
86
-------
Response to Comments from the Oregon State Department of
Environmental Quality, December 1, 1979
1. Comment noted. Revisions were made in the FEIS where
appropriate.
2. Comments noted. If discharge to the North Unit Main
Canal is reevaluated as an ultimate method of effluent
disposal, a more complete analysis of water quality,
canal maintenance, and public health impacts will be
required by EPA.
3. Comments noted. Discharge of effluent to the Deschutes
River has been dropped from consideration as an ultimate
method of effluent disposal.
4. See Response to Comment #2.
5. See Response to Comment #3.
6. Land application of effluent via spray irrigation has been
dropped from consideration as an ultimate method of
effluent disposal.
7. See response to comment #2.
8. Comments noted.
87
-------
Public Hearing Summary
On December 4, 1979, the Environmental Protection Agency
held a public hearing on the draft Environmental Impact
Statement (EIS) concerning sewage effluent disposal for the
City of Bend, Oregon. Due to the costs involved, the public
hearing record was not reproduced for this final EIS. A
summary of the hearing is provided below, however, and a table
has been prepared listing the speakers and their specific areas
of concern (Table 4-2).
Representing EPA at the hearing were: Brian Hansen,
Hearing Officer; Roger Mochnick, Project Officer; Norm
Sievertson, Chief of Grant Operations; William Sobolewski,
Project Engineer; and Dr. Charles Hazel, EIS consultant of
Jones & Stokes Associates.
Bill Sobolewski and Charles Hazel commenced the meeting
with a brief discussion of the project's history, the alterna-
tive methods of sewage effluent disposal, and the environmental
impacts associated with the alternatives. Public testimony
followed the presentations, with approximately nine people
participating. Following is a summary of their remarks:
Richard Carlson, the Mayor of Bend, discussed the City's
request for the EPA's approval and funding of an interim method
of effluent disposal due to the delays in selecting an ultimate
method of disposal.
Ted Fies, of the Oregon Department of Fish and Wildlife,
stated that the department's preferred alternative is the
development of a series of sealed ponds that would enhance
wildlife habitat, although they realize that the costs
associated with this alternative are prohibitive. The
department finds the discharge of effluent into both the
Deschutes River and the North Unit Irrigation Canal unaccept-
able, as the resulting increase in nutrients is conducive to
nuisance algae blooms.
Nels M. Hansen, the Mayor of Metolius, expressed concern that
subsurface disposal had received any consideration in the EIS
due to the potential impacts it could have on the potable water
supply in the area.
Ted Matylinski, President of Metolius City Council,
remarked that if effluent was discharged into the North Unit
Irrigation Canal, the excess effluent not used for irrigation
would flow into the Deschutes River and adversely impact the
quality of fishing. He suggested using the excess effluent
for domestic uses, such as watering lawns.
88
-------
Sam Johnson/ Mayor of Redmond, stated that the City of
Redmond is concerned about water quality and is supportive of
the sewer project, but strongly opposes the discharge of
effluent into the earth or the Deschutes River.
Doug Wilkinson, Legal Counsel for the North Unit Irrigation
District (NUID), stated that the North Unit Board remains
opposed to the discharge of effluent into the canal. Mr.
Wilkinson also briefly discussed the legal and technical prob-
lems associated with discharging effluent into the canal. His
main legal concerns centered on whether or not the canal's
current status as a non-point source pollutant would change if
effluent was discharged into it, and if so, when would the NUID
be required to obtain a discharge permit? Also of concern is
the fact that the portions of land occupied by the canal are in
fee title to the United States and a great majority of it is
also easements, which could have legal ramifications if effluent
is discharged into the canal. He also expressed concern that
organo-chlorides and organomines (by-products of the chlorine
used to treat sewage) could have potential adverse impacts on
crops in the Bend area.
Paul Ramsay, President, Avion Water Company, stated that
the Avion Water Company is concerned about the method of
effluent disposal the City will be employing due to the
potential adverse impacts some methods may have on groundwater
quality. He also remarked that in the event groundwater
becomes contaminated as a result of the disposal method used
by the Bend treatment plant, Avion Water Company would hold
liable all parties involved in the licensing and operation of
the plant. These parties would be held responsible for the
public health of Avion's customers, the expense of interim
service to provide safe drinking water, and the cost of
developing new sources.
Arthur Sykes, representing the Pomona Grange of Jefferson
County, stated that Pomona's three granges oppose discharging
effluent into the canal and the Deschutes River and recommended
that the COI, be considered as a method of effluent disposal.
Gordon Priday stated that he is supportive of the Bend
sewer project and prefers the filter pond alternative. He
considers effluent a valuable resource and opposes disposal
methods such as drill holes, that eliminate the opportunity to
reclaim the water.
89
-------
Table 4-2. Summary of Public Hearing Testimony
for the City of Bend Draft EIS
\D
o
CO
U
H
E-<
IS
H
w
o
K
Pm
H
Eh
H
>H
EH
CO
EH
Pd
«c
w
Q
H
W
<
Eh
<
co
t—l
J
H
N
H
w
H
w
<
p-l
2
!Z
Cfl
2
£
>
ff)
Eh
S
O
<
CM
O
H
<
<
«
M
CO
o
H
Q
Eh
H
5
W
CO
Eh
\
cd
Eh
<
1-3
Q
(J
D
<
as
u
<
<
2
ffi
Cm
fa
<
J
U
R. Carlson
X
X
T. Fies XXX XX
N. Hansen
X
X
X
X
T. Matylinski
X
X
X
X
S. Johnson
X
X
D. Wilkinson
X
X
X
X
X
P. Ramsay
X
X
X
X
A. Sykes
X
X
X
G. Priday
X
X
X
X
X
X
-------
Chapter 5
Comments and Responses to the
Finding of No Significant Impact,
FNSI, and Supplemental FNSI
-------
Chapter 5
COMMENTS AND RESPONSES TO THE FINDING OF NO SIGNIFICANT
IMPACT (FNSI) AND SUPPLEMENTAL FNSI
Letters of Comment
This section contains letters of comment from agencies and
individuals on the June 9, 1980 FNSI and the August 15, 1980
Supplemental FNSI on an interim effluent disposal facility. The
June 9 FNSI and August 15 Supplemental FNSI are included in
Appendix A. Those letters which commented directly on the FNSI
and Supplemental FNSI have been reproduced in this section.
Wherever a response is required by EPA to the letter, a response
page or letter follows.
The EPA wishes to express its appreciation to all commenting
agencies and organizations for the time and effort spent in
reviewing the FNSIs. All comments were fully considered prior to
formulating the EPA's recommended action for interim effluent
disposal.
91
-------
Route 1 Box 2 54
Powell Butte, Oregon
June 23 , 1980
TO:
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
i —CEIVtD
,"J,M 2 7 198i-
FROM:
W. C. Steelhammer
Route 1 Box 254
Powell Butte, Oregon 97753
SUBJECT: Environmental Impact Assessment
City of Bend
Project No. C-410486
To Whom It May Concern:
After studying the environmental impact assessment, I was
appauled. There are several errors, omitions, and faulsehoods
that could not be overlooked. See Environmental Impact Assessment
for the City of Bend, Project No. C-410486.
A. Dry lake bed—no dry lake bed exists.
B. 160 acres pond: no mention is made of a 500 foot
wide buffer zone that will require a total of 470
acres. This buffer zone will be cleared of all veg-
etation and plowed.
C. The current grazing potential of the site is low due
to limited vegetation and water—compared to what?
The area in question has an excellent stand of grass
and is fine grazing. This pasture is better than
most others in this vacinity. Livestock water is
readily available from the North Unit Canal which is
adjacent to the proposed pond.
D. Remote location: Inaccessible: This site is less
than two miles from the Bend Airport. McGrath road
which crosses the highway between Powell Butte and
Bend, runs along one edge of the dyking berm on the
proposed pond. McGrath road, omitted conveniently
from the map, is improved and maintained as an access
to the sewage treatment plant. The pond is less than
a mile from the highway on this improved road. The
Powell Butte-Bend highway is the main artery for those
of us living in Powell Butte, Prineville and Wheeler
County to Bend, the main shopping and medical center
in the area.
92
-------
2.
E. Sparse vegetation: Area in question is densely co»vered
with Juniper trees. The site Is considered part of a
juniper forest, (there are two juniper forests in the
world: one centered at Redmond, Oregon 10 miles from
this site and the other in Jerusalem.)
F. Ponding of a natural area: The area is not sparsely
vegetated as pointed out above. Visual effects of a
160 acre sewage lagoon in the middle of 470 acres
completely devoid of vegetation is neither natural or
aesthetically pleasing—nor will it blend with the
surrounding terrain.
G. Mr. Steelhammer could be allowed to graze in an adjacent
area. If this is so, why hasn't Mr. Steelhammer been
given a firm grazing right to this area?
H. There are other statement that are misleading and should
be cotrected but space, time and urgency of this message
prevents me from doing so.
COMMENTS:
It seems apparent to those of us that know the area that the
assessment survey was made from a desk top in Seattle. The
authors of the assessment could not have overlooked the abundance
of juniper trees, grass, water and the road if they had ever set
foot on the pond site. If they had, they could not have written
this assessment.
The assessment has all the ear marks of a white-wash job to
justify a 53 million dollar treatment plant already constructed.
Total cost of the project to the taxpayer of approximately 75
million. It should be obvious to all that the assessment would
have been more convincing had it been accurate.
If this assessment is a sample of the efficiency and thoroughness
of our government, then thank God, we are not getting all the
government that we are paying for.
SOLUTION:
The proposed sewage disposal site be re-assessed. Re-apprasal
should be made by personnel on site.
State all facts accurately. Cover, topography, and access roads.
Other alternatives should be considered that were not mentioned
in assessment. Irrigation with effluence near pond site.
Treated water could be let into North Unit Canal.
93
-------
3.
Effluence could be stored in North Unit Irrigation Reservoir.
(Haystack Reservoir).
Treated sewage effluence from the Prineville, Oregon sewage
treatment plant is dumped into Crooked River and pumped from
Crooked river into the North Unit Irrigation Canal at Smith
Rock.
Mr. Ray Shumway of Powell Butte, Oregon has offered to dispose
of treated waste water through storage and irrigation.
After spending over 50 million of the taxpayers dollars, it is
doubtful that the E.I.S. will reach a different conclusion from
the Environmental Assessment. All efforts should be made to
make it less the white-wash -job it is.
Let us hope that this can be corrected before the opposition
to this project, there are many, and the news media discover
the shortcomings of this impact assessment. To those of us
who have spent our lives on this land the assessment is not
acceptable .
My purpose is to inform and to preserve a grazing right as it
was in the 1960's that is imparative to my survival as a rancher.
Sincerely,
W. C. Steelhammer
94
-------
V-o/
M/S 4*3
Mr. W. C. Steel hammer
Route 1 Sox 254
Powell Butte, Oregon 97753
Dear Mr. Steel harrier:
Thank you for your comnents dated June 23, 13C0 ori EPA's F1 ndincj of '.'o
Significant Impact for the City of Bend's pronosed 1ntor1n effluent
disposal project. EPA's assessment process which Included numerous
studies and meetings on the proposed project has enabled us to conclude
that the percolation/evaporation oond alternative 1s the nost Institu-
tionally acceptable and environmentally souno method for Interim effluent
disposal.
As you are aware, EPA 1s presently 1n the process of completing an
Environmental Impact Statement (EIS) which evaluates numerous alterna-
tives associated with ultimate effluent disposal. As a part of this
stucjy, members of my staff have spent considerable time 1n the project
area directing specific studies on the suitability of the proposed
Interim disposal site, and other sites, for effluent disposal. One of
the alternatives evaluated by EPA was discharge to the Horth Unit Ir-
rigation Canal. In a meeting with the Board of Directors, however, 1t
was clearly stated that the City would not be allowed to discharge to
the canal on an Interim basis. Discharge to the canal for ultimate
disposal will remain as an alternative In the Final EIS.
Our present schedule calls for the release of tne Final EIS 1n January
1981. Your name is on our mailing list and you will receive a copy upon
Its availability.
Sincerely,
¦ %,;¦ -
Robert S. burd
Director. Water Division
bcc: Bill Sobolewski
95
-------
Advisory
Council On
Historic
Preservation
1522 K Street, NW
Washington. DC 20005
Reply to;
Lake Plaza South. Suite GIG
44 Union Boulevard
Lakowood, CO (1022Q
June 25, 1980
R'CbiVr
¦ REGlC.'ii o
Mr. Robert S. Burd
Director, Water Division
J UN 3 0 1980
WATER DIV!S!0H
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Burd:
We note in the Finding of no Significant Impact report submitted June 9,
1980, that the construction of the Percolation/Evaporation interim
effluent disposal facility, at the City of Bend, Oregon, an undertaking
assisted by the Environmental Protection Agency (EPA project No.
C-410486) may have an effect on archaeological sites.
These properties may possess archaeological significance and therefore
may be eligible for inclusion in the National Register of Historic Places.
Section 800.4(a) of the Council's regulations, "Protection of Historic and
Cultural Properties" (36 CFR Part 800), sets forth the method of evaluating
the significance of such properties. We request that you initiate this
evaluation and inform us of your findings. If the evaluation results in a
determination by the Secretary of the Interior that the property is eligible
for inclusion in the National Register, you should follow the remaining
steps in Section 800.4 to evaluate the effect of the undertaking on the
property and, if appropriate, request the Council's comments. Should you
have any questions or require additional assistance, please call Betty J.
LeFree at (303) 234-4946, an FTS number.
Thank you for your cooperation.
5-fnrprpl v _
Chi«fT Western Division
of Project Review
96
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
M/S 443
JUL 181980
louls S. Wall
Chief, Western Division of Project Review
Advisory Council on Historic Preservation
Lake Plaza South, Suite 616
44 Union Boulevard
Lakewood, CO 80228
Dear Mr. Wall:
This responds to your comments dated June 25, 1980 on the Finding of
No Significant Impact for City of Bend Oregon's proposed percolation/
evaporation pond.
The U.S. Bureau of Land Management (BLM) and the City are presently
negotiating a land lease with purchase option agreement for the proposed
site. As a part of this process a 100% archaeological survey of the
project area was conducted. The survey concluded that none of the
sites Identified are eligible for Inclusion 1n the National Register
of Historic Places. Because the proposed project 1s located on land
administered by the BLM, 1t is our understanding that they are sub-
mitting a determination to your office In compliance with Section
800.4, 36 CFR Part 800. We further understand that 1f any mitigation
measures are required, provisions will be included In the lease agreement.
Sincerely,
Robert S. Burd
Director, Water Division
97
-------
^ United States
ft) Department of
y Agriculture
Soil
Conservation
Service
1220 S.W. Third Avenue
16th Floor
Portland, OR 97204
September 17, 1980
-;c£ivr
Mr. Robert S. Burd M/S 443
Director, Water Division
U, S. Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, WA 98101
WATER lilViSIOK
SEP 2 2 1980
Dear Mr. Burd:
The Soil Conservation Service has reviewed the Supplemental Finding
of No Significant Impact for construction of Percolation/Evaporation
Interim Effluent Disposal Facility, City of Bend, Oregon.
We have no comments to offer.
We appreciate the opportunity to review and comment on this Notice of
Finding.
Sincerely,
State Conservationist
cc: Administrator, SCS, Washington, DC
Thomas N. Shiflet, Director of Ecol Sci, SCS, DC
RECEIVED
S^p 2 3 1980
EPA-RIS
Tha Son Conservation Service
is an agency of the
Department of Agriculture
98
SCS-AS-1
10-79
-------
Of y.
^Ho'ro^
U. S. Envirornnentol Protection Agency
Region X
1200 Sixth Avenue
Seattle, \»A 98101
HE: RINDING OP NO SlGlilFlCi.KT IKP/CT /' ,'•» '•¦'<¦'
dated Aug. 15, 19^0
Our opinion and comment:
We feel a minimum of 5 (five) feet of soil should be re-
quired on ell areas of the disposal area for filtration
purposes.
Also, we feel that sll leakage into the leva should be
sealed (possibly with soil or clay) end again meet the five (5)
feet minimum filtration standard.
Mey we say that compared with drinking impure water, the
effect of the affluent on the environment is likely to be cause
for little concern.
Sincerely,
r-O
k • o V
; t- r
616^ ,j;td .?'o.':d
Bond, O.i 9Y7;H
L e p t. 12, 1 'j ; {)
&'-*i L 'L'
SEPl 8^980
'¦ Mm*. ::'
**?v tf-
^
We'll call onyour
,Mt»F
(OH SH**Ut 6®"""
DSA
Distributor of: Household Cleaners c Lovue Beauty Aids c Deux Vies and Lady Shah lee Fragrances
Shaklee For Mm Original and Golden Maimer Toiletries
Food Supplement. 99 Small Wonder Baby Products
-------
Response to Comments from G. S. and B. J. Priday, September 12,
1980
1. Comments noted. The interim effluent disposal pond will
contain a minimum of three to five feet of soil for percola-
tion. All lava cracks within the infiltration pond will be
sealed if found to cause significant seepage.
100
-------
Public Hearing Summary - June 9, 1980 FNSI
On March 5, 1980, the Bend City Commission held a public
hearing on the EPA June 9, 1980 FNSI concerning an interim
effluent disposal facility for the City of Bend, Oregon. Due
to the costs involved, the public hearing record was not
reproduced for this Final EIS. A complete record of the public
hearing is available at the Bend City Hall.
The hearing began with a presentation by N. Dempsey of
BECON, who described the proposed interim effluent infiltration
pond and the BLM lease area. Following Mr. Dempsey's descrip-
tion of the disposal facilities, their cost and impacts, the
hearing was opened for public testimony.
Comments made at the hearing follow, as summarized by BECON
in Design Definition Memorandum No. 11 (December 1979).
"The first citizen to testify represented a Bend Chamber
of Cormerce carmittee which has been studying the project.
The speaker explained that the committee favors an infiltra-
tion pond and opposes a drill hole or fractured-rock disposal
method. The ccranittee feels that the interim effluent pond
may be useful in the future for irrigation and appears to be
the best possible solution at this time. He recommended that
citizens be more involved in the selection of a final disposal
solution. To accomplish this, a seven-member citizens*
advisory ccnroittee was proposed. The ccnmittee would be
appointed jointly by the City Ccctmission and the County Board
of Commissioners. He stated that in response to the proposal,
which had previously been presented to the County Ccsrmissioners,
they agreed to consider it at their next meeting. The City
made no ocumitment. It is generally felt that the degree of
citizen involvement to date has been adequate and in compliance
with applicable regulations. Further public involvement in the
selection of a final disposal method seems more properly an
adjunct to the Environmental Impact Statement process, vdiich is
currently underway to address this issue. The City's action
(or no action) does not prevent the formation of Ad Hoc citizens'
ccrrmittees, the continuation of the Chamber of Catmerce task
force, or the fonration of citizens' committees to advise EPA
during the preparation of the final Environmental Impact
Statement.
"The second and final citizen to speak was a landowner in
the Powell Butte area who holds a grazing permit on the property
that would be used for the holding pond. He explained that he
had used the property for 20 years and that the Bureau of Land
Management had indicated that they may allow him a permit else-
where. He clarified the amount of acreage that would be required
101
-------
for the system, explaining that a total of 470 acres would be
involved when the berms, buffer zone, and fencing around the
160-acre pond were included. He objected to spending $752,000
on an interim solution. As an alternative, he suggested
discharging effluent to the North Unit Irrigation District
Canal. The acting Chairwoman replied that the discharge
alternative is being considered as one of the ultimate solu-
tions. Secondly, the interim pond may become a part of the
ultimate solution."
102
-------
Chapter 6
List of Preparers of FEIS
-------
Chapter 6
LIST OF PREPARERS OF FEIS
Roger K. Mochnick, EIS Preparation Team Leader, Environmental
Evaluation Branch, Environmental Protection Agency,
Region 10, Seattle, Washington.
Norman B. Sievertson, Project Services Team Leader, Wastewater
Operations Branch, Environmental Protection Agency,
Region 10, Seattle, Washington.
William Sobolewski, Project Engineer, Oregon Operations Office,
Environmental Protection Agency, Portland, Oregon.
Charles R. Hazel, Ph.D., Vice President, Jones & Stokes
Associates, Inc., Sacramento, California. Project
Manager.
Karen J. Miller, M.S., Jones & Stokes Associates, Inc.,
Portland, Oregon. EIS Coordinator.
Robert B. Williams, P. E., Culp/Wesner/Culp, El Dorado Hills,
California. Sanitary Engineering.
103
-------
Chapter 7
Bibliography
-------
Chapter 7
BIBLIOGRAPHY
References
Bend Engineering Consultants. 1977a. City of Bend, Oregon,
wastewater collection, treatment and disposal facilities.
Design Definition Memoranda Nos. 1-9.
. 1977b. City of Bend, Oregon, wastewater collection,
treatment and disposal facilities. Supplemental environ-
mental impact assessment: amendment no. 1 to sewerage
facilities plan. Bend, Oregon.
. 197 9. City of Bend, Oregon, wastewater collection,
treatment and disposal facilities. Design definition memo-
randum no. 11: subsurface effluent disposal feasibility investi-
gation. Bend, Oregon.
. 1930a. City of Bend, Oregon, wastewater collection,
treatment and disposal facilities. Environmental information
document: effluent containment pond and groundwater monitoring
system. Bend, Oregon.
. 1930b. Monitoring well system for interim effluent
containment area, City of Bend, Oregon. Unpublished
report prepared for U.S. Bureau of Land Management. 2 pp.
Jones & Stokes Associates, Inc. 1979. Sewage effluent disposal
for the City of Bend, Oregon: draft environmental impact state-
ment. U.S. Environmental Protection Agency, Seattle.
EPA 910/9-79-063. 153 pp.
Pound, C., and R. Crites. 1973.
by land application. 2 vols.
Agency. EPA 606/2-73-006a,b.
Wastewater treatment and reuse
U.S. Environmental Protection
Sccva, J. 1968. Liquid waste disposal in the lava terrane of
central Oregon. Federal VJater Pollution Control Administration,
U.S. Dept. of Interior.
Stevens, Thompson and Runyan, Inc., and Tenneson Engineering
Corporation. 197 6. Sewerage facilities plan, City of Bend,
Oregon. 2 vols.
U.S. Environmental Protection Agency. 1971. Manual for evaluating
public drinking water supply. Washington, D.C.
. 1975. Best practicable waste treatment technology
program guidance memorandum PG-27A. Washington, D.C. 2 pp.
105
-------
Personal Communications
Carnahan, J. 1980,
Dempsey, N. 1980.
Bend Engineering Consultants, Bend, Oregon,
Bend Engineering Consultants, Bend, Oregon.
Paterno, P. 1980. U.S. Bureau of Land Management, Prineville,
Oregon.
Ziegler, M.
Oregon.
1980. U.S. Bureau of Land Management, Prineville,
106
-------
Chapter 8
Appendix
-------
Chapter 8
APPENDIX
Appendix A
June 9, 1980 Finding of No Significant Impact
and
August 15, 1980 Supplemental Finding of No Significant
Impact on Interim Effluent Disposal Facility
107
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
REPIY TO
ATTN OF:
M/S 443
J"N s saa
FINDING OF NO SIGNIFICANT IMPACT
To All Interested Government Agencies and Public Groups:
In accordance with the procedures for the preparation of environmental
impact statements, an environmental assessment has been performed on
the below proposed Agency action:
The assessment process did not indicate a significant environmental
impact from the proposed action. Consequently, an environmental
impact statement will not be prepared. A copy of the environmental
assessment summarizing the impacts and explaining why a statement
is not required, is attached.
Comments supporting or disagreeing with this decision may be submitted
to EPA for consideration. After evaluating the comments received, the
Agency will make a final decision; however, no administrative action
will be taken on the project for at least thirty (30) calendar days
after release of this Finding of No Significant Impact.
Sincerely,
r7 . ~r ,
Robert S. Burd
Director, Water Division
Attachment
Public Law 95-217 grant to:
City of Bend
P. 0. Box 431
Bend, Oregon 97701
For construction of:
Percolation/Evaporation interim effluent
disposal facility
EPA Project No. C-410486
108
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
.tffco sr,^ REGION X
¦cr
g 1 200 SIXTH AVENUE
3 S SEATTLE, WASHINGTON 98101
%
MPir TO M/s 443
ATTN Ofi °
ENVIRONMENTAL IMPACT ASSESSMENT
A. Project Identification
Name of Applicant: City of Bend
Address : P. 0. Box 431
Bend, Oregon 97701
Project Number : C-410486
Project Description: Percolation/Evaporation interim effluent
disposal facility (See Negative Declarations
for City of Bend, dated April 5, 1977, and
May 3, 1978, for additional information)
Estimated Maximum Eligible Costs $ 852,000
EPA Share: (85%) 724,200
Applicant Share: (15%) 127,800
B. Assessment Summary
1. Description of the Proposed Project
a. Background
On September 27, 1978 the Environmental Protection Agency released
to the public a "Notice of Intent" to prepare an Environmental
Impact Statement (EIS) which would evaluate in detail the environ-
mental impacts associated with a number of alternatives designed
to provide effluent disposal for the City of Bend's new wastewater
treatment plant. Because the City's new treatment facility was
scheduled for completion and start-up in late 1980 and the
109
-------
2
City's financial planning was based accordingly, it was
recognized that the EIS process and selection of an effluent
disposal alternative may not be complete and that an interim
method of effluent disposal would be required. Emphasis was
therefore changed by the City and EPA to evaluating and
selecting an interim effluent disposal alternative while
delaying the remaining steps required to complete a Final
Environmental Impact Statement on the ultimate effluent
disposal alternative.
After release of EPA's Draft EIS and EPA's public hearings,
numerous meetings were held between the City of Bend, the
Oregon Department of Environmental Quality and EPA to discuss
interim effluent disposal alternatives. As a result of these
meetings the City's consultants, BECON, prepared Design Definition
Memorandum No. 11, "Subsurface Effluent Disposal Feasibility
Investigation" dated December 1979. In Memorandum No. 11, the
City recommended the design and construction of a surface
infiltration-overflow pond for interim effluent disposal along
with an extensive wastewater monitoring program. Under the
alternative proposed by the City, effluent would be discharged
to an existing 160 acre dry lake bed. The pond would then allow
natural percolation of the effluent through the existing surface
soil layers. In the center of the natural depression the City
proposed to clear away the existing soil layers and construct
earth dikes including other overflow devices to allow for
effluent overflow in the event the percolation rate through the
natural soils proved to be too slow in comparison to the amount
of effluent to be discharged. After review of Memorandum No. 11
EPA gave the City conditional approval of this alternative
excluding the overflow features and the clearing of the clay
overburden near the center of the natural depression. EPA's
conditional approval was based on a number of additional
concerns that would need to be satisfied prior to a decision to
provide grant assistance for the construction of the proposed
interim effluent disposal project. These additional concerns
were addressed by BECON in a February 1980 report entitled
"Environmental Information Document, Effluent Containment Pond
and Ground Water Monitoring Systems."
b. Relationship to Environmental Impact Statement
As a result of this immediate need to provide the City of Bend
with a method of discharging effluent generated at the new
wastewater treatment facility, EPA has decided to delay its
recommendation for an ultimate effluent disposal alternative.
110
-------
3
Because the interim disposal alternative is considered to be
an effective environmentally sound method of effluent disposal
EPA will include this alternative in its evaluation of an ultimate
disposal solution. As an ultimate solution, the environmental
impacts will need to be evaluated taking into account the
increased effluent discharge flow from 1.5 mgd to 6 mgd. It
is expected that the Final Environmental Impact Statement can
be completed and released for public review in January 1981.
c. Description
The project as proposed includes an effluent pumping station
and force main; an evaporation/percolation pond and monitoring
facilities. The project will serve initially as an interim
facility and potentially as the ultimate system or a component
thereof.
The proposed effluent treatment/disposal facility consists
of a 160 acre ponding area developed by diking lower boundaries
of a natural depression. Effluent will be conveyed to the ponding
area through an effluent pump station and force main. The ponding
area will have storage capacity of approximately 510 million
gallons and will serve as a natural sump providing effluent
disposal through evaporation and percolation. Based upon proposed
conservative percolation rates and upon evaporative losses, the
minimum capacity of the disposal facility should be approximately
3.0 mgd. Experience from operation of the facility will establish
actual percolation capabilities which may indicate that the
interim facility can approach or exceed the 20 year design
capacity requirements.
Effluent discharged to the ponding area will have received
secondary treatment including disinfection. Further effluent
polishing by percolation through existing natural soils at
the effluent disposal site will reasonably assure that EPA
requirements for best practicable wastewater treatment technology
will be achieved.
Monitoring facilities utilizing both existing and newly constructed
wells will be included as a component of the project to assure that
the effects of effluent disposal upon the quality of the underlying
ground water can be monitored. Monitoring facilities are to be
developed sequentially with actual locations and depths based
partially upon hydrogeologic investigations and upon experience
with migration of the effluent plume.
While some diking is proposed, EPA will require that control diking,
forming alternate basins or cells for intermittent flooding and
drying, and for maintenance purposes will be included initially in
the project. Such provisions are to be included to assure that
natural sealing of the pond bottom is prevented.
Ill
-------
4
2. Probable Impact of the Proposed Project
The environmental impacts associated with the construction
of the evaporation/infiltration pond at Site E will be
minimal. Excavation and clearing operations will temporarily
expose soils to wind and water erosion. These impacts,
however, will be limited due to the natural gentle slope of
the depression and because the area experiences little pre-
cipitation. Deposition of any wind driven dust particles is
not considered significant due to the remoteness of the site.
Use of this site will also require the conversion of 160
acres of marginal terrestrial wildlife habitat for use of the
proposed facilities. The current grazing potential of the
site is low due to limited vegetation and water. Alternative
future uses of the land are limited by accessibility, water
availability, soil types and rock outcrops. Because the site
is presently under ownership to the U.S. Bureau of Land
Management (BLM), the City of Bend has submitted an applica-
tion for land lease with an option to purchase. As a result
of this action BLM is presently preparing an environmental
assessment which will evaluate the proposed conversion of the
site from its existing use to an evaporation/Infiltration pond.
It is expected that BLM will complete its assessment this month.
The percolation/evaporation pond will have little visual impact
upon the environment because of its construction features and
the remote location. Diking will be low profile and will be
blended into the existing natural ground relief.
Although the project will result in the ponding of a natural
area with sparse vegetation, the visual effect of a body of
water in this remote area may aesthetically pleasing to those
few persons traversing the area.
Impacts on archeological sites and the Bend-Prineville wagon
road have been investigated. The impact on known archeological
sites will be mitigated through mapping, description, photography,
and disallowing ground disturbing activities such as clearing
or scarification or dike relocation. The Bend-Prineville wagon
road has been determined noneligible for the National Historic
Register. The proposed pond will inundate approximately k mile
of the road. This impact could only be reversible if the ultimate
effluent disposal method resulted in the selection of a different
site.
112
-------
5
3. Probable Environmental Impacts That Cannot Be Avoided
a. Construction related impacts are determined to be insigni-
ficant due to the remote site location. The following
impacts will occur, however they will be temporary.
(1) Increased dust levels
(2) Higher noise levels
(3) Traffic disturbances and associated public inconveniences
b. Conversion of open space land to public facilities use.
c. Inundation of k mile of the Bend-Prineville wagon road.
4. Alternatives Considered
The following six alternatives for interim effluent disposal
have been considered.
a. Disposal to Basalts Above Pumice Deposit. This alternative
incorporates disposal to the basalts above the compact
pumice/ash deposits. Reliability of this approach is
uncertain in terms of the reservoir capacity of the basalts
and their ability to accommodate design discharge loads.
b. Drillhole to Void Zone at 215- to 240-Foot Depth. Effluent
disposal by means of a drillhole extending to the cavernous
zone could be accomplished with high reliability, due to
reservoir capacity and the ability of the zone to accommodate
effluent discharge flows. The system would be simple to
construct and would minimize maintenance effort and cost.
c. Drillhole to Artificially Fractured Basalts Beneath the Pumice
Deposit. Disposal of effluent into artificially fractured
basalts and interflow sedimentary deposits underlying the
pumice deposit may allow shallower dispersion than Alternative
B, and increase effluent retention time and additional
filtering potential prior to any effluent entry into the
underlying cavernous zone.
The capability of the fractured material to accommodate the
design effluent loads by permeation through the fractures
1s not well defined, and reliaibility of this approach is
uncertain.
113
-------
6
d. Surface Infiltration-Evaporation and Overflow to Adjacent
Basins. Effluent discharge into the Site V basin'(100+
acres) east of the treatment plant site would provide
disposal to a limited extent by evaporation, but primarily by
infiltration through the existing soil mantel into the
subsurface. Effluent exceeding evaporation and infiltration
losses will overflow to adjacent basins to the east-southeast.
e. Combined Surface Infiltration and Subsurface Percolation.
Effluent would be disposed into an excavated pond area of
approximately 200 acres in and adjacent to the Site "E"
basin. The pond construction includes removal of the soil
overburden over a 10+ acre area, to expose the underlying
basalt, which would be fractured to depths of 125+ feet
to develop a percolation zone.
f. Surface Infiltration-Overflow Pond and Percolation Zone.
This concept is similar to Alternative e, with effluent
discharged only into the Site "E" basin, which would
allow infiltration through approximately 100 acres of
natural soil deposits into the subsurface. An overflow
system is included, composed of a 10;t acre excavation
near the basin center that is extended to the underlying
basalt- The excavation perimeter would be elevated by
berms to control ponding in the basin area to a specific
elevation prior to overflow irtto the excavation. The
basalt in the excavation bottom would be fractured to
increase permeability.
This alternative excluding the overflow features is the only
alternative approved by EPA for grant funding.
5. Relationship Between Short-Term Uses of the Environment and
Long-Term Productivity
The proposed changes in the project involve a tradeoff of short-
term environmental impacts for long-term productivity. The
short-term impacts are mostly related to construction, such
as increased noise and dust levels. These impacts will be
noticeable, but are only temporary and should not persist
beyond completion of construction. Long-term gains will
result from utilizing the site for an interim effluent disposal
pond. Provision of adequate sewerage service to the City of
Bend will allow growth to continue and allow room for expansion
of the economic base of the City. Long-term productivity will
be enhanced.
114
-------
Irreversible and Irretrievable Commitments of Resources:
Construction of the proposed facilities will result in the
use of resources such as construction materials, energy, fuels
and human resources. These resources are irretrievably committed.
Public Response to the Project
A public meeting on the environmental information document
was held on March 5, 1980. Approximately 39 persons were in
attendance at the public meeting. Following presentation of
the proposed project by BECON, two people presented testimony.
Mr. Wally Corwin, Bend Jaycees, indicated support of the
project. Mr. Corwin recommended formation of a citizen advisory
committee prior to the determination of the ultimate method of
disposal. Mr. William Steel hammer, Powell Butte, objected to
loss of grazing area because of the percolation/holding pond.
To mitigate the grazing loss caused by the effluent pond,
Mr. Steelhammer could be allowed to graze in an adjacent area
which is tentatively planned to be used as a sludge disposal
area for the wastewater treatment plant.
Agencies Consulted
a. U.S. Bureau of Land Management
b. U.S. Forest Service, Deschutes National Forest
c. Deschutes County
d. Oregon State Department of Water Resources
e. Oregon DEQ
f. SHPO
Reasons for Concluding No Significant Impact
The area at Site E is more remote and contains sufficient space
to maintain a suitable buffer around the percolation/holding
pond. An on- and off-site monitoring system will be used to
detect any ground water contamination at the earliest possible
point. EPA will continue its evaluation of an ultimate effluent
solution in a Final EIS scheduled for completion in January 1981.
115
-------
FIGURE 2.
HISTORIC ROADS IN THE PROJECT AREA
116
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
,*eo STjf. REGION X
of*
v. 1200 SIXTH AVENUE
£ i
isssz;
% «o*c'
IEPIY TO u
ATTN Of; M/S 443
SEATTLE, WASHINGTON 98101
AuG 15 1980
SUPPLEMENTAL
FINDING OF NO SIGNIFICANT IMPACT
To All Interested Government Agencies and Public Groups:
On June 9, 1980, the Environmental Protection Agency (EPA) released
a Finding of No Significant Impact (FNSI) on the proposed action
described below:
Public Law 95-217 grant to:
City of Bend
P. 0. Box 431
Bend, Oregon 97701
For construction of:
Percolation/Evaporation Interim Effluent
Disposal Facility
EPA Project No. C-410486
During the thirty (30) day comment period on.the FNSI additional
information was developed regarding the proposed action. Because
this information provides additional analysis regarding the actual
design and potential impacts of the proposed action, EPA has decided
to supplement the original FNSI and re-open the comment period for an
additional thirty (30) days.
Based on this additional information and the June 9, 1980 Environmental
Assessment and FNSI, EPA has determined that an Environmental Impact
Statement for the interim effluent disposal facilities will not be
prepared. Comments supporting or disagreeing with this decision may
be submitted to EPA for consideration. Copies of EPA's June 9, 1980
FNSI can be obtained by contacting the Environmental Evaluation Branch,
M/S 443 at the above address.
Sincerely,
Robert S. Burd
Director, Water Division
Attachment
117
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
^eos,^ REGION X
1200 SIXTH AV E N
SEATTLE, WASHINGTON 98101
^ ^ 1200 SIXTH AVENUE
i mj
r*
PR01*-
REPLY TO . .
ATTN OF: M/S 443
AUG 15 1980
SUPPLEMENTAL ENVIRONMENTAL IMPACT ASSESSMENT
A. Project Identification
Name of Applicant: City of Bend
Address : P. 0. Box 431
Bend, Oregon 97701
Project Number : C-410486
Project Description: Percolation/Evaporation interim effluent
disposal facility (See Negative Declarations
for City of Bend, dated April 5, 1977,
May 3, 1978, and FNSI June 9, 1980 for
additional information)
B. Assessment Summary
1. Description of the Proposed Pro.iect
a. Introduction
On June 9, 1980, EPA issued a Finding of No Significant Impact (FNSI)
which stated the Agency's NEPA decision concerning a proposed interim
effluent disposal facilityfor the City of Bend, Oregon. During the
comment period, following issuance of the FNSI, written comments were
received from three sources as listed below:
1. Mr. W. G. Steelhamer, a local rancher who objects to the proposed
action because of its impact on his ranching operations.
2. The Advisory Council on Historic Preservation who asked for EPA's
determination on the eligibility of four archaeological sites for
inclusion on the National Register of Historic Places, and
118
-------
2
3. Becon, the City's consultant who provided technical comments and further
project and site information.
None of the three comments were judged as significantly effecting the Agency
decision and responses to all have been made.
In addition to the written comments, we were advised by the Oregon Department
of Environmental Quality that after the Bureau of Land Management (BLM) had
reviewed the FNSI statement, they expressed concerns. Subsequently, a meeting
involving officials from BLM, EPA, DEQ, City of Bend and Becon was held.
Discussions during that meeting revealed that some project features were not
adequately described in the FNSI and that EPA's environmental decision
needed to be further clarified.
This supplement is intended to provide to the public such additional project
details and to further stress the Agency's conclusion of no significant impact.
EPA considers the proposed works described in the FNSI to be an interim effluent
disposal facility but recognizes that such facility may remain in operation for a
period of up to three years or longer and that such facility has the potential
for becoming a part of the ultimate disposal solution. The ultimate disposal
solution is not yet fully identified but will be addressed in the final EIS,
which is scheduled for January 1981.
The draft EIS was completed in the fall of 1979, and a public hearing conducted
in December, and comments relative to the proposed project received. At that
time it had been recognized that there remained insufficient time to design
and construct an acceptable ultimate solution which would allow the City
to place their treatment plant into operation by late summer of fall of 1980, a
startup schedule of great importance to the City because of its financial commit-
ments. Efforts were subsequently concentrated toward identifying interim
solutions for effluent disposal. These were presented in Becon's Design
Definition Memorandum No. 11.
During the process of evaluating effluent disposal solutions, EPA has
consistently opposed the use of drill hole or shattered rock solutions on the
basis of potential contamination of the groundwater. The Regional Administrator ...
made this clear to the Oregon Department of Environmental Quality in his letter of
March 16, 1978,which stated that a drill hole situation could be approved only on
an interim basis if no other feasible alternative solutions could be found.
Information contained in Becon's Design Definition Memorandum No. 11 sug-
gested that an alternative interim disposal solution which would
essentially meet the City's schedule and which would provide for the protection
of the groundwater was available. That solution, presented in EPA's June 9,
1980, FNSI would provide natural filtration or soils treatment and evaporation of
the effluent discharged from the City's new secondary treatment facility. EPA
believes that such additional natural treatment will assure compliance with the
Agency's requirement for Best Practicable Wastewater Treatment Technology (BPWTT).
With this goal in mind, EPA was able to conclude that construction of the proposed
interim facility would not be considered a significant environmental impact.
119
-------
3
The FNSI as issued included several errors which are addressed below:
b. Description
1. The FNSI described the project as including "an effluent pumping station
and forcemain." This is not correct. A "gravity pipeline" rather than
"pump station and forcemain" is proposed for conveying treated effluents from
the treatment plant to the disposal area.
2. Herbicides or other chemicals are not to be used for controlling weed
growth on the dikes or pond bottom or on other areas in proximity of the
effluent disposal facility. The intent of this restriction in the use of
chemicals is to protect wildlife. Compliance will be assured through
the use of a condition on the subsequent Step 3 grant.
3. Although the FNSI statement indicated that EPA would require control dikes,
forming alternate basins or cells for intermittent flooding and drying and
for maintenance purposes, to be included initially in the project to assure that
natural sealing of the pond bottom is prevented; it presented only a brief
description of the effluent disposal facility and thereby failed to fully
describe certain special construction activities such as the location and
details of diking, the quantity and source of borrow material including riprap,
and the proposed highwater level. In addition, other features such as the
stripping of vegetative material and the sealing of rock outcrop zones which
are generally included in the design of percolation/evaporation pond systems
were not mentioned within the FNSI. These other features, common with con-
struction of similar projects, were, however, considered by the Agency prior
to the making of its decision.
The location and the details of the control dikes which were not available
at the time the FNSI was issued are now provided in a preliminary diking
plan which is included as an attachment to this assessment. That plan provides
preliminary locations for the dikes, indicates typical dike sections and
locates an approximate highwater level for the facility. The proposed borrow
areas for dike construction which are based on recently available soils information
are also shown and approximate borrow quantities indicated. Removal of borrow
material would result in improved infiltration rates and would also provide for the
remaining soils layer to be a minimum of 3-5 feet in thickness.
2. Probable Impact of Proposed Project
The environmental impacts associated with the proposed project are discussed
in EPA's June 9, 1980, FNSI. The following discussion is intended to supplement
that information.
Stripping of vegetation within the pond bottom area was not discussed in the
original FNSI but was considered to be a common practice in the construction of
infiltration pond systems. Failure to clear brush and trees from the area would
not only interfere with the disking of the pond bottom during maintenance periods,
but would contribute to the sealing of-the soils from the decay of vegetative
matter.
120
-------
4
The FNSI indicated that the capacity of the interim disposal facility would
not be less than 3.0 MGD. That approximation was based on a conservation
infiltration rate of 0.3 gpd/ft2 and an assumed evaporation rate which was
later found to be too high. A more accurate estimate based on the same
conservative infiltration rate and an evaporation rate of 30 in/yr indicates
that the facility would have a sustaining capacity of not less than 2.5 MGD.
The actual capacity of the facility can be realized only after the facility
is placed in operation and the actual capacity could be as high as 3.0 MGD.
During the Portland meeting concern over potential leakage of treated
effluents through rock outcrop zones or at the interface between projecting
rock surfaces and soils was voiced by BLM officials. This same concern had been
recognized by EPA and we had assumed that corrective measures for sealing such
potential leaks would be provided for in the design of the facility. After a
preliminary evaluation to determine the extent of sealing that may be necessary,
Becon requested relaxation of the requirement for sealing and EPA is generally
in agreement with such request. It is not anticipated that during design of the
infiltration pond facility, the potential leakage areas will be identified and
an appraisal of the likelihood for excessive leakage be made. Only for those
which are judged as highly likely to allow seepage to occur will provisions
for sealing be included within the bidding documents. Other potential leakage
sources will be identified and monitored during the operation of the facility
and inspected during maintenance periods. We believe that the expenditure of
additional construction effort to assure total control of such leaks for an
interim solution is not justified. In the event that the interim facility
becomes a component of the ultimate solution, additional efforts to control leakage
may become necessary.
3. Official Response to the Project
During the Portland meeting officials of BLM also expressed concern over the
potential for further EIS delays in order to allow information obtained during
operation of the interim facility to be included in EPA's final decision. A
reluctance to accept piecemeal approval of what may become segments of the ultimate
effluent disposal system without the prior issuance of an EIS was also expressed
by BLM officials. As mentioned above, EPA fully intends to complete the Final
EIS for release to the public in January, 1981. The Final EIS is to include a
description of the interim facility and additional technical information that
will become available during design and construction of the facility. Operational
information if available would also be included.
The interim solution as presently proposed does have the potential to become a
part of the ultimate effluent disposal solution. This possibility, which was
acknowledged in the original FNSI statement, should not however, be accepted as
a foregone conclusion. Performance of the interim facility, when evaluated over
a period of time (possibly several years), would be necessary in order to assess
its suitability and the extent of any necessary expansions if it were to be
proposed as the ultimate facility. In addition, the results of monitoring
would also need to be considered in any such further evaluations conducted during
periods extending beyond the release ofthe Final EIS.
121
-------
-------
APPENDIX B
EIS DISTRIBUTION LIST
123
-------
BEND, OREGON EIS DISTRIBUTION LIST
Federal Agencies
Advisory Council on Historic Preservation
U.S. Department of Agriculture
U.S. Department of Defense
U.S. Department of Health, Education and Welfare
U.S. Department of Housing and Urban Development
U.S. Department of Interior
Bureau of Land Management
Fish and Wildlife Service
Water and Power Resources Service
Federal Aviation Administration
U.S. Department of Transportation
State and Local Officials and Agencies
Office of the Governor
Oregon Aeronautics Division
Oregon Department of Environmental Quality
Oregon Department of Fish and Wildlife
Oregon Health Division
Oregon Land Conservation and Development Commission
Oregon State Clearing House
Oregon State Department of Human Resources
Oregon State Historic Preservation Office
Oregon Water Resources Department
Ruth Burleigh, Mayor, City of Bend, Oregon
Arthur Johnson, Bend City Manager
Jack Donahue, Public Works Director, City of Bend
Nels Hansen, Mayor, City of Metolius, Oregon
Ted Matylinski, City Council, Metolius, Oregon
Samuel S. Johnson, Mayor, City of Redmond, Oregon
Edward English, City Manager, City of Redmond
Bub Miller, City Manager, City of Madras, Oregon
Deschutes County Health and Sanitation Department
Deschutes County Planning Department
R. C. Dodson, North Unit Irrigation District
Roger Wagner, North Unit Irrigation District
124
-------
2
Organ i zat ions
Central Oregon Audubon Society
League of Women Voters
OSPIRG
1000 Friends of Oregon
Oregon Environmental Council
Local Distribution and Other Interested Parties
Ronald Ball
BECON
Bend Bulletin
Keith Carpenter
George Cook
Cooper-Clark and Associates
Culp, Wesner, and Culp
Thomas Gellner
Patrick Gibson
Leslie Graves
Bob Hamchett
Kris Hanson
Kenneth Harris
John Joyce
Gerald Knippel
KTVZ - TV
Frank G. MacMurray, Jr.
Bob Main
Errol Ohlde
Ronald Olson
Dr. William Orr
Gordon Friday
Paul Ramsay
C. E. Rhoads
James Smily
W. Steelhamer
Arthur Sykes
C. E. Ward
Doug Wilkinson
125
------- |