United States
Environmental Protection
Agency
Region 4
345 Courtland St., N.E.
Atlanta, GA 30365
EPA 904/9-90-007a
NOVEMBER 1990
se EPA
ENVIRONMENTAL
IMPACT
STATEMENT
SOUTH BALDWIN COUNTY, ALABAMA
WASTEWATER MANAGEMENT
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ENVIRONMENTAL IMPACT STATEMENT
SOUTH BALDWIN COUNTY, ALABAMA
WASTEWATER MANAGEMENT
Prepared By
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
^iGreer C. Tidwell
' Regional Administrator
Approved
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY ES-1
1.0 PURPOSE AND NEED FOR ACTION
1.1 Purpose and Scope of the EIS 1-1
1.2 Background and Issues 1-1
2.0 ALTERNATIVES DEVELOPMENT AND SCREENING
2.1 Introduction 2-1
2.2 Background Information 2-1
2.2.1 Existing Wastewater Management Practices 2-1
2.2.2 Population Projections 2-3
2.2.3 Wastewater Flow Projections 2-3
2.2.4 Flow and Waste Reduction Analysis 2-6
2.3 Development of Wastewater Management 2-8
Concepts
2.3.1 Sewerage Districts 2-8
2.3.2 Treatment Systems 2-8
2.3.3 Disposal 2-10
2.3.3.1 No-Action 2-10
2.3.3.2 Disposal to Gulf of Mexico 2-10
2.3.3.3 Disposal to Intracoastal 2-11
Waterway
2.3.3.4 Land Application 2-11
2.3.4 Sludge Treatment and Disposal 2-12
2.3.5 Industrial Discharges 2-15
2.4 Wastewater Management Screening 2-15
2.4.1 Technical Feasibility and 2-15
Implementability
2.4.2 Selected Alternatives for Detailed 2-16
Evaluation
3.0 ALTERNATIVES EVALUATION
3.1 Selected Alternatives 3-1
3.1.1 Wastewater Treatment 3-1
3.1.2 Wastewater Disposal 3-2
i
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TABLE OF CONTENTS
(Cont'd.)
Page
3.1.2.1 Alternative 1: No Action
3.1.2.2 Alternative 2: Disposal to Gulf
of Mexico
3.1.2.3 Alternative 3: Disposal to
Intracoastal Waterway
3.1.2.4 Alternative 4: Land Application
3.1.2.3.1 Option 4A: Slow-Rate Land 3-10
Application on Pleasure
Island
3.1.2.3^2 Option 4B: High-Rate Land 3-10
Application on Pleasure
Island with Reuse North
of Intracoastal Waterway
3.1.2.3.3 Option 4C: High-Rate Land 3-13
Application on Pleasure Island
with Wetland Discharges
3.1.2.3.4 Option 4D: Slow-Rate Land 3-13
Application North of Intra-
coastal Waterway
3.1.3 Sludge Treatment Disposal 3-13
3.2 Cost 3-16
3.3 Implementability and Operability 3-17
3.3.1 Operability 3-17
3.3.2 Implementability 3-26
3.4 Environmental Impacts 3-28
3.4.1 Primary Impacts 3-28
3.4.1.1 Surface Water Resources 3-28
3.4.1.1.1 Impacts to the Intracoastal 3-30
Waterway
3.4.1.1.2 Impact to the Gulf of Mexico 3-33
3.4.1.2 Groundwater Resources 3-36
3.4.1.2.1 Impacts to Groundwater 3-37
Quantity
3.4.1.2.2 Impacts to Groundwater 3-40
Quality
3.4.1.3 Ecological Resources 3-41
3.4.1.4 Wetlands 3-49
3-6
3-8
3-8
ii
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TABLE OF CONTENTS
(Cont'd.)
Page
3.4.1.5 Archaeological and Historical 3-51
Resources
3.4.1.6 Recreational Resources 3-54
3.4.1.7 Noise, Odor, and Air Quality 3-54
3.4.2 Secondary Impacts 3-58
3.4.2.1 Population Growth 3-58
3.4.2.2 Land Use 3-60
3.4.2.3 Economics 3-61
3.4.2.4 Transportation 3-62
3.4.2.5 Community Services 3-63
3.4.2.6 Water Quality 3-67
3.4.2.7 Ecological Resources 3-71
3.4.2.8 Archaeological, Historical and 3-72
Recreational Resources
4.0 PREFERRED ALTERNATIVES
4.1 Introduction 4-1
4.2 GSUB 4-1
4.2.1 Description of Alternatives 4-1
4.2.2 Project Costs 4-2
4.2.3 Financing Alternatives 4-4
4.2.4 User Charges 4-4
4.2.5 Environmental Impacts 4-9
4.2.6 Mitigation Measures Required With No-Action 4-9
Alternative
4.2.7 Mitigation Measures Required With Land 4-9
Application Alternative
4.3 IBU 4-14
4.3.1 Description of Alternatives 4-14
4.3.2 Project Costs 4-15
4.3.3 Financing Alternatives 4-15
4.3.4 User Charges 4-15
4.3.5 Environmental Impacts 4-19
4.3.6 Mitigation Measures Required With No-Action 4-19
Alternative
4.3.7 Mitigation Measures Required With Land 4-19
Application Alternative
4.4 SASS 4-24
4.4.1 Description of Alternatives 4-24
4.4.2 Project Costs 4-25
4.4.3 Financing Alternations 4-25
iil
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TABLE OF CONTENTS
(Cont'd.)
Page
4.4.4 User Charges
4.4.5 Environmental Impacts
4.4.6 Mitigation Measures Required With the
No-Action Alternative
4.5 Collection System Construction Environmental Impacts
& Mitigation
4.6 Mitigation Required for Secondary Impacts
5.0 EIS COORDINATION AND PUBLIC PARTICIPATION
5.1 Introduction
5.2 Coordination with Local, Regional, State
and Federal Agencies
5.3 Technical Advisory Groups
5.4 Comments Received on the DEIS and Responses
4-25
4-25
4-30
4-30
4-33
5-1
5-1
5-2
5-2
Comments and Testimony on the DEIS
Requiring Responses
Comments on the DEIS Not Requiring
a Response
Public Hearing Transcript
5.4.1
5.4.2
5.4.3
6.0 LIST OF PREPARERS
7.0 REFERENCES
APPENDIX A: ALABAMA DIVISION OF ENVIRONMENTAL MANAGEMENT AND EPA
ENVIRONMENTAL SERVICES DIVISION FIELD STUDIES AT GULF SHORES
AUGUST 18, 1982 THROUGH NOVEMBER 14, 1982
APPENDIX B: NEAR-SHORE PHYT0PLANKT0N BLOOM POTENTIAL AND PERIPHYTIC ALGAL
CONCENTRATIONS AT GULF SHORES, ALABAMA
APPENDIX C: ANALYSIS OF SEAWATER SAMPLES STATION LOCATIONS IN FIGURE 1,
APPENDIX B
APPENDIX D: DAUPHIN ISLAND SEA LAB WATER QUALITY STATION LOCATIONS IN
FIGURE 1, APPENDIX B
APPENDIX E: GEOLOGICAL SURVEY OF ALABAMA WATER QUALITY MODELING
APPENDIX F: OCEANOGRAPHIC AND METEOROLOGICAL DATA COLLECTION
APPENDIX G: COST ANALYSIS REPORT AND ENGINEERING EVALUATION
iv
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TABLE OF CONTENTS
(Cont'd.)
LIST OF TABLES
Number Title Page
ES-1 Summary of Wastewater Disposal Alternatives ES-6
2-1 Population Growth Scenarios of Permanent 2-4
and Seasonal Residents at Summer Peak
2-2 Total flows by Sewerage District in 2-7
Million of Gallons per Day at Summer Peak
2-3 Summary of Land Application Sittes 2-13
3-1 Summary of Major Physical Components Required 3-4
for Each Disposal Alternative
3-2 Construction, Project and Net Present Worth 3-18
Costs of Wastewater Disposal
3-3 Annual Operation and Maintenance Comta of 3-SO
Wastewater Disposal
3-4 Present Worth Costs of Wastewater Treatment 3-21
and Annual O&M
3-5 Summary of Present Worth Gosts of Wastewater 3-22
Treatment and Disposal
3-6 Summary of Operability and Implementability 3-24
3-7 Potential Land Application Sitses for the 3-39
Wastewater Management Alternatives
3-8 Endangered, Threatened and Species of Special 3-42
Concern in Mobile and Baldwin County
3-9 Potential Construction Impacts to Wetland 3-51
Areas
3-10 Fact Sheet for Secondary Growth Impacts 3-65
3-11 Surface Water Bodies With Use Impairment by 3-68
Non-Point Source Pollution
3-12 Potential Non-Point Source Impacts of the 3-70
Preferred Alternative
4-1 Summary of Coats for GSUB 4-3
v
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TABLE OF CONTENTS
(Cont'd.)
LIST OF TABLES
Number Title PagS
4-2 Annual Debt Payment Breakdown for GSUB 4-7
4.3 Estimated User Charges for GSUB 4-8
4.4 GSUB - Significant Impacts of the Two 4-10
Acceptable Alternatives
4-5 GSUB - Summary of Adverse Impacts and Mitigation 4-12
Measures Required* for the No-Action Alternative
4-6 GSUB Summary of Adverse Impacts and Mitigation 4-13
Measures Required for the Land Application
Alternative
4-7 Summary of Costs for IBU 4-15
4-8 Annual Debt Payment Breakdown for IBU 4-17
4-9 Estimated User Charges for IBU 4-18
4-10 IBU - Significant Impacts of the Two 4-20
Acceptable Alternatives
4-11 IBU - Summary of Adverse Impacts and Mitigation 4-22
Measures Required for the No-Action Alternative
4-12 IBU - Summary of Adverse Impacts and Mitigation 4-23
Measures Required for the Land Application
Alternative
4-13 Summary of Costs for SASS 4-26
4-14 Annual Debt Payment Breakdown for SASS 4-27
4-15 Estimated User Charges for SASS 4-28
4-16 SASS - Significant Impacts of the 4-29
No-Action Alternative
4-17 SASS - Summary of Adverse Impacts and Mitigation 4-31
Measures Required for the No-Action Alternative
4-18 General Mitigation Measures for Collection System 4-34
Construction
4-19 Summary of Adverse Secondary Impacts and 4-35
Mitigation Measures
vi
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Number
5-1
5-2
5-3
5-4
TABLE OF CONTENTS
(Cont'd.)
LIST OF TABLES
Title
Interagency Scoping Participants in Montgomery,
Alabama, April 10, 1985
Agency and Citizen Groups Participating in the
Scoping Process in Gulf Shores, May 13, 1985
Agency and Citizen Groups Participating in the
Public Information Meeting in Gulf Shores,
December 6, 1988
Technical Advisory Group
Page
5-3
5-4
5-5
5-6
Number
ES-1
2-1
2-2
2-3
3-1
3-2
3-3
3-4
3-5
3-6
3-7
3-8
3-9
LIST OF FIGURES
Title
Study Area
Location of Treatment Plants
Approximate Sewerage District Areas
Existing and Potential Land Application Sites
Alternative 1 - No Federal Action
Alternative 2 - Disposal Via a Gulf Outfall
Alternative 3 - Disposal to the Intracoastal
Waterway Via Multiple Outfalls
Alternative 4A - Slow-Rate Land Application
on Pleasure Island
Alternative 4 B - High-Rate Land Application
on Pleasure Island with Reuse North of the
Intracoastal Waterway
Alternative 4C - High-Rate Land Application
on Pleasure Island with Wetland Discharges
Alternative 4D - Slow-Rate Land Application
North of the Intra-Coastal Waterway
Beach Mouse Critical Habitat
Archaeological and Historic Sites
vii
Page
ES-2
2-2
2-5
2-14
3-5
3-7
3-9
3-11
3-12
3-14
3-15
3-47
3-53
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EXECUTIVE SUMMARY
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EXECUTIVE SUMMARY FOR THE
ENVIRONMENTAL IMPACT STATEMENT FOR
SOUTH BALDWIN COUNTY, ALABAMA
WASTEWATER MANAGEMENT
Draft ( )
Final ( X )
Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365
Type of Action Administrative ( X )
Legislative ( )
Purpose and Need
The purpose of this Environmental Impact Statement (EIS) is to identify
the most appropriate strategies for the management of wastewater generated in
the Gulf Coast region of Baldwin County, Alabama (see Figure ES-1). This EIS
was prepared by Region IV of the United States Environmental Protection Agency
(EPA), in cooperation with the Alabama Department of Environmental Management
(ADEM), to: 1) provide a comprehensive analysis of current wastewater manage-
ment strategies for the study area for the 20 year planning period, and
2) analyze the impact of available alternative strategies.
Historical Perspective
Wastewater management problems in this area were precipitated when
Hurricane Frederick devastated South Baldwin County in 1979. Prior to this
time, wastewater facilities in the study area consisted primarily of
individual septic systems. In addition, a utility, organized by the City of
Gulf Shores, operated a three-cell lagoon system for the treatment of sewered
flows, which discharged the treated effluent into the Gulf Intracoastal
Waterway (GIWW) . This wastewater management technique was adequate at the
time, because population density was low and development consisted primarily
of single-family summer cottages along the coast.
ES-1
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When Hurricane Frederick struck South Baldwin County, many buildings were
destroyed, a number of septic tank systems were removed from the ground, and
others were damaged in less obvious ways. Flooding resulted in salt water
contamination of the alluvial/coastal aquifer, especially around Fort Morgan,
and hurricane forces altered physical features of some parts of the coastline.
Following Hurricane Frederick, disaster relief provided to rebuild the
area, sparked a land boom that resulted in rapid population growth. Multi-
story condominiums and hotels were constructed along the beach, and water
access areas were developed for retirement communities. Both seasonal and
permanent growth occurred at a rapid pace; the area was one of the fastest
growing regions of its size in the country. Increased wastewater flows
associated with this growth taxed the capacity of the area's limited
wastewater management facilities. The lagoon system became overloaded and
could not meet discharge limits. As a consequence, the City of Gulf Shores
began planning for a sophisticated new treatment system, and several
entrepreneurs built private state-of-the-art treatment plants and treatment
systems.
As development accelerated, state health officials were concerned about
the number of septic tank systems that had been constructed in low-lying areas
and the concomitant reliance on the shallow underlying aquifer for water
needs. In addition, ADEM became concerned about the periodic occurrences of
low dissolved oxygen (DO) concentrations in the GIWW and area estuaries in
which fish kills occurred. Several seafood processors conducted inter-
mittent operations at the mouth of the Bon Secour River and along the GIWW.
It was not known to what extent Gulf Shores wastewater and seafood processor
discharges were contributing to the low DO concentrations in the GIWW.
To provide a technical basis for water management decisions, ADEM began
water quality modeling studies of the GIWW in 1982. These studies produced
key observations regarding transport characteristics of the GIWW between Bon
Secour Bay and Wolf Bay. Additional technical information was provided by EPA
who began a year-long oceanographic study in mid-1985 to support decision-
making on proposed outfalls to the Gulf of Mexico. The Geological Survey of
ES-3
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Alabama provided groundwater modeling to evaluate potential land application
sites on Pleasure Island and on the farmlands north of the GIWW. These
studies provided the data that drove the decisions rendered here.
Existing Facilities
South Baldwin County is currently served by one publicly-owned and two
privately-owned wastewater treatment plants (WWTP) which use the wastewater
treatment and disposal practices listed below. The construction of these
facilities was substantially completed in 1989.
1) The Utilities Board of the City of Gulf Shores (GSUB) owns and
operates a tertiary WWTP and discharges the final effluent into the
GIWW.
2) Island Bay Utilities (IBU), a private enterprise, owns and operates
a tertiary WWTP and discharges the final effluent to a land applica-
tion site nearby. IBU may also discharge into the GIWW.
3) The South Alabama Sewer System (SASS), also a private enterprise,
owns and operates a tertiary WWTP and discharges the final effluent
into percolation ponds.
Because IBU and SASS facilities are privately-owned and operated, they
are not eligible, under the present regulations, to receive federally
sponsored 201 Construction Grants or State Revolving Fund (SRF) loans. Since
GSUB is a publicly-owned wastewater facility, GSUB is eligible to apply for
state or federal assistance in the form of grants and loans.
Alternatives
Because of the different configurations of one publicly-owned and two
privately-owned WWTP systems, there does not appear to be a single preferred
alternative common for all three systems. This study must deal with the
reality that three WWTP systems were already built and fully operational in
1989. Each is owned, operated, and administrated by a separate independent
ES-4
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entity. Combining GSUB, IBU, and SASS into a single regional wastewater
authority was considered in this study, but rejected on the grounds of
improbable implementation. It would be possible if two operators were to
voluntarily sell or transfer assets to the third, but forcing a merger of the
three facilities would raise serious constitutional issues quite beyond the
scope of this EIS.
Although this study rejects a variety of alternatives on environmental or
economic grounds, it also identifies more than one acceptable solution to the
wastewater disposal question. To this end, the EIS has identified two
acceptable alternatives for each of the three WWTP operators in South Baldwin
County.
Four generic wastewater disposal alternatives were evaluated in the EIS:
1) no-action, 2) Gulf of Mexico discharge via a common outfall, 3) GIWW dis-
charge via multiple outfalls, and 4) land application. Three different out-
fall lengths were considered under Alternative 2 and four land application
options were examined under Alternative 4. The treatment systems were
selected to be consistent with the disposal method used. Table ES-1 sum-
marizes the treatment and disposal methods that would be used by the three
plants for each of the alternatives.
Nn-Action
The no-action alternative (Alternative 1) would represent the wastewater
management strategy that would take place if no federal funding were available
for the GSUB wastewater treatment and disposal components of the wastewater
treatment plant. The IBU and SASS plants are ineligible to receive federal
funds. The no-action alternative would not restrict local, or private invest-
ment in wastewater management. The no-action alternative does not imply no
growth in the study area; growth would occur in response to previously commit-
ted investments and continuing pressures for new residential construction.
Under the no-action alternative, the GSUB wastewater treatment plant
would continue to treat wastewater to tertiary effluent standards and would
discharge all 4.28 mgd (ultimate flow rate with medium growth projections) to
ES-5
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Table ES-1. Summary of Wastewater Disposal Alternatives
Alternative Treatment Plant Wastewater Treatment Wastewater Effluent Disposal
1 GSUB Tertiary G1VM
IBU Tertiary 1.0 mgd-trickle field
>1.0-G1WU and/or land application
SASS Tertiary Percolation ponds
2A
GSUB
Secondary
1 mile outfall to Gulf
IBU
SASS
Secondary
Secondary
1 mile outfall to Gulf
1 mile outfall to Gulf
2B
GSUB
Secondary
3 mile outfall to Gulf
IBU
SASS
Secondary
secondary
3 mile outfall to Gulf
3 mile outfall to Gulf
2C
GSUB
Secondary
6 mile outfall to Gulf
IBU
SASS
Secondary
Secondary
6 mile outfall to Gulf
6 mile outfall to Gulf
3
GSUB
Tertiary
GIUU
IBU
Tertiary
1.0 mad-trickle field
>1.0 mgd-GIWU
SASS
Tertiary
Percolation ponds
4A
GSUB
Secondary +
effluent filtration
Land application on Pleasure Island
IBU
Secondary +
effluent filtration
Land application on Pleasure Island
SASS
Tertiary
Percolation ponds
4B
GSUB
Secondary +
effluent filtration
High rate land application on Pleasure
Island with groundwater recovery and
application north of the GIUU
IBU
Secondary +
effluent filtration
High rate land application on Pleasure
Island with groundwater recovery and
application north of the GIUU
SASS
Tertiarv
Percolation ponds
ES-6
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Table ES-1. Surrmary of Wastewater Disposal Alternatives
(Cont'd.)
Alternative Treatment Plant Wastewater Treatment Wastewater Effluent Disposal
4C
GSUB
Secondary +
effluent filtration
High rate land application on Pleasure
Island with groundwater recovery and
discharge to wetlands
IBU
Secondary +
effluent filtration
High rate land application on Pleasure
Island with groundwater recovery and
discharge to wetlands
SASS
Tertiary
Percolation ponds
4D
GSUB
Secondary +
effluent filtration
Land application north of GIUU
IBU
Secondary +
effluent filtration
1.0 mgd-trickle field
>1.0 mgd-land application north of
GIWU
SASS
Tertiary
Percolation ponds
ES-7
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the GIWW. The SASS wastewater treatment plant would also provide tertiary
treatment, but the final effluent would be discharged to the existing SASS
percolation ponds. IBU would treat the effluent to tertiary standards and
discharge 1.0 mgd of effluent to their existing trickle field. Above 1.0 mgd,
additional flows of up to 1.6 mgd would be treated using IBU's existing carbon
column technology and discharged to the GIWW. Flows above 2.6 mgd (1.0 mgd-
trickle field, 1.6 mgd-GIWW) would be treated using land application on a new
site to be obtained by IBU.
Gulf of Mexico Outfall
The operation of all three plants would be converted to secondary treat-
ment under the Gulf outfall disposal alternative. All wastewater effluent
would be discharged to the Gulf via a common outfall. The SASS percolation
ponds and IBU trickle field would be abandoned. Pumping stations and force
mains would be constructed at SASS, GSUB, and IBU to convey the wastewater to
a common outfall. The common outfall would begin at the intersection of
Routes 180 and 59 and would follow Route 59 to the Gulf of Mexico. Three
different outfall lengths were examined - 1 mile, 3 miles and 6 miles off
shore. These options are referred to as Alternative 2A, 2B and 2C,
respectively.
Disposal to Intracoastal Waterway
The three wastewater treatment plants would continue to operate as
tertiary treatment plants under the GIWW disposal alternative (Alternative 3).
The SASS plant does not currently have a permit to discharge wastewater to the
GIWW so the SASS treated effluent would be discharged to the existing perco-
lation ponds. IBU would discharge 1.0 mgd to the existing IBU trickle field
and the remaining effluent, in excess of 1.0 mgd, would be discharged to the
GIWW. All of the wastewater treated at the GSUB wastewater treatment plant,
4.28 mgd, would be discharged to the GIWW.
ES-8
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Land Application
Four different land application options, described below, were con-
sidered. SASS would continue to discharge its effluent to the existing perco-
lation ponds and IBU would continue to discharge 1.0 mgd to the existing
trickle field. Additional land application sites would be needed by IBU for
the remaining 2.46 mgd and new sites would be needed by GSUB for its entire
flow. Both the IBU and GSUB wastewater treatment plants would be converted to
provide secondary treatment plus effluent filtration and disinfection.
With Alternative 4A, slow-rate land application on Pleasure Island, IBU
would purchaes 53 acres of land on Pleasure Island for the disposal of 2.46
mgd. Park land, golf courses, or sites on Ono Island could also be
negotiated. GSUB would apply its effluent on the existing Gulf State Park
golf course and Gulf Shores Golf Club golf course. The wastewater would be
applied using the existing golf course irrigation distribution systems. In
addition, GSUB would purchase 70 acres on the west side of the Meyer Tract for
land application.
With Alternative 4B, high-rate land application on Pleasure Island with
reuse north of the GIWW, IBU would purchase 26 acres on the east side of the
Meyer Tract and GSUB would purchase 36 acres on the west side. Rapid infil
tration basins, groundwater recovery wells and a pump station would be
constructed on each site. IBU and GSUB would construct force mains to carry
recovered groundwater from the rapid infiltration basins to a common force
main which would convey the recovered groundwater to the Craft sod farm and
Craft Cotton Creek Club golf course north of the GIWW. The recovered ground-
water would be land applied using slow-rate application techniques.
Alternative 4C includes high-rate land application on Pleasure Island
with wetland discharges. IBU would purchase 26 acres on the east side of the
Meyer Tract and GSUB would purchase 36 acres on the west side. Rapid
tration basins, groundwater recovery wells and a pump station would be
structed on each site. IBU and GSUB would construct force mains to transport
ES-9
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the recovered groundwater from the rapid infiltration basins to the wetlands
south of each site. The recovered groundwater would be discharged into the
wetlands.
Alternative 4D involves slow-rate land application north of the GIWW.
Pumping stations and force mains would be constructed to carry the combined
IBU and GSUB wastewater along Route 59, across the GIWW and north to the Craft
sod farms and the Craft Cotton Creek Club golf course. The wastewater would
be distributed using the existing irrigation equipment.
Preferred and Accepted Alternatives
A "preferred alternative" is defined as being superior in terms of
environmental soundness, cost effectiveness or both. When federal funds are
used to assist a project, the action would have to be consistent with the
recommendations in the EIS and not conflict with the preferred alternatives.
This EIS has identified a preferred alternative and an acceptable
alternative; 40 CFR 1502.14 (e) provides that one or more preferred
alternatives may exist. Within the context of the two alternatives, ADEM may
pursue the course of action that is most appropriate without foreclosing the
use of federal funding.
If ADEM were to approve a project, using federal funding, which was
significantly different from the preferred and acceptable alternatives, a
supplemental EIS would have to be prepared. The supplemental EIS would need
to justify, in economic, technical, and environmental terms, why the two
selected alternatives were no longer viable.
This EIS has identified preferred and acceptable alternatives, land
application and no-action, for each of the three WUTP operators in South
Baldwin County. Although the alternatives are not necessarily identical, bot
are considered to be environmentally sound and cost-effective
ES-10
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GSUB
The preferred alternative for GSUB is Alternative 4A, slow-rate land
application on Pleasure Island. The plant would be converted to provide
secondary treatment with effluent filtration and disinfection. The effluent
would be slow-rate land applied to golf courses and a dedicated site on the
west side of the Meyer Tract.
The no-action alternative, Alternative 1, would constitute an acceptable
alternative for GSUB. The treatment plant would continue to provide tertiary
treatment and all the effluent would be discharged to the GIWW.
IBU
The preferred alternative for IBU is slow-rate land application on
Pleasure Island, Alternative 4A. IBU's treatment plant would provide
secondary treatment with effluent filtration and disinfection. The full
permitted amount of effluent (1.0 mgd) would be discharged to the existing
trickle field and the remaining effluent would be slow-rate land applied to
site on the east side of the Meyer Tract.
The acceptable alternative for IBU is no-action, Alternative 1. IBU
would discharge 1.0 mgd to the existing trickle field. The remaining effluent
would be treated to National Pollutant Discharge Elimination System (NPDES)
effluent limitations and discharged to the GIWW (up to 1.6 mgd additional) and
land applied to a new site to be obtained by IBU.
S4SS
For SASS, the no-action and land application alternatives are similar
inasmuch as all flows go into percolation ponds. The existing SASS plant can
accommodate the ultimate flow based on the medium growth population
projections, so no expansion/modification of the plant would be required.
SASS would continue to discharge its effluent to the existing percolation
ponds, but some mitigation is recommended.
ES-11
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Kev Environmental Considerations and Needed Mitigation
The no-action alternative for GSUB involves surface water discharge to
the GIWW while the no-action alternative for IBU involves a combination of
surface water discharge and land application. The environmental concerns and
mitigation measures regarding land application are discussed with the land
application alternative.
The GIWW has experienced water quality degradation problems in the past
and is considered a recreational resource. To mininize nutrient enrichment
and contamination of the GIWW from the wastewater discharges, the wastewater
should continue to be treated to tertiary standards. The water quality of th<
GIWW should be routinely monitored to detect any water quality problems that
could be attributable to the wastewater discharges.
Ecological impacts to the GIWW and adjacent estuaries could result under
the acceptable alternatives for IBU and GSUB, which include wastewater dis-
charges to the GIWW. Ecological impacts of wastewater discharges correlate
directly with water quality impacts. If loading increased above the assimila
tive capacity of the environment, DO violations would increase. Concurrently
the potential for nuisance algal blooms and associated adverse biological
impacts would increase.
Water quality modeling conducted by ADEM concluded that wastewater dis-
charges by existing point sources, both continuous and intermittent, are not
the primary contributors to the DO and algal growth problems. The modeling
study identified benthic oxygen demand, ambient BOD from the waters of Wolf
and Oyster Bays, and non-point and point source discharges as being the
factors contributing to the low DO. Wasteload allocation modeling (Tetra
Tech, Inc., 1984) suggests that an increase of 1,000 pounds of B0D5 per day
over current 1985 inputs of 110 pounds of BOD5 per day would decrease the
minimum DO levels by about 0.1 mg/L. The year 2010 BOD5 inputs would not
appear to cause a substantial decrease in DO levels, but if discharges to the
GIWW were continued, the GIWW should be routinely monitored to ensure that nc
significant decline in DO levels occurred.
ES-12
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Although wastewater discharge may not be the primary cause of the low DO,
they do contribute particulate matter and BOD and are subject to upset condi-
tions, which can lead to the discharge of partially or untreated wastewater.
These sources of pollution are controllable and removal of even low quantities
of pollution input may improve the GIWW water quality.
The GIWW will continue to be eutrophic in the future, due to sediment
oxygen demand, non-point source inputs, sediment nutrient releases, and
consequent stimulation of algal blooms in late summer. Large power vessels
will continue to resuspend sediments, perpetuating sediment nutrient releases
and elevating suspended solids concentrations. Some of these sediment
problems exist today because of historic discharges which did not meet
appropriate limits. The GIWW will eventually recover if such discharges do
not exceed their limits; recovery could occur somewhat faster if discharges
are reduced or eliminated.
The land application alternatives for GSUB and IBU would involve land
application on Pleasure Island. The key environmental concerns with land
application would be the potential for groundwater contamination an
formation of aerosols at the spray site.
The potential for groundwater contamination would be minimized with
several mitigation measures: 1) the applied wastewater would recharge
alluvial/coastal aquifer, rather than the Pliocene/Miocene aquifer (the major
source of drinking water in the area), 2) the wastewater would
secondary treatment, plus effluent filtration and disinfection prio
application, 3) the application rate would be consistent with the crop uptake
and soil capacities, and 4) the groundwater quality upgradient and down
gradient from the site would be monitored.
Mitigation measures to minimize aerosols and the public s exposure to
them would include the following: 1) treating the wastewater to secondary
standards and including effluent filtration and disinfection, 2) designing the
distribution system to reduce aerosols (e.g., using low pressure, downward-
directed nozzles, 3) limiting public access to dedicated application sites,
4) applying wastewater to public use sites at low use times (in the late
ES-13
-------
evening and early morning) , and 5) locating a buffer zone around the spray
site and planting vegetation in this area.
The land application alternative for SASS, which is also the acceptable
alternative, invovles the use of the existing percolation ponds. The major
concern with this alternative is the possibility of breakthrough, which could
lead to groundwater contamination and nutrient enrichment and possible con-
tamination of Oyster Bay.
This EIS recommends the percolation ponds be monitored until break-
through is detected (i.e., the point at which the wastewater effluent would
enter groundwater without receiving additional treatment through soil
contact). At that point in time, the SASS plant's permit would be restruc-
tured to allow the discharge of a percentage less than the breakthrough flow,
perhaps 90 percent, to the percolation ponds. An additional land application
site would have to be identified for disposal of the excess effluent.
Bpcnmmp.nded Non-Point Source Controls
Non-point source pollution can be attributed to failing on-lot treatment
systems, erosion at construction sites, the creation of large impervious areas
(e.g., parking lots, roads, buildings), and increased use of pesticides and
fertilizers. Providing sewerage service to areas with failing on-lot systems
would eliminate this source of pollution. The other sources must be addressed
through appropriate control strategies.
ADEM established a non-point source management program in 1989 pursuant
to the Federal Water Quality Act of 1987. This plan will be implemented from
1989 - 1992, and includes the use of Best Management Practices (BMPS) to
control erosion and sedimentation. The Gulf Shores area should adhere to
ADEM s guidelines to control future and existing non-point source pollution.
ES-14
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PURPOSE AND NEED
FOR ACTION
-------
1.0 PURPOSE AND NEED FOR ACTION
1.1 PURPOSE AND SCOPE OF EIS
The purpose of this EIS is to identify the most appropriate wastewater
management strategies for the Gulf Coast region of South Baldwin County,
Alabama. This EIS provides a comprehensive analysis of current wastewater
management strategies and evaluates available alternative strategies.
1.2 BACKGROUND AND ISSUES
Historically, the wastewater treatment and disposal needs of the study
area (the area between U.S. Highway 98 and the Gulf of Mexico including Gulf
Shores, Orange Beach, Romar Beach and Fort Morgan) were met primarily by
individual septic systems. In addition, sewered flows were treated with
three-cell lagoon system, operated by a utility organized by the City of Gulf
Shores, which discharged to the Gulf Intracoastal Waterway (GIWW).
Hurricane Frederick struck South Baldwin County in 1979 causing the
destruction of buildings, the alteration of the physical features along par
of the coastline, the contamination of the coastal aquifer by salt water, an
the removal of some septic systems from the ground. Other septic systems were
damaged in less obvious ways.
Disaster relief started a land boom that resulted in rapid popu
growth and for a time the growth of the seasonal and permanent popul
so great that the area became one of the fastest growing regi
in the country. The increased wastewater flow associated with th g
could not be handled with the existing limited wastewater treatment resources.
The lagoon system became overloaded and could not meet disc g
Also, state health officials were concerned about the number of sep
systems constructed in low lying areas and the concomitant reli
j lWAucse of the obvious need tor
shallow underlying aquifer for water needs.
1-1
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wastewater treatment facilities, the City of Gulf Shores began planning for a
sophisticated, state-of-the-art treatment system and several entrepreneurs
built state-of-the-art treatment plants.
South Baldwin County is currently served by one publicly-owned and two
privately-owned wastewater treatment plants (WWTP) which employ the treatment
and disposal practices listed below. The construction of these facilities
was substantially completed in 1989
1) The Utilities Board of the City of Gulf Shores (GSUB): tertiary
treatment plant, wastewater effluent discharged to the GIWW.
2) Island Bay Utilities (IBU) (private enterprise): tertiary treatment
plant, wastewater effluent land applied and/or discharged into the
GIWW.
3) The South Alabama Sewer System (private enterprise): tertiary
treatment plant, wastewater effluent discharged to percolation
ponds.
M>EM has been concerned about periodic occurrences of low dissolved
oxygen concentrations in the GIWW and area estuaries that resulted in fish
kills. Several seafood processor discharged wastewater in the GIWW and it is
not known to what extent the seafood processors and sanitary wastewater
discharges were contributing to the GIWW's low DO.
To provide a technical basis for water quality management decisions, ADEM
began water quality modeling studies of the GIWW in 1982. The studies included
key observations regarding the transport characteristics of the GIWW between
Bon Secour and Wolf Bays.
Additional technical information was provided by the EPA who began a
year-long oceanographic study in mid 1985 to support decision-making on
outfalls to the Gulf of Mexico. Also, the Geologic Survey of Alabama provided
groundwater modeling information to be used in the evaluation of potential
land application sites on Pleasure Island and the farmlands north of the GIWW.
1-2
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This EIS used the information described above to evaluate the areas of
concern with the potential disposal options, including: 1) the potential for
nutrient enrichment and beach impacts with a Gulf discharge, 2) the impact of
continued wastewater discharges to the environmentally stressed GIWW, and 3)
the potential for groundwater contamination with land application, given the
fact that most of the fresh water in the area is derived from groundwater
resources. The purpose of the EIS is an in-depth evaluation of the various
disposal alternatives and the identification of the cost-effective,
environmentally sound solution.
1-3
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ALTERNATIVES DEVELOPMENT
AND SCREENING
-------
2.0 ALTERNATIVES DEVELOPMENT AND SCREENING
2.1 INTRODUCTION
The first step in wastewater management planning includes a survey of
existing conditions and a projection of future demands in order to determine
facility and management needs. Major components of the survey are: planning
area populations, wastewater generation rates and current wastewater manage-
ment practices. Future needs are determined so that management alternatives
that meet these needs can be developed and evaluated. This section reviews
the existing conditions in the South Baldwin County study area, projects
future population and resultant wastewater flows and develops preliminary
alternatives for the treatment and disposal of the region's wastewater.
2.2 BACKGROUND INFORMATION
2.2.1 Existing Wastewater Management Practices
Wastewater in the study area is treated in a variety of ways including
individual homeowner septic tanks, small community systems, and three waste-
water treatment plants, GSUB, IBU and SASS. In addition, six industrial
wastewater treatment plants serve the seafood and petroleum industries. The
location of the GSUB, IBU and SASS plants are shown on Figure 2-1.
Currently, GSUB has a 3-mgd plant which uses the extended aeration Orbal
process plus microscreens, and discharges all of its treated effluent to the
GIWW. The NPDES permit allows effluent limits of 4 mg/L BOD5, 1 mg/L NH3-N, 3
m8/L TKN and 5 mg/L DO. Sludge is placed on drying beds and subsequently
hauled to a landfill. The plant began operating in December 1987.
IBU has two plants; however, one of these two plants, known as the former
Baldwin County Sewer Authority Plant, is inactive. The other IBU facility,
formerly known as the Pleasure Island Sewer Service, is a 1.6-mgd plant that
uses the extended aeration activated sludge Schreiber process plus micro-
screens. To upgrade the plant, an activated carbon column with 0.75 mgd
2-1
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140814
BON SECOUR NATIONAL
WILDLIFE REFUGE
GULF
LEGEND
PLANT
¦SHELBY LAKES
SOUTH BALDWIN COUNTY,ALABAMA
WASTEWATER MANAGEMENT EIS
LOCATION OF
TREATMENT PLANTS
SCALE IN MILES
US EPA REGION I3E
ATLANTA ,GEORGIA
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capacity and ultraviolet sterilizing units to reduce fecal coliform bacteria
were added. The NPDES permit contains effluent limits of 2.0 mg/L BOD5 and
0.6 mg/L TKN for discharges to the GIWW. IBU owns a trickle field land appli-
cation site, located behind the treatment facility, which is permitted by ADEM
for a maximum of 1.0 mgd of wastewater disposal. Sludge is placed on drying
beds and subsequently hauled to a landfill. The plant went into full
operation in July of 1988.
Currently, SASS has a 1.8 mgd plant using the extended aeration activated
sludge Schriber process followed by sand filters. ADEM has permitted 1.2 mgd
of flow to percolation ponds on the SASS site. The NPDES permit to the ponds
is as follows: 5 mg/L BOD5 and 1.0 mg/L NH3-N. Sludge is placed on drying
beds and subsequently hauled to a landfill. The expanded plant started
operation in 1987.
2.2.2 Population Projections
Alternate population projections were prepared for low, medium and high
growth. Table 2-1 summarizes the population for the permanent, seasonal and
total residential population for the three growth projections for each
sewerage district. The five-year growth rates for permanent and seasonal
residents are also presented for each of the three sewerage districts.
2.2.3 Wastewater Flow Projections
This section presents projected wastewater flows for the three major
sewerage districts in the EIS study area. The districts were artificially
created for this EIS to facilitate analysis of area wastewater needs and do
not necessarily reflect existing political or franchise boundaries. The
districts are shown on Figure 2-2.
The wastewater flow due to seasonal and permanent residents was calcu-
lated first, followed by the calculation of the wastewater flows generated by
commercial and day visitors. The two flows were added to determine the total
wastewater generated in each district. The flows handled by small community
2-3
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Table 2-1. Population Growth Scenarios of Permanent and
Seasonal Residents at Simmer Peak
5-Year
1985 2000 2010 Growth Rate %
Sewerage District Permanent Seasonal Total Permanent seasonal Total Permanent Seasooat Total Permanent Seasonal
A. tow Growth Scenario
IBU
4,310
17,918
22,228
5,599
20,954
26,553
6,410
24,895
31,305
7
9
GUSC
2,463
13,683
16,146
3,400
16,559
19,959
3,892
19,674
23,566
7
9
SASS
3.770
3,218
6.989
4.434
6,774
11,208
5,076
8.048
13.124
7
9
TOTAL
10,543
34,819
45,363
13,433
44,287
57,720
15,378
52,617
67,995
Medium Growth Scenario
IBU
4,310
17,918
22,228
6,771
28.665
35,436
8,799
41,969
50,768
14
21
GUSC
2,463
13,683
16,146
4,111
22,652
26,763
5,342
33,165
38,507
14
21
SASS
3.770
3.218
6,989
5,363
9.267
14.630
6.969
13.568
20.537
14
21
TOTAL
10,543
34,819
45,363
16,245
60,584
76,829
21,110
88,702
109,812
High Growth Scenario
IBU
4,310
17,918
22,228
8,096
46,333
54,429
11,853
93,427
105,280
21
42
GUSC
2,463
13,683
16,146
4,916
36,614
41,530
7,198
73,828
81,026
21
4?
SASS
3.770
3.718
6.989
6,412
14,978
21,390
9,387
30.204
39.591
21
42
TOTAL
10,543
34,819
45,363
19,424
97,925
117,349
28,438
197,459
225,897
2-4
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ALABAMA
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WILDLIFE REFUGE
SOUTH BALDWIN COUNTY, ALABAMA
WASTEWATER MANAGEMENT E I S
APPROXIMATE
SEWERAGE DISTRICT
AREAS
SCALE IN MILES
US EPA REGION 12
ATLANTA , GEORGIA
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systems and septic tanks were subtracted from the total for each district to
project the flows that would be entering the three sewer systems.
Total wastewater flows are presented in Table 2-2 for the three growth
projections. All flows presented in the table were calculated at summer peak
in order to present the maximum flow. The high growth rate scenario most
closely reflects the recent growth of the area. However, the tax reform act
of 1986 and its effect on second home ownership may result in a decrease in
seasonal unit development as compared to previous levels. The medium growth
scenario appears to represent a more likely estimate of future growth in the
study area. Therefore, the E1S will focus on the medium growth projections.
2.2.4 Flow and Waste Reduction Analysis
In the study area, wastewater flow volumes are proportionately related to
the public water consumption. Based on consultations with ADEM and the three
sewerage plant operators concerning the quantity of water usage that would
become wastewater, the average per capita residential wastewater production
was determined to be 100 gpd. This value was used in the future flow pro-
jections, but the number could be revised as better data becomes available.
The per capita number assumes that some form of water conservation would be
instituted, if necessary, to limit the increases expected in per capita water
consumption.
In addition to establishing water conservation practices, the hydraulic
loading to a treatment plant can also be reduced by instituting the practice
of routine sewer system maintenance to locate and repair areas with excessive
infiltration and/or inflow. GSUB, the only sewerage district with gravity
sewers, currently has such a program. Associated with this program is the
requirement that developer installed sewers conform to sewer system specifica-
tions and that new sewers be tested for tightness during installation.
2-6
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Table 2-2. Total Flows by Sewerage District
in Million Gallons Per Day at Summer Peak
Sewerage
District 1985 1990 1995 2000 2005 2010
A. Low Growth Scenario
IBU 0.39 0.50 0.66 0.83 1.07 1.33
GSUB 1.76 1.83 2.00 2.18 2.38 2.59
SASS 0.01 0.10 0.20 0.32 0.41 0.51
Total 2.16 2.43 2.85 3.34 3.86 4.43
B. Medium Growth Scenario
IBU
0,
.39
0.
.74
1.20
1,
.77
2.
.53
3,
.46
GSUB
I,
.76
2.
.02
2.45
2
.96
3.
.56
4,
,28
SASS
0
.01
0.
.14
0,33
0
.61
0.
.87
1.
.18
Total
2,
.16
2.
.89
3.98
5.
.33
6.
.96
8.
,92
C. High Growth Scenario
IBU 0.39 1.12 2.22 3.76 6.08 9.38
GSUB 1.76 2.34 3.29 4.60 6.43 8.97
SASS 0.01 0.19 6.57 LJJL 1-93 2.96
Total
2.16 3.65 6.08 9.54 14.44 21.30
2-7
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2.3 DEVELOPMENT OF WASTEWATER MANAGEMENT CONCEPTS
2.3.1 Sewerage Districts
For the purposes of this EIS, the study area was divided into five
sewerage districts, which are shown on Figure 2-2. Two of the five, Weeks Bay
and Perdido Beach, will be served by small community systems and septic tanks.
The other three, IBU, GSUB, and SASS, will be mostly served by the three
wastewater treatment plants, although a small portion of each of the three
sewerage districts will continue to be served by small community systems and
septic tanks. The boundaries of these districts are not well defined;
individual operators would provide sewerage service as needs arise in areas
where it would be cost effective for the plant owner to provide the service.
Each of the three sewerage districts, IBU, GSUB, and SASS, currently operates
a wastewater treatment plant and disposes of the wastewater as described in
Section 2.2.1.
2.3.2 Treatment Systems
The degree of wastewater treatment required is linked to the wastewater
effluent disposal method. Higher levels of treatment remove more organic
matter and solids to decrease the amount of oxygen demanding substances and
the quantity of nutrients (e.g., nitrogen, phosphorus) leaving the treatment
plant. Higher levels of treatment may be required to prevent degradation of a
sensitive surface water body that would receive the effluent. Lower levels of
treatment could be used if disposal methods, such as land application, are
used that are not as sensitive to inputs of solids, nutrients and oxygen
demanding substances.
Currently, the three wastewater treatment plants practice tertiary
treatment using the extended aeration activated sludge process in combination
with clarification, effluent filtration and disinfection. An alternative to
conventional treatment methods is the use of wetland hyacinth cells. Several
systems of this type are operating vlthin the State of Alabama or proposed for
operation. Some examples are listed below.
2-8
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1. Camp Hill, Alabama - (1988) a 0.15 mgd water hyacinth cell for
advanced treatment.
2. Fort Deposit, Alabama - (1990) a 0.24 mgd system comprising three
wetland cells.
3. Citronelle, Alabama - (1990) a 0.35 mgd system with one water
hyacinth cell.
4. Luverne, Alabama - (1990) a 0.45 mgd system with 3.3. acres of water
hyac inths.
5. Cottonwood, Alabama - (1989) a 0.155 mgd lagoon/water hyacinth/rock
reed filter system; the rock reed filter portion is used for final
effluent polishing.
Although created wetlands are good systems that have been used
successfully for wastewater treatment, they do not represent a viable option
for wastewater treatment in the study area. The main reason is because the
treatment plants were already built or scheduled to be built before the EIS
was underway. Therefore, an examination of created wetlands as a treatment
method is after-the-fact. In addition, the flows that are projected for the
end of the 20-year planning horizon, using the medium growth projection,
(GSUB-4.28 mgd, IBU-3.46 mgd, SASS - 1.8 mgd) would require large tracts of
land to be dedicated to wetland treatment. For example, using EPA hydraulic
loading criteria, the created wetland area required for the treatment of
GSUB's wastewater could be between 200 and 250 acres. The systems currently
in use in Alabama tend to have smaller flows (the examples range between 0.15
mgd and 0.45 mgd) so these projected flows may be a bit large for a wetland
system.
Another consideration is the highly cyclical nature of the wastewater
flows. The area has a large tourist and temporary population which causes
weekday versus weekend flow variations as well as summer versus winter
2-9
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variations. The wetland systems may not be able to handle these wastewater
surges, given that the detention time must be 5-7 days for full treatment.
Created wetlands do not present a viable alternative for the Gulf Shores
area at present, but they may warrant more consideration in the future as the
area progresses.
2.3.3 Disposal
Two wastewater disposal methods were examined - surface water discharge
and land application - in the final phase of the alternatives development.
Surface water discharges would include the GIWW and the Gulf of Mexico. Land
application could be slow-rate irrigation or rapid infiltration. Potential
land application sites include golf courses, farm land such as existing or
future sod farms and land which would be purchased and dedicated to land
application activity.
Four disposal alternatives were examined: no action, GIWW discharge, Gulf
of Mexico discharge and land application and each is introduced below.
2.3.3.1 No-Action
The objective of the no-action alternative is to present the wastewater
treatment and disposal options that would be instituted in the study area if
no construction grants (Title 2 of the Clean Water Act) or Revolving Loan Fund
(Title 6 of the Clean Water Act) money were available for GSUB for treatment
and disposal facilities. Neither Title 2 nor Title 6 funds would be available
for SASS or IBU since both sewerage districts are owned and operated by
private investors. The State of Alabama does not maintain a construction
grants program with a state appropriated budget.
2-3.3.2 Disposal to the Gulf of Mexi'cn
The objective of this alternative would be to utilize the Gulf of Mexico
for the disposal of wastewater from all three wastewater treatment plants.
2-10
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The combined wastewater flow from the three plants would be discharged from an
outfall one to six miles offshore. A potential location for the outfall,
immediately south of State Highway 59, was selected to minimize the number of
interceptors needed to reach the outfall.
2.3.3.3 Disposal to Intracoastal Waterway
The objective of this alternative would be to utilize the Intracoastal
Waterway for the disposal of wastewater from the IBU and GSUB wastewater
treatment plants. The SASS plant currently does not have a permit to
discharge to the GIWW so they would continue to utilize percolation ponds.
2.3.3.4 Land Application
The objective of this alternative would be to utilize land application
sites to dispose of all wastewater generated by the three wastewater treatment
plants. The existing GSUB and IBU discharges to the GIWW would be eliminated.
This EIS does not provide the detailed on-site engineering analyses that
would be needed for land disposal site evaluations. The ADEM "Guidelines for
Land Application of Treated Waste" established a two phase approach to obtain
regulatory approval for land application. In Phase 1, a preliminary report
must be submitted that describes the feasibility of land application. The
report must include: preliminary design criteria, site limitations, charac-
teristics of the wastewater effluent, and data regarding climate, topography,
geology, soils, depth and quality of groundwater, and general land use. If
the Phase 1 report determines the project is feasible, a Phase 2 report must
be written, which is a detailed continuation of Phase 1. Included in this
report are: detailed design criteria, limitations and a water and nutrient
mass balance. Soil test borings must be taken to verify the soil series and
groundwater quality must be determined. All potentially effected water supply
wells have to be located and plotted and water quality analysis must be
performed on each well. Only after the land application was proven feasible
and environmentally acceptable, would it receive regulatory approval.
2-11
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Various sites were evaluated and are shown in Table 2-3 and on Figure
2-3. The options for land application that were examined in depth were slow-
rate and high-rate land application. Typical slow-rate application involves
application rates (hydraulic loading) of 0.1 to 6 inches per week, depending
on the permeability of the soils and the nitrogen uptake of the crop. With
this land application method, the wastewater is applied directly on the land.
Slow-rate application sites on both Pleasure Island and north of the GIWW were
considered as well as existing slow-rate sites such as golf courses and sod
farms. At these sites the owner would control the rate of application. At
sites which would be purchased, the operators of the treatment plants would
control the rate of application.
Typical high-rate application involves land application rates of up to 48
inches per week and involves the use of a rapid infiltration basin. To
prevent groundwater mounding near the basins, shallow extraction wells should
be constructed to recover the water. The recovered water could be discharged
to wetlands or slow-rate land application sites or it could be injected into a
groundwater aquifer. Injection of the recovered wastewater into a groundwater
aquifer was not considered in this EIS because of the State of Alabama's
underground injection control policy. Only sites on Pleasure Island were
considered for rapid infiltration so that the sites would be close to the
existing plants, but sites on both Pleasure Island and North of the GIWW were
considered for the slow-rate application of the recovered groundwater
2.3.4 Sludge Treatment and Disposal
The current operation of the treatment plants requires only sludge
dewatering on sludge drying beds. The dried sludge is then transported to a
landfill for disposal. Some of the wastewater management alternatives would
permit the conversion of treatment plant operation from tertiary to secondary
which not only increases the throughput of the plant but also the quantity of'
sludge generated. Additional sludge handling units, such as aerobic sludge
digestion, would have to be added to the plants to handle the increased sludge
production. The digested, dried sludge would continue to be disposed of in
the landfill. Due to decreasing availability of landfill space, however
2-12
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Table 2-3. Summary
Site
1. Gulf Shores Golf Club
2. Gulf State Park Golf
Course
3. IBU Trickle Field
4. Meyer Tract East of Bon
Secour Bay
5. Meyer Tract West of IBU
6. SASS Percolation Ponds
7. Craft Cotton Creek Club
Golf Course
8 . Craft Sod Farm
9. Future Craft Sod Farm
10. Land East of Jack Edwards
Airport
11. Land West of State Route 51
(1) Permitted values.
Land Application Sites
Irrigation Peak Month
Limiting Suitable Capacity
Factor Acres fmgd)
Hydrology 50 0.58
Hydrology 100 0.14
- (1) 20 1.00
Nitrogen 310 22.9
Nitrogen 220 14.2
- (1) 12 1.2
Hydrology 130 0.18
Hydrology 1,000 7.06
Hydrology 250 1.77
Hydrology 270 1.91
Nitrogen 230 16.7
2-13
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140814
SHELBY LAKES
MEXIC0
BON SECOUR NATIONAL
WILDLIFE REFUGE-
CD
C
X
m
to \
LEGEND
¦ PLANT
A DISPOSAL POINT (SW)
A DISPOSAL POINT ( LA)
SOUTH BALDWIN COUNTY, ALABAMA
WASTEWATER MANAGEMENT E.I S
EXISTING AND POTENTIAL
LAND APPLICATION
SITES
SCALE IN MILES
US EPA REGION LZ
ATLANTA , GEOR GI A
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alternative disposal methods should be considered. The use of dried sludge as
a soil amendment is encouraged, provided that low toxicity can be demonstrated
and sludge application is consistent with state and federal guidelines.
2.3.5 Industrial Discharges
There is currently one seafood processing plant discharging into the GSUB
WWTP. Except for restaurants, laundries and one small plastics manufacturer,
there are no major industrial discharges in the South Baldwin County area.
Most seafood processing in the area involves shrimp, which occurs from
May through December, and oysters. The average flow from the processors is
generally less than 100 gallons per day because they operate only intermit-
tently. Simple washing operations produce a wastewater typically averaging 5
mg/L of suspended solids. Peeling and deveining operations, even when con-
ducted on a small scale, can result in discharges of more than 1,000 pounds
per day of organic solids.
2.4 WASTEWATER MANAGEMENT SCREENING
The initial screening of alternatives was conducted in 1985 by ADEM and
the U.S. EPA. These agencies held a public workshop in September 1986 to
allow for participation by local governments, organizations and individuals in
the alternatives selection procedure.
2.4.1 Technical Feasibility and Implementabilitv
As the alternatives screening progressed, many impractical and less cost
effective alternatives were discarded as were alternatives which were judged
to be essentially the same. About 30 alternatives were discussed at the
public workshop.
2-15
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2.4.2 Selected Alternatives for Detailed Evaluation
Following the screening process, the following four alternatives were
selected for detailed evaluation:
1. No action;
2. Disposal via a Gulf outfall;
3. Disposal to the Intracoastal Waterway; and
4. Disposal via land application.
Three options were considered for Alternative 2:
2a. Disposal one mile offshore;
2b. Disposal three miles offshore; and
2c. Disposal six miles offshore.
Four options were considered for Alternative 4:
4a. Slow-rate land application on Pleasure Island;
4b. High-rate land application on Pleasure Island with reuse north of
the Intracoastal Waterway;
4c. High-rate land application on Pleasure Island with wetland
discharges; and
4d. Slow-rate land application north of the Intracoastal Waterway.
2-16
-------
ALTERNATIVES EVALUATION
-------
3.0 ALTERNATIVES EVALUATION
3.1 SELECTED ALTERNATIVES
No-action and three comprehensive wastewater management alternatives for
the South Baldwin County study area have been selected for a detailed analysis
of economic costs and environmental impacts. For one alternative, land appli-
cation, four different options have been analyzed. For another alternative,
disposal via a Gulf outfall, three options have been considered. The four
alternatives include facilities for the treatment of wastewater and disposal
of treated effluent and residual waste products.
3.1.1 Wastewater Treatment
Three types of wastewater treatment systems are used in conjunction with
the four wastewater disposal alternatives. The systems vary from secondary to
secondary plus effluent filtration to tertiary.
Secondary treatment refers to the removal of BOD5 (5 day biochemical
oxygen demand) and suspended solids (SS) to concentrations of 30 mg/L or less
(often referred to as the 30/30 standard) and the maintenance of a pH between
6.0 and 9.0. Secondary treatment, in general, involves preliminary treatment
to remove grit (e.g., dirt, sand, seeds), biological processes to remove
organic matter, final settling to remove organic solids, and disinfection to
destroy pathogenic constituents. Specifically, the unit processes that would
be used by each treatment plant to achieve secondary treatment are listed
below:
1. IBU - Influent pumping, bar screen, grit removal, conventional
activated sludge, secondary clarification, and ultraviolet (UV)
disinfection.
2. GSUB - Remote pump station and force mains, static screen, grit
removal, conventional activated sludge, secondary clarification,
chlorination, and post-aeration.
3-1
-------
3. SASS - Influent pumping, bar screen, grit removal, conventional
activated sludge, secondary clarification, and chlorination.
In some alternatives, secondary treatment is combined with effluent
filtration to produce lower concentrations of BOD5 and SS in the effluent.
The IBU and GSUB plants would use effluent micorscreens, while the SASS plant
would use an effluent sand filter in addition to the secondary treatment
components listed above.
Tertiary treatment refers to the addition of unit processes beyond
secondary to achieve a greater degree of treatment than the 30/30 secondary
standard. Generally, this type of treatment is required if nutrient removal
is desired (nitrogen and phosphorus) or if stringent BOD5 or SS limits are
imposed. Currently, the IBU, GSUB and SASS plants are operated as tertiary
treatment plants. The unit processes that are different or additional to
upgrade the plants to tertiary are listed below.
1. IBU - Extended aeration (achieves nitrification), effluent
mitroscreens, carbon adsorption, and cascade aeration.
2. GSUB - Extended aeration (achieves nitrification), and effluent
microscreens.
3. SASS - Extended aeration (achieves nitrification) and effluent sand
filters.
Secondary treatment plus effluent filtration would be used with all land
application alternatives. Secondary treatment would be used if the effluent
were discharged to the Gulf of Mexico. Discharges to the GIWW would require
tertiary treatment.
3.1.2 Wastewater Disposal
Four different wastewater disposal alternatives were examined, including
discharges to the GIWW, the Gulf of Hexico and land application. Depending on
the disposal option, either secondary, secondary plus filtration, or tertiary
3-2
-------
wastewater treatment would be required. A description of each of the disposal
alternatives, based on the medium growth projection only, is presented below.
(The criteria for selecting the medium growth projection were presented in
Section 2.2.3). Table 3-1 contains a summary of the major physical components
needed for each of the disposal alternatives.
3.1.2.1 Alternative 1: No-Action
The no-action alternative would represent the wastewater management
strategy that would take place if no federal funding were available for the
GSUB wastewater treatment and disposal facilities. The IBU and SASS plants
are privately owned and operated; so federal funding would not be available
for these facilities regardless of the alternative selected. The no-action
alternative would not restrict local, or private investment in wastewater
management. The no-action alternative does not imply no growth in the study
area; growth would occur in response to previously committed investments and
continuing pressures for new residential construction.
Under the no-action alternative, the GSUB wastewater treatment plant
would continue to treat wastewater to tertiary effluent standards and would
discharge all 4.28 mgd (ultimate flow rate with medium growth projections) to
the GIWW. The SASS wastewater treatment plant would also provide tertiary
treatment but the final effluent would be discharged to the existing SASS
percolation ponds. IBU would continue to use tertiary treatment and land
apply the effluent, up to the authorized 1.0 mgd, on the dedicated trickle
field site they currently own. For the discharge of the excess wastewater
effluent, IBU could employ its existing carbon column technology to achieve
the required effluent limitations and discharge up to an additional 1.6 mgd to
the GIWW. For the discharge of the remaining effluent (above 2.6 mgd) IBU
could purchase 13.5 acres on the east side of the Meyer tract for slow-rate
land application. Alternatively, IBU could pursue providing water to meet
community irrigation needs. Figure 3-1 shows the layout of the no-action
disposal alternative.
3-3
-------
3-1. Summary of Major Physical Components Required for Each Disposal Alternative
Alternative
ITEM 1 2A 2B 2C3 4A 4B AC 4D
IBU
Pumping Stations 2.46 3.46 3.46 3.46 1.86 2.46 2 32.46 2 32.46 2.46
(mgd)
Force Mains 2,600 - 10 17,600 - 18 17,600 - 18 17,600 - 18 7,200 - 14 2,600 - 14 2,600 - 14 2,600 - 14 17,100-18
(ft - inches)
Spray Field 40 40
(acres)
Rapid Infiltration - ----- 17 17
Basins (acres)
Land Purchase 53 - - - - 53 26 26
f GSUB
Pumping Stations 1.28 4.28 4.28 4.28 1.28 4.28 2 34.28 2 34.28 4.28
(mgd)
Force Mains 1,000-12 - - - 1,000-12 12,700-10 & 6,300-20 & 6,300-20 & 500-20
(ft-in) 6,300-20 500-20 6,800-20
Spray Field - ----55 - -
(acres)
Rapid Infiltration - ----- 25 25
Basins (acres)
Land Purchase - 70 36 36
(acres)
SASS
Pimping Stations - 1.18 1.18 1.18 ....
(mgd)
Force Mains - 17,600-12 17,600-12 17,600-12 ....
(ft-in)
Cotnmon
Force Mains - 21,400-30 21,400-30 21,400-30 - - 19,300-24 - 13,500-24
(ft-in) 5,280-30 15,840-30 31,680-3 2,600-8 2,600-8
(1) No facilities required
-------
140814
LEGEND
¦ PLANT
A DISPOSAL POINT (SW )
A DISPOSAL POINT (LA)
TRANSMISSION
SOUTH BALDWIN COUNTY .ALABAMA
WASTEWATER MAN AGEMENT E I S
ALTERNATIVE I -
NO FEDERAL ACTION
SCALE IN MILES
US EPA REGION HL
ATLANTA ,GEORGIA
-------
Although the No-Action alternative considers the possibility of not
receiving Federal funds, state and federal funding may be available to finance
expansion or construction of the wastewater treatment and disposal facilities.
Section 201, Title II of the Clean Water Act of 1977 (PL 95-217) provides
federal authority to fund sewage construction projects.
Although federal grants are being phased out and being replaced with
State loan programs, the State of Alabama has some federal funds to finance
wastewater projects. These 201 (Title II) funds are grants available to
eligible recipients that are not to be repaid.
Alabama also received a $10,500,000 capitalization grant in 1989 to fund
the State Revolving Fund (SRF). SRF was authorized in 1897 by the Water
Quality Act Amendments (PL 100-4; Title VI). These funds are grants given to
the State to capitalize low interest loans to eligible applicants. The State
does not repay the federal granting agency (EPA) for the SRF capitalization
grant, however, unlike the 201 funds, these loans must be repaid to the State
by the recipient.
3.1.2.2 Alternative 2: Disposal To Gulf Of Mexico
The operation of all three wastewater treatment plants would be converted
to secondary treatment under the Gulf outfall disposal alternative. All
wastewater effluent would be discharged to the Gulf via a common outfall. The
SASS percolation ponds and IBU trickle field would be abandoned. A pumping
station would be constructed at the IBU plant and a force man would be added
to convey the wastewater to the GSUB plant. A pumping station and force main
would be constructed at GSUB to convey the combined wastewater to the common
outfall. A pumping station and force main would be added to the SASS plant to
transport the SASS effluent to the outfall. The common outfall would begin at
the intersection of Routes 180 and 59 and would follow Route 59 to the Gulf of
Mexico. Three different outfall lengths were examined - 1 mile, 3 miles and 6
miles off shore which are referred to as Alternative 2k, 2B and 2C, respec-
tively. The layout of this alternative is presented in Figure 3-2.
3-6
-------
140614
BON SECOUR NATIONAL
WILDLIFE REFUGE
LEGEND
_ ¦ PLANT
g ~ DISPOSAL POINT (SW)
^ A DISPOSAL POINT (LA)
OJ TRANSMISSION
I
rv>l
I TO 6 MILES OFFSHORE
( NOT TO SCALE )
SOUTH BALDWIN COUNTY, ALABAMA
WASTEWATER MANAGEMENT EIS
ALTERNATIVE 2-
DISPOSAL VIA A
GULF OUTFALL
SCALE IN MILES
US EPA REGION HL
ATL ANTA , GEORGI A
-------
3.1.2.3 Alternative 3: Disposal To The InCracoastal Waterway
The three wastewater treatment plants would continue to operate as
tertiary treatment plants with the GIWW disposal alternative. The SASS plant
does not currently have a permit to discharge wastewater to the GIWW, so the
SASS treated effluent, 1.18 mgd, would be discharged to the existing percola-
tion ponds. IBU would discharge 1.0 mgd to the existing IBU trickle field.
The remainder of the effluent, 2.46 mgd, would be discharged to the GIWW. All
of the wastewater treated at the tfSUB Wastewater treatment plant, 4.28 mgd,
would flow to the GIWW. Because the current IBU and GSUB outfalls do not have
sufficient capacity, new pump stations and force mains would be be constructed
at each plant to convey the wastewater from the plants to their existing
points of discharge. Figure 3-3 shows the layout of this disposal option.
This alternative is similar to the no-action alternative; for GSUB and
SASS, the two alternatives are the same. The difference between the two is
the amount of wastewater IBU would discharge to the GIWW. With both
alternatives, the existing trickle field would continue to be used for the
discharge of up to 1.0 mgd. With the no-action alternative, 1.60 mgd of the
excess effluent would be discharged to the GIWW and the remaining effluent
above 2.6 would be land applied to an additional site IBU would have to
acquire. With Alternative 3, GIWW discharge, IBU would discharge all excess
wastewater (above 1.0 mgd) to the GIWW and would not acquire an additional land
application site.
3.1.2.4 Alternative 4: Land Application
Four different land application options were considered and each is
described below. SASS would continue to discharge its effluent to the exist-
ing percolation ponds and IBU would continue to discharge 1.0 mgd to the
existing trickle field. Only the additional facilities needed by IBU for the
land application of the remaining 2.46 mgd and the facilities needed by GSUB
will be discussed. Estimates of land to be acquired are based upon land
availability and costs on Pleasure Island in late 1989. Alternative sites may
of course, be considered as land application areas should they become
available. The IBU and GSUB wastewater treatment plants would be converted to
secondary treatment with effluent filtration.
3-8
-------
140814
BON SECOUR NATIONAL
WILDLIFE REFUGE-
-T\
O
e
3D
m
oj
oj
LEGEND
¦ PLANT
~ DISPOSAL POINT (SW)
A DISPOSAL POINT ( LA)
TRANSMISSION
-SHELBY LAKES
SOUTH HA I DWIN COUNTY, ALABAMA
WASltWAlf R MANAGEMENT ElS
ALTERNATIVE 3-
DISPOSAL TO GIWW
VIA MULTIPLE OUTFALLS
SCALE IIM MILES
U b L f'A REGION HZ
A T L ANTA , GEORGIA
-------
3.1.2.4.1 Option 4A! Slow-Rate Land Application On Pleasure Island
IBU would purchase 53 acres of land on the east side of the Meyer tract
for the disposal of 2.46 mgd. Center pivot sprinkling would be used on this
site. GSUB would apply its effluent on the existing Gulf State Park golf
course and Gulf Shores Golf Club golf course, using the existing golf course
distribution system. In addition, GSUB would purchase 70 acres on the west
side of the Meyer tract. The distribution of this site would be via center
pivot sprinkling.
Storage facilities would be constructed at both the IBU and GSUB waste-
water treatment plants to hold up to 14 days of wastewater. All wastewater
would be applied at slow-rate land application rates and pump stations and
force mains would be constructed to convey the wastewater effluent to the land
application sites. Figure 3-4 shows the layout of this disposal option.
3.1.2.4.2 Option 4B: High-Rate Land Application On Pleasure Island With Reuse
North of the Intracoastal Waterway
IBU would purchase 26 acres on the east side of the Meyer tract and GSUB
would purchase 36 acres on the west side. Rapid infiltration basins, ground-
water recovery wells and a pump station would be constructed on each site.
Recovery wells were assumed to be needed at a rate of 2 wells for 0-24
acres, 3 wells for 25 - 49 acres and 4 wells for over 50 acres.
IBU and GSUB would construct force mains to carry recovered groundwater
from the rapid infiltration basins to a common force main. The common main
would convey the recovered groundwater to the Craft sod farm and Craft Cotton
Creek Club golf course north of the GIWW. The recovered groundwater would be
applied at slow-rate application rates.
Storage facilities sufficient to hold up to 14 days of wastewater would
be constructed at both the IBU and GSUB plants. Figure 3-5 shows the layout
of this alternative.
3-10
-------
140614
LEGEND
PLANT
DISPOSAL POINT (SW
O
§ A DISPOSAL POINT ( LA)
m
Oj —— TRANSMISSION
i
-I*
/
XI
—i
m
<0 MEYER
TRACT
GULF
SHORES
— 4 *
, ^GULF STATE
^I^UB PARK "
SHELBY LAKES
SOUTH BALDWIN COUNTY, ALABAMA
WASTEWATER MANAGEMENT EIS
ALTERNATIVE 4A-
SLOW-RATE LA
ON PLEASURE ISLAND
SCALE IN MILES
US EPA REGION ESI
ATLANTA , GEORG tA
-------
4081 A
LEGEND
¦
PLANT
A
DISPOSAL POINT ( SW )
A
DISPOSAL POINT (LA)
TRANSMISSION
/
MEYER
TRACT
UULF Tf|
.LL-'J^gulf s'tIte
¦t&uB park
SHELBY LAKES
SOUTH BALDWIN COUNTY, ALABAMA
WASTEWATER MANAGEMENT ElS
ALTERNATIVE 4B-
HIGH-RATE LA ON
PLEASURE ISLAND WITH
REUSE NORTH OF ICW
SCALE IN MILES
US EPA REGION CHI
ATLANTA , GEORGIA
-------
3.2.3.3 Option 4C: High-Rate Land Application On Pleasure Island With
Wetland Discharges
IBU would purchase 26 acres on the east side of the Meyer tract and GSUB
would purchase 36 acres on the west side. Rapid infiltration basins,
groundwater recovery wells and a pump station would be constructed on each
site. Recovery wells were assumed to be needed at a rate of 2 wells for 0-24
acres, 3 wells for 25-49 acres and 4 wells for over 50 acres.
IBU and GSUB would construct force mains to transport the recovered
groundwater from the rapid infiltration basins to the wetlands south of each
site. The recovered groundwater would be discharged into the wetlands.
Storage facilities sufficient to hold up to 14 days of wastewater would be
constructed at both the IBU and GSUB plants. Figure 3-6 shows the layout of
this alternative.
3.1.2.3.4 Option 4D: Slow-Rate Land Application North of the Intracostal
Waterway
Pumping stations and force mains would be constructed from both the GSUB
and IBU wastewater treatment plants to a common force main. This main would
carry the combined wastewater along Route 59, across the GIWW and north to the
Craft sod farm and the Craft Cotton Creek Club golf course. The wastewater
would be distributed using the existing irrigation equipment.
Storage facilities would be constructed at both IBU and GSUB plants to
store up to 14 days of waste water. Figure 3-7 shows the layout of this
alternative.
3-1.3 Sludge Treatment and Disposal
The quantity of sludge generated is dependent upon the treatment process
used. The GSUB, SASS and IBU plants currently operate as tertiary treatment
plants using the process of extended aeration. The detention time in the
aeration tank is increased to 24 hours allowing time for the sludge volume
reduction and stabilization in the aeration tank.
3-13
-------
140814
M
0> L
LEG END
¦ PLANT
DISPOSAL POINT (WETLANDS)
A DISPOSAL POINT ( LA)
TRANSMISSION
SOUTH BALDWIN COUNTY. ALABAMA
WASTEWATER MANAGEMENT E.I S
ALTERNATIVE 4C-
HIGH-RATE LA ON
PLEASURE ISLAND WITH
WETLAND DISCHARGES
3 O 3
SCALE IN MILES
US EPA REGION EL
ATLANTA , GEORGI A
-------
[
LEGEND
¦ PLANT
~ DISPOSAL POINT (SW)
A DISPOSAL POINT ( LA)
TRANSMISSION
SHELBY LAKES
SOUTH BALDWIN COUNTY, ALABAMA
WASTEWATER MANAGEMENT E I S
ALTERNATIVE 4D-
SLOW-RATE LA
NORTH OF GIWW
3 0 3
SCALE IN MILES
US EPA REGION ' EE
ATI A N I A , GEORGIA
-------
The sludge can be settled out of the wastewater in the settling tank,
withdrawn and placed on sludge drying beds for dewatering. These beds are
constructed of sand which allows the waster in sludge to seep down through the
sand. The dried sludge is then scraped off the top of the bed and transported
to a landfill for disposal.
With conventional activated sludge, the process the three plants would
use to achieve secondary treatment, the sludge generation rate is higher than
extended aeration and the sludge does not become stabilized during the treat-
ment process. Therefore, the sludge can not be taken directly from the
aeration tank to the sludge drying beds. With this type of treatment, the
sludge would first undergo aerobic digestion to reduce the sludge volume.
Following aerobic digestion, the sludge would be placed on sludge drying beds
for dewatering. The dewatered sludge would be transported to a landfill for
disposal.
3.2 COST
Wastewater treatment and disposal costs associated with the medium growth
scenerio were estimated for the four alternatives including the four land
application options. This section summarizes the results of the cost evalua-
tion. All costs reported in this section are for the three sewerage
districts only and reflect costs for new facilities and the upgrading of
existing facilities only. These costs do not include the existing treatment
and disposal facilities currently owned and operated by GSUB, SASS and IBU.
The costs are meant to show incremental costs (i.e., the costs associated with
expanding the capacity to meet the 20 year demands). All costs were estimated
using the methods detailed in the EIS Task 8 report, Appendix G.
Annual operation and maintenance costs and year 2010 salvage values were
calculated to determine the total present worth costs for each of the alterna-
tives. Present worth is the sum that, if invested now at a given rate, would
provide exactly the funds required to make all future payments. By using
present worths, dollars spent on construction at the beginning of the planning
period are made equivalent to dollars spent on operating costs at the end of
the period. When facilities are scheduled to function beyond the end of the
3-16
-------
planning period, a credit is given for salvage values. Therefore, the total
cost of a project with high initial capital cost and a low operating cost can
be more equitably compared to the costs of a project with a low initial
capital cost but a high operating cost.
The construction, project, and net present worth costs for wastewater
disposal for each alternative are presented in Table 3-2. The annual opera-
tion and maintenance and net present worth costs are presented in Table 3-3.
The costs associated with wastewater treatment facilities are presented in
Table 3-4. Included in this table are project costs, annual O&M costs,
salvage values and net present worths for each of the four altenatives.
Summaries of the total present worth of treatment and disposal are presented
in Table 3-5. The alternatives are ranked based on the lowest present worth.
Alternative 1, no-action, has the lowest present worth and Alternative 3, GIWW
discharge, has the next lowest cost.
3.3 IMPLEMENTABILITY AND OPERABILITY
3.3.1 Operabllitv
System operability provides a measure of the ability of a wastewater
management system to continuously provide the service for which it is
designed. The evaluation of the operability of a system should include the
assessment of the following three factors:
o reliability of treatment
o flexibility of operations
o maintenance of facilities
The evaluation of reliability concerns the ability of the treatment
process, surface water disposal and/or land application facilities to maintain
the intended treatment levels. Flexibility is a measure of the ability of the
treatment components to adapt to changes in wastewater characteristics and
flow and to comply with changes in water quality goals. The flexibility of
the disposal is defined in terms of how adaptable the system is to flow
3-17
-------
Table 3-2. Construction, Project and Net Present Worth Costs
of Wastewater DisposaL
Alternative
Item 1 2A 2B 2C 3 4A 48 4C 4D
Construction Costs:
IBU
Punping Stations $232,000 $ 386,000 $ 386,000 S 386,000 $228,000 t 358,000 $ 716,000 $ 716,000 $ 358,000
Force Mains 124,800 1,584,000 1,584,000 1,584,000 439,200 158,600 1,006,500 359,900 1,539,000
Spray Fields 83,000 - - - - 194,000
RI Basins ... ... 164,000 164,000
Recovery Wells ... ... 24,000 24,000
Monitor Wells ... . . . 2,800 2,800
Reservoir 115,000 - - - 283,000 283,000 283,000 283,000
Land 379,500 - - - - 914,500 448,500 448,500
j
, GSUB
Punping Stations $199,000 $ 338,000 $ 338,000 $ 338,000 $199,000 $ 484,000 $ 968,000 $ 968,000 $ 489,000
Force Mains 53,000 - - - 53,000 1,227,000 666,400 1,283,800 49,800
Spray Fields ... . 257,000
RI Basins ... ... 229,000 229,000
Recovery Wells ... . . . 26,000 26,000
Monitor Wells ... ... 4j20o 4,200
Reservoir ... . . 469,000 464,000 464,000 464,000
Land ... . 1,207,000 621,000 621,000
SASS
Punping Stations - $ 241,000 $ 241,000 $ 241,000 ...
Force Mains - 932,800 932,800 932,800 ...
Spray Fields ... ....
RI Basins ... ....
Recovery Wells ... ....
Monitor Wells ... ....
Resevoir ... ....
Land ... ....
-------
Item
COMMON
Puiping Stations
Force Mains
Outfall
Spray Field
Rl Basins
Recovery Wells
Reservoir
Land
Table 3-2. Construction, Project and Net Present Worth Costs
of Wastewater Disposal
(Cont'd.)
Alternative
2A
2B
$2,953,000
4,910,400
$ 2,953,000
14,731,200
Total Construction Costs $1,186,000 $11,345,400 $21,166,200
Total Project Costs^) $1,542,000 $14,749,000 $27,516,000
Salvage Value $1,274,000 $ 8,515,000 $16,175,000
Net Present Worth $1,309,000 $13,194,000 $18,502,000
2C
$ 2,953,000
29,462,400
$35,991,400
$46,789,000
$27,706,000
$41,730,000
$ 991,200
$1,950,000
$ 569,000
$1,091,000
4A
4B
$2,254,100
$5,547,350 $ 7,877,500
$7,212,000 $10,241,000
$6,791,000 $ 6,732,000
$5,972,000 $ 8,147,000
4C
$5,594,000
$7,272,000
$3,920,000
$6,557,000
4D
$1,610,000
$4,787,000
$6,223,000
$3,024,000
$5,195,000
(D Costs in 1989 dollars.
(2> Project costs reflect construction costs times 1.30 to account for engineering, contingency, legal fees.
-------
Annual 0 & M
SA5S
IBU
GSUB
CCWMON
TOTAL
Present Worth of 0 8 M
SASS
IBU
GSUB
CCWMON
$ 508,000
259,000
* 226,000
119,000
Table 3-3. Annual Operation and Maintenance Costs of Wastewater Disposal
Alternative
2A
* 369,000
638,000
376,000
284,000
2B
* 383,000
680,000
443,000
396,000
$ 162,000
273,000
167,000
131,000
$ 167,000
289,000
195,000
183,000
2C
* 404,000
747,000
548,000
565,000
4A
4B
* 767,000 *1,667,000 $1,902,000 *2,264,000
S 174,000
314,000
238,000
260,000
*355,000
259,000
*614,000
*157,000
119,000
* 987,000
1,952,000
*2,939,000
* 383,000
833,000
*1,919,000
3,783,000
230,000
*5,932,000
* 719,000
1,613,000
106,000
AC
40
*1,678,000 *1,025,000
3,651,000 1,971,000
171,000
*5,329,000 *3,167,000
* 629,000 * 381,000
1,561,000 833,000
79,000
TOTAL
* 345,000 * 733,000 * 833,000 * 986,000
*276,000
*1,216,000
*2,438,000
*2,190,000 (1,293,000
' Total of years 1991 through 2010 annual 0 & N costs.
-------
Table 3-4. Present Worth Costs of Wastewater Treatment and Annual O&M
IBU
GSUB
SASS<2)
Design flows, mad
Year 2010 3.46
Existing 1.60
Additional Needs 1.90
Year New Facilities Qn-Line 1999-
4.28
3.00
1.28
2001
1.18
1.80
0
Project Costs
Alternative 1
Alternative 2
Alternative 3
Alternative 4
$4,066,000
2,822,000
4,991,000
3,484,000
$ 2,291,000
803,000
2,291,000
1,334,000
Annual O&M
Alternative 1
Alternative 2
Alternative 3
Alternative 4
$11,068,000
7,573,000
15,000,000
8,590,000
$14,380,000
11,828,000
14,380,000
13,450,000
$3,576,000
2,964,000
3,576,000
3,576,000
Salvage Value of New Facilities
Alternative 1 $1,924,000
Alternative 2 1,335,000
Alternative 3 2,361,000
Alternative 4 1,648,000
$ 1,207,000
423,000
1,207,000
703,000
Net Present Worth
Alternative 1
Alternative 2
Alternative 3
Alternative 4
$5,561,000
3,821,000
7,336,000
4,445,000
$ 6,497,000
5,012,000
6,497,000
5,829,000
$1,210,000
1,003,000
1,210,000
1,210,000
(1) Total of years 1991 through 2010 annual O&M costs.
(2) No new facilities required.
3-21
-------
Table 3-5. Summary of Present Worth Costs of Wastewater Treatment and Disposal
Present
Worth
of Disposal
Present
Worth of
Treatment
Total
Present
Worth
Ranking
of
Alternative^)
Alternative 1,
No-Act ion
1,654,000
13,268,000
14,922,000
1
Alternative 2A,
1 mi Gulf Outfall
13,927,000
9,836,000
23,763,000
Alternative 2Bf
3 mi Gulf Outfall
19,336,000
9,836,000
29,172,000
Alternative 2C,
6 mi Gulf Outfall
42,717,000
9,836,000
52,553,000
Alternative 3,
GIWU Discharge
1,367,000
15,043,000
16,410,000
Alternative 4A,
LA on PI
7,189,000
11,484,000
18,673,000
Alternative 4B,
Hi LA on PI to
North of GIWW
10,585,000
11,484,000
22,069,000
Alternative 4C,
Hi LA on PI to
Wetlands
8,748,000
11,484,000
20,232,000
Alternative 40,
LA North of GIWW
6,488,000
11.484,000
17,972,000
(1) Based on lowest present worth.
Note:
LA = Land Application.
PI = Pleasure Island.
Hi LA = High rate Land Application.
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changes. Maintainability considerations include the complexity of equipment,
frequency of maintenance down time, and efficiency of providing required
maintenance.
The operability analysis will focus on the treatment and disposal aspects
of the medium growth projection only. A summary of the major operability
concerns with each alternatives is contained in Table 3-6.
The major operability concern with Alternative 1 is the disposal reli-
ability. All of the effluent from the GSUB wastewater treatment plant and a
portion of the effluent from IBU would be discharged to the GIWW which is
sensitive to the input of oxygen demanding substances. Conditions, such as
extremely heavy rainfall, can lead to hydraulic or organic overloading of
treatment plants that could cause the discharge of partially treated or
untreated sewage. The GIWW would be negatively impacted by the occurrance of
these conditions.
Alternative 2 requires maintenance of a Gulf outfall ;hat would range
between 1 and 6 miles offshore. Also, the disposal reliability is a concern
because the water quality of the Gulf of Mexico could be degraded from the
input of nutrients contained in the wastewater effluent. The Gulf currently
experiences problems with algae blooms and these problems could increase with
this disposal option.
Alternative 3 would involve the operation and maintenance of the most
complex treatment process. With this alternative, the three wastewater
treatment plants would operate as tertiary plants. The majority of the
ij v fn GIWW which would reduce disposal
treated wastewater would be discharged >
reliability.
In general, the land application Alternatives, 4A, «. 4C and 4D, have
good treatment and disposal reliability. The wastewater would undergo secon-
dary treatment with effluent filtration and the effluent would receive further
treatment as it percolated through the soil. However, Alternatives 4B and 4D
would recharge the Pliocene/Miocene aquifer, the major source of fresh water
In the Gulf Shores area, which would lower their disposal reliability. Main-
a v.*. rii Ff 1 rult because of the extensive
tenance of the disposal system would be dillicu
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Table 3-6. Sunmary of Operability and laplementability
Alternative
Qperabilitv
Inolementability
1. Requires operation of both tertiary
and secondary treatment processes
and surface and land application
discharges.
2. Low disposal reliability because GIUU
is a sensitive water body.
1. Public concern regarding environmental
sensitivity.
2. Difficult to obtain permit for increased
GIUU discharge.
2A 1. Gulf outfall is difficult to maintain.
2. Low disposal reliability because
outfall is in close proximity to
Gulf beaches.
1. Public concern about potential beach
impacts.
2. Difficult to obtain permit because a
Gulf discharge would set a precedent.
2B 1. Gulf outfall is difficult to maintain.
2. Low disposal reliability because outfall
is in close proximity to Gulf beaches.
2C 1, Gulf outfall is difficult to maintain.
3. Management difficulties with ownership
arid operation of common Gulf outfall.
1. Public concern about potential beach
impacts.
2. Difficult to obtain permit because a Gulf
discharge would set a precedent.
3. Management difficulties with ownership
arid operation of common Gulf outfall.
1. Public concern about potential beach
inspects.
2. Low disposal reliability because outfall
is in close proximity to Gulf beaches.
1. Requires operation of conplex treatment
processes.
2. Low disposal reliability because GIUU is a
sensitive water body.
2. Difficult to obtain permit because a Gulf
discharge would set a precedent.
3. Management difficulties with ownership
and operation of coiranon Gulf outfall.
1. Public concern regarding environmental
sensitivity.
2. Difficult to obtain permit for increased
GIUU discharge.
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Table 3-6. Sumnary of Operability and Implementability
(Cont'd.)
Alternative Operability
4A 1. Good treatment and disposal reliability.
2. Limited flexibility because of loading
rate limitations.
4B 1. Good treatment reliability but lower
disposal reliability because recovered
groundwater would be applied north of
the GIUU and would recharge the Pliocene/
Miocene aquifer.
2. Limited flexibility because of loading
rate limitations.
1. Good treatment and disposal reliability.
2. Little knowledge of the operation of a
wetlands discharge system.
1. Good treatment reliability but lower
disposal reliability because applied
wastewater effluent would recharge the
Pliocene/Miocene aquifer.
2. Limited flexibility because of loading
rate limitations.
ImptementabiIi ty
1. Low planning flexibility because large
tracts of land on Pleasure Island are
required.
2. Coordination of application rates with
golf course operators required.
1. Low planning flexibility because large
tracts of land on Pleasure Island are
required.
2. Coordination of application rates with
golf course and sod farm operators
required.
3. Management difficulties with ownership
and operation of cotrmon force mains.
4. Long-term availability of sod farm
property is questionable.
1. Little planning flexibility because large
tracts of land on Pleasure Island are
required.
2. Management and regulatory difficulties
because of limited experience with
wetland discharge.
1. Highest planning flexibility of all land
application alternatives because all
sites are located north of the GIWW.
2. Coordination of applicaiton rates with
golf course and sod farm operators
required.
3. Management difficulties with ownership
and operation of common force mains.
4. Long-term availability of sod farm
property is questionable.
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conveyance lines, distribution equipment and the ground water recovery system
(Alternatives 4B and 4G only). Alternatives 4A, 4B and 4D would have limited
disposal flexibility because of loading rate limitations on the slow-rate land
application sites. There is little knowledge regarding the operation of a
wetlands reuse system, which would make the operation of Alternative 4C
difficult.
Alternatives 4A and 4D appear to have the greatest overall operability.
These altenatives would be the most reliable and the easiest to maintain
overall. They are less flexible than Alternatives 2A, 2B and 2C, the Gulf
outfall alternatives, but would be at least as flexible as Alternatives 1 and
3, the tertiary treatment alternatives.
Between the two selected alternatives, Alternative 4A would have a higher
operability ranking. It would be easier to maintain than Alternative 4D
because of the shorter distance to the land application sites in Alternative
4A and would be more reliable than Alternative 4D because the effluent would
recharge the alluvial/coastal aquifer rather than the Pliocene/Miocene
aquifer.
3.3.2 Implementab i1i tv
System implementability considers the practicalities of implementing a
specific wastewater management alternative within the study area. The
implementability evaluation assesses the factors that affect the successful
implementation of the alternatives based on public and institutional
realities. The four factors to be considered and assessed are: 1) public
acceptability, 2) regulatory considerations, 3) manage,concerns, and 4)
planning flexibility.
Implementability is not independent, but rather is somewhat dependent on
the results of other evaluations such as cost effectiveness and operability.
This dependence is especially evident with public acceptance which is very
much influenced by the estimated users costs and the enviornmental impacts of
the various alternatives.
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The implementability discussion presented here focuses on the treatment
and disposal systems needed for the medium growth projection only. A summary
of the major implementability concerns of each alternative is contained in
Table 3-6.
The GIUW is a sensitive waterway and the public perception is that dis-
charges to this waterway are environmentally unacceptable. As development
occurred, the volume discharged would increase. The regulatory agencies would
be reluctant to grant an NPDES permit to the treatment plants whose discharge
would lower dissolved oxygen more than 0.1 mg/L. The regulatory agencies may
have to address the dissimilar permit limitations between the GSOB and IBU
plants.
Disposal to the Gulf of Mexico, Alternative 2, would probably be unac-
ceptable to the public. With the recent negative publicity regarding ocean
disposal near the beaches in the northeast, the public would be hesitant about
ocean discharges near the Gulf beaches. Currently, there are no discharses to
the Gulf of Mexico within the United States and the permitting of this outfall
would set a precedent which might encourage other discharges. Also, waste-
,. r„if of Mexico is inconsistent with
water treatment plant discharge to the G
EPA's National Coastal and Marine Policy.
Alternatives 4A, 4B, 4C and 4D, secondary treatment followed by land
application, seem to have a high degree of public acceptance. Out of these
four alternatives, the public would probably agree to Alternative 4A which
involves reusing wastewater to irrigate golf courses and dedicated land on
Pleasure Island. The land on Pleasure Island recharges the alluvial/coastal
aquifer which is not heavily used as a drinking water source. The land north
of the G1WU recharges the Pliocene/Miocene aquifer, the major source of fresh
water in the area, and the public would be hesitant in accepting the applica-
tion of wastewater to this land.
All of the land application alternatives require large tracts
Alternatives 1, 4A, 4B and 4C would use land on Pleasure Island for land
application. Pleasure Island will probably come under heavy development
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pressure in the future which would drive up land prices and the demand for
land. All of the land needed would have to be purchased or dedicated before
heavy development occurred to prevent the possibility of not being able to
obtain the land in the future. Alternative 4D which uses only land north of
the GIWW would be the most flexible of the land application alternatives.
When considering all the facets of implementability, cost, public accept-
ance, regulatory acceptance, environmental concerns, planning flexibility and
management concerns, Alternative 4A appears to have the greatest overall
implementability.
3.4 ENVIRONMENTAL IMPACTS
This section addresses potential environmental impacts for each of the
alternatives assuming that the medium growth scenario occurs. This EIS
principally addresses the disposal of treated wastewater, so the emphasis of
this section will be disposal related environmental impacts. It is assumed
that the collection system expansion would be largely independent of the
disposal option selected and, therefore, impacts from collection system
expansion would be the same for all alternatives.
3.4.1 Primary Impacts
3.4.1.1 Surface Water Resources
The two major surface water resources in the study area are the
GIWW, which connects Bon Secour Bay with Portage Creek and Wolf Bay, and the
Gulf of Mexico. There are numerous small streams and wetlands that are
hydraulically connected to the GIWW, but it and the Gulf of Mexico are the
only surface waters that are potentially suitable for treated wastewater
disposal. Oyster Bay and Wolf Bay were precluded from consideration as
receiving waters because of long detention times and low assimilative
capacity, respectively. The analysis of surface water impacts is, therefore,
limited to the GIWW and the Gulf of Mexico
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A substantial amount of data were developed to perform water quality
modelling studies to determine the impacts of discharging treated wastewater
to the Gulf of Mexico or the GIWW. These studies are listed below.
ADEM and EPA, 1982. Data Report on Gulf Intracoastal Waterway performed
by Alabama Division of Environmental Management and EPA's Environmental
Services Division from 8/18/82 - 11/14/82. The data included sediment
oxygen demand, tidal velocity and stage readings, dye dispersion of
overall tidal transport during spring and neap tidal cycles, point source
discharger studies, light/dark bottle studies, long-term BOD and nutrient
studies. See Appendix A.
Tetra Tech, 1984. Final Report on Water Quality Modelling Study, Gulf
Intracoastal Waterway, Baldwin County, Alabama. Mathematical modelling
of GIWW water quality parameters; performed for the Alabama Department of
Environmental Management. The conclusions are described in this chapter.
EPA, 1987. Nearshore Phytoplankton Bloom Potential and Periphytic Algal
Conditions at Gulf Shores, Alabama. Performed by EPA's Environmental
Services Division, this study examined the public health and nutrient
implications on the Gulf of Mexico from potential offshore discharges.
See Appendix B.
Raytheon Service Company, 1987. Gulf Shores Ocean Outfall Study.
Oceanographic study conducted, under contract to EPA, from 6/26/86
through 4/9/87 for assistance in determining impacts of potential
offshore discharges. See Appendix F.
Thompson Engineering Data, 1987. A water quality study conducted, under
contract to EPA, that focused upon bacterial loading in the GIWW and the
Gulf of Mexico, from 6/26/86 - 4/9/87. See Appendix C.
Dauphin Island Sea Lab, 1986-87, study performed under EPA contract for
nine monthly sampling events. Nine surface, midwater and bottom station
water quality parameters were sampled hourly over one 24-hour event. See
Appendix D.
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3.4.1.1.1 Impacts to the Intracoastal Waterway
Water quality degradiation in the GIWW has been well documented.
Sampling of the GIWW at the Route 59 bridge, conducted by ADEM from 1974
through 1982, showed that dissolved oxygen (DO) values frequently fall below
a 5 mg/L standard. Three sampling efforts, conducted in the fall of 1982, not
only confirmed DO depletion, but documented elevated chlorophyll-a
concentrations, evidence of an increased biomass and unacceptable algal
productivity.
Water quality modeling studies conducted by ADEM (Tetra Tech, Inc., 1984)
concluded that wastewater discharges by existing point sources, both con-
tinuous and intermittent, are not the primary contributors to the DO and algal
growth problems. These studies identified benthic oxygen demand, ambient BOD
from the waters of Wolf and Oyster Bay, and non-point and point source dis-
charges as being the factors contributing to the low DO.
Benthic oxygen demand, also referred to as sediment oxygen demand (SOD),
is a measure of oxygen consumed during natural oxidation of organic detritus
and nutrients found in bottom sediments. This demand may exert pressure on
the water column above the sediments, and deplete oxygen in bottom and
near-bottom environments.
Field studies demonstrated GIWW mean SOD values of 2.06, 1.68, 2.69 grams
per square meter per day (g/m2/day; see Appendix A), typical of estuarine
muds, which are significantly higher than sandy and mineral soils. To provide
a frame of reference for the GIWW SOD data, some reference values are given
below:
Type of Bottom
Typical Value (g/m2/day)*
Estuarine mud
1.5
Sandy
Mineral Soils
0.07
0.5
* USEPA, 1985b.
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It should be noted that the EPA SOD data were taken in 1982 and therefore may
not accurately represent sediment conditions in 1990.
Another factor affecting dissolved oxygen concentrations is turbidity.
Turbidity may be either natural or man-induced and refers to the amount of
suspended solids in the water column and the corresponding decrease in light
transmittance. Turbidity may reduce the dissolved oxygen concentration of the
water column through two processes: 1) increased turbidity reduces the amount
of the water column in which light intensity is sufficient for the rate of
photosynthesis to exceed respiration, and 2) microorganisms in the water
column consume oxygen in the process of breaking down the organic matter in
the suspended solids. (Novotny and Chesters, 1981).
Natural processes, such as high flow velocities, or man-induced
processes, such as power boats and large barges driven by tugboats, can cause
resuspension of bottom sediments and increase the water turbidity. Another
man-induced process, dredging, has also been observed to decrease dissolved
oxygen concentrations through increasing the turbidity. Simon and Dryer
(1972) reported dissolved oxygen concentrations surrounding an active dredge
of 16 to 33 percent below normal and an eightfold increase in BOD values.
The Army Corps of Engineers performs dredging in the GIWW as needed to
maintain the waterway at project depth. The dredging is necessary to remove
silts and sediments which accumulated as a result of natural siltation.
Although dredging increases turbidity, the effects of this process should be
interpreted in the context of ambient turbidity levels. In areas where
turbidity is naturally high, an increase in turbidity from dredging would have
less impact (EPA, 1985b). In the case of the GIWW, natural turbidity may be
relatively high due to sediments from rivers and stormwater runoff. Chapman
(1968) reports that most of the Gulf of Mexico and south Atlantic estuaries
can be characterized as either naturally turbid or comparatively clear. The
Mobile Bay area and the Apalachicola-Cuspate Delta area, along the Florida
panhandle (Beccasio, et al., 1982), are examples of turbid water zones.
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Clearly, other oxygen-reducing forces, other than point source pollution
impacts, are reducing DO concentrations in the GIWW, including non-point
source runoff, poor mixing from lack of complete tidal exchange, and natural
and man-induced turbidity.
Although wastewater discharges may not be the primary cause of the low
DO, they do contribute particulate matter and BOD and are subject to upset
conditions, which can lead to the discharge of partially or untreated waste-
water. These sources of pollution are controllable and removal of even low
quantities of pollution input may improve the GIWW water quality.
Alternatives 1 and 3 would continue the discharge of wastewater to the
GIWW. With Alternative 1, the GSUB plant would discharge 4.3 mgd (year 2010)
and the IBU plant would discharge up to 1.60 mgd (year 2010) and with Alterna-
tive 3 the IBU plant would discharge 2.5 mgd (year 2010) while the GSUB plant
would discharge 4.3 mgd (year 2010). Given these discharges and the current
effluent limits of 2 mg/L BOD5 for IBU and 4 mg/L BOD5 for GSUB, the following
quantities of BOD5 would be discharged to the GIWW:
Alternative 1:
GSUB - 4.3 mgd, 143 pounds of BOD5 per day
IBU - 1.6 mgd, 27 pounds of BOD5 per day
Total - 5.9 mgd, 170 pounds of BOD5 per day
Alternative 3:
IBU - 2.5 mgd, 42 pounds of BOD5 Per ^ay
GSUB - 4.3 mgd, 143 pounds of BOD5 per day
Total - 6.8 mgd, 185 pounds of BOD5 per day
Wasteload allocation modeling (Tetra Tech, Inc., 1984) suggests that an
increase of 1,000 pounds of BOD5 per day over current 1985 inputs of 110
pounds of BOD5 per day „ould decrease the minimum DO levels by about 0.1 mg/L.
The 2010 Inputs presented above »ould not appear to cause a substantial
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decrease in DO. levels, but if discharges to the GIWW were continued, the GIWW
should be strictly monitored to ensure that no significant decline in DO.
levels occurred.
Alternatives 2 and 4 would remove the current wastewater discharges to
the GIWW, thus reducing the GIWW's organic loading. This reduction would
positively impact the water quality of the GIWW and the Bon Secour and Wolf
Bays.
All of the alternatives would extend sewer service to failing septic tank
areas which currently cause water quality degradation in Bon Secour and Wolf
Bays through contamination of recharge groundwater. The adoption of any of
the wastewater management alternatives would have a beneficial water quality
impact to the bays.
3.4.1.1.2 Impacts to the Gulf of Mexico
Alternatives 1, 3 and 4 would not involve discharges of wastewater to
the Gulf of Mexico and thus are consistent with EPA's National Coastal and
Marine Policy statement (January 18, 1989) which supports programs that seek
to reduce the total volume of pollutants disposed of in coastal and marine
waters. Alternative 2 would involve the disposal of all wastewater effluent
to the Gulf of Mexico via a 1, 3 or 6 mile Gulf outfall. The potential
impacts associated with the outfall will be the focus of this section.
A discharge of wastewater to the Gulf would be precedent-setting; at this
time there are no American wastewater treatment plants permitted for direct
discharge to the Gulf of Mexico. The potential adverse impacts include the
production of algal blooms in the vicinity of local beaches and the potential
for pathogen contamination of beach areas.
Because there are currently no wastewater discharges to the Gulf of
Mexico, the likelihood of increased algal bloom production can only be assumed
based on the examination of the effects of ocean discharges elsewhere, and
model predictions of the effects of wastewater discharges to the Gulf. In
1988, McDavid Associates studied a 36 mgd wastewater discharge to the Atlantic
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Ocean located at Dam Neck, Virginia. Chlorophyll-a concentrations were
projected to be 13 - 19 ug/L in the ocean, and increased algae growth can be
detected visually from the air in the vicinity of the outfall. Also,
dissolved oxygen concentrations are typically 10 to 20 percent below satura-
tion near the outfall. No signifffcant shoreline effects were reported by
McDavid Associates.
The Virginia discharge can only be used to theorize the potential impacts
to the Gulf. The Gulf discharge would be 9.0 mgd compared to the 36 mgd
Virginia discharge and the Gulf outfall would be 1, 3 or 6 miles offshore,
while the Virginia outfall is 1.5 miles from shore. Additionally, the
Atlantic Ocean is much deeper and has better mixing and assimilative capaci-
ties than does the Gulf of Mexico.
To assess the possibility and potential severity of algal blooms from
wastewater discharge to the Gulf, water quality data collection and prediction
modeling were conducted (See Appendices). Chemical analyses showed that the
Gulf waters were either phosphorous limited or both phosphorous and nitrogen
limited. Thus algae growth estimates were based on the predicted concentra-
tions of phosphorous in the wastewater effluent. The potential for algae
blooms was determined to be high with effluent concentrations of 1 mg/L and 5
mg/L total phosphorous (TP). Furthermore, impacts were predicted to be much
more severe with the 5 mg/L discharge. The amount of algae that would reach
the shore would depend on the following highly variable parameters: dilution
in outfall plume, movement of the plume, time of year, current patterns, and
temperature.
Algal blooms have been documented in the area and would most likely be
increased by the wastewater discharges proposed in Alternative 2
The second potential adverse impact to the Gulf of Mexico from
Alternative 2, would be the possibility of contamination of the beach area
with fecal coliform bacteria, viruses, and other pathogens (e.g., fungi,
protozoa, and flatworms).
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The health risk of pathogens in beach areas would be caused by those
enteric bacteria and viruses that survive the sewage treatment process.
Protozoans and helminths (worms) pose a lower significant risk because they
survive for only short periods of time after entry into seawater (Livingston
et al., 1968 in: NCSU et al., 1979). The primary variables affecting the
magnitude of the risk are die-off rates and ambient water densities following
outfall dispersion. Dispersion is influenced by wind direction, wind
intensity, and tidal currents, all of which affect the path of the discharge
plume. In addition, there are many other physical and biological factors
affecting pathogen survival in seawater such as salinity, temperature, trace
metals and solar radiation.
To assess the potential for beach contamination, dispersion modeling was
conducted for 1-, 3-, and 6-mile offshore discharge points. The assumptions
on which the modeling was based were as follows:
o 17.5 cfs discharge;
o Zero current velocity for estimation of initial dilution;
o 50 cm/sec current velocity (on-shore) for far-field
dilution calculation; and
o 1 fecal coliform/day die-off rate.
These assumptions represent worst-case conditions, so that the results were
conservative. The initial dilutions (near-field) were estimated to be 53, 60,
and 62 for the 1-, 3-, and 6-mile discharge points. Far-field (beyond the
point of initial plume entrapment) dilutions were 2.3, 3.8, and 5.2 for the
1-, 3-, and 6-mile discharge points, respectively. A dilution equal to 2.3
means that an initial coliform count of 23 MPN/100 ml would be reduced to 10
MPN/100 ml. Total dilutions of 122, 228, and 322 were obtained my muliplying
the near-field dilutions by the far-field values. Raw wastewater, which
contains 10? to 108 total coliforms per 100 ml, would be diluted to 10^ to 10?
MPN/100 ml, which would greatly violate the 200 MPN/100 ml standard for the
beach front. However, chlorinated wastewater which would contain less than
1,000 total coliforms per 100 ml, would be diluted to about 3 to 8 MPN/100 ml
and would be far below the beach front standard.
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The analysis shows that there would be a low likelihood of pathogen
contamination at local beaches from a disinfected wastewater discharge. Under
normal operation conditions, the wastewater discharged to the Gulf would
receive secondary treatment and chlorination or ultra violet radiation.
In conclusion, the treated wastewater discharge to the Gulf would have a
high potential to cause algal blooms and, under normal operation, a low
potential for beach contamination. An upset condition at any of the treatment
plants could cause the discharge of partially or untreated wastewater that
could lead to beach contamination. The discharge of wastewater to the Gulf of
Mexico should be viewed as an adverse environmental impact.
3.4.1.2 Groundwater Resources
The stratigraphy of the study area consists of three geologic units
(USGS, 1988). One is the alluvial and coastal deposits, which is located
along the coast up to a line that is approximately parallel and 2.5 miles
north of the GIWW. The second and third geologic units are the sedimentary
deposits of clays, sands, sandy clays and gravelly sands in the Pliocene and
Miocene series, which are directly below the coastal deposits and which crop
out north of the above described parallel line. Within the three geologic
units are two aquifers: an alluvial/coastal aquifer and a Pliocene/Miocene
aquifer. Discontinuous layers of clay within the deposits retard vertical
movement of groundwater but do not separate the aquifers. Because of this
hydraulic connection, the aquifers generally respond to pumping stresses as a
single aquifer. The groundwater in both aquifers is recharged via the
infiltration of rainfall and generally flows in a southerly direction.
The wastewater management alternatives may impact both the quantity and
quality of groundwater in the EIS study area. These two areas of possible
impacts are described below. Groundwater impacts are particulary important
because groundwater is currently the principal source of freshwater within the
study area.
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3.4.1.2.1 Impacts to Groundwater Quantity
The potential negative impacts of increasing groundwater withdrawal
without concomitant recharge are outlined below:
o Saltwater intrusion into the freshwater aquifers;
o Localized groundwater draw-down reducing yields and
resulting in uneconomical pumping costs; and
o Mutual interference between wells that may reduce yields.
The primary way in which the wastewater management alternatives could
impact groundwater quantity would be the increase or decrease of recharge
volumes. Alternative 4, Land Application, would provide the greatest volume
of treated effluent for recharge and thus have the most beneficial impact.
Alternatives 1 and 3 would combine land application (SASS percolation ponds,
IBU trickle field and an additional IBU land application site with Alterna-
tive 1) with surface water discharge, thus providing some beneficial water
quantity impacts but not as much as Alternative 4. Alternative 2 would not
include any land application and, in fact, would remove the existing land
application sites (the percolation ponds and the trickle field). From a
groundwater recharge perspective, Alternative 2 would have the least bene-
ficial impact.
It is difficult to quantify these beneficial or adverse impacts to
groundwater quantity because of several complex variables, which include:
o The projected demands for groundwater use, including the
seasonal effect of summer peak population;
o The aquifers that would be tapped;
o The aquifers that would be recharged by the land
application percolate water; and
o Safe yields for the aquifers being tapped.
Assuming infiltration/inflow is controlled, future groundwater withdrawal
for non-irrigation uses should be about equal to projected wastewater flow,
because virtually all fresh water used in this area is from groundwater
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sources. Therefore, groundwater withdrawals in year 2010, for other than
irrigation uses, should exceed 4.4, 8.9 and 21.3 mgd for the three population
growth scenarios. Irrigation water withdrawal during years 1980-1984 was
approximately 85 percent of municipal withdrawls. Using this percentage, the
projected groundwater withdrawal for both municipal and irrigation uses in
year 2010 is 8.1, 16.5 and 39 mgd, respectively for the low, medium, and high
population growth scenarios.
Major water users, as well as all public water supplies and several
substantial agricultural irrigation systems, withdraw water from the Pliocene/
Miocene aquifers. Some water is withdrawn from the alluvial/coastal aquifer
south of the GIWW, but only by relatively small operations.
Table 3-7 shows the proposed land application sites for each alternative
and the quantity discharged. All of the sites, except the Craft sod farm and
the Cotton Creek Club golf course would recharge the alluvial/coastal aquifer.
Alternative 4D, which would use the Craft sod farm and the Cotton Creek Club
golf course, would have the most positive impact on groundwater quantity
because it would recharge the Pliocene/Miocene aquifer, the most heavily used
aquifer.
Safe yield refers to the amount of water that can be withdrawn from an
aquifer without producing negative impacts. Stewart et al. (1976) estimated
the recharge rate for southern Alabama to be between 10 and 28 inches depend-
ing upon soil hydrologic group. Hydrologic group B, the soils that predomi-
nate in the EIS study area, recharge at a rate of about 18 inches per year
(Stewart et al. 1976). Assuming 18 inches per year percolates in the
estimated 17 square miles recharge area, the safe yield for the Pliocene/
Miocene aquifer would be approximately 10-14 mgd. As described above, the
projected water demand for the medium growth scenarios is 16.5 mgd which
exceeds the estimated safe yield of 10-14 mgd. This projected shortfall in
groundwater strengthens the conclusion that Alternatives 1, 3 and 4 would have
positive and Alternative 2 a negative impact on ground water quantity.
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Table 3-7. Potential Land Application Sites for the Wastewater Management Alternatives^'
Medium Growth Scenario
Alternative 1 - NA
Alternative 3 - GIWW
Alternative 4A - S.R. on P.I
Alternative 4B - H.R. on P.I. &
Reuse
Alternative 4C - H.R. on P.I. &
Wetlands Disposal
Alternative 4D - S.R. N. of GIWW
Projected Design Flow (mod)
No. 1,
G.S. Golf
Club
No. 2,
G.S.P. Golf
Course
No. 3,
IBU
Trickle
Field
No. 5,
Meyer
T rack-W
of IBU
No. 6,
SASS
Percolation
Ponds
No. 7,
Cotton
Creek
Golf Course
No. 8,
Craft
Sod Farm
0.8
0.5
1.0
1.0
1.0
2.4
6.0
1.2
1.2
1.2
1.0
6.7
1.2
0.6
6.1
1.0
1.0
6.7
1.2
1.2
0.6
6.1
See Figure 2-3 for location of sites. (Note: Sites 4, 9, 10, 11 and 12 (as shown on Figure 2-3) were evaluated in the preliminary phases of the
alternatives analysis, but were not used with the final selected alternatives).
-------
3.4.1.2.2 Impacts to Groundwater Quality
In contrast to groundwater quantity impacts, Alternative 2 which involves
no land application, would have no adverse impacts to groundwater quality.
The land application alternative would have the highest potential for adverse
impacts and Alternatives 1 and 3, which involve both surface water and land
application discharge, would have a moderate potential for adverse impacts to
groundwater quality.
Properly designed and operated land application systems should have
minimal adverse impacts to groundwater quality. Wastewater effluent receives
additional treatment via adsorption, filtration and biological decay as it
percolates through the soil (Loehr et al., 1979). Water quality impacts can
occur if the hydraulic or nutrient loading capacities of the system are
exceeded and usually involve mobile pollutants such as nitrate-nitrogen
chlorides, and pathogens. Nitrate-nitrogen can move freely with water and has
frequently been documented in groundwater at levels that exceed the public
health standard of 10 parts per million (Hubbard and Sheridan, 1989). Other
common pollutants (BOD, most pathogens, and phosphates are removed from the
percolation water near the soil surface (Novotony and Chesters, 1981) and
don't normally contribute to water quality problems.
To minimize the potential for exceedance of the nutrient loading capacity
of the soil, the loading rates projected for the land application sites were
based on the assumption that the average total nitrogen input (both organic
and inorganic) should equal the expected crop uptake minus a 20 percent
allowance for gaseous losses (ammonia volatilization and dentrification)
(The 20 percent value is an EPA recommended number for planning purposes (EPA,
1981).) In addition, the sites were evaluated for infiltration/hydraulic
limitations in determining the projected loading rates.
Alternatives 4B and 4D have the potential to impact the groundwater
quality of the most heavily used aquifer, the Pliocene/Miocene. These two
alternatives involve land application sites that would recharge this aquifer.
Because of this potential for the applied wastewater to impact the drinking
water aquifer, the Geological Survey of Alabama (1989) used the RESSQ model to
3-40
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investigate saturated zone transport of mobile pollutants (see Appendix E).
The preliminary results of the model predict that after a period of 10 years,
nitrate concentrations reaching the nearest downgradient municipal well would
be less than fifty percent of the concentrations percolating from the site.
Because wastewater would be applied to land application sites at agronomic
rates, nitrate-nitrogen concentrations in percolation water are expected to be
less than 10 mg/L.
The other land application sites would recharge the alluvial/coastal
aquifer, which is used mainly for industrial and irrigation purposes.
3.4.1.3 Ecological Resources
The study area includes a wide variety of valuable ecological resources.
These resources include marine and estuarine fisheries, extensive wetlands,
bird rookeries, and seagrass beds. The area also harbors a wide variety of
State or Federally listed (or proposed) threatened or endangered plant and
animal species. Table 3-8 lists the endangered, threatened and species of
special concern in Mobile and Baldwin Counties.
The ecological resources of the Gulf of Mexico could be impacted by
implementation of Alternative 2. The major issues concerning the potential
ecological impacts include:
1. Nature and quantity of pollutants
2. Potential for transport of pollutants
3. Composition and vulnerability of biological communities exposed to
pollutants
4. Importance of receiving waters to biological community for spawning,
feeding and migrating
5. Existence of special aquatic sites in the vicinity of the proposed
outfall
6. Potential for human health impacts
7. Impacts on existing and potential uses
8. Applicable requirements of any coastal area management plan
9. Applicable marine water criteria
3-41
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Table 3-8. Endangered, threatened and species of special concern
in Mobile and Baldwin counties
Auburn U.S. Dept. of
Scientific Name University the Interior
Common Name (1986') (1987)
Fishes
Ammocrvpta asprella Crystal darter SC(a)
Scaphirhvnchus sp. Alabama shovelnose
sturgeon PK
Amphibians
Ambvstoma cingulatum
Rana areolata sevosa
Siren lacertina
Flatwoods salamander SC
Dusky gopher frog T
Greater siren PK
Reptiles
Alligator mississippiensis
American alligator
SC
T
Ambvstoma texanum
Small-mouthed
salamander
PK
Amphioma pholeter
One-toed amphiama
PK
Caretta caretta caretta
Atlantic loggerhead
turtle
E
T
Chelonia mydas
Green sea turtle
E
T
Crotalus adamanteus
Eastern diamondback
rattlesnake
SC
Dermochelvs coriacea
Leatherback sea
turtle
E
E
Desmoenathus auniculatus
Southern dusky
salamander
PK
Drvmarchon corais couperi
Eastern indigo snake
E
T
Eretmochelvs imbricata
Atlantic hawksbill
turtle
E
Eumeces anthracmus
Coal skink
PK
Faraneia ervtropramma
Rainbow snake
ervthropramma
PK
Gopherus polvphemus
Gopher tortoise
T
Graptemes pulchra
Alabama map turtle
SC
Heterodon simus
Southern hognese
snake
T
Lepidochelvs kempi
Atlantic ridley turtle
E
E
Malademvs terrapin pilear.a
Mississippi diamond-
Masticophis flap-ellnm
back terraprin
SC
Eastern coachwhip
flagellum
SC
Nerodia fasciata clarlci
Gulf salt marsh snake
SC
3-42
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Table 3-8. Endangered, threatened and species of special concern
in Mobile and Baldwin counties (Continued)
Scientific Name
Common Name
Auburn
University
f19861
U.S. Dept. of
the Interior
(19871
Reptiles (Cont'd.)
Pitophis melanoleucas lodingi
Pseudemvs alabamensis
Pseudotritron ruber vioscai
Rhadinaea flavilata
Terrapine Carolina
Birds
Accioiter cooperii
Ammodramus henslowii
Ammodramus leconteii
Anas fulvigula
Asio otus
Campephilus principalis
Charadrius alexandrinus
Charadrius melodus
Charadrius wilsonia
Columbina passerina
Coturnicops noveboracensis
Egretta rufecscens
Falco columbarius
Falco peregrinus tundrius
Grus canadensis
Haematopus palliatus
Haliaeetus leucocephalus
Laterallus iamaicensis
Elycteria americana
Pandion haliaetus
Pglecanus erthrorhvnchs
Pelecanus occidentalis
ZlcoidfiH horp.al i s
Sterna ni 1 nt-.-f c.a
Ihrvomanes bewickii
Vgrmivpra bachmanii
Black pine snake
Alabama red-bellied
turtle
Southern red salamander
Pine woods snake
Box turtle
Cooper's hawk
Henslow's sparrow
Leconte's sparrow
Mottled duck
Long-eared owl
Ivory-billed woodpecker
Snowy plover
Piping plover
Wilson's plover
Common ground dove
Yellow rail
Reddish egret
Merlin
Artie peregrine falcon
Sandhill crane
American oyster-
catcher
Bald eagle
Black rail
Wood stork
Osprey
American white pelican
Brown pelican
Red-cockaded wood-
pecker
Gull-billed tern
Bewick's wren
Bachman's Warbler
PK
PK
SC
SC
PK
PK
SC
PK
SC
SC
PK
SC
SC
T
E
SC
E
PK
E
SC
SC
E
SC
T
E
E
T
E
E
Mammals
iialaenoptera horealis
£§laennpfpra phvsalus
Sei whale
Finback whale
E
E
3-43
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Table 3-8. Endangered, threatened and species of special concern
in Mobile and Baldwin counties (Continued)
Auburn U.S. Dept. of
Scientific Name University the Interior
Common Name (1986) (1987)
Mammals (Cont'd.)
Eubalena placialis
Right whale
E
Felis concolor corvi
Florida panther
E
E
Felis vapouaroundi
J aguarundi
PK
Geomvs pinetis
Southeastern pocket
gopher
SC
Lasiurus floridanus
Florida yellow bat
PK
Meeactera novaeaneliae
Humpback whale
E
Mvotis austrorioarius
Southeastern myotis
austroriparius
SC
Peromvscus Dolionotus
Alabama beach
ammomates
mouse
E
E
Peromvscus polionotus
Perdido Key beach
trissvllepsis
mouse
E
E
Phvseter catodon
Sperm whale
E
Plecotus rafinesquii
Rafinesque's bigeared
bat
SC
Svlvilaeus palustris
Marsh rabbit
PK
Tadarida brasiliensis
Brazilian freetailed
bat
SC
Trichechus manatus
Florida manatee
E
Ursus americanus
Florida black bear
floridanus SC
(a) E: Endangered, T: Threatened, SC: Special Concern, PK: Poorly Known.
3-44
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The nature and extent of impacts would depend on such factors as the
length and placement of the outfall, dilution, current speed and direction and
the degree of wastewater treatment.
Ecological impacts to the GIWW and adjacent estuaries could result under
Alternatives 1 and 3, which include wastewater discharges to the GIWW.
Ecological impacts of wastewater discharges correlate directly with water
quality impacts. If loading increased above the assimilative capacity of the
environment, DO violations would increase. Concurrently, the potential for
nuisance algal blooms and associated adverse biological impacts would
increase. This increase could lead to a reduction in the value of the GIWW as
a sport fishery and as an estuarine zone (nursery, spawning, and feeding
habitat). If the impacts were severe, there could be a reduction in the
biological quality of adjacent estuarine zones, including valuable seagrass
beds on Wolf Bay, Oyster Bay, and Mobile Bay.
The GIWW will continue to be eutrophic in the future, due to sediment
oxygen demand, non-point source inputs, sediment nutrient releases, and
consequent stimulation of algal blooms in late summer. Large power vessels
will continue to resuspend sediments, perpetuating sediment nutrient releases
and elevating suspended solids concentrations. Some of these sediment
problems exist today because of historic discharges which did not meet
appropriate limits. The GIWW will eventually recover if such discharges do not
exceed their limits; recovery could occur somewhat faster if discharges are
reduced or eliminated.
With the elimination of organic loadings, the periodicity and intensity
of nuisance algal blooms during late summer are expected to decrease over the
years as the system purges itself of nutrients in the water column and of
nutrients exchanged with the bottom sediments. The excessive sediment oxygen
demand would be reduced over the years as well. Estuarine benthic communities
^ the GIWW would respond by shifting towards populations more characteristic
°f oxygen-rich (aerobic) environments, and away from oxygen-poor (anaerobic)
Populations. Estuarine fish would eventually increase in abundance and
diversity as a result of improved oxygen conditions and increased availability
°f food in the form of benthic invertebrates. Conditions for important
3-45
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estuarine communities in Wolf Bay would also improve due to reduced suspended
solids loadings and reduced potential for algal blooms. Benthic communities
in these areas would benefit as a result (including seagrass communities--
vitally important resources which have experienced reductions in abundance in
recent years). In summary, the biological health of the GIWW and adjacent bays
would be improved as a result of reduced loadings of organic material and
nutrients.
The removal of the GSUB and IBU discharges to the GIWW, Alternatives 2 and
4, would have a slight beneficial impact, in that these dicharges represent
small inputs of organics and nutrients. However, there would still be
significant inputs from non-point sources and industrial discharges so water
quality degradation would continue to be evidenced.
No direct impacts on protected animal species are expected during
construction or expansions to WWTPs or conveyance lines in the study area.
The most significant potential effects of the alternatives on these species
would be related to higher-density commercial and residential growth induced
by the availability of wastewater treatment facilities. The type and extent
of such induced growth would be the same under all alternatives and the
greatest potential impacts would be to Alabama beach mouse and Perdido Key
beach mouse habitat on Pleasure Island (see Figure 3-8). Examples of habitat
impacts would be the development itself and activities of the residents such
as walking, use of the beaches, etc. and the increase of household pets which
could reduce the mouse population. Because little can be done to avoid growth
in surrounding areas on Pleasure Island, which would result in a reduction in
the value and quality of beach mouse habitat, the impacts could be quite
severe, including possible extinction. The existing sewer lines serving
beachfront development were built without USEPA funds, and no new sewer lines
in these areas are envisioned in the development scenarios.
Florida manatees have been sited along the Alabama coast and the GIWW at
Gulf Shores (O'Neil and Mattee, 1979; USFWS Region IV, 1986). Habitat for the
manatee would be improved under Alternatives 2 and 4, since all flows would be
diverted from the GIWW. The impacts of the ocean outfall (Alternative 2)
depend on the degree of influence the ocean outfall exerts over nearshore
3-46
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t406/4
S
ALABAMA
STUDY
AREA
MOB' . £ BAr
FORT
MORGAN
I?
El BE R T A
SECQuH NAllONAl
Wu DliFE Rt FUGE
LEGEND
Y//A HABITAT AREAS
SOUTH BALDWIN COUNTY .ALABAMA
WASTEWATER MANAGEMENT E IS
BEACH MOUSE
CRITICAL HABITAT
SCAl.F IN MILLS
US l PA
AT i A N T A
region ry
, O E O R b I A
-------
waters. The probability of major adverse impacts to manatees is low if the
discharge point is located 6 miles offshore. If a discharge point closer to
shore is selected, the potential for adverse effects could increase.
The potential impacts on any endangered or threatened plants or plants of
special concern that may exist in the study area could include: (1) effects on
those species inhabiting areas wheje construction activities take place; and
(2) effects on those species living in or adjacent to areas to be used for
land application, rapid infiltration basins, or percolation ponds, or
receiving a discharge (to wetlands). Construction-related impacts would be
due to the removal of vegation during placement of conveyance lines. Impacts
would be kept to a minimum by placing pipes adjacent to roadways, where
possible. Operation-related impacts would primarily be due to the changes
that would occur in the hydrological and nutrient regimes of existing plant
habitats. Such changes would alter the seasonal nature of existing hydro-
logical regimes, increase the overall degree of wetness, and increase nutrient
availability to plants.
Many of the endangered, threatened, and special concern plant species
with potential to occur in the study area are associated with wetlands, either
growing directly in them or occuring in their ecotones (edges). Most of these
wetland-associated species have very specific requirements concerning the
degree and seasonality of wetness in their habitats. Usually these species
are also sensitive to nutrient levels, and frequently require low levels of
nutrition, especially nitrogen. Alteration of these habitat parameters
usually means death or decline of the population.
In order to minimize the potential adverse impacts of the chosed alterna-
tive, all areas to be affected by construction or by proposed application of
effluent upon or adjacent to a site, should be surveyed for endangered,
threatened, or special concern plant species where Federal funding is in-
volved. This recommendation also applies to those areas adjacent to terres-
trial disposal sites where a change in amount of effluent discharged is
proposed. If any of these species are found, appropriate mitigation measures
should be addressed at that time.
3-48
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3.4.1.4 Wetlands
A wide variety of emergent and forested wetlands occur over a large
portion of the study area. These wetlands consist primarily of tidal fresh-
water and saltwater marshes, non-tidal freshwater marshes and forests, and
tidal flats. The wetlands are valuable natural resoruces which serve a
variety of important functions, including: (1) production of large amounts of
plant material, which forms the base of detrital food chains; (2) provision of
excellent habitat for fish and wildlife, many of which are important com-
mercial species; (3) provisions of habitat for endangered or threatened
species; and (4) performance of various hydrologic functions, including
groundwater recharge or discharge, erosion control, flood storage, and flood
desynchronization. Wetlands within the study area were identified using
National Wetland Inventory (NWI) maps prepared by the U.S. Fish and Wildlife
Service. The NWI classification system (Cowardin et al., 1979) includes
estuarine, marine, palustrine, lacustrine, and riverine ecological systems.
The wetlands within the study area could be impacted by both the con-
struction and operation of the various alternatives. With the exception of
Alternative 4B, which involves the direct discharge of recovered groundwater
to wetlands, and Alternative 2 which uses no land application sites, opera-
tional impacts related to wetlands would be due almost entirely to the
hydrologic effects of the various alternatives. Impacts would vary m
proportion to the magnitude of the hydrologic changes, which in turn depend
upon the volume and periodicity of wastewater discharges to adjacent land
application sites.
In general, affected wetlands would become less mesic as the water table
rises. Species composition would gradually change, with the most pronounced
effects being near the upland edge proximal to the land application site. In
addition to increases in the average groundwater level, the periodicity of the
hydrologic regime would be changed. Peak flows are expected m summer,
ordinarily the driest part of the year. Hence, the magnitude of periodic
hydrologic changes would be damped out, leading to more constant conditions.
Wetland habitats which depend on this periodicity would be changed over time
and replaced by types adapted to wetter and more constantly wet conditions.
3-49
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An example of the occurrence of this kind of succession is the northern
boundary of the SASS site. Most of the taller trees in the proximal zone have
died and are being replaced by scrub shrub and other low-lying vegetation more
tolerant of constant wetness.
This type of succession in a narrow zone adjacent to the land application
site ought to be the limit of impacts under Alternatives 1 and 3 near the IBU
site. Projected flows are simply not great enough to have a pronounced
effect. However, under Alternatives 1 and 4 near Oyster Bay and under
Alternative 4 at IBU, greater flows are anticipated, and hydrologic-related
impacts could be substantial. Impacts could easily extend throughout the
palustrine zone and may even move the palustrine-estuarine boundary oceanward.
Insufficient data currently exist to predict the magnitude of these impacts;
modeling of the hydrologic changes has not yet been performed.
Little information is available regarding the use of natural wetland
systems in the disposal of recovered groundwater which would occur with
Alternative 4B. Potential impacts could include the following:
o Flushing of nutrients and/or sediments out of the wetlands
o Alteration of the vegetative community
o Modification of the wildlife due to habitat change
o Organic overloading of the wetland.
Further studies would be required to determine the nature and extent of
the actual impacts.
In addition to operational related impacts, the construction of
conveyance lines and pump stations could impact wetlands. The lines would be
placed adjacent to roadways, where possible, to minimize the potential for
impacts during construction and maintenance activities. Table 3-9 lists
wetland areas and the alternatives that would cause conveyance lines to be
constructed within 1,000 feet of the wetlands. This assessment was based on
preliminary estimates of the potential locations of conveyance lines.
3-50
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Table 3-9. Potential Construction Impacts to Wetland Areas
Alternatives
Location of Uetland Area
Alt 1
Alt 2
Alt 3
Alt 4A
Alt 4B
Alt 4C
Alt 4D
A. Adjacent to Oyster
Bay near Bear Creek
B. Adjacent to SR 59
between Little Lagoon
and Gulf State Park
C- Adjacent to and south
of SR 180 and west of
the claypit near 1BU
D. West of 1BU and adjacent
to SR 180
E- South of GIWW near Gulf
State Park and Gulf
State Park Golf Course
1/4 mile directly south
of IBU and north of
Shelby Lake
G- Adjacent to and east of
Bon Secour Bay, southwest
of Oyster Bay
ii . . . ,nnP1 nf a wetland in the mediim growth scenario.
N°te: X indicates a conveyance line comes within 1000 feet
3-51
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3.4.1.5 Archaeological and Historic Resources
The records of the Alabama Historical Commission list several historic
and archaeological sites within the study area. Two af the historic sites are
currently listed in the National Register of Historic Places (NRHP), and
several other structures have the potential for nomination to the National
Register. However, a few of thes^e structures have been moved and/or are in
poor condition, which reduces their potential for designation as sites of
historic significance. The Swift House and the Magnolia Springs district have
the most potential for inclusion in the National Register because of their
architectural styles and ages. The locations of the historic sites in the
study area are shown on Figure 3-9.
About 145 archaeological sites are located within Baldwin County. While
125 of these sites were not evaluated as to eligibility for inclusion on the
NRHP, 20 of these sites were considered potentially eligible for NHRP nomina-
tion by professional archaeologists. Additionally, a large portion of the
study area has never been surveyed for cultural resources.
In 1981, a reconnaissance-level archaeological survey was conducted by
N.R. Stowe in southern Alabama, covering land which included the study area.
Several village sites, shell scatters, and shell mounds were found. It is
believed that villages were inhabited during the Early Woodland Period (around
200-100 B.C.). It is not known if one group or several groups of people were
responsible for the scatters, mounds, and villages. The locations of some
archaeological sites found in the study area are shown on Figure 3-9.
Neither the SASS, IBU nor GUSC wastewater treatment plants are located on
historical or archaeological sites. In addition, proposed conveyance lines
which would carry treated wastewater from the treatment plants to the disposal
sites would not impact historical or archaeological sites. Three of the nine
historic sites lie outside of the boundary of the area to be served by the
three sewerage districts. If new raw wastewater conveyance mains were
installed or lines were replaced near historical sites, any blasting or
3-52
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right-of-way acquisition could impact the historical sites. Twenty-seven
archaeological sites shown on Figure 3-9 are located near water bodies, thus
there is little likelihood that these sites would be impacted by raw waste-
water conveyance mains. However, if a conveyance main is to be installed near
one of the sites, preconstruction surveys by a professional archaeologist
should be conducted to minimize the potential for impacting these sites.
3.4.1.6 Recreational Resources
The Gulf Shore area posses the natural beauty which is typically of most
coastal regions. The natural attributes of this area include the Gulf of
Mexico, the GIWW, Barrier Islands, beaches, sand dunes, fresh and salt water
marshes. These resources provide pleasure and recreation for both local
residents and tourists.
The region contains 32 miles of Gulf beaches; 395,000 acres of estuaries,
bays and inlets; and a 700 acre freshwater lake (Lake Shelby) in Gulf State
Park. The Weeks Bay Wildlife Sanitary is also located in the study area. At
least seven marinas serving the area give boaters and fishermen easy access to
nearby waters.
Impacts could result from conveyance line and pump station construction
but would be primarily short-term and related to erosion, noise and dust. The
land application alternative would have a long-term positive impact because
the existing wastewater discharges to the GIWW would be removed. Alternative
2 would have a long term negative impact on recreational resources because all
the wastewater effluent would be discharged to the Gulf of Mexico.
3.4.1.7 Noise. Odor and Air Quality
Air quality impacts could occur from both construction and operation of
the proposed wastewater treatment facilities. Construction activities include
the expansion or upgrading of the facilities and installation of piping, while
operational impacts may occur at the wastewater treatment facilities or at
land application sites.
3-54
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Construction impacts would be related to particulates in the form of
fugitive dust. Fugitive dust results primarily from earth-moving activities,
disturbance of the ground by the wheels of motor vehicles, and wind action on
loose soils. Impacts from fugitive dust are typically short-term and very
localized. The emissions can be minimized by watering during dry periods,
covering dump truck beds, reducing the speed of motor vehicles on unpaved
surfaces, and placement of gravel at dirt road and pavement interfaces to
minimize tracking of dirt onto pavements. If the above mitigation practices
are observed, air quality impacts from construction activities due to any of
the four alternatives should be insignificant.
Impacts related to operation would be associated with aerosol formation
from the activated sludge process at the treatment plants and the land
application systems. All three plants use the activated sludge process in
some manner for each of the alternatives so impacts caused by treatment plant
operation would be essentially the same regardless of the alternative
selected. Land Application impacts would vary among the alternatives based on
the number and type of land application sites used. More aerosols are
generated with spray irrigation than rapid infiltration basins and there would
be a bigger public health threat with public use land application sites (e.g.,
golf courses) than dedicated sites. Alternative 4 would have the most impacts
and Alternative 2 would have no impacts. Alternatives 1 and 3 would have
minimal impacts.
Aerosols are very small airborne droplets, less than 20 microns in
diameter, that may carry bacteria and viruses. Normally, neither pathogenic
protozoa and helminthis nor their eggs are contained in the aerosols.
Immediately following generation, aerosols are subjected to an impact factor
which may reduce bacteria concentrations by 90 percent and virus concentra-
tions by 70 percent. Further reduction may be caused by desicassation,
temperature, deposition, and solar radiation. The dispersion of the aerosols
is influenced by wind speed, air turbulence, and local topography.
The concentration of bacteria and viruses in aerosols generated from
sprinklers at land application sites is a function of their concentration in
the applied wastewater and the aerosol production efficiency of the sprinkler.
3-55
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This latter factor depends on nozzle size, pressure, angle of spray tra-
jectory, angle of spray entry into the wind and impact devices. Bacteria can
not be detected in aerosols at distances of greater than 10 meters when
bacteria concentrations in the applied wastewater are between lO^/mL and
lOVmL (EPA, 1981) . Disinfected effluent would be applied in each of the
alternatives, so the concentrations of bacteria would be expected to be lO^/mL
or less. Aerosols containing bacteria would not travel far from the spray
site and therefore public health impacts would be minimal. To further reduce
the potential for public health impacts: 1) spraying could be conducted
during daylight hours only to increase the number of microorganisms killed by
ultraviolet radiation, 2) downward-directed, low pressure sprinklers could be
used to reduce the quantity of aerosols generated, 3) a buffer zone could be
placed around the spray site to separate the spray source from the general
public, and 4) vegetation could be planted around the site to act as a natural
filter.
Because the concentration of bacteria is higher in activated sludge
aeration tanks than disinfected effluent, the concentration of bacteria in
aerosols generated from these processes is higher. Epidemiological studies of
activated sludge plants indicate that there is no significant disease rate
increase for nearby populations (EPA, 1981).
Impacts associated with odor can occur at the wastewater treatment
facilities and at land application sites. Odors from treatment facilities
will be minimal if the facilities are properly designed, constructed, oper-
ated, and maintained. Odors from land disposal would vary with the amount of
pre-application treatment and the type of application (i.e. public use vs.
non-public use).
Potential odor impacts from facility operation can result from each of
the four alternatives being considered, since all facilities would operate
under each alternative. Odor problems at wastewater treatment facilities are
more likely to occur during the summer months, due to the higher loadings and
lower oxygen transfer efficiencies associated with warmer weather.
3-56
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The GSUB plant could potentially have an odor impact on the eastern
portion of Gulf Shores, especially during the spring and late summer when
winds are predominantly from the east.
The SASS plant is relatively isolated, with the exception of a few
scattered residences to the east of the facility. Westerly winds, which occur
predominantly during the summer, create the greatest potential for impacts to
these residences.
The IBU plant is physically isolated, and therefore has little potential
for creating odor impacts. Proper zoning of land around this plant can keep
future odor impacts at a minimum by creating buffer zones around the facility.
Land application may produce odor-related impacts. This disposal option
is proposed for Alternatives 1, 3 and 4. Alternatives 1 and 3 consider land
application at the existing land application site adjacent to the IBU plant
and at the existing land application site adjacent to the SASS plant. For
Alternative 1, IBU would acquire an additional land application site. As
discussed above, the IBU and SASS plants are isolated, and no odor impacts
should occur. The Alternative 4 options consider land application south and
north of the GIWW. These sites may involve human activities (e.g., golf
courses and sod farms), but because the effluent placed on these sites would
be treated to secondary standards plus disinfection, there would be a low
probability of producing a significant odor impact. Proper location of land
application sites would minimize potential impacts by providing buffer zones
between the site and any receptors.
Noise impacts would be associated with construction activities. Con-
struction noise impacts would occur in areas where heavy equipment, such as
earth movers and dump trucks, were operated. These impacts would be of short
duration and would occur primarily during daylight hours. Daytime operation
and proper use and maintenance of equipment would help mitigate potential
construction noise impacts.
Noise impacts could also result from increased traffic in the study area
and from population growth. Since all alternatives are projected to accommo-
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date future growth in the study area by providing wastewater treatment facil-
ities , these impacts would be the same for each of the alternatives under
consideration. Even if development caused traffic to double, it would result
in only a 3-dba noise increase which is barely discernable to the human ear.
Therefore, no adverse noise impacts are predicted for implementation of any of
the project alternatives.
3.4.2 Secondary Impacts
The primary purpose of this EIS is to examine the direct impacts of
expanding wastewater facility capacities and disposing of the wastewater
effluent. However, the availability of sewage treatment facilitates economic
and residential development. The effects of this growth are considered
secondary impacts and will be described in this section. The secondary
impacts are considered to be essentially the same for all of the alternatives
because the impacts stem from the availability of sewer service and are not a
function of the disposal method used.
3.4.2.1 Population Growth
The growth in the study area, particularly since Hurricane Fredrick in
1979, has been phenominal, but there are indications that the rate of growth
has peaked and is beginning to level off. City officials and members of the
Alabama Gulf Coast Chamber of Commerce indicated that requests for building
permits have declined and that a number of proposed major residential projects
have been delayed. Furthermore, the impact of the Tax Reform Act of 1986 on
second-home development could significantly reduce the growth rate for
seasonal housing, which has been nearly four times that for permanent housing
in the study area. As a result, the growth rates seen in the study area since
1980 are not likely to be maintained over the next 25 years
The growth rates selected for the population projections developed for
this EIS were based on those developed by the Southern Alabama Regional
Planning Commission (SARPC) (1983) for Baldwin County. The average growth
rate of 14 percent per 5-year period was used as the basis for permanent
growth for the medium-growth scenario. The low and high growth rates were set
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at 7 percent and 21 percent, respectively, levels 50 percent below and above
the average growth rate. These 50-percent adjustments were used to encompass
a range of growth scenarios based on SARPC's average regional growth rate.
Although seasonal housing growth during the past 5 years has been nearly
four times the rate of growth for permanent units, it was determined that this
rate of growth would not be maintained. Instead, a ratio of permanent to
seasonal housing unit growth of 1:2 was applied to the high-growth scenario,
1:1.5 was applied to the medium:growth scenario, and 1:1.25 was applied to the
low-growth scenario. Using these ratios and the permanent population growth
rates, the following quinquennial growth rates were used for each of the
scenarios:
o High Growth:
Permanent Housing Unit Increases - 21 percent
Seasonal Housing Unit Increases - 14 percent
o Medium Growth:
Permanent Housing Unit Increases - 14 percent
Seasonal Housing Unit Increases - 21 percent
o Low Growth:
Permanent Housing Unit Increases - 7 percent
Seasonal Housing Unit Increases - 9 percent
The resultant projections of both permanent and seasonal population are
indicated in Table 2-1, presented previously.
These figures were allocated among the EIS service areas using ADECA's
Projected percentage distribution by service area (ADECA, 1986). The sub-
areas were then combined to determine the population for each of the sewage
districts. Both Weeks Bay and Perdido Beach are to remain unsewered. The
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other three areas, SASS, GSUB and IBU, will be provided service by the
appropriate companies.
Based on recent historical growth rates, the high-growth scenario, most
closely reflects a continuation of the area's rapid growth. The recent
changes in the tax laws and their effects on second-home ownership should
result in a decrease in seasonal unit development as compared with previous
levels. Consequently, the medium-growth scenario appears to represent a more
likely estimate of future growth in the study area. The secondary impacts of
the medium growth scenario only will be discussed in the following sections.
3.4.2.2 Land Use
The study area includes the portion of Baldwin County lying south of the
GIWW and the portion north of the GIWW up to U.S. 98, excluding the City of
Foley. No comprehensive land use survey has been conducted for the study
area. However, a 1983 planning area trends and analysis study was completed
for the City of Gulf Shores, including all of Pleasure Island, Ono Island, the
Alabama portion of Perdido Key and all of the land extending 4.5 miles north
of the GIWW. The study reported that of the 39,360 acres in the planning area,
only 5,642 acres were developed. Nearly 40 percent of the developed land
consisted of residential uses while transportation uses, including the Jack
Edwards Airport, accounted for another 50 percent. The remaining 10 percent
was devoted to commercial, industrial, institutional and recreational uses.
The study reported that 201,198 acres of vacant land remained to be developed.
Ample undeveloped land exists to provide for development within the planning
period (2010).
As future development takes place, there are several methods available to
preserve environmentally sensitive areas and increase recreational
opportunities. These methods can include:
o Wetlands and floodplain preservation
o Mandatory dedication of recreation lands by developers.
o Transfer of development rights from one property to a second
property, thus preserving the first property permanently.
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o Establishment of linear parks along streams and pipeline
routes.
The additional acreage required for treatment plant expansion and con-
struction, collection lines, holding ponds, and land application fields would
be minimal under Alternative 1. With the amount of developable land remaining
throughout the study area, the land requirements for additional treatment
facilities would have no impact on land use. One land application site would
be purchased for 1BU east of the Meyer Tract but this purchase would not be
expected to interfere significantly in development patterns.
Because all three plants would be converted to secondary treatment in
Alternative 2, plant expansion would be reduced compared to Alternative 1. No
land application sites would be used with this alternative, so there would be
no interference with future development patterns.
Alternative 3 would require the most treatment facility expansion but
there would not be any additional land application sites. (The SASS percola
tion ponds and IBU trickle field would continue to be used). This alternative
is expected to have minimal land use impacts.
Although Alternative 4 would require the least expansion and/or con-
struction of wastewater treatment plant facilities, the use of land applica
tion techniques may necessitate the use of additional land areas. Optio
would require the most land purchase on Pleasure Island. Pleasure Islan
expected to come under heavy development pressure in the future, so op
would be expected to have the greatest impacts on land use. Options
would also require Pleasure Island land purchase but not as much
Alternative AD would not use any land on Pleasure Island and only sod
golf course land north of the GIWW. No conversion of land use would be
required with this option so it would have the least impacts on land use.
3.4.2.3 Economics
There are both short-ter» and long-term econo.lc i»pacts associated with
providing expanded wastevater facilities. The short-t.rM impacts .ill be
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those associated with expanding the wastewater treatment facilities and the
collection and conveyance systems. These construction projects will offer
jobs to people in the construction trades and supporting services. However,
these projects will only last a few years and then this short-term economic
impact will cease.
The long-term impacts are much more significant. First the availability
of wastewater facilities will stimulate growth in terms of new construction.
This construction will be a mixture of residential, commercial, and office/
industrial depending on local zoning regulations. New roads will also need to
be constructed to service this development. Therefore, the long-term effects
on the construction industry could be significant.
Significant long-term economic impacts will also come from the permanent
jobs that are created in the South Baldwin County area. Portions of the area
would be zoned for office or industrial uses and, with the availability of
wastewater facilities, these areas would become attractive for economic
development and the creation of permanent jobs.
The industries and services supporting the seasonal tourist trade would
also be expected to increase by either expanding existing establishments or
constructing new places. This expansion would provide more jobs for the area.
3.4.2.4 Transportation
Transportation modes in the study area include roadways, rail, air,
and water, with roadways being the most heavily used means of transportation.
The primary north-south roadway is State Route 59 which is routed through the
cities of Foley and Gulf Shores and terminates to the south on Pleasure Island
at its intersection with State Route 182. State Route 59 provides primary
access to U.S. Interstate 10, located approximately 25 miles north of Gulf
Shores. The northern border of the study area is U.S. 98, which is the major
east-west route on the mainland of the study area. State Routes 180 and 182
are the two primary east-west routes on Pleasure Island with State Route 180
serving Fort Morgan and Orange Beach and State Route 182 providing access to
Florida. County and local roadways are dispersed throughout the study area
serving outlying areas.
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The CSX Railroad serves the study area. The primary rail line is a
north-south line which parallels State Route 59 and terminates in the City of
Foley. Air service in the study area is provided by Jack Edwards Airport in
Gulf Shores. The field is a general aviation airport with no commercial
service. Water transportation routes in the service area consist of the Gulf
of Mexico, the GIWW, and numerous bays and inlets. The waterways are primarily
used for recreation and commercial fishing.
Transportation-related impacts will be associated with increased numbers
of motor vehicles due to population growth in the study area. Transportation
impacts will be the same for each of the four alternatives which were con-
sidered. Traffic congestion is seasonal and occurs during summer months due
to the large influx of vacationers. The seasonal population is predicted to
approximately double by the year 2010, which will require selected roadway and
intersection improvements.
Recently the City of Gulf Shores underwent a traffic study. Short and
long-term recommendations included widening Route 59, Fort Morgan Route (Route
180) and Route 182 and constructing two four lane bridges across the GIWW
including an eastern bypass.
Several short-term impacts associated with roadway construction are
noise, dust, erosion and loss of habitat. Stream crossings could cause a
major impact to the natural environment. Long-term impacts wo
associated with such projects as roadway widening and new roadway construc-
tion. Adjacent homes and businesses would experience higher noise levels and
carbon monoxide gas from vehicle exhaust.
3.4.2.5 Community Services
Community facilities such as fire and police protection, hospitals,
schools, and refuse disposal are essential components of any neighborhood. As
the study area develops, it is important to ensure that sufficient community
facilities are available to meet the increasing population.
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Table 3-10 presents the anticipated effect the population growth may have
in the South Baldwin County area. The factors in the table are based on
national trends and are assumed to be applicable to the study area. The table
provides a comparison of the year 1985 and year 2010 requirements and is based
on the medium growth projections. This analysis does not take into considera-
tion those facilities and services that currently exist.
Table 3-10 provides estimates of the school age children; however, this
section does not endeavor to analyze current enrollments in the schools. The
estimates provide a general idea of the impact that growth and development in
the study area could have upon school enrollments. The estimates are based on
the number of permanent households in the study area. Since the study area
development trend is in the direction of an older, retirement-oriented
community, the above estimates may be too high.
According to Urban Planning and Design Criteria, there should be one
library for a minimum of 6,000 persons. Using this standard there would be a
demand for new library facilities in the study area. This would require an
increase of two facilities by year 2010. The number of facilities presented
in Table 3-10 are based on the permanent population value estimates. The
number of new facilities would be decreased if the minimum population served
was increased.
Based upon a national standard of 2.08 offices per 1,000 population, the
study area will require an additional 134 officers by the year 2010. The
numbers presented in Table 3-10 are based on both the permanent and seasonal
population estimates. It should be stated that the number of police officers
were not inventoried.
Based upon a minimum standard of 0.99 firemen per 1,000 population,
the study area would require an additional 64 firemen by year 2010. The
numbers presented in Table 3-10 are based on both permanent and seasonal
population estimates. The number of firemen were not inventoried.
The analysis in Table 3-10 simply demonstrates the number of hospital
beds required for current and projected populations in the study area. These
requirements are based upon a national standards of 4 beds per 1,000 persons
3-64
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Table 3-10. Fact Sheet for
Secondary Growth Impacts
Population Total
Number of Permanent Households
Permanent Population
- 2.3 persons per household
Number of Seasonal Households
Seasonal Population
- 4.0 persons per household
Solid Haste
3.5 lbs/day/person
Recreation Facilities
Standard for playground is
1.5 acres per 1,000 population
Police Protection
2.08 officers per 1,000 population
1985
45,363 persons
4,584 households
8,705 households
158,770 lbs/day
79 tons
30 acres
2010
109,812 persons
9,178 households
22,176 households
383,340 lbs/day
192 tons
73 acres
Increase
64,449 persons
4,594 households
13,471 households
225,170 lbs/day
113 tons
43 acres
94 police officers 228 police officers
134 police
officers
Fire Protection
0.99 firemen per 1,000 population
Fire Flow
Required is 3,500 gpm per 14,000
population for 10 hour duration
Transportation Personnel
1.15 per 1,000 population
Traffic Generation
10 trips per household per day
Neighborhood Shopping
Minimum is 2,500 persons
45 firemen
109 firemen
64 firemen
11,340 gpm for 10 hour 27,450 gpm for 10 hour 16,110 gpm for 10
_i—hour duration
duration
39 personnel
132,890 trips
18 facilities
duration
95 personnel
313,540 trips
44 facilities
56 personnet
180,650 trips
26 facilities
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Table 3-10. Fact Sheet for
Secondary Growth Impacts
(Cont'd.)
J2§5 2010 Increase
Schools
Nursery School
0.20 children times nuntoer of 917 children 1,836 children 919 children
households
Elementary School
0.54 children times nuiber of 2,475 children 4,130 children 1,655 children
households
Junior High
0.22 children times nunber of
households
Senior High
0.22 children times mmber of
households
Libraries
Require minimum of 6,000 persons
Health Care
1,008 children
1,008 children
2 facilities
2,019 children
2,019 children
4 faciliti<
1,011 children
1,011 children
2 facilities
National standard for acute 181 beds 439
health care is 4 beds per 1,000
persons in SHSA's
"•"'V""''" W, v„ Moslrand WW
Corrpany Inc., New York, New York
Fiscal Impact Handbook, Robert W. Burchell and David Listokin, 1978, The Center for Urban Policy
Research, P.O. Box 38, New Brunswick, New Jersey.
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for acute health care. Since many persons may go to health care facilities
located outside of the study area, the number is shown in Table 3-10 could
possibly be reduced.
An overall analysis of Table 3-10 vould indicate the demand for addi-
tional services. There will be more people, demanding more and better
services.
3.4.2.6 Water Qua! i t-y
Population growth and land development could increase non-point source
pollution which leads to water quality impacts. All alternatives were assumed
to have the same level of population growth and land development so similar
impacts would occur.
The term "nonpoint source" pollution refers to those pollutants that
enter surface water or groundwater at nondiscernable points. Within the EIS
study area, existing nonpoint source pollution occurs in at least two distinct
ways. The first is rapid leaching of pesticides, fertilizers and septic tank
effluent to shallow groundwater in the portion of the study area that has
excessively drained, porous, sandy soils along the Gulf coast and Bon Secour
Bay. The second is runoff carried sediment, organic materials, toxic metals,
toxic organic compounds, oil and grease, and so on. The surface water runoff
of these materials generally occurs in inland portions of the study area which
have sandy loam soils.
The Alabama Department of Environmental Management has prepared a Non-
point Source Assessment Report (1988) and a Nonpoint Source Management Program
(1989) pursuant to Section 319 of the Federal Water Quality Act of 1987. The
first of these two reports identifies surface waters that have impaired use
because of nonpoint source pollution. The second report proposes a Nonpoint
Source Management Plan that ADEM will implement from 1989 through 1992. Table
3-11 shows three surface water bodies of the study area that have use impair-
ment by nonpoint source pollution. Sources of pollution affecting these
surface water bodies include agricultural runoff, failing septic tank over-
flow, illegal roadside garbage heaps, and natural occurrences. (An example of
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Table 3-11. Surface Water Bodies Uith Use Impairment
by Nonpoint Source Pollution
Water Body
Name
Extent of
Impairment
Designated
& Impaired
Use
Perdido Bay 32,000 acres Shellfish Production
Cause & Maani tude
Pesticides - Slight
Nutrients - Moderate
Organic Enrichment/DO
Moderate
Sources &
Magnitudes
Nonirrigated Crop Production
Septic Tanks - Moderate
Natural - Moderate
Wolf Creek
5 miles
Primary Contact
Priority Organics -
High
Nonpriority Organics -
High
Nutrients - High
Organic Enrichment/DO
High
Other Habitat Altera-
tions - High
Pathogens - Moderate
Landfills - High
(illegal roadside garbage
dimps)
Intracoastal
Waterway
5 mi les
Aquatic Fish and
Wildlife
Organic Enrichment/DO
High
Natural - Moderate
Source: Alabama Nonpoint Source Assessment Report. Alabama Department of Envirormental Management 1988.
3-68
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a natural occurrence is low dissolved oxygen water draining from swampy
areas.) Sufficient information was not available to assess groundwater
impacted by nonpoint source pollution. However, ADEM identified nonpoint
source impacted groundwater as an issue in the Assessment Report (1988) and
plans to conduct groundwater assessments during 1989 and 1990. The results
are to be included in the FY90 Nonpoint Source Assessment Report.
Table 3-12 lists potential nonpoint source impacts. Providing sewer
service to houses with failing septic tanks would have a beneficial
effect by eliminating the leaching and runoff of nutrients and pathogens.
The remaining four activities shown in Table 3-12 have the potential to cause
adverse nonpoint source impacts and are associated with development in the
study area. Erosion at construction sites can cause sedimentation in surface
waters. Increasing road, parking lots and other impervious areas can result
in runoff of toxic metals, toxic organic compounds, sediment and other
pollutants. As coastal areas are developed for commercial and residential
uses there will be increased traffic, pedestrian pathways, litter, and the use
of pesticides and fertilizers. Wind erosion may be increased. The shallow
groundwater aquifer may be impacted by the leaching of nitrates and mobile
pesticides/herbicides. Development inland also would cause increased traffic,
pedestrian travel, and increased pesticide and fertilizer use. Surface water
runoff would contain increasing amounts of sediment, toxic compounds, pet
debris, and other pollutants.
The City of Gulf Shores has standards for the control of erosion, sedi-
mentation, and storm water runoff (1984). The standards outline the require
ments of Ordinance Number 311 adopted by the City of Gulf Shores on December
17, 1984. Orange Beach does not have such a standard. A recommendation of
this EIS is that Orange Beach adopt erosion control, sedimentation and storm-
water runoff controls consistent with ADEM's nonpoint source management
Program.
The Mining and Nonpoint Source Section of ADEM uses the enforcement
authority granted to the Agency by the federal Water Quality Act and Alabama
Water Pollution Control Act in requiring the implementation of Best Management
Practices (BMPs) for controlling erosion and sedimentation. This authority
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Table 3-12
Potential Nonpoint Source Impacts of the
Preferred Alternative
Activity
Sewer service provided
to failing septic tank
houses.
Construction activities.
Runoff from roads, parking
lots and other impervious
areas.
Commercial and residential
development of coastal
areas.
Commercial and residential
development of inland areas.
Impact
Beneficial - Eliminate
leaching and runoff of
nutrients and pathogens.
Adverse - Erosion.
Sedimentation of surface
water.
Adverse - Toxic metals,
toxic organic compounds,
sediment, and oil and
grease in surface water.
Adverse - Beach and dune
erosion. Leaching of
pesticides and fertilizers
to groundwater. Litter.
Adverse - Sediment fertil-
izer, pesticides, and
other pollutants in surface
water.
Mitigation
None required.
Silt fence curtains.
Vegetate disturbed
land.
Infiltration
structures. Sedi-
ment basins.
Created wetlands.
Buffer strips. Bank
Stabilization.
Street cleaning.
Maintain wind
breaks. Maintain
vegetated areas.
Land use controls:
zoning ordinances
fertilizer manage-
ment
pesticide manage-
ment
Infiltration
structures. Sedi-
ment basins.
Created wetlands.
Buffer strips.
Land use controls:
required sewer
hookup
zoning ordinances
fertilizer and
pesticide manage-
ment
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applies only to State of Alabama Waters in areas not governed by local or
county ordinances. Baldwin County does not have an erosion and sedimentation
ordinance and, therefore, would fall under ADEM's jurisdiction.
Reducing nonpoint source pollution is probably the key element in
improving area water quality, especially Bon Secour and Wolf Bays from which
source waters for the GIWW are derived. Nonpoint source pollution is a
national problem not unique to Alabama. To help improve area surface and
groundwater quality, Alabama has generated an extensive Section 319(h)
Nonpoint Source Management Plan. A total of $1,196,501 in federal and state
monies has been scheduled for FY 1991.
3.4.2.7 Ecological Resources
The increased population associated with the expanded wastewater facili-
ties would cause impacts to the ecological resources of the area. Increased
population could cause development in areas currently serving as wildlife
habitat. This encroachment could reduce the quantity of wildlife and force
the remaining animals into smaller and smaller areas. Eventually a shift in
the dominant type and distribution of wildlife could occur.
The increased development may have a very serious impact on the Pleasure
Island habitat of the endangered Alabama beach mouse and Perdido Key beach
mouse. The construction of residences and other structures would cause a
decrease in the mouse population but in addition, activities such as biking,
walking, use of beaches, driving and the increase in household pets could also
decrease their numbers. Although critical habitat areas are protected under
the Endangered Species Act and any federal funding or permitting of projects
would be required to consider impacts to the mice, little can be done to avoid
growth in surrounding areas on Pleasure Island.
Increased development would lead to the removal of native vegetation
and the replacement of some native vegation with grass species. The severity
°f impacts would depend on the location and density of development and the
quantity of open, undisturbed space that would remain.
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3.4.2.8 Archaeological- Historical and Recreational Resources
Indirect impacts on cultural resources (e.g., archaeological, historical
and recreational resources) would result from implementation of any of the
project alternatives. Induced growth typically leads to increased tourism and
area development. Since all of.the alternatives are projected to induce
growth in the study area, impacts on cultural resources due to population
increases would be the same for each of the alternatives. Increases in
tourism in the study area would be seasonal, and would occur primarily during
the summer months. The permanent and seasonal populations are predicted to
increase significantly by the year 2010. This influx of tourists would
increase the number of people who visit cultural resource sites, and may
affect the use and development of the land surrounding the sites. With an
increase in tourism, land use surrounding the cultural sites may change from
low-density agricultural to residential/urban. Construction of apartments,
condominiums, houses, hotels, and shopping centers would increase to meet the
needs of tourists. When wastewater expansion occurs, site-specific historic/
archaeologic studies of those sites identified in Figure 3-9 presented earlier
would be necessary to accurately assess impacts due to growth.
As population increases, the amount of land dedicated to parks and open
spaces should also increase proportionately. Land should be acquired through
fee-simple purchases or dedication of land by developers as development
occurs.
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PREFERRED ALTERNATIVES
-------
4.0 PREFERRED ALTERNATIVES
4.1 INTRODUCTION
The four alternatives described in Chapter 3 were evaluated and
culminated in the identification of a preferred and an acceptable alternative.
A "preferred alternative" is defined as being superior in terms of
environmental soundness, cost effectiveness or both. When federal funds are
used to assist a project, the action would have to be consistent with the
recommendations in the EIS and not conflict with the selected alternatives.
This EIS has identified a preferred and an acceptable alternative; 40 CFR
1502.14 (e) provides that more than one preferred alternative may exist.
Within the context of these selected alternatives, ADEM may choose the course
of action that is most appropriate without foreclosing potential federal
funding.
If ADEM wanted to approve a project for Title II or VI funding which was
significant]v different from the preferred and acceptable alternatives, a
supplemental EIS would have to be prepared. The supplemental EIS would need
to justify, in economic, technical, and environmental terms, why neither the
preferred or acceptable alternatives were no longer viable.
This chapter will describe the selected alternatives, no action and land
application, for the three sewerage districts. Because the three districts
are financially and administratively independent, the two alternatives must be
addressed separately for each system. Although the alternatives are not
necessarily identical, both are considered to be environmentally sound and
cost effective.
^•2 GSUB
^•2.1 Description of Alternatives
Th, preferred alternative for GSUB Is Alternative 4A, slow-rate land
aPPlication on Pleasure Island. The operation of the wastewater treatment
4-1
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plant would be converted to provide secondary treatment with effluent
filtration and disinfection. The wastewater effluent would be applied to the
Gulf State Park golf course and Gulf Shores Golf Club golf course, using the
existing golf course distribution systems, and to a dedicated site on the west
side of the Meyer Tract.
The no-action alternative, Alternative 1, would constitute an acceptable
alternative for GSUB. The treatment plant would continue to provide tertiary
treatment and all of the effluent would be discharged to the GIWW.
4.2.2 Project Costs
The ultimate cost to provide sewer service to the GSUB system users would
include capital costs for facility construction and annual costs for facility
operation and maintenance. The capital costs for construction would entail
raw sewage collection and conveyance sewers, wastewater treatment facilities,
treated effluent force mains and conveyance lines, and sludge treatment
facilities. Both treatment and disposal costs for wastewater and sludge are
included in annual operation and maintenance.
Table 4-1 lists the costs for the two selected alternatives for GSUB. It
should be noted that all costs are in 1989 dollars. The costs for raw sewage
collection and conveyance lines were not included; it was assumed that the
size and location of new collection lines would be a function of develop- ment
and would be independent of the wastewater disposal alternative selected.
Collection system costs would be the same regardless of the alternative
selected and therefore, are not included in the analysis. Also, the analysis
does not include the cost of any existing treatment or disposal facilities.
The total present worth of the land application alternative, as presented
in Table 4-1, was calculated to be $10,622,000. The no-action alternative was
determined to have a present worth of $6,920,000.
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Table 4-1. Summary of Costs for GSUB(1)
Cost
Component
Treatment
Project Costs(2)
Total Annual 0&m(3)
Salvage Value
Net Present Worth
Disposal
Project Costs
Total Annual O&mO)
Salvage Value
Net Present Worth
Total Present Worth
Land Application
Alternative
$ 1,334,000
13,450,000
703,000
5,829,000
4,731,000
1,952,000
4,226,000
4,793,000
$10,622,000
No-Action
Alternative
$ 2,291,000
14,380,000
1,207,000
6,497,000
328,000
259,000
127,000
423,000
$ 6,920,000
Notes:
(1) All costs in 1989 dollars.
(2) Project costs reflect construction costs times 1.3 to account for
engineering, contingency, legal fees.
<3> Total for 1991-2010.
4-3
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4.2.3 Financing Alternatives
In addition to local funding sources, GSUB could receive money from the
State Revolving Loan Fund or the Grant Program, both supported by federal
dollars, to finance the expansion of the wastewater treatment plant and the
construction of the wastewater disposal facilities.
The EPA issued the State of Alabama a capitalization grant of $10,500,000
in 1989 to start the State Revolving Loan Fund. This fund was authorized by
Title VI of the 1987 Water Quality Act (PL 100-4) and is used to finance
wastewater projects. The monies are loaned from this fund at approximately 5
percent interest and are distributed based on a priority system.
Also in 1989, the EPA allotted the State of Alabama a construction grant
of $10,500,000 to finance wastewater projects. The money in this fund is
distributed in a manner to the State Revolving Loan Fund.
The total federal allocation to Alabama was $21,000,000. Alabama
provides an additional 20% from the State budget for the State Revolving Loan,
as required by EPA. The State does not maintain a separate revolving loan
program with State appropriated funds.
4.2.4 User Charges
User charges were calculated for both of the preferred alternatives.
The charges would vary because each alternative would involve different
treatment and disposal processes. For the purposes of this report, user
charges were based on annual cost per Equivalent Dwelling Unit (EDU). The
wastewater generation rate per EDU was assumed to be 300 gpd.
The purpose of estimating user charges was not to predict the actual cost
to consumers, but rather to estimate charges under "worst case" conditions, to
assess the affordability of the alternatives.
4-4
-------
The assumptions used in generating the analysis are outlined below:
o Number of households based on medium range population projections.
o All construction costs (treatment and disposal) to be paid by users
of the system.
o Existing sewerage districts connection fees would remain constant,
with revenues generated by the fees used to retire debts associated
with the project costs of construction of new treatment and disposal
facilities.
o Developers would pay for new collection facilities.
o All bonds will be amortized over 20 years with an interest rate of
6.0 percent for municipal bonds and 8.5 percent for private bonds.
The 6.0 percent interest rate was chosen for municipal revenue bonds
based on information obtained from GSUB.
o The 1987 median income value from the Bureau of Census will be used
to calculate percentage of median income values.
o All costs were translated into 1989 dollars using an interest rate
of 8-7/8 percent.
o Connection fees and grinder pump costs were assumed to be add-on
costs to the purchase.price of new homes. As such, these costs were
financed through a home mortgage amortized over 30 years with an
annual interest rate of 10 percent.
As previously stated, this analysis considers the "worst case ' cost which
W°uld occur at the beginning of the planning period when new debt payments are
distributed over the smallest number of customers or when new facilities are
instructed during the planning period. Construction on the disposal facili-
ties was assumed to begin in year 1991, the beginning of the planning period.
4-5
-------
Construction for new treatment facilities was assumed to begin in year 2000,
one year before the facilities would be needed. User charges were calculated
for both years (1991 and 2000) to determine which year would result in higher
charges. The "worst case" results are presented in the analysis.
As part of the analysis, the annual debt service associated with new
treatment and disposal facilities and mortgage payments associated with
connection fees had to be calculated. These values are presented in Table
4-2. The annual debt service charges were then added to annual O&M costs for
treatment and disposal to calculate total annual user charges.
Table 4-3 lists the results of the user charge analysis. Annual costs
are listed as a total cost per EDU. It is important to recognize that the
total costs listed in the table would not be directly charged to users by the
sewerage utility since a portion of the cost may be incorporated in the
household's monthly mortgage payment.
Standard affordability criteria, for sewerage systems developed by EPA,
consider a project affordable to the community if the total annual user charge
falls within the following guidelines (EPA, 1983):
o 1.0 percent of median income if income is less than $10,000
o 1.5 percent of median income if income is between $10,000-§17,000
o 1.75 percent of median income if income is above $17,000
The 1987 median family income for Baldwin County as measured by the Bureau of
Census, was $32,400. Following the EPA criteria, the 1.75 percent value would
apply to Baldwin County. As seen from Table 4-3, annual user charges for both
alternatives comprise less than 1.75 percent of the median income under "worst
case" conditions.
It should be reiterated that all costs were based on a "worst case"
condition and that actual user charges would likely be less than those
presented here. Several factors could cause a reduction in user charges,
including the following:
4-6
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Table 4-2. Annual Debt Payment Breakdown for GSUB
Land Application No-Action
Alternative Alternative
Treatment
Project Costs
Year of Facilities Construction^)
Annual Debt Service(2)
Disposal
Project Costs
Year of Facilities Construction^)
Annual Debt Service^)
Connection Costs(^)
Tap-In
Grinder System
Annual Mortgage(5)
$1,334,000
2000
$ 116,300
$3,644,000
1991
$ 317,700
$
$
1,000
0
106
$2,291,000
2000
199,700
$
$
$
327,600
1991
28,600
1,000
0
106
Note;
(1)
(2)
(3)
(4)
(5)
Construction assumed to occur 1 year before °™nt'
Assumes municipal revenue bond at 6 percent interest, 20 year paym
period. Capital Recovery Factor - 0.0871846.
Construction assumed to occur at beginning o p ann g
Initial cost to homeowner to tie into ^em.^ ^ Recovery Factor
Assumes 30 year mortgage at 10 percent in
= 0.1060792.
4-7
-------
Table 4-3. Estimated User Charges for GSUBC1)
Land Application No-Action
Alternative (2) Alternative(3)
Annual O&M Costs
$519,100
$683,000
Annual Debt Payment
$317,700
$228,300
Total Cost (O&M + Debt)
$836,800
$911,300
Flow in Max. Cost Year (mgd)
2.10
2.96
Customer Base, EDU
7,000
9,867
Annual Cost (O&M + Debt)/EDU
$ 119
$ 92
Annual Connection Fee/EDU
$ 106
$ 106
Annual User Charge/EDU
$ 225
$ 198
Percent of Median Income(^0
0.69
0.61
Notes:
(!•) All costs in 1989 dollars.
(2) Costs for year 1991.
(3) costs for year 2001.
W Based on 1987 Baldwin County median income of $32,400.
4-8
-------
o More rapid growth increases the number of households available to
pay treatment costs.
o Grant or low interest rate loan money becomes available to fund
portions of the project.
Businesses, industries or developers pay higher portions of the
facility's construction costs.
4.2.5 Environmental Impacts
T.bl. 4-4 highlights the primary and secondary Impacts associated with
the two preferred alternatives for GSDB. A detailed description of the
t-hat would occur with each of the
impacts, both primary and secondary,
rj Thaf discussion stiovzl.cl b© consio&xsu.
alternatives is contained in Chapter 3. That discu
supplemental to the review of impacts presented h
4.2.6 ReauiredjfltlUfe^^ Alternates
A summary of the measures required to mitigate the pri y P
associated with the nc-action alternative is presented In Table 4-5. Ml lg»-
tion associated with secondary impacts Is presented in Section . .
The wastewater entering the GIW should continue to receive
treatment, as is the present practice, to minimise impacts to the ^
,, f t-hp GIWW could be monitored above and below the
addition, the water quality of the GIWW .
U +- fkfl discharge of wastewater was having an
discharge if there was evidence that th
impact on GIWW water quality.
4.2.7 HlrigflHnn M»,...ires p.T.
-------
Table 4-4. GSUB - significant Impacts of the Two
Acceptable Alternatives
Land Application Alternative
Mo-Action Alternative
Impact
Primary Impacts
Surface Water Resources
Groundwater Resources
Ecological Resources
Wetlands
Beneficial
Removes wastewater
discharge from the
GIUW.
Recharges the alluv-
ial/coastal aquifer.
Adverse
Beneficial
Potential for ground-
water contamination.
Potential for a shift
in the vegetative com-
munity on the land
application sites.
The hydrologic regime
of wetlands near land
application sites
could be altered.
No inpacts to ground-
water quality.
No inpacts to wet-
lands.
Adverse
Increases discharge
to G1MJ.
No aquifer re-
charge.
Could potentially
reduce the value of
the GIUU as a sport
fishery.
Archaeological/Historical/
Recreational Resources
Ho impacts to archaeo-
logical or historical
resources. Removes
discharge to GIUU, a
recreational resource.
No inpacts to archaeo-
logical or historical
sites.
Continued discharge
to GIUU, a recrea-
tional resource.
Noise/Odor/Air Quality
Secondary Inpacts
Population Growth
Land Use
Sewer service avail-
ability would facil-
itate (but not cause)
growth in the area.
Aerosol formation at
treatment plant and
land application
sites; odor generation
at treatment plant and
land application sites.
Requires land on
Pleasure Island to be
dedicated to land
application.
Sewer- service avail-
ability would facil-
itate (but not cause)
growth in the area.
No impact; land appli-
cation not required.
Aerosol formation
and odor generation
at treatment plant.
4-10
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Table 4-4. GSUB - Significant Impacts of the Two
Acceptable Alternatives
(Cont'd.)
Land Application Alternative
Mo-Action Alternative
Impact
Economics
Transportation
Community Services
Beneficial
Could provide long-
term economic
improvement as the
availability of sewer
service promotes
location of new
businesses and expan-
sion of existing
businesses.
Adverse
Beneficial
Could provide long-
term economic improve-
ment as the avail-
ability of sewer
service promotes loca-
tion of new businesses
and expansion of
existing businesses.
Increased traffic and
congestion on road-
ways.
Number and quality of
services would need to
be increased.
Adverse
Increased traffic
and congestion on
roadways.
Nunber and qual ity
of services would
need to be in-
creased.
Water Quality
Ecological Resources
Archaeological/Historical/
Recreational
Number of visitors
to archaeological/
h i stor i caI/recrea-
tional sites could
increase.
Increased nonpoint
source pollution.
Habitat destruction
could occur.
Increased development
around cultural
resource sites could
occur.
Murfcer of visitors
to archaeological/
historical/recrea-
tional sites could
increase.
Increased nonpoint
source pollution.
Habitat destruction
could occur.
Increased develop-
ment around cul-
tural resource
sites could occur.
4-11
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Table 4-5. GSUB - Sunrery of Adverse Iiipacts and
Mitigation Heasures Required for the No-Action Alternative
Primary Impact
Category
Surface Uater Resources
Associated Adverse
Impact
Increased discharge to GIUU.
Groundwater Resources
Ecological Resources
No aquifer recharge.
Could potentially reduce the value of
the GIUW as a sport fishery.
Archaeological/Historical/ Continued discharge to GIUW, a recrea-
Recreational Resources tional resource.
Noise/Odor/Air Quality
Aerosol formation and odor generation
at the treatment plant.
Mitigation
Continue to treat the wastewater
to tertiary standards. Monitor
the water quality of the GIUU
above and below the wastewater
discharge.
Unavoidable adverse impact with
complete surface water discharge.
Continue to treat wastewater to
tertiary standards prior to dis-
charge.
Unavoidable adverse impact with
GIUU discharge.
Aerosol generation at treatment
plant is unavoidable with acti-
vated sludge treatment. Main-
tain treatment facility compo-
nents and operation to minimize
odor generation.
4-12
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Table 4-6. GSUB - Summary of Adverse Impacts and
Mitigation Measures Required for the Land Application Alternative
Primary Impact
Category
Groundwater Resources
Associated Adverse
Impact
Potential for groundwater contamination.
Ecological Resources
Wetlands
Noise/Odor/Air Quality
Potential for shift in vegetative com-
munity within and near land application
sites.
Hydrologic regime of wetlands near site
could be altered.
Aerosol and odor formation at treatment
plant and land application sites.
Mitigation
Monitor groundwater upgradient
and downgradeent from land
application site. Application
rate should not exceed soil and
crop uptake capacity. Only land
application sites that would
recharge the coastal/alluvial
aquifer should be chosen to avoid
potential for contamination of
Pliocene/Miocene aquifer (the
major drinking water source).
Unavoidable impact with land
application.
Unavoidable adverse impact.
Artificial wetlands could be
created to replace affected
wetlands.
Wastewater should be applied to
public access areas during off-
peak times (at night and early
morning). The application
process should be designed to
minimize aerosol formation. The
t reatment and di sposaI fac iIi t i es
should be well maintained to
minimize odor generation.
4-13
-------
The most important mitigation required with the land application alterna-
tive, is monitoring of the groundwater quality upgradient and downgradient
from the land application sites. This monitoring could detect groundwater
contamination caused by failure of the land application system. If contamina-
tion was discovered, the operation of the land application system could be
altered to prevent further contamination.
To minimize air quality impacts caused by aerosol formation at the land
application sites, the wastewater land application system should be designed
to minimize aerosols and the public's access to them. Downward-directed, low
pressure sprinklers should be used instead of high pressure sprinklers, when
possible. A buffer zone should be placed around the spray site and, if
possible, vegetation should be planted in the buffer area. Public access to
dedicated sites should be limited. When public use sites (e.g., golf courses)
are used, the application should take place during periods of low use, such as
early morning or late evening. In addition, treating the applied wastewater
to secondary standards and incorporating effluent filtration and disinfection,
would greatly minimize the number of pathogenic organisms in the wastewater
and thus reduce the potential for organisms to become airborne.
4.3 IBU
4.3.1 Description of Alternatives
The preferred alternative for IBU would be slow-rate land application on
Pleasure Island, Alternative 4A. IBU's treatment plant would be converted to
provide secondary treatment and the full permitted amount of effluent would be
discharged to the existing trickle field. The remaining effluent would be
slow-rate land applied to a site on the east side of the Meyer tract.
The no-action alternative, Alternative 1, would constitute an acceptable
alternative for IBU. IBU would discharge the full permitted flow of waste-
water effluent, 1.0 mgd, to the existing trickle field. Flows in excess of
1.0 mgd, up to 1.60 mgd, could be treated to NPDES effluent requirements,
4-14
-------
including the use of IBU's carbon column technology, and discharged to the
CISW. Remaining flows (above 2.6 mgd) could be land applied to a suitable
site on Pleasure Island or Ono Island.
4.3.2 Project Costs
rhf» two preferred alternatives for IBU.
Table 4-7 lists the costs for the two prei.ej.
. 10QQ dollars Costs for collection sewers and
All costs on the table are in 1989 d
, 1 4n the table. The net present worth of the
conveyance lines were not included in tne caoo-e.
ifiliated to be $6,840,000, while the
land application alternative was calc
. . ,tqc <4ptermined to have a net present worth
no-action application alternative was
of $6,792,000.
4.3.3 Financing Alternatives
. r investors so no Title II or Title VI
IBU is owned and operated by private
funds would be available.
4.3.4 User Charges
i iot-aA following the same procedures as
The user charges for IBU were calcu
outlined for GSUB in Section 4.2.4.
The worst case years for I* were considered to be 1991, the assume^
initiation of new disposal facilities construction activity, and ^
year prior to new treatment facilities being placed on lin
npr vear was included in the
calculated for both years and the higher cost p
analysis.
. included on Table 4-8 and the
Annual debt service cost calculat ons bl 4 9
results of the user charge analysis are presented in Ta
. f.y.o nprcent of median income
Following the EPA affordability deteralned to be
»« Ovulated for both alternatives. tL V ^ ^ galdelte,
•L-71 percent and 1.75 percent, which tali
4-15
-------
Table 4- 8. Annual Debt Payment Breakdown for IBU
Land Application No-Action
Alternative Alternative
Treatment
Project Costs
Year of Facilities Construction^)
Annual Debt Service(2)
$3,484,000
1998
$ 369,600
$4,066,000
1998
$ 429,700
Disposal
Project Costs
Year of Facilities Construction^)
Annual Debt Serviced)
Connection CostsW
Tap-In
Grinder System
Annual Mortgage^5)
$1,908,100
1991
$ 201,600
$
$
$
1,500
2,000
371
$1,214,600
1991
$ 128,300
$
$
$
1,500
2,000
371
Notes:
(1) Construction assumed to occur 1 year before facilities needed on-line.
(2) Assumes municipal revenue bond at 8.5 percent interest, 20 year payment
period. Capital Recovery Factor - 0.105671.
(3) Construction assumed to occur at beginning of planning period.
Initial cost to homeowner to tie into system. Assumes homeowner's
mortgage increases by a stun equal to connection costs.
(5) Assumes 30 year mortgage at 10 percent interest. Capital Recovery Factor
= 0.1060792.
4-16
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Table 4-8. Annual Debt Payment Breakdown for IBU
Land Application No-Action
Alternative Alternative
Treatment
Project Costs
Year of Facilities Construction(l)
Annual Debt Service(2)
Disposal
Project Costs
Year of Facilities Construction^)
Annual Debt Service(2)
Connection Costs(4)
Tap -In
Grinder System
Annual Mortgage^)
$3,484,000
1998
$ 369,600
$1,908,100
1991
$ 201,600
§
$
$
1,500
2,000
371
$4,066,000
1998
$ 429,700
$1,214,600
1991
$ 128,300
$
$
$
1,500
2,000
371
Notes:
Construction assumed to occur 1 year before facilities needed on-line.
Assumes municipal revenue bond at 8.5 percent interest, year payment
period. Capital Recovery Factor — 0.105671.
Construction assumed to occur at beginning of planning period.
Initial cost to homeowner to tie into system. Assumes homeowner s
mortgage increases by a sum equal to connection costs.
(5) Assumes 30 year mortgage at 10 percent interest. Capital Recovery Factor
- 0.1060792.
(1)
(2)
(3)
(4)
4-17
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Table 4-9. Estimated User Charges for IBU(l)
Land Application No-Action
Alternative (2) Alternative(2)
Annual O&M Costs
Annual Debt Payment
Total Cost (O&M + Debt)
Flow in Max. Cost Year (mgd)
Customer Base, EDU
Annual Cost (O&M + Debt)/EDU
Annual Connection Fee/EDU
Annual User Charge/EDU
Percent of Median Income(3)
$369,200
$571,200
$940,400
1.53
5,100
$ 184
$ 371
$ 555
1.71
$ 448,700
$ 558,000
$1,006,700
1.53
5,100
$ 197
$ 371
$ 568
1.75
Notes:
(1) All costs in 1989 dollars.
(2) Costs for year 1998.
(3) Based on 1987 Baldwin County median income of $32,400.
4-18
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4.3.5 Environmental Impacts
Table 4-10 highlights the primary and secondary impacts associated with
the two preferred alternatives for IBU, A detailed description of the
impacts, both primary and secondary, that would occur with each of the
alternatives is contained in Chapter 3, That discussion should be considered
supplemental to the review of impacts presented here.
4.3.6 Mitigation Measures Required With the No-Action Alternative
A summary of the measures required to mitigate the primary impacts
associated with the no-action alternative is presented in Table 4-11.
Mitigation associated with the secondary impacts is discussed in Section 4.5.
The no-action alternative uses a combination of land application and
surface water discharge. The mitigation required for the land application
portion would be the same as discussed with the land application alternative.
The mitigation for surface water impacts would include treating the wastewater
to tertiary standards prior to discharge. In addition, the water quality of
the GIWW could be monitored above and below the discharge if there was suf-
ficient evidence that the discharge of wastewater was having an impact on GIWW
water quality.
4.3.7 Mitigation Measures Required With Land Application Alternative
A summary of the measures required to mitigate the primary impacts
associated with the preferred alternative is presented in Table 4-12. Mitiga-
tion associated with the secondary impacts is discussed in Section 4.5.
If the land application alternative were implemented, the groundwater
quality would have to be monitored upgradient and downgradient from the
application sites. This monitoring program could detect groundwater contami-
nation caused by failure of the land application system. If contamination was
discovered, the operation of the land application system could be altered to
prevent further contamination.
4-19
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Table 4-10. IBU - Significant Impacts of the Two
Acceptable Alternatives
land Application Alternative
No-Action Alternative
Impact
Primary Impacts
Surface Uater Resources
Beneficial
Removes wastewater
discharge from the
GIUU.
Adverse
Beneficial
Adverse
Increases discharge
to the GIUU.
Groundwater Resources
Increases recharge of
the alluvial/coastal
aquifer.
Potential for ground-
water contamination.
Increases recharge of
alluvial/coastal
aquifer but not as
much as the preferred
alternative.
Potential for
groundwater con-
tamination.
Ecological Resources
Wetlands
Potential for a shift
in vegetative com-
munity on land appli-
cation sites.
Hydrologic regime of
wetlands near land
application sites
could be altered.
Potential for shift
in vegetative com-
munity on land
application sites.
Minor impact to
wetland hydrologic
regime anticipated.
Archaeological/Historical/
Recreational Resources
No impact to archaeo-
logical, historical,
recreational
resources. Removes
discharge to GIUU, a
recreational
resource.
No inpact to archaeo-
logical or historical
resources.
Continued discharge
to GIUU, a recrea-
tional resource.
Noise/Odor/Air Quality
Secondary Impacts
Population Growth
Aerosol formation at
treatment plant and
land application
sites. Odor genera-
tion at treatment
plant and land appli-
cation sites.
Sewer service avail-
ability would facil-
itate (but not cause)
growth in the area.
Sewer service avail-
ability would facil-
itate (but not cause)
growth in the area.
Aerosol formation
at treatment plant
and land applica-
tion sites. Odor
generation at
treatment plant and
land application
sites.
4-20
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Table 4-10. IBU - Significant Impacts of the Two
Acceptable Alternatives
(Cont'd.)
Impact
Land Use
Economics
Transportation
Community Services
Water Quality
Ecological Resources
Archaeological/Historical/
Recreational
Land Application Alternative
Beneficial Adverse
Requires land on
Pleasure Island to be
dedicated to land
application.
Could provide long-
term economic
inprovement as the
availability of sewer
service promotes
new business growth
and expansion of
existing businesses.
Increased traffic and
congestion on road-
ways.
Nunber and quality of
services would need to
be increased.
No-Action Alternative
Beneficial Adverse
Requires small
tract of land on
Pleasure Island to
be dedicated to
land application.
Could provide long-
term economic improve-
ment as the avail-
ability of sewer
service promotes new
businesses and expan-
sion of existing
businesses.
Increased traffic
and congestion on
roadways.
Number and quality
of services would
need to be in-
creased.
Number of visitors
to archaeological/
historical/recrea-
tional sites could
increase.
Increased non-point
source pollution.
Habitat destruction
could occur.
Increased development
around cultural
resource sites could
occur.
Nunber of visitors
to archaeological/
historical/recrea-
tional sites could
increase.
Increased non-point
source pollution.
Habitat destruction
could occur.
Increased develop-
ment around cul-
tural resource
sites could occur.
4-21
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Table 4-11. IBU - Summary of Adverse Impacts and
Mitigation Measures Required for the No-Action Alternative
Primary Impact
Category
Associated Adverse
Impact
Mitigation
Surface Uater Resources
Increased discharge to GIUU.
Continue to treat wastewater to
tertiary standards. Monitor
water quality of the GIWW above
and below the wastewater dis-
charge.
Groundwater Resources
Potential for groundwater contamination.
Monitor groundwater upgradient
and downgradient from land
application site. Application
rate should not exceed soiI and
crop uptake capacity. Only land
application sites that would
recharge the coastal/alluvial
aquifer should be chosen to avoid
the potential for contamination
of the Pliocene/Miocene aquifer.
Ecological Resources
Potential for shift in vegetative com-
munity within and near land applica-
tion site.
Unavoidable impact with land
application.
Wetlands
Hydrologic regime of wetlands near
land application sites could be
altered.
Unavoidable adverse impact.
Artificial wetlands could be
created to replace affected wet-
lands.
Archaeological/Historical/ Continued discharge to GIUU, a recrea-
Recreational Resources tional resource.
Noise/Odor/Air Quality
Aerosol formation and odor generation
at treatment plant and land application
sites.
Unavoidable impact with GIUU dis-
charge.
The wastewater application
process should be designed to
minimize aerosol formation.
Wastewater should be applied to
public access areas at off-peak
times (at night and early
morning). The treatment and dis-
posal facilities should be well
maintained to minimize odor
generation.
4-22
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Table 4-12. IBU - Sumnary of Adverse Impacts and
Mitigation Measures Required for the Land Application Alternative
Primary impact
Category
Groundwater Resources
Associated Adverse
Impact
Potential for groundwater contamination.
Mitigation
Monitor groundwater upgradient
and downgradient from land
application site. Application
rate should not exceed soil and
crop uptake capacity. Only land
application sites that would
recharge the coastal/alluvial
aquifer should be chosen to avoid
the potential for contamination
of the Pliocene/Miocene aquifer.
Ecological Resources
Potential for shift in vegetative com-
munity within and near land applica-
tion site.
Unavoidable impact with land
application.
Wetlands
Hydrologic regime of wetlands near
site could be altered.
Unavoidable adverse impact.
Artificial wetlands could be
created to replace affected wet-
lands.
Noise/Odor/Air Quality
Aerosol formation and odor generation
at the treatment plant and land
application sites.
The wastewater application
process should be designed to
minimize aerosol formation.
Wastewater should be applied to
public access areas at off-peak
times (at night and early
morning). The treatment and
disposal facilities should be
well maintained to minimize odor
generation.
4-23
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To minimize air quality impacts caused by aerosol formation at the land
application sites, the wastewater land application system should be designed
to minimize aerosols and the public's access to them. Downward-directed, low
pressure sprinklers should be used instead of high pressure sprinklers, when
possible. A buffer zone should be placed around the spray site and, if
possible, vegetation should be"planted in the buffer area. Public access to
dedicated sites should be limited . When public use sites (e.g., golf
courses) are used, the application should take place during periods of low
use, such as early morning or late evening. In addition, treating the applied
wastewater to secondary standards and incorporating effluent filtration and
disinfection, would greatly minimize the number of pathogenic organisms in the
wastewater and thus reduce the potential for organisms to become airborne.
4.4 SASS
4.4.1 Description of Alternatives
For SASS, the land application and no-action alternatives are similar
inasmuch as all flows go into percolation ponds. The existing SASS plant can
accommodate the ultimate flow, based on the medium growth population
projections, to the year 2010 so no expansion/modification of the plant would
be required. SASS would continue to discharge its effluent to the existing
percolation ponds but an extensive groundwater monitoring program would be
required. SASS would discharge increasing quantities of wastewater until the
monitoring program determined breakthrough (i.e., the point at which the
wastewater effluent would enter the groundwater without receiving additional
treatment through soil contact).. After breakthrough detection, the SASS NPDES
permit would be restructured to reduce the discharge to 80 or 90 percent of
the flow observed when breakthrough occurred. SASS would have to obtain an
additional land application site for disposal of the excess effluent.
4-24
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4.4.2 Project Costs
Table 4-13 lists the costs for the no-action alternative for SASS. All
costs on the table are in 1989 dollars. Costs for collection sewers and
conveyance lines are not included. The total present worth of each alterna-
tive was calculated to be $1,210,000.
4.4.3 Financing Alternatives
SASS is owned and operated by private investors so no Title II or Title
VI funds would be available.
4.4.4 User Charges
The user charges for SASS were calculated following the procedures
outlined for GSUB in Section 4.2.4.
Because no new treatment and disposal facilities would be required by
SASS during the planning period, the worst case year was assumed to be 1991,
the beginning of the planning period.
Annual debt service cost calculations are included on Table 4-14 and the
results of the user charge analysis are presented in Table 4-15.
Following the EPA affordability criteria, the percent of median income
was calculated. As shown on the table, the value falls within the EPA
guidelines.
4.4.5 Environmental Impacts
Table 4-16 highlights the primary and secondary impacts associated with
the no-action alternative for SASS. A detailed description of the Impacts,
both primary and secondary, that would occur with each of the alternatives is
contained in Chapter 3. That discussion should be considered supplemental to
the review of impacts presented here.
4-25
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Table 4-13. Summary of Costs for SASS(l)
Component
Treatment
Project Costs(3)
Total Annual 0&m(^)
Salvage Value
Net Present Worth
Disposal
Project Costs(3)
Total Annual O&M
Salvage Value
Net Present Worth
Total Net Present Worth
Cost
No-Action Alternative (2)
0
3,576,000
0
1,210,000
0
0
0
1,210,000
Notes:
(1) All costs in 1989 dollars.
(2) Land application and no-action alternatives are equivalent for SASS.
w) No new facilities required.
(4) Total for 1991-2010.
4-26
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Table 4-14. Annual Debt Payment Breakdown for SASS
No-Action Alternat-iwd)
Treatment
Project Costs(2) 0
Year of Facilities Construction n/A
Annual Debt Service 0
Disposal
Project Costs(2) 0
Year of Facilities Construction N/A
Annual Debt Service 0
Connection Costs(3)
Tap-In $2,100
Grinder System $2,000
Annual Mortgage(^) $ 435
Notes:
(!) Land application and no-action alternatives are equivalent for SASS.
(2) No new treatment or disposal facilities required.
Initial cost to homeowner to tie into system. Assumes homeowner's
mortgage increases by a sum equal to connection costs.
(4) Assumes 30 year mortgage at 10 percent interest. Capital Recovery Factor
- 0.1060792.
4-27
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Table 4-15. Estimated User
Annual O&M Costs
Annual Debt Payment(3)
Total Cost (O&M + Debt)
Flow in Max. Cost Year (ragd)
Customer Base, EDU
Annual Cost (O&M + Debt)/EDU
Annual Connection Fee/EDU
Annual User Charge/EDU
Percent of Median Income^)
Charges for SASS(D
No-Action Alternative(2)
$47,200
0
$47,200
0.17
567
$ 83
$ 435
$ 518
1.60
Notes:
(1) All costs in 1989 dollars.
(2) Land application and no-action alternatives are the same. Costs for year
1991.
(3) No new treatment or disposal facilities required.
(4) Based on 1987 Baldwin County Median Income of $32,400.
4-28
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Table 4-16. SASS - Significant Impacts of the No-Action Alternative
No-Action Alternative
Impact
Primary Impacts
Surface Uater Resources
Groundwater Resources
Ecological Resources
Wet lands
Beneficial
Recharge of the coastal/alluvial
aquifer.
Adverse
Potential for nutrient enrichment and
contamination of Oyster Bay if break-
through occurred.
Potential for groundwater contamination.
Observed shift in vegetative comnunity
at land application site would continue.
The hydraulic regime of wetlands near
land application sites could be altered.
Archaeological/Historical/ No impacts to archaeological,
Recreational Resources historical, recreational resources.
Noise/Odor/Air Quality
Odor generation at treatment plant and
land application sites. Aerosol forma-
tion of treatment plant.
Secondary Impacts
Population Growth
Land Use
Economics
Transportation
Community Services
Uater Quality
Ecological Resources
Archaeological/Historical/
Recreational
No impact.
Could provide long-term economic
improvement as the availability of
sewer service promotes new busi-
nesses and expansion of existing
businesses.
Number of visitors to archaeo-
logical/historical/recreational
sites could increase.
Could require land on Pleasure Island
to be dedicated to land application.
Increased traffic and congestion on
roadways.
Number and quality of services would
need to be increased.
Increased non-point source pollution.
Habitat destruction could occur.
Increased development around cultural
resource sites could occur.
4-29
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4.4.6 Mitigation Measures Required With the No-Action Alternative
A summary of the measures required to mitigate the primary impacts
associated with the no-action alternative is presented in Table 4-17.
Mitigation associated with the secondary impacts is discussed in Section 4.5.
The major impact associated with the SASS plant's disposal is the poten-
tial for breakthrough to occur which could cause groundwater contamination and
nutrient enrichment and contamination of Oyster Bay. The groundwater in the
area of the percolation ponds would have to be strictly monitored to detect
breakthrough. Following detection, the discharge to the percolation ponds
would have to be reduced to a percentage, perhaps 90 percent, of the break-
through flow. This value should be specified in the NPDES Permit. An
additional land application site would have to be identified for the disposal
of the remaining effluent.
4.5 COLLECTION SYSTEM CONSTRUCTION ENVIRONMENTAL IMPACTS AND MITIGATION
Collection system construction was considered to be independent of the
treatment and disposal systems employed and no determination was made as to
specifically which areas would be served by which sewerage district. There-
fore, only general collection system environmental impacts and needed mitiga-
tion will be discussed.
Collection system construction could occur in areas near historical,
archaeological or recreational sites. The degree of impact would be related
to the proximity to the site, the nature of the site and the type of con-
struction activities required. EPA-funded projects are subject to the
requirements of Section 106 of the National Historic Preservation Act of 1966,
the Archaeological and Historic Preservation Act of 1974, Executive Order
11593, and regulations of the Advisory Council on Historic Preservation (36
CFR Part 800). In essence, these laws and regulations require the identifica-
tion of historic resources, their evaluation, assessment of the construction
and operation of the project on the resources, and mitigation of the adverse
effects. This EIS recommends:
4-30
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Table 4-17. SASS - Suonary of Adverse Impacts and
Mitigation Measures Required for the No-Action Alternative
Primary Impact
Category
Surface Water Resources
Associated Adverse
Impact
Potential for enrichment and contamination
of Oyster Bay if breakthrough occurred.
Groundwater Resources
Potential for groundwater contamination.
Ecological Resources
Wetlands
Observed shift in vegetative community
at the land application site would
continue.
The hydrologic regime of wetlands near
land application sites could be
altered.
Noise/Odor/Air Quality Odor generation at treatment plant and
land application sites. Aerosol forma-
tion at treatment plant.
Mitigation
The groundwater in the vicinity
of the percolation ponds must be
monitored for breakthrough. The
flow rate to the perc ponds must
be less than the breakthrough
flow.
Groundwater quality must be
monitored upgradient and down-
gradient from the perc ponds.
The application rate must not
exceed the breakthrough flow.
Unavoidable impact with land
application.
Unavoidable adverse impact.
Artificial wetlands could be
created to replace affected wet-
lands.
Treatment and disposal facilities
should be well maintained to
minimize odor generation.
4-31
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o Coordination with the State Historic Preservation Office (SHPO) and
the State Archaeologist prior to construction to determine impacts
on any known archaeological sites on or eligible for
the National Register; and
o Pursuing acceptable mitigation measures with the state archaeolo-
gist/SHPO if surveys of the project areas yield historic resources
that might be impacted by the project.
Another concern is possible stream crossings and construction impacts to
floodplain and wetland areas. The following mitigation measures should be
applied:
o Floodplains. Any impacts caused by the placement of conveyance pump
stations within the floodplain that could not be relocated are con-
sidered unavoidable impacts. Such locations will require flood
protection, presumably levees, which will reduce the floodplain
area.
o Wetlands. Wetlands may be encountered along stream corridors.
Construction in wetlands requires a permit from the U.S. Army Corps
of Engineers, as authorized by Section 404 of the Clean Water Act.
Wetland impacts can be minimized through use of carefully controlled con-
struction techniques and by the development of artificial wetlands to replace
natural areas destroyed by construction.
Noise related impacts would result from raw wastewater pump station
operation. Specific locations away from the nearest noise sensitive receptor
should be planned for each pump station. In addition, it is recommended that
noise mitigation strategies be prepared as part of the pump station designs.
Typical criteria are that 55 dBA daytime and 45 dBA nighttime noise levels be
achieved at the pump station property line. Wherever impacts are possible, a
noise mitigation specialist should be consulted to ensure proper acoustical
design.
4-32
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Additional impacts related to conveyance and treated wastewater force
main construction include noise, dust and aquatic and terrestrial ecosystems.
Although short-term in nature, noise and dust impacts should be mitigated by
limiting construction hours and using noise barriers where necessary. The
type and magnitude of mitigative measures required to protect the aquatic and
terrestrial resources vary widely, depending upon the value of the resource
and the expected impact. Three different degrees of impacts and corresponding
potential mitigation measures are presented in Table 4-18.
4.6 MITIGATION REQUIRED FOR SECONDARY IMPACTS
Because secondary impacts are a function of the increased availability of
sewer service brought about by the expansion of the treatment/collection/dis-
posal facilities and not the specific treatment and disposal processes used,
the mitigation measures required for secondary impacts would be essentially
the same regardless of which alternative is chosen for the three sewerage
districts.
Secondary impacts resulting from population growth and impacts to the
man-made environment resulting from construction of the project have been
summarized in Table 4-19.
The most significant secondary impacts are (1) increased nonpoint source
pollution and (2) increased demand for community services and facilities. The
expansion of sewer service can eliminate some pollution problems by providing
service to areas that currently have failing on-lot disposal systems. How-
ever, the growth facilitated by the expansion of sewer service would increase
stormwater runoff and non-point source pollution. (A discussion of non-point
source pollution impacts is contained in Section 3.4.2.6). Without the
implementation of proper stormwater management controls, the non-point source
pollution caused by increased development could be greater than the elimina-
tion of pollution caused by failing on-lot systems.
4-33
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Table 4-18. General Mitigative Measures for Collection system Construction
Degree of
Inpact Potential Mitigative Measures
High Completely re-route conveyance and treated wastewater force mains construction in specific
areas.
Go ahead with construction: re-establish resources elsewhere.
Go ahead with construction: restore resource to original condition.
Seek expert guidance in planning and construction of corridors.
Medium Re-Route conveyance and treated wastewater force mains slightly so as not to disturb
resource.
Re-establish topographic contours after construction and replant vegetation.
Time construction to minimize some adverse impacts.
Establish environmentally sound construction techniques to mitigate soil losses, habitat
losses, and visual intrusions during arid after construction.
Confine construction to previously disturbed areas if possible.
Route construction outside of drip line of major trees.
Locate conveyance and treated wastewater force mains out of streambeds; do not interfere
with stream flow or wetland processes.
Low Practice environmentally sound construction and backfill techniques to reduce soil
subsidence and erosion.
Practice restorative post-construction techniques and maintenance of corridors.
4-34
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Table 4-19. Summary of Adverse Secondary Impacts and
Mitigation Measures
Secondary Impact
Category
Land Use
Associated Adverse
Impact
Requires land on Pleasure Island to be
dedicated to land application.
Transportation
Increased traffic and congestion on
roadways.
Community Services
Uater Quality
Additional demand for services and
facilities.
Increased non-point source pollution.
Ecological Resources Habitat destruction could occur.
Archaeological/Historical/ Increased visitation to sites and
Recreational potential for vandal ism. Increased
development around sites.
Mitigation
Strict zoning of land on Pleasure
Island would be required to
ensure that land was available
for application and to ensure
land use surrounding the sites
was conpatible.
Improve existing roadways and
construct new roadways. Improve
traffic movement in the study
area.
Increase personnel and facilities
to meet demand.
Use structural best management
practices and land use controls.
Areas should be zoned for habitat
preservation to prevent complete
destruction of habitat.
Areas should be more frequently
maintained and strict attention
to the type of land use zoning
around these areas.
4-35
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Stormwater management control techniques can generally be classified by
the runoff attribute controlled and/or the philosophical approach of control.
The four categories associated with controlling various runoff attributes are
described below:
o Runoff Volume Control - Control techniques designed to prevent a
certain amount of the total rainfall from becoming surface runoff by
providing an opportunity for the rainfall to infiltrate into the
ground. Runoff infiltration into the ground can be encouraged by
increasing the soils' infiltration rates, increasing surface
retention or detention storage (allows more time for infiltration),
and increasing the interception of rainfall by growing plants.
o Runoff Peak Rate Control - Control techniques designed to regulate
the peak flow rate of runoff by increasing the hydraulic resistance
of the surface, decreasing the landslope, increasing the length of
flow path, or providing temporary storage and outlet control of
runoff that would otherwise leave the site at an unacceptably high
flow rate.
o Erosion Control - Control techniques designed to minimize acceler-
ated soil erosion and corresponding downstream sedimentation.
Accelerated erosion is defined as that erosion caused by land
disturbance, such as development and agricultural activities. This
is erosion other than that resulting from natural geologic processes
such as wind, rain, temperature fluctuations, frost action, etc.
Sediment covers aquatic plants and fish spawning areas. It also
carries pollutants such as nutrients, pesticides, and other oxygen
demanding material that are attached to sediment particles.
o Source Pollution Controls - Control techniques designed to minimize
the accumulation of pollutants on the land surface, in the soils and
in the atmosphere prior to rainstorms, which controls pollution of
downstream receiving waters during and following the rainstorm
events. Source pollution controls are generally supplementary to
the other control techniques because by themselves they usually do
4-36
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not provide sufficient control to meet regulatory requirements for
control of flow volumes and peaks.
The four means of control commonly used are presented below:
° Structural - Control techniques consisting of physical facilities
designed, constructed and installed for the exclusive function of
storm runoff abatement including erosion and sediment runoff
control.
o Nonstructural. - Control techniques consisting of land use management
techniques geared towards minimizing storm runoff impacts through
control of the type and extent of new development and of land
disturbance activities in general.
° On-Site - Control techniques designed to control runoff at the
source of origin which is the development or land disturbance site
0 Off-Site - Control techniques located downstream of the development
or land disturbance site which are designed to control runoff by
intercepting it or by purposely diverting it to another control
facility.
With the implementation of proper stormwater management controls, the impact
of non-point source pollution can be minimized.
Increased development in the area would also cause an increased demand
for community services and facilities, including hospitals, schools, fire and
police protection. Table 3-10 presented in Chapter 3 listed the quantity of
new services that would be required if the population increased at the rate
projected in the medium population projection. To ensure that community
services would continue to expand as required by the growing population,
long-term community planning should be undertaken and zoning of the area
should be carefully considered. Space must be available to expand existing
facilities or build new facilities and budgets must include monies to provide
for increased staff, where appropriate.
4-37
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EIS COORDINATION
AND PUBLIC
PARTICIPATION
-------
5.0 EIS COORDINATION AND PUBLIC PARTICIPATION
5.1 INTRODUCTION
Public participation was an integral part of the preparation of this EIS.
Not only is it required by federal regulations governing the preparation of
environmental impact statements, but it is also vital to the successful
selection of the preferred alternative.
5.2 COORDINATION WITH LOCAL, REGIONAL, STATE AND FEDERAL AGENCIES
Interagency scoping was conducted by EPA and ADEM in Montgomery on April
10, 1985 to determine Agency responsibilities and involvement in the study
area. Those participants are listed on Table 5.1. The input of these local,
regional, state and federal agencies is greatly appreciated by U.S. EPA Region
IV.
A public scoping meeting was held by EPA and ADEM in Gulf Shores on May
13, 1985. Wastewater management options were explained to the public and
their input was received. In addition to private citizens, various agencies
and citizens groups also participated (See Table 5.2).
A public information meeting was held by EPA and ADEM in Gulf Shores on
December 6, 1988. The revised wastewater treatment and disposal alternatives
that were considered to be the most feasible options for detailed analysis
were presented to the public. Also, this meeting provided an update on the
EIS process and presented the concepts of the four alternatives. Comments
were received from the public as well as representatives of local, city,
state, and federal agencies. (See Table 5-3)
Following distribution of the draft EIS, a public hearing was held on
September 27, 1990 to receive verbal and written comments.
5-1
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5.3 TECHNICAL ADVISORY GROUPS
A technical advisory group (see Table 5-4) was convened on August 27,
1985 in Atlanta to determine technical data needs in order to assess the
environmental impacts of a wastewater discharge to the Gulf of Mexico. The
scientists, engineers and consultants debated such issues as: the merits of
dilution field versus plume disposal modeling, which nutrients would be of
primary concern, what bacterial decay rates to use, and other technical
concerns.
5.4 COMMENTS RECEIVED ON THE DEIS AND RESPONSES
The notification of issuance of the DEIS was published in the Federal
Register on August 24, 1990. A public hearing was held in Gulf Shores,
Alabama at the Gulf Shores State Park Resort Hotel on September 27, 1990 in
order to allow interested individuals, governmental agencies and other
organizations the opportunity to ask questions and comment on the DEIS. In
addition, written comments were accepted during the comment period following
issuance of the DEIS (August 24 through October 16, 1990).
This final EIS was prepared to address the comments received and to
incorproate them into the EIS process. This portion of the EIS was organized
in three sections 1) Comments and Testimony on the DEIS Requiring Responses
(Section 5.4.1), 2) Comments on the DEIS Not Requiring a Response (Section
5.4.2), and 3) Public Hearing Transcript.
5-2
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Table 5-1. Interagency Scoping Participants in
Montgomery, Alabama, April 10, 1985
Organization
Representative
Alabama Department of Conservation and Natural Resources
Alabama Department of Economic & Commonwealth Affairs
Alabama Department of Economic & Commonwealth Affairs
Alabama Department of Economic & Commonwealth Affairs
Alabama Department of Economic & Commonwealth Affairs
Alabama Department of Environmental Management
Alabama Department of Environmental Management
Alabama Department of Environmental Management
Alabama Department of Environmental Management
Alabama Department of Environmental Management
Alabama Department of Environmental Management
Alabama Department of Environmental Management
Alabama Department of Environmental Management
Alabama Department of Environmental Management
Alabama Department of Public Health
EPA Region IV
EPA Region IV
EPA Region IV
Geological Survey of Alabama
Geological Survey of Alabama
U.S. Army Corps of Engineers
U.S. Army Corps of Engineers, Mobile
U.S. Department of Housing & Urban Development
U.S. Fish & Wildlife Service
Walter Tatum
David Barley
Walter Stevenson
Sherman Shores
Mike Amos
Jim Warr
James Mclndoe
Cliff Evans
Marilyn Elliott
Gene Cody
John A. Poole, Jr.
Tom DeLoach
Charles Horn
Shelton Prine
Wade Pitchford
Bob Howard
Ted Bisterfeld
George White
Danny Moore
Bob Chandler
Paul Bradley
John Winn
Jim Spann
Pete Douglas
5-3
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Table 5-2. Agency and Citizen Groups
Paticipating in the Scoping Process in Gulf Shores, May 13, 1985
Organization
Alabama Department of Environmental Management
Planning and Projects Branch
Alabama Department of Public Health
Alabama Office of Attorney General
Alabama Department of Economic and Commercial Affairs
Alabama Department of Conservation and
Natural Resources
Marine Resources
Alabama Wildlife Federation
Baldwin County Engineer
Baldwin County Wildlife Federation
Baldwin County Department of Public Health
Bon Secour River Protective Association
City of Gulf Shores
Mayor,
Community Development Coordinator
City of Orange Beach
Mayor
Committee for Clean Water
Fort Morgan Civic Association
Government Utilities Service Corporation
League of Women Voters, Mobile
Mobile Bay Audubon Society
Pleasure Island Sewer System
Riviera Utilities
South Alabama Regional Planning commission
U.S. Corps of Engineers, Mobile
Representative
Gary Ellis
Michael Cash
Russ Stoddard
David Baxley
Walter Tatum
Vernon Minton
John Wingo
Percy Nixon
Charles Barton
C.P. St. Amant
Katherine Vann
Sara Wood
Jim DuBose
June Taylor
Thomas Norton
George Phillips
Ronald Callaway
K. L. Cortright
Gayle Will
Ken Steiner
Larry Stejskal
Herbert Malone
Barbara Caddell
Barbara Caddell
Ralph Eastburn
Michael Dugger
Don Pruitt
Don Brady
Paul Bradley
Davis Findley
5-4
-------
Table 5-3. Agency and Citizen Groups Participating in the
Public Information Meeting in Gulf Shores, December 6, 1988
Orpanization
Alabama DNCR Marine Resources Division
Alabama Gulf Coast Conservation Association
Alabama Department of Environmental Management
Mobile Field Office
Water Division
Alabama House of Representatives
City of Orange Beach
City of Gulf Shores
Water Board
Government Utility Service Corportion
Baldwin County Parks and Land Management
Baldwin County Wildlife Federation
Baldwin County EMC
Baldwin County League of Women Voters
Bon Secour River Protective Association
Environmental Coalition of Concerned Citizens
Fort Morgan Civic Association
Geological Survey of Alabama
Island Bay Utilities
South Alabama Sewer Service
U.S. Corps of Engineers
U.S. Fish and Wildlife Service
Perdido Bay Environmental Association
Mobile Bay Audubon Society
Marine Environmental Sciences Conservati
Representative
Walter Tatum
Brad Darling
John Carlton
Charles Horn
Steve McMillan
Ronnie Callaway
Don Howell
Bob Burgess
George Law
Larry Stejskal
Anton Witte
Tim Savage
Earnest Clark
Leon Richardson
Doris Naylor
June Taylor
Janay Dawson
Jack Starbuck
Ken Steiner
Robert Chandler
Ralph Eastburn
Phillip Bass
Curtis Flakes
John McFadyn
Pete Douglas
Thorton Garth
JoAnn Allen
Susan Phillips
E.L. Davidson
L. Davidson
Craig Trexler
Myrt Jones
tjeorge Crozier
5-5
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Table 5-4. Technical Advisory Group
Organization Representative
Alabama Department of Environmental Management James Mclndoe
1751 Federal Drive
Montgomergy, AL 36130
Camp Dresser & McKee Ray Walton
Suite 500
7630 Little River Turnpike
Annandale, VA 22003
EPA Region IV
Atlanta, GA 30365
EPA Region IV
Atlanta, GA 30365
EPA
College Station Road
Athens, GA 30613
Robert B. Howard
Ted Bisterfeld
Tom Cavinder
EPA - Narragansett, RI
ERAS, Inc.
Environmental Research
Application Systems
19 Hillcrest Drive
Potsdam, NY 13676
Raytheon Service Co.
Hammarlund Way
Middletown, RI 02840
John Paul
Arsev H. Eraslan
Gary Parker
Science Applications International Corp Evans Waddell
4900 Waters Edge Drive Peter Hamilton
Raleigh, NC 27606
Tetra Tech, Inc. James Pagenkopf
1911 North Ft. Myer Drive
Arlington, VA 22209
University of Alabama, Dauphin Is., AL Will Schroeder
U.S. Army Corps of Engineers Paul Bradley
Mobile District, P.O. Box 2288
Mobile, AL 36628
Wapora, Inc. Steven Bach
5980 Unity Drive
Suite F
Norcross, GA 30071
5-6
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Table 5-4. Technical Advisory Group
(Cont' d.)
Organization
Wapora, Inc.
5980-F Unity Drive
Norcross, GA 30071
Wapora, Inc.
6709 Joy Drive
Colony, TX 75056
Wapora,Inc.
6900 Wisconsin Avenue
Chevy Chase, MD 20854
Representative
William March
Gene Newton
Larry 0linger
5-7
-------
5.4.1
Comments and Testimony on the DEIS Requiring Responses.
l.ist. of Letters
8/6/90 Larry S. Stejskal, Utilities Board of the City of Gulf Shores.
10/15/90 EPA Region IV to Larry S. Stejskal.
10/4/90 Andreas Mager, Jr., NOAA, National Marine Fisheries Service.
9/27/90 Pete Douglas, U.S. Fish and Wildlife Service (Public Hearing
Testimony)
9/27/90 R. Vernon Minton, Walter M. Tatum and Dr. Henry LazauskL,
Alabama Department of Conservation and National Resources,
Marine Resources Division (Public Hearing Testimony).
10/9/90 James H. Lee, U.S. Department of the Interior
letter to Heinz J. Mueller, Region IV EPA.
9/27/90 Doris C. Naylor, Public Hearing Testimony
9/27/90 Joy F. Morrill, PhD. Perdido Coastal Environmental Laboratory
10/26/90 Hugh A. McClellan, Department of the Army, Environment and
Resources Branch of Army Corps of Engineers
12/07/90 EPA response to Mr. James H. Lee, U.S. Department of the
Interior.
-------
Gulf Shores
Utilities
¦h
Till: I'TIUTIES BOARD OF THE CITY OF CHEF SHORES
September 6, 1990
Mr. Heinz J. Mueller, Chief
Environmental Policy Section
Federal Activities Branch
Region IX, USEPA
•345 Courtland St., N.E.
Atlanta, Ga. 30365
Re: Draft EIS, South Baldwin County, Alabama
Dear Mr. Mueller:
We have reviewed the referenced draft document and appreciate the
opportunity to share our observations thereon. The majority of
our comments are presented for information/clarification
purposes. Our review was not sufficiently exhaustive to generate
substantive technical critique.
In the general sense, Gulf Shores Utilities (BSU) can support the
recommended alternatives identified for its system. Our briefly
stated comments following should serve to present the nuances of
our understanding of the generation and development of the EIS.
Our comments are keyed to pertinent page numbers in the document.
Comments pertinent only to the Executive Summary are presented
last.
P. 1-ls last paragraph; BSU is aware of no order by any
regulatory agency "....to shut down." its lagoon treatment
system. Also: ES - 3, second paragraph.
P. 2-Is third paragraph; NPDES Permit No. AL0055B41 establishes
effluent limits for TKN of 3 mg/1.
p. 2-3: fourth paragraphs GSU does not recognize nor is aware of
any EIS authority to establish "sewerage districts". BSU is a
municipal corporation franchised to operate within the City of
Gulf Shores and has the authority to extend service at will into
unincorporated areas. BSU does not concur with such "district"
delineation and, in fact, is currently extending service beyond
the artificial "Approximate Sewerage District Areas" depicted in
Figure 2-2. In this regard, the population distributions
presented in Table 2-1 and the flow projections presented in
Table 2—2 may be in question. Also: p. 4—31, first paragraph.
P(> HOX 1229
149 K 16th AVE
GIXFSHORES. ALABAMA
36542
(205) 968-6323
-------
H. Mueller/ADEM
Draft EIS, South Baldwin County, A1 .
09/06/90
Page 2
p. 2-4: The major reason that created wetlands are not a viable
option -for this area as a treatment process is that the
anticipated effluent quality from such systems does not come
close to satisfying the stringent requirements for discharge
established by ADEM
-------
H. Muel1er/ADEM
Draft EIS, South Baldwin County, A1.
09/06/90
Page 3
p. 3-42: third paragraph; The clear point of this paragraph is
that no current point source discharges are the controlling
factors in ICW water quality levels. Maintenance dredging of the
ICW by the Corps of Engineers in 1987—1988 has effectively
removed the alleged problem sediments. Elsewhere in this EIS,
in Tetra Tech and in other ADEM evaluations it is established
that municipal point source discharges at currently permitted
levels, and even at less stringent levels, will have negligible
impact on the ICW. In light of all this, what is the
substantiation for the claim that ICW...... recovery could
occur somewhat faster if discharges are reduced or eliminated."?
Recognizing that in the context of this paragraph, "discharges"
is implied to be the "....historic discharges which did not meet
appropriate limits.", namely point sources. Also: ES-13, second
paragraph.
p. 3-43: first paragraph; this paragraph is applauded as a clear
statement of the realities of ICW water quality considerations.
p. 3-43: last paragraph; For clarification and to ensure against
mi simplication, no EPA funds were utilized by 0SU to construct
any elements of its wastewater collection, transport, treatment
or disposal systems.
p. 4-3: Table 4-1; GSU cannot comment on the reasonableness of
presented cost (both construction and operation) data as we have
virtually no information on the particulars of the projects
proposed or the costing factors utilized by the EIS team. GSU
would be most interested in reviewing the concepts of the
projects envisioned by the EIS. Also: p. 4-7, Table 4-2; p. 4-8,
Table 4-3.
p. 4-5: third item; SSU does not know the source of the reported
interest rate of 6.0V. Interest rates on current GSU revenue
bonds range from approximately 6.9% to 7.4%.
p. 4—5: first paragraph; As for Table 4—1, GSU cannot address
the scheduling of unknown projects.
ES-3: last paragraph; GSU is not cognizant of these studies that
" provided the data that drove the decisions rendered here.".
Are these studies those listed in References as "unpublished"?
Have these studies, which apparently directed the decision-making
process of the EIS, been subjected to independent review for
accuracy?
-------
H. Muel 1 er./ADEM
Draft EIS, South Baldwin County, A1 .
08/06/90
Page 4
ES-12: -fourth paragraph; Creditable, -factual statement of the
assimilative capabilities of the ICW and the realities of the
e-f-fects of permitted waste discharges.
ES-13: -first paragraph; It is misleading to state that existing
wastewater discharges "....contribute particulate matter and
BOD " without recognizing the stringent limits being met by
existing WWTP's. All existing WWTP's utilize some type of
effluent filtration and produce low single digit BOD's. When
considered in perspective, the impact on ICW water quality,
either positively or negatively, by the continuance or removal of
the discharges is documented to be negligible. This clear fact
must not be clouded by generalized statements.
Your effort to afford this review opportunity and your time to
consider our observations is appreciated. We hope that if there
are any questions or confusions resulting from our comments you
will feel free to call.
We commend you and your staff on the successful completion of
this important program.
Sincerely
(
i. <. < ( i ( ^ >£¦*-¦•
Larry S. Stejskal, P.E.
Manager
LSS/cb
-------
Uffizi
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
3-45 COURTLAND STREET. N.E.
ATLANTA. GEORGiA 30365
October 15, 1990
Mr. Larry Stejskal/ P.E.
Manager, Gulf Shores Utilities
Box 1299
Gulf Shores, Alabama 36542
Dear Larry:
This letter is in response to "Sj!
on the Draft Environmental Impact Statement (DEIS) that examines
wastewater disposal options in South Baldwin County. Your comment s
were very helpful and will be included in
following responses to your comments are provi
p. 1-1: "GUS is unaware of any order....to shut down.
Response: The Final EIS will be amended to reflect this comment.
p. 2-1: "NPDES permit limits are...TKN 3 mg/L.
Response: This correction is noted.
p. 2-3: "GUS does not recognize...sewage districts"
Resr>on«?^« we have already acknowledged this fact on page 2-3 of the
DEIS? The DEIS stated that "districts- were artificially created for
this stud? ?o facilitate the analysis of wastewater flows and do not
necessarily reflect existing political of franchiseboundaries.
was necessarv to delineate and name sub-areas within South Baldwin
Countv in order to quantify wastewater flows. Our wastewater flows
are only estimates predicated upon population groj£h ls'
are subject to error depending upon economic growth of the nation
a whole income and real estate taxes, price of gasoline fuels
affecting our population's mobility, and popularity of this tourist
area. Because the service area boundaries are fluid J*" South Baldwin
County, the wastewater flows may not coincide precisely with
projected in the DEIS.
p. 2-10: "It is misleading to imply funding options have dictated
wastewater options..."
Response: Potential funding options will dictate the selection of
wastewater disposal alternative if federal funds ^re used in project
construction. Were GUS to dispose of wastewater in a manner that was
at variance with the preferred alternatives identified m the EIS,
the project would be ineligible for 201 construction grant or State
Revolving Fund loans.
Printed or, Buc; -:'3C Paper
-------
- 2 -
p. 3-1: "GUS does not have on-site influent pumping.."
Response: This change is noted.
p. 3-30: Comment questioning the removal of point-source from ICW.
Response: We hold that a reduction of BOD from a point source
discharge into the Intracoastal Waterway would improve overall water
quality, particularly dissolved oxygen.
p. 3-42: Comment about sediments being removed by dredging.
Response: Maintenance dredging by the Army Corps of Engineers cannot
possible remove all the sediments from the Intracoastal waterway.
The Corp's dredging activity is to maintain project depth, and is not
intended as a cleansing operation. We maintain that any reduction in
BOD load to the ICW would be beneficial to the overall quality of the
aquatic environment, although BOD contributions from GUS is probably
negligible.
p. 4-3: Question on EPA's costing study.
Response: EPA's costing methods will be forwarded to you.
p. 4-5: Question on EPA's source of interest rates.
Response: The same credit costs were applied to each costing scenario
to provide comparative project present worth costs using the same
basis for all options. Municipal bond interest rates vary depending
upon prevailing market rates, the Federal Reserve discount rate, an
individual town's credit (or bond) rating, its size and credit risk
as perceived by the bond underwriters. Smaller towns will generally
pay a higher premium for funds as compared with large cities, all
other factors being equal.
p. ES-3: Question about studies and decision-making.
Response: The studies referenced in this paragraph, available upon
request, were the following:
TetraTech, 1984. Final Report, Water Quality Modelling Study,
Intracoastal Waterway, Baldwin County, Alabama. This study was
performed for ADEM and was reviewed by their water resources
technical staff.
EPA, 1987. Nearshore Phytoplankton Bloom Potential and
Periphytic Algal Conditions at Gulf Shores, Alabama. This study
was performed by EPA's (Athens, Georgia) Environmental Service
Division on site at Gulf Shores. This study was reviewed by
EPA's Water Management Division in Atlanta.
Raytheon Service Company, 1987. Gulf Shores Outfall Study,
conducted from 6/26/86 through 4/9/87 for WAPORA under Contract
Number 2701-204.
-------
- 3 -
Sho?esPfre!d ^iifw^reSiewed by^PA-s Water Management
Division in Atlanta.
fpa i<3fi2 Data Report, Intracoastal Waterway, Baldwin County,
Alabama^ Field surveys performed by EPA-s Environmental Servrce
Division from 8/18/82 - 9/29/82.
p. ES-13: Comment about stringent limits.
Response: We recognize that the GUS little Negative
conjunction with good plant operation
impact on the ICW.
Again, please accept my thanks being^repared. Your
help in reviewing the document while it was being prep
cooperation with our staff was commendabi .
Sincerely,
Heinz J. Mueller, Chief
Environmental Assessment Brancn
-------
UNITED STATES DEPARTMENT OP COMMERCE
National Oceanic and Atmospheric Administration
Office of the Chief Scientist
Washington. D C. 20330
October 5, 1990
Mr. Heinz J. Mueller
Chief, Environmental Policy Section
Federal Activities Branch
U.S. Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. Crura:
Enclosed are comments to the Draft Environmental Impact Statement
for the South Baldwin County, Alabama, Wastewater Management. We
hope our comments will assist you. Thank you for giving us an
opportunity to review the document.
Sincerely
David Cottingham
Director
Ecology and Environmental
Conservation Office
Enclosure
-------
•"Ssi:.
'^1$ O* *
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
9450 Koger Boulevard
St. Petersburg, Florida 3 3702
October 4, 1990
Mr. Heinz J. Mueller
Chief, Environmental Policy Section
Federal Activities Branch
U.S. Environmental Protection Agency
345 Courtland Street NE
Atlanta, Georgia 30365
Dear Mr. Mueller:
The National Marine Fisheries Service (NMFS) has reviewed the Draft
Environmental Impact Statement (DEIS) for the South Baldwin County,
Alabama, Wastewater Disposal System. In general, the DEIS xs well
written and the information presented can be easily interpreted.
The NMFS believes that the discussion regarding the Gulf of Mexico
is too limited and is counter productive since it eliminates
alternatives to outfalls in estuaries.
Based on the discussion of alternatives selected by the Utilities
Board of the Citv of Gulf Shores and Island Bay Utilities, tertiary
treatment prior to discharge into the Intracoastal Waterway would
be required. However, when discussing the Gulf of Mexico outfall
only secondary treatment would be required even though these plants
currently employ tertiary treatment. It appears that if tertiary
treatment was required prior to discharge into Gulf of Mexico
waters, problem algal blooms and pathogen contamination of the
beach areas would be alleviated.
Finally the NMFS does not support the no action alternative
because discharges into the Intracoastal Waterway would continue.
We support the land application alternatives. We would also
consider discharge into the Gulf of Mexico if tertiary treatment of
the wastewater was required.
Sincerely yours
Ahdreas Mager, JrC
Assistant Regional Director
Habitat Conservation Division
MF-l
MF-2
-------
Responses to National Marine Fisheries Letter
MF-1 EPA Region IV policy is to discourage the use of coastal and
marine waters for yaste disposal, as stated in our Agency's
National Coastal and Marine Policy.
MF-2 Tertiary treatment would probably alleviate algal bloom and
pathogen contamination if this level of treatment were applied
to an offshore discharge. Tertiary treatment coupled with an
offshore discharge would combine the most expensive treatment
mode with the most costly disposal option. Such a system,
although technically feasible, would be prohibitively expensive
to build and operate, and would be inconsistent wish EPA policy
to minimize discharges into coastal and estuarine waters.
-------
U.S. Fish & Wildlife testimony provided by M. Pete Douglas. Responses to this
testimony are provided in EPA's response of 12/7/90 to Mr. James H. Lee, U. S.
Department of the Interior.
Draft ELS, South Baldwin County, Alabama Wastewater
Management. - Public Meeting statement, Gulf Shores, AL,
September 27, 1990
tn identify the most appropriate
The purpose of this EIS is to _ -wastewater generated in the Gulf
strategies for the management of Th*ee treatment
Coast region of evaluation: the Utilities Board
facilities were included the • ^ IslandL Bay Utilities
of the City of Gulf Shores (GS < (SASS). The EIS
( 1 Bl') , and the South Ajab"; n no-action, 2) secondary
evaluated four disposal alt r harge to the Gulf of Mexico
treatment of all w5s^wa^rdi"harge to the Intracoastal Waterway
via one common outfall, ¦> i - wastewater in excess of
(ICW) of all GSUB wastewater and ail lb n.
1.0 mgd, 4) four variation of land app
. * cci through the EIS to identify the
Tt is the responsibility of ' superior environmental
preferred alternative that ex s>' There is also the option
soundness and/or cost, eff&ct1 * d alternative which this
of designating more than °n ' J ; ined that alternative 1, no-
document has done. It, has det application of Pleasure
action, and alternative 4A,slow rate land app
Island, as equally acceptable.
i r^mont in the wastewater
Since the inception of our inv° shores area it the been the Fish
management planning for the uu .. only preferred
and Wildlife Service's position this wastewater is land
alternative for the ultimate a e , stressed condition of
application. This is based on tn. - ^ value of these area to
the ICW and adjoining waterbodies ^ little disagreement over
marine fishery resources. There ° urring jn the waterway,
the poor water quality conditima Department of Environmental
Studies conducted by both the A »esources Division have
Management, and the Alabama Mar^n®, _ lve(j oxygen concentrations
confirmed regular and sustain© Duality Criteria value of 5.0
substantially below the state «ate juvenile shrimp and fish
PPm. ,\t the same time, co^ec, I0"!, nai as a nursery area. Even
have documented the value of t^55 trout, have been collected
larval fish, most probably spotte . a spawning habitat for
during periods of high sal in i ty in ^ commercial value,
fishery resources of substantial sp
/continued discharge into the ICW
The determination of no-actJ on ( results of two
as a preferred alternative is bfsea erWJlv by Tetra Tech Inc. and
modeling studies conducted of the rnCt which concluded that the
Post, Ruck ley, Schuh, and Jernigan, -tattle impact on lowering
point-source dischargers were havin inappropriate fo^ EIS to
dissolved oxygen levels. It is ^ota-Ly^ studies since there
Place so much emphasis on these . an(j actual field
wpre major discrepancies in the re- were published indicate
measurements obtained since these studies
-------
.. degradation than predicted by the
much more severe water qua * one Gf the model studies concluded
models. As a further exa P rrvfW was to the West at a rate of
that the average flow of - tcfs) while the other concluded that
, 000 cubic feet per s*con? '° , 200 cfs. The direction and
U was to the East at nearly > is of extreme significance in
Magnitude of flow in '^ effects.
determining loading source
faiied to evaluate a number of
These modeling studies also ^ algnificant effect on ICW
mnortant variables that cou of the adjacent water bodies such
Jllev quality. The BOD l°*dla®d Arnica Bay that provide water to
XI Bon Secour Bay, Wolf ' the modeling computation. The
the TOW were not factor^L^v that was concluded to have a major
oediment oxygen demand (*> never quantified as to oxygen
Vnmact on dissolved oxygen w* through the water column. We
.lake or its impact ver^ic^ he totally reformulated giving full
believe that the EIS needsf°lA water quality information. A
consideration to existing " formulated upon which future waste
water quality baseline musT ' Reliance on hypothetical models
disposal decisions can be ma ^ is inappropriate,
that have already been sh
which GSUB and IBU operate require a
The discharge permits under Maintaining this treatment level
tertiary level of tr®at™e"„ from both the personnel and the
requires optimum production therP have been occasions in the
equipment. As a consequence, ^ which inadequately treated
past where upsets have into the waterway. We believe
effluents have been disch* ®!LeSS that an£ additional wastewater
that the ICW is under sUC", J-al, has a detrimental impact,
loading, permitted or acci en
the ICW is severely stressed,
There can be no argument that Water Quality Criteria, and can
frequently is in violation ot Qading, Common sense should
tolerate no additional organic wagtewater inputs would only
dictate that the removal of any ^ 4B <8low_rate land
improve the system. A?;te^ „OUld not only remove all permitted
application north of the IC^ utUizing land application but
discharges from the waterway by^uti depleting groundwater,
also assist in recharging
int pollution sources should
Tn addition, the impacts from the EIS. Rapid urban growth
be fullv considered in reformuliat already and wlu continue to
both north and south of the ^.*ional water quality degradation,
contribute substantially to t of these facts oincf toth
The EIS should reflect Integra tio^ adJacent „aterbodies.
pollution sources affect t
P Wildlife Service's position
it is the Fish ana **i , , be presented by this
ha?0non y one'preferred ?»«~^a^UoltioAlt.r».tiv. 4A or
EIS and that should h f^.Sla«." °f document.
4D. We recommend complete
-------
Response to this testimony is provided in EPA's 12/7/90 letter to Mr. James H.
Lee, U.S. Department of the Interior.
TESTIMONY PRESENTED TO THE U. S. ENVIRONMENTAL PROTECTION AGENCY ON THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT - SOUTH BALDWIN COUNTY, ALABAMA
WASTEWATER MANAGEMENT
R. Vernon Minton, Walter M. Tatum and Dr. Henry Lazauski
Marine Resources Division
Gulf Shores, AL
Ladies and Gentlemen, my name is Vernon Minton, Mr. Tatum, Dr.
Lazauski and myself are Marine Biologists with the Marine Resources
Division, Alabama Department of Conservation and Natural Resources. We
appreciate the opportunity to address your group today. First, we would
like to congratulate EPA on the quality of work demonstrated in the
Draft EIS. We share the concerns addressed in the document about the
present status of the Intracoastal Waterway (ICW) and are intimately
involved with its water quality. The Marine Resources Division operates
a marine hatchery and research facility, the Claude Peteet Mariculture
Center in Gulf Shores, Alabama. Since 1972 the mariculture center has
been using water from the Intracoastal Waterway for the culture of
marine invertebrates and vertebrates. We monitor dissolved oxygen,
temperature and salinity daily during our production season which
generally runs from mid-April to late November. These readings are
recorded with a YSI 51-B oxygen meter compensated for temperature and
salinity. For several years we have recorded dissolved oxygen levels
well below the 5 mg/1 standard for this waterbody. We have witnessed a
gradual downward trend in oxygen levels over the last few years. During
1990, dissolved oxygen levels taken at 6:00 a.m. only met the 5 mg/1
standard 6 percent of the time. The lowest reading recorded was >.9
mg/1 on June 29, 1990 and levels below 3 mg/1 were recorded on 18
-------
occasions from 87 samples or approximately 21% of the time. On page 3-
29 of the EIS you reference^ the study conducted by Tetra Tech, Inc.
conducted in 1984. The study concluded that wastewater point source
discharges were not the primary contributors of the dissolved oxygen and
algal growth problems. Instead, Tetra-Tech, Inc. concluded that benthic
oxygen demand, ambient BOD from the waters of Wolf and Oyster Bay, and
non-point and point discharges as being the factors contributing to the
low dissolved oxygen. In 1986, we contracted with Auburn University to
conduct a detailed chemical analysis on the water quality of our rearing
ponds. As part of that study water quality in the intracoastal waterway
adjacent to the Claude Peteet Mariculture was also investigated.
Because bottom sediments frequently contain higher concentrations of
organic matter, and the Mariculture Center uses the Canal water for its
ponds, the effect of barge traffic on water quality in the Canal was
examined. Water samples were taken at timed intervals during the
passage of barges on four different occasions. The section of the Canal
Adjacent to the Mariculture has an average depth of about 15 feet.
Loaded barges typically have a draft of approximately 9 feet.
Therefore, the amount of water displaced by the passage of barges and
tugboats can be considerable.
The results are shown in Figure 1. Although Total Particulate
Matter (TPM) increased rapidly during and immediately after barge
passage, concentrations declined to previous levels within 4 minutes.
This suggests that the particulate matter was of a sandy or non-organic
nature. This is illustrated by tests conducted on the Loss On Ignition
(LOI) of the same samples. The decline in LOI occurred simultaneously
with the increase in total particulate matter. Thus, the amount of
-------
organic matter probably remained unchanged during barge passage
(Daniels. 1986). This information leads us to believe that benchic
loading is probably not contributing to the low dissolved oxygen as has
been indicated by the Tetra—1Tech, Inc. study.
In the draft EIS page 3-42 it is stated that "ecological impacts
to the ICR and adjacent estuaries could result under Alternatives 1 and
3. which include wastewater discharges to the ICH. Ecological impacts
of wastewater discharges correlate directly with water quality impacts.
In the same paragraph it is further stated that "If the impacts were
severe, there could be a reduction in the biological quality of adjacent
estuarine zones, including valuable seagrass beds on wolf Bay. Oyster
Bay. and Mobile Bay". Bottom dissolved oxygen samples taken from 1983-
1989 in Arnica bay as part of our division's monitoring and assessment
work have indicated that the dissolved oxygen was less than 5 mg/1 in 36
to 83 percent of each years samples (Table 1). Samples taken at the
mouth of the Bon Secour River in the same time frame (1983-1989) have
shown to be less than 5 mg/1 in 8 to 88 percent of each years samplea.
These data indicate that the biological quality of these adjacent water
bodies is already degraded and can only deteriorate if additional
discharge into the ICM is allowed. It is felt that this degradation is a
result of the condition of the ICH. We are in total agreement with the
findings of the Draft EIS (page 3-43) that states "...the biological
health of the 10i and adjacent bays would be improved as a resul
reduced loadings of organic material and nutrients . Alternative
maintenance of the status quo leaves us with a degraded resource with no
chance of recovery and probable further degradation. Our information
indicates this present situation is tenuous, at beat, for the survival
-------
of the marine species inhabiting the ICW. This waterway is a vital link
between the Perdido and Mobile Bay systems. Its continued degradation
is unacceptable.
It is our firm belief that the only viable alternative, which will
provide relief from the organic loading in the Intracoastal Waterway is
the alternative number 4, land application. With this alternative, we
believe, as is stated in the Draft EIS, that the biological health of
the ICW and adjacent bays will be improved. The benefits of reuse of
the waste water occur not only to this resource but to the recharge of
the alluvial/coastal aquifer. These benefits will ultimately outweigh
the cost differential indicated in switching to a land application
system. Based on EPA'S standard affordability criteria it is indicated
that sewerage systems are affordable to a community if the total amount
of user charge is less than 1.75% of the user's median income. The
estimated percentage costs for land application was 0.69% while the no
action alternative was 0.61% for a difference of 0.08%. Using the
median income indicated in your report of $32,000 for residents of
Baldwin county this translates into a difference of $25.00 per year. As
managers of the living marine resources in Alabama it appears to be a
small price to pay for the health of our environment.
In conclusion, we would like to strongly recommend that the
alternative number 4 be listed as the preferred alternative. It's
affordable, it's practical, it's biologically sound and will go a long
way towards reversing the lowering water quality trend that has occurred
in the intracoastal waterway for the past decade.
-------
Literature Cited
Daniels, H. V. 1986. Final Report for Contract Period April 1 to
November 30, 1986. Alabama Department of Conservation and Natural
Resources, Marine Resources Division Mimeo File Report.
-------
ioo r
2
|>50
Q.
H
o
8
L0 I
TPM
12
16
TIME m i n
Figure 1. Total Particulate Hatter and LOI values during barge passage in Gulf Intracoastal Waterway.
-------
Table 1. Bottom Water Quality
Arnica Bay for 1983-1989.
Samples
from
the Bon Secour River and
1983
MONTH STATION
5 BON SECOUR
6 BON SECOUR
7 BON SECOUR
8 BON SECOUR
9 BON SECOUR
10 BON SECOUR
11 BON SECOUR
12 BON SECOUR
5 ARNICA BAY
6 ARNICA BAY
7 ARNICA BAY
8 ARNICA BAY
9 ARNICA BAY
10 ARNICA BAY
11 ARNICA BAY
DO
SAL
TEMP
RIVER
6.2
0
21.5
RIVER
2.8
2
27.0
RIVER
2.4
7
29.5
RIVER
4.0
13
30.5
RIVER
4.4
14
24.5
RIVER
2.2
16
25.0
RIVER
4.4
23
23.0
RIVER
4.4
15
14.5
6.0
8
25.0
2.2
24
25.5
1.0
23
29.0
•
4.2
22
25.0
1.6
23
23.0
4.2
24
22.0
-1984-
MONTH
STATION
DO
SAL
TEMP
1
2
3
4
5
6
7
8
9
10
11
12
1
2
3
4
5
6
7
8
9
10
12
BON SECOUR
BON SECOUR
BON SECOUR
BON SECOUR
BON SECOUR
BON SECOUR
BON SECOUR
BON SECOUR
BON SECOUR
BON SECOUR
BON SECOUR
BON SECOUR
ARNICA BAY
ARNICA BAY
ARNICA BAY
ARNICA BAY
ARNICA BAY
ARNICA BAY
ARNICA BAY
ARNICA BAY
ARNICA BAY
ARNICA BAY
ARNICA BAY
RIVER
RIVER
RIVER
RIVER
RIVER
RIVER
RIVER
RIVER
RIVER
RIVER
RIVER
RIVER
4.6
4
7.0
6.2
5
14.0
3.6
10
21.5
9.2
4
21.0
6.4
5
25.0
8.0
5
23.5
3.2
8
31.0
4.2
12
30.0
4.8
17
27.5
9.2
17
22.0
4.2
22
15.0
6.0
18
20.5
3.2
22
10.0
4.2
22
14.0
2.6
24
18.0
2.8
18
20.0
2.6
20
24.5
2.6
21
30.0
2.2
25
28.5
4.2
22
28.5
4.8
22
27.5
5.0
24
24.0
3.6
28
19.0
-------
YEAR=85
MONTH
STATION
DO
SAL
TEMP
1
BON
SECOUR
RIVER
9.8
14
9.5
3
BON
SECOUR
RIVER
2.8
14
20.0
4
BON
SECOUR
RIVER
4.8
15
22.0
5
BON
SECOUR
RIVER
8.2
12
26.0
6
BON
SECOUR
RIVER
7.4
8
27.5
7
BON
SECOUR
RIVER
8.2
14
27.0
8
BON
SECOUR
RIVER
6.4
16
29.5
9
BON
SECOUR
RIVER
7.4
15
30.0
10
BON
SECOUR
RIVER
4.6
18
26.5
11
BON
SECOUR
RIVER
7.2
14
14.0
12
BON
SECOUR
RIVER
10.8
17
14.5
1
ARNICA BAY
4.2
23
10.0
3
ARNICA BAY
5.6
20
18.5
4
ARNICA BAY
5.2
22
21.0
5
ARNICA BAY
6.4
20
25.0
6
ARNICA BAY
2.2
25
25.0
7
ARNICA BAY
4.8
22
27.0
8
ARNICA BAY
4.2
20
30.0
9
ARNICA BAY
5.8
23
29.5
10
ARNICA BAY
2.6
25
25.5
11
ARNICA BAY
5.2
20
17.5
12
ARNICA BAY
8.0
24
17.0
-------
1
2
3
A
5
6
8
9
10
11
12
1
2
3
4
5
6
7
8
9
YEAR=86
STATION
DO
BON SECOUR
RIVER
11.6
BON SECOUR
RIVER
6.4
BON SECOUR
RIVER
9.4
BON SECOUR
RIVER
8.8
BON SECOUR
RIVER
4.2
BON SECOUR
RIVER
5.2
BON SECOUR
RIVER
5.0
BON SECOUR
RIVER
3.8
BON SECOUR
RIVER
3.0
BON SECOUR
RIVER
7.2
BON SECOUR
RIVER
6.2
ARNICA BAY
4.4
ARNICA BAY
5.6
ARNICA BAY
7.6
ARNICA BAY
6.6
ARNICA BAY
3.8
ARNICA BAY
4.0
ARNICA BAY
3.0
ARNICA BAY
3.0
ARNICA BAY
2.0
ARNICA BAY
3.2
ARNICA BAY
4.4
ARNICA BAY
6.0
SAL TEMP
11
8.5
12
16.5
15
15.5
6
20.0
16
24.0
16
26.0
15
27.5
21
28.0
20
25.5
17
16.5
12
8.0
25
10.5
22
17.0
15
16.5
22
18.0
21
23.0
24
28.5
27
25.5
24
28.5
20
26.5
25
26.0
24
18.0
24
11.0
-------
1
2
3
4
5
6
7
8
9
10
11
12
1
2
3
4
5
6
7
8
9
10
11
12
YEAR=87
STATION
DO
SAL
TEMP
BON SECOUR
RIVER
8.8
12
8.5
BON SECOUR
RIVER
12.6
3
9.5
BON SECOUR
RIVER
7.6
9
18.5
BON SECOUR
RIVER"
10.2
6
10.5
BON SECOUR
RIVER
7.6
6
20.5
BON SECOUR
RIVER
6.0
12
26.0
BON SECOUR
RIVER
5.2
13
BON SECOUR
RIVER
4.4
15
27.0
BON SECOUR
RIVER
4.6
20
24.5
BON SECOUR
RIVER
8.2
19
15.0
BON SECOUR
RIVER
8.4
25
9.0
BON SECOUR
RIVER
7.8
20
12.5
ARNICA
BAY
7.0
20
11.0
ARNICA
BAY
7.4
23
12.0
ARNICA
BAY
5.2
18
17.5
ARNICA
BAY
8.0
24
14.5
ARNICA
BAY
3.0
17
25.0
ARNICA
BAY
20
30.0
ARNICA
BAY
4.4
18
26.0
ARNICA
BAY
2.0
23
24.0
ARNICA
BAY
3.0
23
23.0
ARNICA
BAY
5.6
26
21.7
ARNICA
BAY
22
ARNICA
BAY
8.6
22
13.9
-------
1
2
3
4
5
6
7
8
9
10
11
12
1
2
4
5
6
7
8
9
YEAR=88 -
STATION
DO
SAL
TEMP
BON SECOUR
RIVER
10.2
22
3.0
BON SECOUR
RIVER
11.4
18
3.0
BON SECOUR
RIVER
7.4
12
11.0
BON SECOUR
RIVER
7.4
8
12.5
BON SECOUR
RIVER
3.6
12
17.5
BON SECOUR
RTVER
5.6
19
27.0
BON SECOUR
RIVER
5.2
18
30.0
BON SECOUR
RIVER
4.0
16
31.0
BON SECOUR
RIVER
7.4
12
30.5
BON SECOUR
RIVER
7.2
12
21.5
BON SECOUR
RIVER
6.8
17
18.0
BON SECOUR
RIVER
11.4
15
10.5
ARNICA BAY
4.4
21
10.0
ARNICA BAY
6.8
22
6.5
ARNICA BAY
6.8
25
13.0
ARNICA BAY
5.4
22
15.0
ARNICA BAY
2.8
27
25.0
ARNICA BAY
1.8
26
28.9
ARNICA BAY
1.0
18
27.8
ARNICA BAY
2.2
18
26.7
ARNICA BAY
2.0
25
23.3
ARNICA BAY
5.2
24
21.6
ARNICA BAY
8.4
22
16.0
-------
1
4
5
6
7
8
9
10
11
12
1
4
5
6
7
8
9
10
11
12
YEAR=89
STATION
DO
SAL
TEMP
BON SECOUR
RIVER
10.8
14
13.0
BON SECOUR
RIVER
10.0
7
18.5
BON SECOUR
RIVER
6.8
4
24.0
BON SECOUR
RIVER
5.6
10
30.5
BON SECOUR
RIVEft*
8.0
4
27.5
BON SECOUR
RIVER
8.8
7
30.0
BON SECOUR
RIVER
4.8
16
29.0
BON SECOUR
RIVER
6.0
16
25.0
BON SECOUR
RIVER
5.2
14
22.0
BON SECOUR
RIVER
10.0
11
11.5
ARNICA BAY
8.0
25
13.5
ARNICA BAY
4.2
18
19.4
ARNICA BAY
7.0
18
25.0
ARNICA BAY
0.8
11
27.2
ARNICA BAY
16
28.3
ARNICA BAY
4.4
24
28.5
ARNICA BAY
3.6
23
20.6
ARNICA BAY
6.4
24
20.0
ARNICA BAY
6.2
20
17.0
ARNICA BAY
9.0
22
13.5
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
Office of Environmental Affairs
Richard B. Russell Federal Building
75 Spring Street, S.W.
Atlanta, Georgia 30303
907 9 1990
ER 90/786
Mr. Greer C. TidweI I
Regional Administrator
tnvi rorimentai Protection Agency
34b Court I and Street, Nfc.
Atlanta, Georgia 30365
Dear Mr. Ildwel1:
i ci cru/imomenta 1 impact statement (EIS) for Wastewater
We have reviewed the dra Alabama and have the following comments.
Management. South Baldwin county, Alabama, aria
General Comments
We do not believe the EIS adequately covers a the current
situation in south Baldwin county in eim dgta> Qr probab)e
reflect complete analysis or basic wa q Uoni u 1nCjudes tentative
consequences of available c0ntlnue to contribute to degradation of
selection of an als fie)d conditions be established
shortcomings, a complete baseline of a ^ w11d|ife service
for the study area, field data availa auaHty in the ICW, Wolf Bay, and
indicates a significantly deter.orated water quality
Bon Secour Bay.
Another significant point not adequately 'The Gulf Shores-
»n the study area of a nonpoint sour^® ^urbanizing in recent years. Elevated
Orange Beach-Foley area has been raPidl^ ,tressed ecosystem should be fully
honpoint pollution inputs to tins airea y disposal alternatives. As
accounted for in any analysis of point pollution
Population growth and associated developmen estuaries in the study area
inputs will increase. It is clearly evident that
cannot assimilate any additional waste.
-------
witlr tins info riiia t i of i, 11. i s apparent that the alternative-:; considered in the
fcIS should i>e rei,» i icteiJ to those that will effectuate a reduction in waste
input to 111 e ijtudy area. Hence, the -.election of a preferred alternative that
will not rt-'Liit in additional wa^te load my, such as land application found in
alternative-. 4- field) and at least one pipeline near Gulf State
Hark. Because the document does not mention mineral resources, it is unclear
what etteci iand a«.qui j|t ion for Alternative 4a would have on continued
development oh the yas resource, we recommend future environmental documents
desi-i iue ihis resource, discuss impacts ;it any), and elaborate on any
necessary mitigation measures, it the land application preferred alternative
would noi affect 1 ield production or development, the document should include
a statement to that eifect io the user will know such impacts were considered.
liuint you fni the opportunity to comment ori tins, statement.
Sincerely yours,
James H. Lee
Regional Environmental Officer
-------
/ jb \
I 9 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
DEC 0 7 1990
Mr. James H. Lee
Regional Environmental Officer
U. S. Department of the interior
Office of Environmental Affairs
75 Spring Street
Atlanta. Georgia 30303
RE: Draft Environmental Impact s^enient
South Baldwin County Wastewater management
Dear Mr. Lee:
, __ 4.ho rvraft Environmental Impact
Thank you for your comments on prepared on the referenced
Statement (DEIS) that our »||°cy J?lr expressed concern that the
project. Your October __lpte anaivsis of basic water
document inadequately reflected c p tions relied too heavily on
quality data, and that ^enc/n""^"e £or laSd application was
two water quality models. A pref orowth, non-point source
expressed, as were concerns over rap g -q found in the Gulf
pollution, and impacts on the natural gas wexxs
Shores Park.
• rvr-nhablv the best alternative for
We agree that land application is pro lfJqh res wastewater treatment
wastewater management at the City of Gulf Shores^ ^ ^
Plant (WWTP). This option will be gi can certainly use
EIS. The adjacent Gulf State Park tion needs, and the City is
treated wastewater to meet their irr g an(J the goif course share
anxious to provide this resource. f treated wastewater a
a common boundary making the conveyan state of Alabama would
relatively easy matter. It is °u* ^J^ite permits to allow
assist this venture by providing the requ"^,,
groundwater application on the golf
•« Drobably the key element
^ agree that non-point source Pollu^?allv Bon Secour and Wolf bays
J1* improving area water quality, esp mtracoastal Waterway
from which the source waters for the ,,-tion is a national problem
(Glwv?) are derived. Non-point source p surface and ground water
unique to Alabama. To help improve a gection 319(h) Nonpoint
quality, Alabama has submitted an national and Region IV
Source Management Management plan bas P federal and state
E^A guidancl and funding. A total of $1,196,501 m
Monies has been scheduled for FY 1991.
Printed on Recycled Paper
-------
- 2 -
Only one modelling study of the GIWW was considered in our
assessment, that done for the Alabama Division of Environmental
Management (ADEM) by Tetra Tech, Inc. We are aware of another
modelling study conducted by Post, Buckley, Schuh, and Jernigan, Inc.
(PBS&J) in support of a local marina siting application, but this
model was not reviewed by EPA technical staff, and accordingly, its
conclusions were neither contemplated nor cited in the Draft EIS.
The field data for the Tetra Tech model was provided by EPA and
USGS.
A substantial amount of data were produced during the development of
this EIS, and these data will be made available in the Final. The
studies are listed as follows:
EPA, 1982. Data Report on Intracoastal Waterway performed by
EPA's Environmental Services Division from 8/18/82 - 9/29/82.
The parameters measured included sediment oxygen demand, tidal
velocity and stage readings, dye dispersion of overall tidal
transport during spring and neap tidal cycles, point source
discharger studies, light/dark bottle studies, long term BOD and
nutrient studies.
Tetra Tech, 1984. Final Report on Water Quality Modelling Study,
Intracoastal Waterway, Baldwin County, Alabama. Mathematical
treatment of EPA data base, above.
EPA, 1987. Nearshore Phytoplankton Bloom Potential and
Periphytic Algal Conditions at Gulf Shores, Alabama. Performed
by EPA's Environmental Services Division.
Raytheon Service Company, 1987. Gulf Shores Ocean Outfall
Study. Oceanographic study conducted from 6/26/86 through 4/9/87
for potential offshore outfall sites.
Thompson Engineering Data, eleven monthly sampling events from
6/26/86 - 4/9/87 at stations in the Gulf and the ICW.
Dauphin Island Sea Lab, monthly sampling events (6/26/86-2/12/87)
nine surface, midwater and bottom stations, including hourly
readings for all parameters over one 24-hour event.
Alabama Geological Survey, 1989. Letter report and data
submitted to EPA showing MODFLO and RESSQ modelling effects of
land application of land applied pollutants to two hydrological
units in the Gulf Shores area.
It is extremely difficult for this Agency to deny Gulf Shores WWTP
discharge to the GIWW because of the high quality of the effluent.
The NPDES limits imposed by ADEM are 4 mg/L BODc, 1 mg/L NH3-N, 3
mg/L TKN and 5 mg/L DO. Were the plant to release 1.0 million
gallons per day (mgd) at the 4 mg/L BOD= limit, their total
contribution to the GIWW would be less than 35 pounds BODc per
day. (One milligram per liter is equivalent to 8.34 pounds per
-------
- 3 -
million gallons). Most of the Discharge Monitoring Reports we have
seen show the Gulf Shores WWTP discharging effluent at about one-half
of their required limits, that is, about 2.0 or less mg/L B0D5.
The mathematics of the discharge data, in concert with the water
quality modelling study, would justifiably argue that the Gulf Shores
Plant is having a negligible impact on the ICW.
We have examined dissolved oxygen data presented at the 9/27/90
public hearing by the State of Alabama Marine Resources Division.
These bottom dissolved oxygen values from Bon Secour River and Arnica
Bay from 1983-1989 suggest that the dissolved oxygen levels at these
sites may be improving. If the number of observations for dissolved
oxygen greater or equal to 5.0 mg/L divided by the total number of
observations (n > 5.0 mg/L divided by N; Y axis) reported in any one
year (X axis) is plotted (Figure 1), and a trend of increasing
dissolved oxygen is demonstrated. This observation is corroborated
in Figure 2, again using Division data, whereby annual means of
dissolved oxygen (Y) are plotted against time (X), and again a
positive trend is demonstrated. Although the number of samples is
far too low to attach any statistical significance to these
observations, were this trend to continue, we may be observing
improvements due to cessation of seafood processor discharge and
improved WWTP operations.
We feel that high sediment oxygen demand (SOD) may be contributing
some level of oxygen consumption in the GIWW. Sediments within the
GIWW are resuspended by large barges, driven by tugboats, which can
be observed churning the bottom sediments as they pass. Data showing
Total Particulate Matter (TPM; Division testimony; Figure 1) are
credible evidence that TPM settles relatively quickly following barge
Passage, however, we cannot accept the a priori assumption that
density of particles in the water column is a function of BOD. TPM
does not measure BOD, nor does it translate into SOD. It is with
nutrients, released by reduction of organic detritus at the molecular
level, that we are concerned.
Our belief that SOD may be contributing low DO is based upon EPA SOD
?ork (see attached data; note the SOD rates in the EPA data are given
ln grams of oxygen/square meter /hour.) conducted i <->f
stations within the GIWW were observed to have mean SOD J^lue
2-06, 1.68, 2.69 g/m2/day at Stations 1, 4, and 17,
These stations manifested SOD levels that are well the
SOD rates for various estuaries and their associ,ated sediments
^thin the Southeast. We fully acknowledge the EPA SOD data were
iSen in 1982 and therefore may not totally ^hese
£990, however, it is difficult to ignore the 5®?5t that
Innervations have on dissolved oxygen levels. .n_llldina non-Doint
sr> oxygen reducing forces are at work here, exchange and
the^t runoJf' P?or mixin9 *r
-------
4
Course were examined. According to the State of Alabama Lands
Division, if land application were permitted in the vicinity of the
gas wells, no significant impacts on these.resources is anticipated.
In closing, it is our hope that Gulf Shores will land apply their
treated effluent, and not waste this water and nutrient resource. In
the meantime, we would be hard-pressed to justify on technical
grounds removal of the new Gulf Shores plant discharge from the ICW.
Also, any land application scenario would not eliminate this
facility's need for an NPDES permit, because emergency bypass needs
and excess capacity disposal would have to be accommodated.
Your input to the Draft EIS was appreciated. Please keep me apprised
of any issues affecting water quality in South Baldwin County.
Sincerely,
Heinz J. Mueller, Chief
Environmental Policy Section
Attachments: Marine Resources Bottom DO Data
Figures 1, 2
EPA 1982 SOD Data
CC: R. Vernon Minton
Department of Conservation and Natural Resources
-------
FIGURE 1
arnica bay
YW+ BON SECOUR BAY
FIGURE 2
arnica bay
YEAR
+
BON SECOUR BAY
-------
DATA FOR FIGURE 1
PERCENT OBSERVATIONS WATER D.O. >= 5.0 PPM
YEAR
ARNICA BAY
REGRESSION
"LINE
BON SECOUR
Regression
LINE
n/N
%
n/N
%
1983
1/7
14.30
17.50
1/8
12.50
32.31
1984
1/11
9.00
24.44
6/12
50.00
43.34
1985
6/11
54.50
31.38
8/11
72.70
54.37
1986
4/12
33.30
38.31
8/12
66.60
65.40
1987
6/10
60.00
45.25
10/12
83.00
76.43
1988
5/12
41.60
52.19
10/12
83.00
87.46
1989
5/9
55.50
59.13
9/12
90.00
98.49
Regression Output:
Constant -13743.1071
Std Err of Y Est 15.17396030
R Squared 0.539418689
No. of Observations 7
Degrees of Freedom 5
Regression Output:
Constant -21837.3
Std Err of Y Est 13.48597
R Squared 0.789255
No. of Observations 7
Degrees of Freedom 5
X Coefficient(s)
Std Err of Coef.
6.93928
2.86760
X Coefficient(s)
Std Err of Coef.
11.0285714
2.54860906
-------
DATA FOR FIGURE 2
MEAN BOTTOM OXYGEN, MG/L
YEAR
ARNICA BAY
REGRESSION
LINE
BON SECOUR
REGRESSION
LINE
N
AVE
N
AVE
83
7
2.70
4.01
8
3.90
4.96
84
11
3.40
4.36
12
5.80
5.49
85
11
4.90
4.72
11
7.10
6.01
86
12
4.70
5.07
11
6.40
6.53
87
10
5.40
5.43
12
7.60
7.05
88
12
3.90
5.78
12
7.30
7.57
89
9
5.50
6.13
10
7.60
8.09
Regression Output:
Constant -697.12142
Std Err of Y Est 2.36786522
R Squared 0.11100163
No. of Observations 7
Degrees of Freedom 5
X Coefficient(s) 0.35357
Std Err of Coef. 0.44748
Regression Output:
Constant ~1029.02
Std Err of Y Est 0.782486
R Squared 0.713195
No. of Observations 7
Degrees of Freedom 5
X Coefficients) 0.521428571
Std Err of Coef. 0.147876120
-------
ENVIRONMENTAL PROTECTION AGENCY
REGION IV
SURVEILLANCE AND ANALYSIS DIVISION
ATHENS, GEORGIA 30601
REF: 4ES-EC
Mr. Bob Cooner
Department of Environmental Management
State Capitol
Montgomery, Alabama 36130
Dear Bob:
Accompanying this letter are the tabulated results of the Gulf
Shores SOD study conducted on October 19-21, 1982. Also enclosed
is an excerpt from our branch's SOP manual detailing the field
and rate calculation methodology. Mr. Warr indicated to Mr. Billy
Adams of our division during a pre-Christmas telephone conversation
that the methods and results in this format would be sufficient
in lieu of a full report in order to expedite your receipt of
the data. Actually, since the sole purpose of our effort was the
determination of SOD rates, a narrative presentation is unnecessary
as you have already conducted other assessments of water and sedi-
ment quality at the selected SOD stations.
In regards to the accompanying Table 1, one item may require clari-
fication. In calculation of the mean SOD rate at Stations 1 and
17, clear chamber replicate was omitted and is presented apart
from the dark chamber replicates. This is standard practice in
our data presentation when light transmission at the bottom exceeds
the one percent (1%) value (Table 2) since, theoretically, clear
chamber SOD rates at or above such values can be influenced by
photosynthesis. As you can see, this does not appear to be the
case in this study since clear chamber rates at Stations 1 and 17
appear consistent with dark chamber replicates.
It was our pleasure to be of assistance in this effort. If you
have any questions or need any further information, please do not
hesitate to call me.
Sincerely yours,
Philip J. Murphy
Ecological Support Branch
Enclosures
-------
1
2
2i
3
4
6
8
10
12
14
16
17
18
CANAL STUDlf - GULF SHORES
DATE SAiMPLED 9-15-82 - SEDIMENTS
COD
% MOISTURE
0 mg/kg dry we.
48
19,500
34.5
29,300
35.0
15,400
33.1
31,200
46.5
24,600
36.8
2,000
24.4
900
21.3
800
23.1
12,300
30.0
13,500
30.1
23,000
40.0
45,700
45.1
% VOLATILE RESIDUE
3.7
1.8
1.6
1.8
3.8
3.2
2.6
.7
.2
2.0
1.6
2.4
4.0
-------
TABLE 1. STATION REPLICATE SOD RATES AND MEAN WITH STANDARD DEVIATION
AND PERCENT COEFFICIENT OF VARIATION.
GULF INTRACOASTAL WATERWAY AT GULF SHORES, ALABAMA, OCTOBER 1982.
Station
Chamber
Rep
Avg Rate of
Change
ng/L/mln
Adjusted Avg
mg/L/mln
SOD Rate or
Respiration
g 02/m^/hr
SOD Mean
g 02/n^/hr
1
jd
C2
Water Column R
mg/L/mln
I 1
Dark
Dark
Dark
Dark
Clear
1
3
4
5
6
.00481
.00500
.00412
.00630
.00424
.00460
.00479
.00391
.00609
.00403
.082
.086
.070
.109
.072
.086
.016
18.8
.00021
A
*
Dark
Dark
Dark
3
4
5
.00435
.00366
.00367
.00435
.00366
.00367
.078
.066
.066
.070
.069
9.9
17
Dark
Dark
Dark
Dark
Clear
1
3
4
5
6
.00571
.00774
.00458
.00916
.00807
.00517
.00720
.00404
.00862
.00753
.093
.129
.072
.154
.135
.112
.036
32.7
.00054
yd m Standard deviation
Coefficient of variation as percent
-------
TABLE 2. PERCENT LIGHT TRANSMISSION AND EXTINCTION COEFFICIENT (K),
GIWW AT GULF SHORES, ALABAMA, OCTOBER 1982.
K
Station
Depth
% Transmission
Extinction Coefficient
I
S
1
2
3
4
100
22
09
05
02
-1.51
-.89
-.59
-.92
4
S
1
2
3
4
5
100
11
06
03
02
01
-2.21
-.61
—. 69
-.41
-.69
17
S
1
2
3
4
5
6
100
43
26
16
09
04
03
-.84
-.50
-.49
-.58
-.81
-.29
-------
l..j~KL<
1 ' 1
" 1
:<* rowAMD;
i «*onr
--M l ' 3-- )
^HrH- -J :.-&k-j?s-!
s ^.
FIGURE 1
-------
FIGURE 1 (Cont'd)
-------
Sectior. No. 2.12
Revision No. 0
Date: March 29, 1982
Page 46 of 51
2.12.9.2 Procedures
• Inventiqators should calibrate dissolved oxygen motors
(Winklor method) and othor monitoring equipment such as
salinnmotcrs, conductivity motors, and recorders; DO probe
should be solC-stirring.
• Then team should begin recording daily solar intensity and
obtain vertical profile of dissolved oxygen, light extinction
and other desired parameters such as temperature, salinity
and conductivity; continue procedures by checking delivery
of power and operation of circulation pump.
• After preliminary checks and information gathering are
completed, team should deploy dome gently lowering with
rope. When dome is on the bottom, placement, positioning,
and securing of seal should be done by divers working as a
buddy team. (Note: Buddy system is essential as standard
diving practice due to potential for entanglement with
cables and rope.)
• Approximately 10 minutes should be allowed for settlement
of any resuspended materials? then team should start pump?
placo nonitoring probes in chamber and secure lid with C-
cLimpn. Ambient probes should be lowered to dome .level
and approximately one foot above bottom.; record initial
monitoring data. (Note:. If used in fresh water, salt
solution would be injected into pump discharge port at
this time.) Light and dark bottle experiments should begin
at this time positioned at sane depth as chamber. A minimum
of two light bottles and two dark bottles should be filled
with bottom water collected adjacent to chambers and de-
ployed alongside the chambers for incubation
during the course of the SOD experiments.
• Team should record monitoring data either continuously or
at \0-minute intervals. If 10-minute intervals are u3ed,
probe stirrer may be turned off between readinqs but should
bo turned on a sufficient time (approximately 1 minute)
before reading so meter can reach stabilization; check
zero and power output (red line) of DO meter frequently;
continue experiment for approximately 1 to 1-1/2 hours.
Oxygen readings at 10-minute intervals during the period
will provide sufficient data points (6-9) for analysis.
• After obtaining a sufficient number of data points, moni-
toring probes should be removed from dome and calibration
chocked.
• Immediately after the experiment, team should collect sedi-
ment core and vegetation biomass from within dome placement.
Then they nhould relocate dome to nearby position and begin
replicate experiment; allow light and dark bottle experiment
to continue.
-------
Section No. 2.12
Revision No. 0
Date: March 29, 1982
Page 47 o£ 51
2.12.9.3 SOP Rate Calculations and Data Assessment
During in-situ SOD rate determinations, the decay or production
rate of oxygen is recorded as the instantaneous dissolved oxygen
concentration at specific time intervals, usually 10 or 15 minutes.
The specified interval must be adhered to throughout each individual
experiment.
Rate calculations are accomplished by solving the equation:
sS' "^ir * 9 °2/m2/hr
whe re,
¦6 a rate of change in 00 as mg 02/L/min
v ¦ chamber volume in liters
A a chamber area in meters square
.06 = constant
Beta (£) is determined by calculation of the average rate of
change in DO (mg 02/L/minute) for each recorded interval. Negative
rates represent respiration (R) of the benthic community while
positive rates, obtained only in the clear chamber, represent net
primary production (NPP).
All rates should be adjusted for water column metabolic function;
at the mg 02/L/min level before being extended to the hourly rate.
Light and dark bottle (water column NPP and R) values should be deter-
mined by simple division of the average change in DO concentration
within each set of bottles by the incubation period.
2.12.9.4 Precision (see section 2.11.2)
2.12.9.5 Quality Control Checks with Acceptable Limits When/Where
•Applicable "
• All DO meters should be calibrated via the Winkler method
(Standard Methods,- 1980) prior to determination of dissolved
oxygen profile and initiation of SOD experiment. Salinometer
and conductivity meters should be calibrated electronically.
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Section No. 2.12
Revision No. 0
Date: Mardi 2lJ, lV«2
Pacjo 48 of l> I
Se.ilinn ot chjunber to substrate should bo conducted and
cnnLirmed by divers ih both salt and fresh water. Addition-
ally, in I cetth waters a concentrated salt solution may bo
injected into tin: chamber nnd conductivity monitored. Any
decline in conductivity after equilibrium would indicate
intrusion of outside ambient water.
Pump operation should be determined prior to chamber deploy-
ment and confirmed by divers prior to securing the lid to
the chamber.
Resusjponsion should be visually checked by divers in waters
with sufficient clarity, but in all casus a 10 minute tine
delay i*.: observed prior to be»j i nninij pump operation, to
allow time for settlement. Plotting of obaerved data points
durinq and after experiments also should be accomplished
to determine resuspension'and its effect on S00 rates.
Between and post experiment calibration checks should be
accomplished by removing DO probes from chambers durinq
relocation or retrieval apd positioning the chamber probes
ad j.iceut to the ambient probe. Similarity in probe measured
DO concentrations (less than 0.5 mg/L deviation) indicates
adequate calibration maintenance. Deviation in concentra-
tion;! beyond the above dictates recalibration.
All liqht and dark bottle DO concentrations should be determin
VJ.1 llt.intl.inJ Methods. (l')ttU).
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Se.pt. 27. 1990
7fie £/ufiJionjrr>ntoJ.. fiaenaj.. Reg.. 4
3£5 CouJitlcuid Si.
fAlanta, Qa. 303&5
Subject: dt ft Eru/V,-x.-rvre/ttcU. 3; pact
State;" - at, Sc. BaA.owin Co..
Be.ci.-t S its :
3 have, 'iead the. dJua^t Envi-tcnraentcA 3mpact St tenant -f-OJt So.
Lialdwin Co uritii WassteLcateJi i<- anaqer.ient and 3 am suApJvised by. the. -fact ¦that
no mention is mcuie o,i the. -tam sewag.e being, plpi.ec. faom. tne vainAand to
the. baAAAeJi. island -poJt tA.ectm.ent end disposal. 7'iis is -tiskjj, business,
pA.pA.nq. June 4ja*;.e. undeA. a •bu4$ canal* TipeA leak. I li.p&4 bmitexL undeA
wateA can be. dui?xuq.ed by. boat ancho-ts. Same, state foJibid. such a p/uxctlce.
3t is possible to have a leaJ- and. have it g.o imde.te.cte.d- -f.oJt a -Long. tl^.e-
7his is a hAch jlIsL p-iactice and mutt cease. T/ie <3e..wag.e qeneAc.-ted nolth
of, the canal niusi be. tAejzed in a seieeA pilant not-th of. the, canaL. BJiAnq.-
inc. ua-6s.ea-t.ed s&wa.q.e fAjon the. vainLanc. to a ba-iAA.r •?. -L/>tand -f..oJi tA.ca.tirie.nt
and d-isposcA is p^obablij. an aAA time, act of. fx>lhi..
iinotJicJi cutea. net cdxi'ie^sed bij. the. Jmoact. Study Id the pAoblem.
of. septic -tanJis, mom;, of. which lie. necA -aea leveA. :c-e can bu-iAA the. be^t
sto.te of -iJ\e cAt seweA a Lent in the woJiid bat ill it is not used ou-t
co as to a. ica-teAsO oilL ccn-tAnue to be. r.o-LAjited.
Reviewing. the voAious cAteAnaiAue^ of. Ilea ed va^te. cLUposaA
3 feet /i-e d c£ disposal. _ HowcueA tlieAe oa*
pJiobler^ to be consideA&d. Qol~ coatees on the baAAA.eJL ^lancU aAe. buU,t
on Aand and. uxcvcie urate*. ujUA pe*± thAu *0 pvst there until be UAAle. clean-
*inq.. 7hi* *ituatAon U compounded bv a hAnh wateA table and. the. jacl
that g.cll couju&c on an,. baAAA^i Uiand po*e theiA own *p.eocax. pAx>bl
ao all .ol/ cou^eo use tclt-Uize^, peJiAAccdeo ana lietA^ae*. Lha<. a.
witches' bJiewl! PAA. -the cclp cou^oe chmlcaA^ andth.e uro^te wa^Ji di^caU
7u.JLth.esi, q.o->4. couJuse* do not have ueq.eta.U-on sp.ecAl^caAAij- gAourn to also Jib
Hili type c/. efifMient.
a j. 1 1 "n v n AiAnnsiiA oAoa 1$ no-c c v-ioAle oltsAna-^lue.
LLo-tno. wetlaJic^s f- ' _ o f- - maAsh wetland* and contAnue to
naue aAj;.PMxhj. djestA.ou.ec. muai op oua salt m. , j
UM. tlwi jJrut thupv-uu. a* U f. o
feci r**t valacM.* M ImM mUM ^ ^
od-dAticnc.L s-bless.
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Subf. di/L-it £nv. 3mpact Sta.tejn.e.nt
So. Baldwin Co.
Sept. 27, IP90
On 4UMicAi±, onJjj. -ieuage. g.e/ip.^ur-.ted cn -the. BaA.-':i l
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Responses to Doris Naylor Letter
DN-1 The Draft Environmental Impact Statement (DEIS) was not
intended to address the siting of wastewater treatment plants
(WWTPs) but the management of the effluent. Siting decisions
are largely a matter for local zoning boards.
DN-2 We agree that any septic tanks that are failing, not located in
proper soils, or are contributing to non-point pollution should
be required to be connected to a municipal WWTP system.
DN-3 Golf courses will use herbicides, pesticides, and fertilizers
whether or not tertiary treated effluent is used for
irrigation. Because heated effluent contains nitrates and
phosphates, reusing this product reduces fertilizer and
groundwater pumping costs. Modelling studies show groundwater
flow to be from north to south.
DN-4 We agree that using wetlands for WWTP disposal is not a viable
solution at Gulf Shores.
DN-5 Both ADEM and EPA question the wisdom of transporting treated
effluent north of the Intracoastal Waterway for disposal
because 1) this region is the recharge area for the
Pliocene/Miocene aquifer, the major source of drinking water in
the area, 2) this area seems to be undergoing development now,
and will probably continue to see residential/commercial
development. Because of this development, it would be
difficult to secure long-term commitments for large tracts of
land required to receive treated effluent for the next twenty
years and beyond.
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27 September 1990
RECOMMENDATIONS: REGARDING SEWAGE DISPOSAL/South Baldwin County, AL
Prepared for EPA Hearing, Gulf Shores, AL
RECOMMENDED:
Tcland be sent to mainland for treatment; NO
1) That ALL SEWAGE from Pleasure Isla
STP's on island.
n . tmported onto the island for treatment--an uncon-
Nov, sewage actually is EMPORTE .g tQQ shallow. land too scarce; too
scionable arrangement. Water. foo sufc>iect to exploitation S< profiteering,
sandy and otherwise inappropriate, too suwj
i ^ frv to operate STP without properly-trained personnel;
2) That NO ONE be allowed to try to ope
sanitation engineers.
«n frpated (ostensibly well-treated) be dumped into
3) That NO SEWAGE, however f^ ; ^ ous, creeks, branches, ditches,
the Gulf Intracoastal Waterway, river , y whatsoever, NOR
borrow-pits, bays, Gulf, nor any other open boay or
injected underground.
, stp has the capability of tertiary or
It is naive to assume that, becau actually treat it to that level, es-
better treatment that they can or important than ever that
pecially in times of ^raffL^Sds, storms, rains, etc.).
it be properly treated (holidays, heavy-trarric w
• i f- chould receive at least primary treat-
*4) After sewage is piped to& MAINTAINED ARTIFICIAL WETLANDS
ment and then go into PROPERLY DESIGNED those in use by the city
(NOT natural wetlands) d®S^f^^a1°Jstem "aquaculture" method developed
of San Diego (the natural biological sy q
for NASA by Bill Wolverton).
Wbiverton recently has retired from NAS^ 3^ Advisor/consultant/trouble-
Picayune, MS (601-799-syst«.
shooter during set-up of properiy ruiu-u-i.
wetlands systems: Haughton, LA (Mayor Harold
Properly functioning artificial ^lan y Forrest, 318/965-9889); Collins,
Lee, 318/949-9401); Benton, LA (Mayor Georg
MS (Mayor V.O. Smith, 601/765-4491).
_ , , . 4.ank-c! be allowed to continue operating, if
5) That correctly positioned 2^rrectiv That all septic tanks that
functioning properly and maintained co Y^tland properties be condemned
are floating, in low-lying or °^r be ^ . h inappropriate areas;
and discontinued; that no more *ul£ng ^ng they have
that proper sewage disposal be required tor sucn
been in existence (no grandfathering).
6) That marinas ALL BE ®001® to
to use them ""hout^ception^at toats have ^ans te devised £or preventing
and accomnodations of »*rinas be umited
in a given body of water.
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There no longer is any excuse whatsoever for dumping sewage overboard into rivers,
waterways, and bays. Good alternative treatment works and is affordable. Even
if expensive, we no longer can afford to add to the nutrient and disease organism
load in coastal waters.
No other species on Earth tries to live in its own excrement...just the one with
the big brain he is so proud of.
In Perdido Bay we already are having problems with human diseases (rashes such as
impetigo, yeast infections, septicemias, blood-poisonings of various types,
systemic tuberculosis, cholera and typhoid organisms showing up in tissue sables,
Salmonella, Pseudomonas, Vibrio, and the like.
There is saltwater incursion in wells on the island. We cannot afford to waste
the freshwater—properly treated it could be applied to horticultural projects
and recovered in the watertable, eventually.
Our marine system already is suffering not only from sewage, but from excess
fresh water—the Bay is fresher than it used to be, fresh enough to be causing
losses of Bay plants and other organisms.
Invertebrate diseases are becoming rampant (parasites organisms did not lave in
the past; such problems as microsporidian cotton-disease of shrimp and crabs).
Dolphins apparently have their immune systems knocked down sufficiently to suffer
from filamentous fungus infestations (apparently the OOmycete, Saproleqnia) never
before observed on marine marnnals from anywhere.
San Diego has 190,000,000 gallons/day of sewage to contend with. It is treated
only to primary level and dumped 2.5 miles out into the Pacific Ocean into a
kelp bed (huge ocean, open waters—unlike the enclosed Gulf of Mexico). Even
so, swintning beaches have to be closed because of unacceptably high coliform
counts (1,000+ count coliforms—not so high as Perdido Bay's though!). They
will extend pipe by 3.5 miles to try to meet current standards. As pilot pro-
ject, they treat 300,000 gpd by artificial wetlands aquaculture system and
reduce coliform count to 2/100 ml with retention time of 1-3 days (using water
hyacinthsAoi carp/crayfish in biological system).
Aeration is required to completely prevent odors. Cfast for aerafcietf is 18.5^/HlM
(ours is 7.5
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Responses to Joy F. Morrill, Ph.D. Letter
The Draft Environmental Impact Statement (DEIS) addressed management of
treated wastewater, not the siting of the wastewater treatment plants
(WWTP) in South Baldwin County. These facilities were under construction
prior to the preparation of the EIS. Siting of WWTPs is largely a local
zoning decision.
WWTP operators are trained under ADEM's licensing procedures.
The purpose of the EIS is to examine wastewater management alternatives
and impacts, one of which was land application. We hoped to elicit
comments on this option.
Tertiary treatment describes a process (sand filtration, microscreens),
not the specific amount of pollutants discharged from a system. All
three WWTP operators in South Baldwin County have tertiary systems at
their facilities and provide a high level of treatment. Daily monitoring
reports of each operator are available through ADEM.
Pages 2-8 through 2-10 of the DEIS address potential created natural
(water hyacinth) disposal options for South Baldwin County. Although
wetland cells are an innovative idea for wastewater management, there are
problems that must be overcome before this solution will work at Gulf
Shores. One such problem is availability of land. Using EPA's hydraulic
criteria, the acreage required for treating GSUB's anticipated wastewater
flow of 4.28 mgd would be between 200-250 acres, a large area on an
island where land is scarce.
Eight natural systems have been placed in operation in Alabama (as of
1988) and 5 more are planned. ADEM has permitted system that have flows
ranging from 0.15 mgd to 0.45 mgd, an order of magnitude less than the
projected 4.28 mgd for Gulf Shores. This technology should be carefully
evaluated using smaller systems before committing resources to larger
flow systems.
Another consideration in vising natural systems at Gulf Shores is the
highly cyclical nature of the wastewtaer flows from this service area.
The region has a large temporary and tourist population which causes
weekend versus weekday flow variations as well as summer versus winter
variations. Natural systems may not be able to properly handle the
wastewater surges, given that the detention time in the wetland systems
must be 5-7 days for full treatment.
Because of the stringent effluent requirements for the discharge required
by ADEM (NPDES AL0055841), it is problematical that 4.0 mg/L BOD, 1.0
mg/L NH3-N, 3.0 mg/L TKN could be achieved by natural systems.
We agree that when soil conditions and percolation are adequate for
septic tank use, their operation should continue. Septic tanks use in
inappropriate areas, however, should be discouraged to reduce non-point
source runoff and groundwater contamination.
This DEIS was not intended to address the waste disposal practices at
marinas; however, these recommendations are sound.
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-2-
impact DO concentrations. Therefore, it is unlikely that power
vessels contribute significantly to low DO levels.
The DEIS states that EPA's preferred alternatives 1 and 3 could
result in ecological impacts (decrease DO levels) due to the
continuation of wastewater discharge into the Gulf Intercoastal
Waterway (GIWW). These alternatives appear to he inconsistent with
EPA's strong opposition to issuance of a Department of the Army
permit for a marina in Gulf Shores, since EPA's concern was for
degradation of water quality (DO violations).
We concur with the findings that DO levels should increase with time
due to the elimination of organic loadings which exceeded the
appropriate limits.
d. Page 3-48, paragraph 3.4.1.5, Archeological and Historic
Resources - The DEIS does not indicate whether the reconnaissance
level cultural resources survey was conducted specifically for the
proposed project. However, it is apparent from the text that the
reconnaissance survey indicated that cultural resource sites may be
present.
The results of the surveys must be coordinated with the Alabama
State Historic Preservation Officer (SHPO). If sites are eligible
for the National Register of Historic Places and would be adversely
affected by the proposed construction, additional consultation with
the Alabama SHPO and the Advisory Council on Historic Preservation
would be required in accordance with the Advisory Council's
procedures, at 36 CRF Part 800.
e. Page 4-31. section 4.5. Collection System Construction
Environmental Impacts and Mitigations - Reference second paragraph
of this section. The referenced laws and regulations require the
identification of historic resources, their evaluation, assessment
of the proposed undertaking effects on the resources and mitigation
of the adverse effects. Mitigation is not certification from the
SHPO that no resources would be affected. We recommend that this
section be reevaluated to adequately address the Historic Resources
and reflect coordination with the SHPO.
If there are any questions concerning these comments, please
contact Ms. Alfedo Acoff at FTS 537-3886 or commercial 205/694-3886.
COE-4
COE-5
Sincerely,
Hugh A. McClellan
Chief, Environment and
Resources Branch
enclosure
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Responses to Army Corps of Engineers Letter
Information on potential contributors to low dissolved oxygen
have been added to Environmental Impact Section 3.4 and
Technical Appendices A through E. Other reviewers also made
this request.
The COE statement that theire are no seafood processing plants
discharging into any of the area WWTPs is no longer correct.
Gulf Coast White Knight Seafoods sewer Permit No. 5116 was
authorized 4-25-90 by the Gulf Shores Utility Board for a
maximum daily discharge of 72,000 gallons per day.
Please refer to EPA response to U.S. Pish and Wildlife October
9, 1990 letter. We believe that resuspension of sediments may
play a role in dissolved oxygen depletion of the GIWW, but do
not know the extent of this depletion.
This EIS must recognize that construction on the Gulf Shores
WWTP was substantially completed in 1989, without federal
funds, and in a state which has a delegated NPDES program. We
believe that the effluent limitations are sufficiently
stringent to protect the water quality of the GIWW.
The EIS has been amended to reflect adequate coordination with
the offices of Historic Resources and SHPO.
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5.4.2 Comments on the DEIS Not Requiring a Response.
List of Letters
10/16/90 Memorandum from Dan Ahem, EPA Water Quality Standards and
Monitoring Section, to Heinz Mueller, EPA Environmental Policy
Section.
10/17/90 Keneth W. Holt, Center for Environmental Health and Injury
Control.
8/22/90 Memorandum from Carey B. Oakley, Alabama State Museum of
Natural History, to Heinz Mueller, EPA Environmental Policy
Section.
8/27/90
F. Lawerence Oaks, State Historic Preservation Officer.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLANO STREET. N.E.
ATLANTA. GEORGIA 30365
OCT 1 6 1990
memorandum
FROM:
SUBJECT:
Water Quality Stan ring Section
Heinz Mueller, Chief,
Environmental Policy Section
Dan Ahern, Chief
Gulf Shores Draft
TO:
The subject document has been reviewed for water quality issues. Two
recommended alternatives for each of the three WWTP facilities in
South Baldwin County were listed. Alternative #1 for Gulf Shores
Utility Board (GSUB) consists of a 4.3 MOD discharge to the
Intracoastal Waterway (ICW). Alternative #1 for Island Bay Utilities
(IBU) consists of a discharge, of up to 1.6 MS), to the ICW.
Alternative #2 for both GSUB and IBU consists of slow rate land
application on Pleasure Island. Alternative # 1 and 2 for the South
Alabama Sewer System (SASS) are basically the same, as the flows
enter percolation ponds under each alternative.
The draft report states that wastewater point sources to the ICW are
not the primary reasons for the dissolved oxygen and algal growth
problems. Water quality sampling and modeling studies conducted by
ADEM indicate benthic oxygen demand, ambient BOD from wolf and Oyster
Bay, and other point and non-point sources, as primary contributors
to the water quality problems in the ICW.
In spite of the above information and -J811 .
discharge tertiary treated waste <4-1-5, BOD5-MH3-W-D.0^,
2-1-5, respectively) to the ICW, if Alternative #1 for both GSUB *nd
IBU is chosen (i.e., continue discharging t*i the
the recommendation in the draft SIS *»
quality monitoring should occur in the IGm afiosre aacr tfuwi
and IBU during the summer months (May - September). parameters for
monitoring should include temperature, pH, dissolved oxygen, BQD5,
and NH3-N, and should be collected every two weeics.
The monitoring data will help serve as a veff
modeling studies and to determine if the t£®
adequate. The option of slow rate land
Preferred option for GSUB arid I£U if the ICW water quality
continually degrades. Please contact John Xroske at 2126 if
additional information is needed.
Printed on Recycled Piper
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DEPARTMENT OF HEALTH & HUMAN SERVICES J i.
4(J' L' Sf-'^Vrr LoM''
A,r : . ' .1 o A $0t,
Oct 17 ^ S8 ^ 3i] October 12, 1990
. ^ 1 ¦ 'J - ' ' v.
Heinz J. Mueller, Chief asSlS ,. KCH
Environmental Policy Section
Federal Activities Branch, U.S. EPA
345 Courtland Street
Atlanta, Georgia 30365
Dear Mr. Mueller:
We have completed our review of the Draft Environmental Impact
Statement (DEIS; for South Baldwin County, Alabama Wastewater
Management. We are responding on behalf of the U.S. Public
Health Service.
The DEIS does a good job of weighing the environmental, economic,
public health, ecological, implementability and operability,
aesthetic, and secondary impacts of the options considered. We
agree that the two preferred alternatives appear to be both cost
effective and environmentally sound.
Any land application system should incorporate the mitigation
measures which are presented - both for the control of
groundwater contamination and the prevention of the possible (but
unlikely) transmission of infectious disease via aerosol
dissemination. We concur with the need for land application to
be proven feasible and environmentally acceptable by detailed on-
site engineering analysis (Section 2.3.3.3).
Further information on how many residences in the affected area
are still served by septic tank systems would be helpful as would
a discussion of how the alternatives would extend sewer service
to failing septic tank areas (Section 3.4.1.1.1)
Thank you for the opportunity to review and comment on this
document. Please insure that we are included on your mailing
list to receive a copy of the Final EIS, and future EIS's which
may indicate potential public health impact and are developed
under the National Environmental Policy Act (NEPA).
Sincerely yours,
Kenneth W. Holt, M.S.E.H.
Environmental Health Scientist
Center for Environmental Health
and Injury Control
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AUG 2 4 /iU/D
STATE MUSEUM OF NATURAL HISTORY
August 22, 1990
MEMORANDUM
Archaeology Division
To: Mr. Heinz J. Mueller, Chief ... _ ,
Environmental Policy Section, Federal Activities Branch
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, GA 30365
From: Carey B. Oakley, Assistant Director
Alabama State Museum of Natural History
Archaeology Division
Office of Archaeological Research
. TYraft- fis for South Baldwin County
Subject: Public Notice Concerning Draft mi> ror
Wastewater Management
Upon reviewing the Draft Enviroimental Impact StatementJEIS^fo^
South Baldwin County Wastewater Managem®^ed J£at 27 archaeological/his -
Archaeological and Historic Resources After examining the Ala-
toric sites are recorded within the st y dl*scovered that at least 145
bama Archaeological State Site J1*" Baldwin County below UTM Northing
archaeological sites are located withi ^ 125
3,364,000, the approximate northern hountory ror ^ incluslon on the
of these sites were not evaluated as to g ^ considered
National Register of Historic ?laces' . professional archaeologists,
potentially eligible for NRHP no®inatl has neVer been surveyed for
Additionally, a large portion of the study
cultural resources.
_ Mnn wells conveyance lines and pumping
The construction of extraction we , sludge disposal areas
stations and the use of land application s ^ well as any sites
could potentially impact the abovement one icg therefore recommends
which have not been recorded thus far. miction cr disposal activi-
that all areas considered for excavationcons this project be sur-
ties, or any other possible disturbanc ,^4-onriallv significant cultural
veyed for archaeological sites to preven p
resources from being destroyed.
cc: State Historic Preservation Officer
CB0/BJ
EIS-BA.EPA
«» 348-7774, « ^ ^ ^3"'2494
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STATE OF ALABAMA
ALABAMA HISTORICAL COMMISSION
725 MONROE STREET
MONTGOMERY, ALABAMA 36130-5101
F LAWERENCE OAKS
EXECUTIVE DIRECTOR
TELEPHONE «&MBER
261-3184 ^
261-3184
August 27, 1990
f
Mr. Heinz J. Mueller
US EPA
345 Courtland St., NE
Atlanta, Ga 30365
Re: Draft EIS for Wastewater Management
Baldwin County, AL
Dear Mr. Mueller:
The Alabama Historical Commission agrees with the recommendations provided by
the Office of Archaeological Research. The Alabama Historical Commission
requests that the project area be surveyed by a professional archaeologist.
The archaeologist's report should be submitted to our office for review and
concurrence prior to any construction activities.
Should you have any questions, please contact our office.
Sincerely,
F. LaWrence Oaks
State Historic Preservation Officer
FLO/LAL/gtj
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Public Hearing Transcript.
Pt'BLIC HFARING FOR THF
F\V1ROXMFNTM PROTECTION AGENCY
%
DATE: September 27, 1990
TIME: 7:15 p.m.
PLACE: Gulf Shores State
Park Resort Hotel
Gulf Shores, Alabama 36542
REPORTED BY: SHELAGH D. McCLAIN
McClain Reporting Service
8 Parkwood Drive
Foley, Alabama 36535
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A P P FAR A V C E K
hearing officer*.
PRESENTATION: BY:
SPEAKERS:
HEIMZ MUELLER
JOHN HAMILTON
PF.TF DOUGLAS
YFRN'ON MTNTON
DORIS f. VAYT.OR
JESSF B. HARVARD
SHFLAGH D. McHLATN'
Court Reporter
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WHFRFrpCA thF FOl.I.OWTVG PROCFEDI\TtS KERF HELD:
3
MR. MiTI [ FR:
I'm going to go ahead and try to get: started.
I'd like to welcome you to a public hearing in Gulf
Shores.
My name is Heinz Mueller. I'm chief of the
Environmental Policy Section of the Environmental
Protect inn Agency in Atlanta. I'll be the hearing
officer for tonight's hearing. I want to make a verv
brief statement if you will bear with me.
John Hamilton who had been the project manager on
this particular draff, will make a very short
presentation for those of you who are not. familiar
with the project, at which time we will open it up
for public comment.
T would like to emphasize again for those of you
who have not filled out a registration card, please
do so. We do have about four speakers right now but
we would certainly like to have a couple moie. If
vou do not wish to make 3 statement we woti>ld still
like to have you fill out a card so we can put you on
our mai.1 ing list.
At this time T would like to acknowledge any
elected officials or public officials. Would you
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like to stand up and he recognized? T know we have a
couple >f publ ic officials here that, are not
necessarily elected. Would anyone like to stand up
and introduce themselves?
(No response.)
MR. MUFI.I FR :
The authority for tonight's hearing comes from
the National Environmental Policy Act, often referred
to as "Federal NEPA," that requires the Environmental
Protection Agency and other federal agencies to an
examination of actions carried out by the federal
government to determine any significant impact on the
environment. Title II of the construction of
publicly-owned waste water treatment plants requires
us to do a reauthorization and amendments made in '87
are replacing these grants with a loan program
administered by the State of Alabama.
Under Environmental Protection Agency rules and
regulations, all findings of the EIS are to be made
public, and the public may comment on the draft up to
45 days after its being made available. All comments
made at the hearing tonight are being reported by our
court reporter and will become a part of the final
EIS.
We would ask that as you make your comment to
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please come up, stand at the mie and provide our
court reporter with your name and address, and if you
feel like there may be some question about the
spelling, you might want to spell out your name.
The type of hearing we are having tonight is an
informational hearing. As the hearing officer I
would like to lay down a couple of ground rules:
This hearing is for the Environmental Protection
Agency to receive comments. We are not here tonight
to debate issues or to defend or to debate anv
recommendations made in the draft EIS. Therefore,
there will be no cross examination.
I may ask questions of the people that make
statements, or I may ask for information of persons
on the panel in order for clarification. I
If you are an individual please limit your
comments to approximately five minutes. Because of
the small turnout we could probably give you about
five minutes more than that. If you represent a
group you may have 10 minutes. J
The draft EIS which I hope most of you have seen j
by now was made available and advertised in the
Federal Register on August 24. Written comment in
addition to any statements made tonight will be
accepted by Environmental Protection Agency until the
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close of business October 16 1990.
The draft EIS will then be revised and we will
prepare a final EIR. The final EIS will include a
summary of findings, a preferred alternative or
alternatives, public comment on the preferred
alternative, and Environmental Protection Agency's
response to those comments, and a transcript of this
hearing will also be included in the document.
This document will then be made available to the
public. Environmental Protection Agency's regional
administrator in Atlanta will then examine the final
EIS, make his decision, and publish a record of its
decision in the Federal Register which will then
complete Environmental Protection Agency's
involvement in this particular process. If you have
registered for this hearing you will be advised of
the final Environmental Protection Agency decision.
I'll now introduce John Hamilton, who has been
the project manager, to give us a brief presentation.
John.
MR. HAMILTON:
Thank you. I think I'm going to make this very
brief because you didn't come to hear me. I think
you came to hear other comments, but just to put some
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sort of a framework on what we're doing here
Basically the alternatives that we looked at were
no action, disposal to the Gulf of Mexico, making
everybody join forces arvd link their discharge pipes
for discharge in the Intracoastal Waterway, various
land application scenarios which'included a slow rate
land application on Pleasure Island.
(Showing slides on overhead projector.)
The fifth option was a high rate land application
which somewhat involved discharge in the field and
then repumped and relocated somewhere else.
The sixth option was basically the same thing
except, there would be a wetland created and then a
disposal by a slow rate land application oh the land
north of the — well, let me go through these very
verv quickly and focus on what our purpose is.
Basically, we looked at three ultimate
configurations, the one mile, three miles, and six
miles. And a fair amount of evaluating work was done
with this. This one was rejected largely on
environmental ground because of the inadvisibilitv,
we felt, of discharging all the treated sewerage, but
sewerage nonetheless, to Gulf Shores.
Gulf Shores is a resort area and derives most if
not all of its income from tourism and we felt this
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would be a very poor section. Tt would be bad for
business and it would most probably increase the
nutrient level and possibly add other contamination
to the locale.
This is a quick look at what one of these would
look like. I think this is sort of a horrible
picture but nonetheless, this is probably what a
multi-port confusion discharge pipe would look like.
There probably would be no health impact but there
would be nutrient impact. Also, this was the most
expensive option.
We looked at having — is this in focus? Is it
okay?
MR. PIINTON:
It's all right.
MR. HAMILTON:
We looked at tying all systems into discharging
into the Intracoastal Waterway. We looked at various
land disposal sites. This was our preferred all the
-- we will talk about this a little more later.
Basically, what this is would be some spray field
configuration. When I use the word "spray field"
it's not necessarily a nozzle configuration system,
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but would use areas of ground that would be either
dedicated or would have some long-term commitment to
sewerage effluent discharge.
There is a problem with this though. There is a
good — I think I want to come back to this later on.
Let me finish up with the rest of the others. I'm
not going to dwell on.
This was the various high rate disposals with
repumping and trans-location of the waste to other
spray areas. Those were rejected because these were
somewhat contrived and required a fair amount of
hardware, and tied up perhaps more real estate than
would be cost effective. Real estate is expensive in
Gulf Shores. That's one of the difficulties with a
dedicated land application system.
This was another presentation of the same thing
except that wetland would be created and we didn't
dwell too long on this one for very much the same
reasons.
This would be a discharge system through the
trans-location area, repuitping and then try to
relocate to another location. Again, hardware
problems and not very cost effective. We looked at
land disposal sites north of the Intracoastal
Waterway. This was the Craft Farms area and this was
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very, very appealing.
We spent a good bit of time with ADEM on this one
and in the final affalysis ADEM ground water people
did not feel comfortable with any waste water
application through the ground water north of the
Int.racoastal Waterway for reasons of potential well
contamination, and I guess when I look at that I
would have to agree with them. There is a good bill
of well activity here.
Not all of these are major wells, but the aquiffec
situation down here -- you have basically thiree
aquifers and if you can imagine the three being a
wedding cake and slicing in between each layer and
then you tilt the wedding cake to one side and you
take the bread knife and slice it horizontally, yearn
would end up with roughly what the aquifer situation
looked like.
Most of the aquifer water is from the mid-aQuifer
in this area that's known as the Gulf Shores aquifer.
This rechargi© area is for the most part in the farm
land area aaround the airport. To look at what a land
application scenario would do, the Alabama Geological
Survey provided us with a fairly basic model that
looks at flume configurations and what this shows is
the various boundaries that would occur if vou had
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12b acres -- two 1?,5 acre spray fields.
This particular one is a site north of the
airport but you can see as time passes -- first of
all the orientation of this is north (pointing at
diagram), south is down by my feet -- there is pretty
much agreement on the direction of the aquifer flow
and you can see the various wells that this — I
think it's the municipal well 117 which I think is a
major well from which Gulf Shores provides the bulk
of the water. That would start being potentially
impacted in probably 5 to 10 years.
And this would be a look at the mobile or
conservative ions which are -- we are primarily
concerned with nitrogen. Nitrogen, as you know, is a
fairly common contaminate because of somewhat lethal
implications with infants. If you got a condition
X
which is Nephromyloglobinuria which interestingly
enough don't seem to bother adults as much as it does
infants. I won't go into the metabolic reasons for
that, but young infants cannot tolerate nitrogen in
the water, period. So this is mainly what we are
concerned about.
We looked at one ground land application scenario
and this shows a lesion -- that's the airport. This
is the site of Crsft Farms and shows that there is
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verv definite well involvement problems within 20
vears, and this is at not a terrible risk flow. It's
about 4.3 MGD, 125 or so acres. And accordinglyr we
did not pursue this site.
We looked at another site just north of the,
airport, same acre size same flow, same level of
V»
treatment and the zone of influence in both of these
wells even though that was north of the spray field
were still at a high likelihood of being impacted so
that wasn't terribly good.
A site that we do like is the golf course. The
dotted blue line that's crudely hand drawn is the
Intracoastal Waterway and this is roughly the
location of the Gulf Shores plant over here. And
this will do very nicely. This particular well is,
in fact, the well that the golf course water source
is being irrigated from, then it would not need that
well anyway.
One of the definite sites for spray irrigation
on the island is Mr. Eastburn's site. We didn't
model that because it's already working and I think
he has 20 acres there which is being actively used
and seems to be quite effective and I think he's up
to one — he's permitted for up to one M.G.P. that's
correct? And, we haven't shown that site because
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it's already a "done deal" and working.
We like the land application because of the water
resources that it will save and it's a higher
product, a high quality product. The treatment
operators here have completed plants and produce a
high quality water that we hate to see thrown away.
And, if water resources get scarce down here, and
they may not, it would make sense to use these
resources.
If at all land application has a down side to it
it's that it is a product that comes to you whether
you want it or not, like a retail store where you
have no control over inventories coming in. When the
treated water comes to you you have to store it. We
found that in other areas, in Florida and
particularly in Hilton Head, South Carolina, in the
land applications you have to treat the recipient, or
the customer, who may or may not want the product
when you want to get rid of it. This creates a
storage problem. So you have to build into your land
application scenario some storage capacity.
The difficulty here is when you have built your
capacity storage it's gone. So if you have filled
for three days and you have seven days of wet
weather, nobody wants your water this week and you
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have used up your storage capacity what do you do?
The answer is, you have got to dump it somewhere.
All the land application scenarios I have worked with
on Hilton Head, have a P.D.S. discharge help them out
in all of these indications because they must have a
back up. So regardless of your land application you
need to have, you would have to have a permit in
order to discharge the water when it comes to
customers who don't want it.
Additional problems, when your storing the water
and customers don't want it algae grows in it and
that clogs the sprinkler heads and you either have to
chlorinate or in the case of Hilton Head, they had to
build covered storage. So there are problems with
keeping the water when the customers don't want it
such as the algae.
That's pretty much all I'm going to say. I'll
show you this one last overlay because it's
reasonably attractive.
The little flume that we like is the golf course
and this is for a good possibility which is the
other, I believe it's the municipal golf course which
are both within, I think, fairly reasonable
computations to dispose of the waste water.
Okay, the bottom line is that we have come up
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with two recommendations. I have been stressing the
land application because this makes environmental
sense. We have also recommended in the draft a "no
Federal action" which recognizes several things. It
recognizes that those plants that we're talking about
have already been built. It also recognizes that
even if you were to go to plant application a NPDS
permit would be required anyway. You cannot have a
land application without having a backup system.
And, third, we do not have strong evidence that
the plants that are contributing to the Intracoastal
Waterway are seriously degrading. That is a
debatable issue but the data that we looked at
suggested that the impact of the plant has been
marginal. And, I would like to conclude on that
note.
MUELLER:
Thank you, John.
T would like to now start calling up those people
that have filled out one of the speaker cards. And
again, if you have not already done so there is
plenty of opportunity to do that any time while we re
in session here.
The first person 1 would like to ask to come up
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is Pete Douglas with the Fish and Wildlife Service.
MR. DOUGLAS:
My name is Pete Douglas. I work for the U.S.
Fish and Wildlife Service with the field office in
Daphne, Alabama.
I would say that it's rather appropriate that we
called the meeting on the day that we did because a
number of us might be out of work come Monday so
there might even be fewer people than there are here
today. I wonder what happened to everybody. We were
here a year ago and there was standing room only in
this room. Either we have other interests, or there
seems to be some satisfaction with the product that
you've presented.
Since the inception of our involvement of the
waste water management planning for the Gulf Shores
area it's been the Fish and Wildlife Service's
position that the only preferred alternative for the
ultimate fate of this waste water is land
application. This is based on the highly stressed
condition of the Tntracoastal Waterway and adjoining
waterbodies and the value of these areas to marine
fishery resources. There can be little disagreement
over the poor water quality conditions occurring in
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the waterway.
Studies conducted by both the Alabama Department
of Environmental Management and the Alabama Marine
Resources Division have confirmed regular and
sustained dissolved oxygen concentrations
substantially below the state Water Quality Criteria
value of five parts per million. At the same time,
collections of juvenile shrimp and fish have
documented the value of this canal as a nursery area.
Even larval fish, most probably spotted sea trout, or
"specks" as we call them in this part of the world,
have been collected during periods of high salinity
indicating a spawning habitat for fishery resources
of substantial sport and commercial value.
The determination of "no action" which is
continued discharge into the Intracoastal Waterway as
a preferred alternative is based on the results
primarily of two modeling studies conducted on the
waterway. And they concluded that point-source
discharges are having very little impact on lowering
dissolved oxygen levels in the canal.
We feel it's inappropriate for the EIS to place
so much emphasis on these two model studies since
there were major discrepancies in the results and
actual field measures obtained since these studies
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were published indicate that more severe water
quality degradation than predicted by the models have
occurrei].
As a further example, one of the models concluded
that the average flow in the Intracoastal Waterway
was to the west at a rate of 1,000 cubic feet per
second while the other study concluded that the flow
was to the east at nearly 1,200 cubic feet per
second. Obviously the direction and magnitude of the
flow in the canal is of extreme significance in
determining loading sources and effects.
These modeling studies also failed to evaluate a
number of important variables that could have a
significant effect on waterway's water quality. The
BOD loading of the adjacent water bodies such as Bon
Secour Bay, Wolf Bay that provide water to the
waterway were not factored into the modeling
computation. The sediment oxygen demand that was
concluded to have a major impact on dissolved oxygen
was never quantified as to oxygen uptake or it's
impact vertically through the water column. We
believe that the EIS needs to be reformulated giving
full consideration to existing field water quality
information. A water quality base-line must be
formulated upon which future waste disposal decisions
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can be made. Reliance on models that have already
been proven in error is inappropriate.
The discharge permits under which Gulf Shores and
Island Bay Utilities operate require a tertiary level
of treatment. Maintaining this treatment level
requires optimum production of both the personnel and
the equipment. As a consequence, there have been
occasions in the past where upsets have occurred in
which inadequately treated effluents have been
discharged into the waterway. We believe that the
Intracoastal Waterway is under such stress that any
additional waste water loading, permitted or
accidental, has a detrimental impact.
There can be no argument that the Intracoastal
Waterway is severely stressed, frequently in
violation of the Water Quality Criteria, and can
tolerate no additional organic loading. Common sense
should dictate that the removal of any waste water
inputs would only improve the system. Alternative 4A
or 4B, which is slow—rate land application north of
the Intracoastal Waterway, would not only remove all
permitted discharges from the waterway by utilizing
land application but also assist in recharging the
area's depleting ground water.
In addition, the impacts from nonpoint pollution
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sources should be fully considered in reformulating
the EIS. Rapid urban growth both north and south of
the Tntracoastal Waterway have already and will
continue to contribute substantially to additional
water quality degradation. The EIS should reflect
integration of these facts since both pollution
sources affect the Intracoastal Waterway and adjacent
waterbodies.
In conclusion, it is the Fish and Wildlife
Service's position that only one preferred
alternative should be presented by this EIS and that
should be either land application alternative 4A or
4B.
Now, I realize — you know, you write this thing
one day and you read it the next, and as I read this
over I was sitting back there. I said that we say
that one alternative should be presented and I give
you two.
MR. MUELLER:
We weren't counting.
MR. DOUGLAS:
In essence what we're saying is that the Fish and
Wildlife Service strongly recommends and proposes
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land application. We can live with slow-rate
application south of the Intracoastal or north of the
Intracoastal. And, we will present a copy of this
through our regional office within the required time
frame.
Thank you.
MR. MUELLER:
We appreciate your coming.
Okay, the next speaker card is Vernon Minton,
Assistant Chief Marine Biologist.
MR. MINTON:
Mr. Mueller, Mr. Hamilton, ladies and gentlemen,
as stated, my name is Vernon Minton. This report
that I'm about to present was prepared by myself, Mr.
Walter Tatum and Dr. Henry Lazauski. We are marine
biologists with the Marine Resources Division,
Alabama Department of Conservation and National
Resources located here in Gulf Shores, Alabama, at
Post Office Drawer 458.
We appreciate the opportunity to address your
group today. First, we would like to congratulate ,
EPA on the quality of work demonstrated in this draft
EIS. We share the concerns addressed in the document
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about the present status of the Intracoastal Waterway
and are intimately involved with its water quality.
The Marine Resources Division operates a marine
hatchery and research facility, the Claude Peteet
Mariculture Center in Gulf Shores, Alabama. It was
noted on one of your slides earlier as the fish
hatchery up there.
Since 1972 the mariculture center has been using
water from the Intracoastal Waterway for the culture
of marine invertebrates and vertebrates. We monitor
dissolved oxygen, temperature and salinity in the
Intracoastal Waterway daily during our production
season. This season generally runs from mid-April to
late November. These readings are recorded with a
Yellow Springs Instrument Company YSI 51-B oxygen
meter which is compensated for temperature and
salinity.
For several years we have recorded dissolved
oxygen levels well below the 5 milligrams per liter
standard for this waterbody. We have witnessed a
gradual downward trend in oxygen levels over the last
few years. During 1990, dissolved oxygen levels
taken at 6:00 a.m. only met the 5 milligram liter
standard 6 percent of the time. These standards were
taken between May through the present time today.
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The lowest reading recorded was 1.9 milligrams
per liter ori June 29, 1990 and levels below 3
milligrams per liter were recorded on 18 occasions
from 87 samples or approximately 21 percent of the
time.
On page 3-29 of the draft ETS you reference the
study conducted by Tetra Tech, Incorporated in 1984.
That study concluded that waste water point source
discharges were not the primary contributors of the
dissolved oxygen and algal growtfi problems. Instead,
Tetra Tech, Inc. concluded that benthic oxygen
demand, ambient BOD from the waters of Wolf and
Oyster Bay, and non-point and point discharges as
being the factors contributing to the low dissolved
oxygen.
In 1986, we contracted with Auburn University to
conduct a detailed chemical analysis on the water
quality of our rearing ponds. As part of that study
water quality in the Intracoastal Waterway adjacent
to the Claude Peteet Mariculture was also
investigated. Because bottom sediments frequently
contain higher concentrations of organic matter, and
the Mariculture Center uses the canal water for its
ponds, the effect of barge traffic on water quality
in the canal was examined.
¦
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Water samples taken at timed intervals during the
passage of barges was examined on four different
occasions. The section of the canal adjacent to the
Mariculture Center has an average depth of about 15
feet. Loaded barges typically have a draft of
approximately 9 feet. Therefore, the amount of water
displaced by the passage of barges and tugboats can
be considerable.
The results of this study show that although the
Total Particulate Matter increased rapidly during and
immediately after the barge passage, concentrations
declined to previous levels within 4 minutes. This
suggests that the particulate matter was of a sandy
or non-organic nature.
This is further illustrated by tests conducted on
the Loss On Ignition of the same samples. The
decline in Loss On Ignition occurred simultaneously
with the increase in total particulate matter. Thus,
the amount of organic matter probably remained
unchanged during the passage of the barges. This
information leads us to believe that the benthic
loading experienced in the canal is probably not
contributing to the low dissolved oxygen as has been
indicated by the Tetra Tech study.
In the draft EIS page 3-42 it is stated that
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ecological impacts to the Intracoastal Waterways and
adjacent estuaries could result under Alternatives 1
and 3, which include waste water discharges to the
Intracoastal Waterway. Ecological impacts of waste
water discharges correlate directly with water
Quality impacts* In the same paragraph xt is further
stated that "If the impacts were severe, there could
be a reduction in the biological quality of adjacent
estuarine zones, including valuable seagrass beds on
Wolf Bay, Oyster Bay, and Mobile Bay."
Bottom dissolved oxygen samples taken from 1983
through 1989 in Arnica Bay as part of our division's
monitoring and assessment work have indicated that
the dissolved oxygen was less than 5 milligrams per
liter in 36 to 83 percent of each year's samples.
Samples taken at the mouth of the Bon Secour River,
which is located immediately west of the canal,
indicated that in samples there was less than 5
milligrams per liter in 8 to 88 percent of each
year's sample over that 1983 to 1989 sample.
These data indicate that the biological quality
of these adjacent water bodies is already degraded
and can only deteriorate if additional discharge into
the Intracoastal Waterway is allowed. It is felt
that this degradation is a result of the condition of
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the Intraeoastal Waterway.
We are in total agreement with the findings of
the Draft EIS, page 3-43, that states "... the
biological health of the Intraeoastal Waterway and
adjacent bays would be improved as a result of
reduced loadings of organic material and nutrients."
Alternative 1 or maintenance of the status quo leaves
us with a degraded resource with no chance of
recovery and probable further degradation. Our
information indicates this situation is tenuous, at
best, for the survival of the marine species
inhabiting the Intraeoastal Waterway. This waterway
is a vital link between the Perdido and Mobile Bay
systems. Its continued degradation is unacceptable.
It is our firm belief that the only viable
alternative, which will provide relief from the
organic loading in the Intraeoastal Waterway is
alternative number 4. And again, as was stated by
the Fish and Wildlife Service, alternative number 4A
or 4B are acceptable. This is land application.
With this alternative, we believe, as is stated
in the draft EIS, that the biological health of the
Intraeoastal Waterway and adjacent bays will be
improved. The benefits of reuse of the waste water
occur not only to this resource, but to the recharge
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of the alluvial/coasta] aquifer. These benefits will
ultimately outweigh the cost differential indicated
in switching to the land application system.
Based on EPA's standard affordability criteria it
is indicated that sewerage systems are affordable to
a community if the total amount of user charge is
less than 1.75 percent of the user's median income.
The estimated percentage costs for land application
-- this is from your document -- was 0.69 percent
while the "no action" alternative was 0.61 percent
for a difference of .08 percent. Using the median
income indicated in your report of thirty-two
thousand dollars ($32,000) for residents of Baldwin
County, this translates into a difference of
twenty-five dollars ($25) per year per user. As
managers of the living marine resources of Alabama it
appears to be a small price to pay for the health of
our environment.
In conclusion we would like to strongly recommend
that, alternative number 4 be listed as the preferred
alternative. It's affordable, it's practical, it's
biologically sound and will go a long way towards
reversing the lowering water quality trend that has
occurred in the Intracoastal Waterway for the past
decade.
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Thank you.
MR. MUELLER:
Thank you for your comments.
I'd now like to call Doris Naylor.
MS. NAYLOR:
Good evening.
I have read the draft of the Environmental Impact
Statement for South Baldwin County Waste Water
Management, and I ain surprised by the fact that no
mention is made of the raw sewage being piped from
the mainland to the barrier islands for treatment and
disposal. This is risky business, piping raw sewage
under a busy canal. Pipes buried underwater can be
damaged by boat anchors. Some states forbid such a
practice. It is possible to have a leak and have it
go undetected for a long time. This is a high risk
practice and must cease. The sewage generated north
of the canal should be treated in a sewer plant north
of the canal. Bringing untreated sewage from the
mainland to a barrier island for treatment and
disposal is probably an all time act of folly.
Another area not addressed by the Impact Study is
the problem of septic tanks, many of which lie near
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sea level. We can build the best state of the art
sewer plant in the world but if it is not used our
coastal waters will continue to be polluted.
Reviewing the various alternatives of treated
waste disposal I feel the Gulf disposal alternative
is not an option. The Gulf does not need any
additional burdens.
Disposal of treated waste water on golf courses
on the barrier island seems to be the preferred
method of disposal. However, there are problems to
be considered. Golf courses on the barrier islands
are built on sand and waste water will perk through
so fast there will be little cleansing. This
situation is compounded by a high water table and the
fact that golf courses on any barrier island pose
their own special problems. All golf courses use
fertilizers, pesticides and herbicides. What a
witches brew. All the golf course chemicals and the
waste water chemicals. Further, golf courses do not
have the specific vegetation grown to absorb this
type of effluent.
Using wetlands for a disposal area is not a
viable alternative. We have already destroyed much
of our salt marsh wetlands and continue to fill them
in. At this point we should be trying to restore and
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build back the most valuable asset we have rather
than risk the wetlands to additional stress.
In summary, only sewage generated on the barrier
island should be treated at the sewer plants located
on the island. No raw sewage should be piped to the
barrier island as this is too risky. Sewage
generated north of the Intracoastal Canal should be
treated at a sewer plant north of the canal.
Golf courses on barrier islands should not be
considered as viable disposal sites due to the fact
that a variety of chemicals are used on golf courses,
plus the fact we have a high water table and no
vegetation that has high absorption qualities.
A possible solution to disposal of treated waste
water would be to transport the treated effluent to
the mainland and put it on a tree farm. The trees
would be grown that have exceptional absorption
qualities.
Thank you.
MR. MUELLER:
Thank you for your comments.
The next card I have is Jesse B. Harvard.
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MR. HARVARD:
I must admit, my name is Jesse Harvard. I live
at Fort Morgan Road about 6 miles beyond the plant I
want to talk about, SASS, the plant on Fort Morgan
Road. And, I'm a meteorologist and that's what I
want to talk about. Believe it or not it's going to
rain again here some time, and when it does rain that
plant has problems some time.
Since it's been built, we had one period of rain
7 inches plus in about 60 hours that caused a breach
in the percolation pond and all of the effluent
flowed down hill and across marsh land, which is now
Wildlife Refuge land, into the area that we know as
Sand Bayou.
Now, this breach has occurred once in the short
life of that plant. I must admit, I didn't go
through this thoroughly, but I could find nothing
about this danger. I think the danger is quite a big
one. About 11 or 12 years ago we had what I would
call perhaps, about a "25 year rain," once in 25
years, in which we had 13 inches in about as many
hours. And, this percolation pond on this island is
risky and the results of that risk have already been
seen once in the life of this plant.
I just wanted to bring that point out. Thank you
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very much.
MR. MUELLER:
Thank you. We appreciate your comments.
At this time are there any additional people who
would like to speak or anyone who would like to speak
perhaps a second time after hearing some of the
previous comments?
(No response.)
MR. MUELLER:
Did we call on everybody who wanted to speak? I
know we had a yellow card initially that had a "yes"
on there and that seems to have disappeared. Did we
miss somebody?
(No response.)
MR. MUELLER:
You can tell I'm really trying to get the crowd
involved here.
All right, if not, this meeting is now adjourned.
Thank you very much.
(Whereupon the Proceedings concluded at 8:05 p.m.)
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33
STATE OF ALABAMA
COUNTY OF BALDWIN )
CERTIFICATE
I, SHELAGH D. McCLAIN, Court. Reporter and Notary in
the State at Large, do hereby certify that the above and
foregoing transcript of the Proceedings in the matter
aforementioned was taken down by me in machine shorthand,
and the same was reduced to typewriting under my personal
supervision, and that the foregoing represents a true and
correct transcript of the Proceedings given by said witness
upon said hearings.
T further certify that I am neither of counsel nor of
relation to the parties to the action, nor am I in anywise
interested in the result of said cause.
shelaghJd. Mcclain
Court Reporter, Notarv
Commission expires *?•- ,t>" '1 '¦)
October 3, 1990
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LIST OF PREPARERS
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6.0 LIST OF PREPARERS
U. S. Environmental Protection Agency
Robert Howard/Robert Cooper/
Heinz Mueller
Ted Bisterfield/
John fi. Hamilton
Chief, NEPA Compliance Section
Project Monitors
Land Application Specialist
Environmental Services Division
David Ariail
Ron Rashke
Alabama Department of Environmental Management
Truman Green
Janes E. Mclndoe ChUf. Planning/Projects Branch
Fred C. Mason Groundvater Section
Geoloplcal Survey of Alabama
Robert V. Chandler Water Resources Division
Gannett Fleming Environmental Eneineers,—Inc.,.
Thomas M. Rachford, P.E., Ph.D. Program Manager
Laurence E. Benander, P.E.
D. Randy Grubbs, P.E.
Mark C. Mvuumert, Ph.D.
Heather G. Mcllvried
Mark A. Malarich
Steven B. Deck
James K. Griffiths
Joseph E. Wilk
Kenneth B. Kullman
Wapora Environmental Engineer."entistg
Project Director
Environmental Engineer
Environmental Engineer
Environmental Engineer
Environmental Engineer
Environmental Scientist
Environmental Scientist
Graphics Specialist
Graphics Specialist
Charles Beck
Steven Bach
Environmental Scientist
Environmental Scientist
6-1
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REFERENCES
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7.0 REFERENCES
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Analysis of Pleasure Island, Alabama.
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Land Application of Treated Waste.
Alabama Department of Environmental Management. 1987. Natural Treatment
Systems For Upgrading Secondary Municipal Wastewater Treatment
Facilities. A Preliminary Report.
Alabama Department of Environmental Management, 1988. Natural Treatment
Systems For Upgrading Secondary Municipal Wastewater Treatment
Facilities.
Alabama Department of Environmental Management. 1988. Alabama Nonpoint
Source Assessment 1988.
Alabama Department of Environmental Management. 1989. Alabama Nonpoint
Source Management Program 1989.
Alabama Museum of Natural History. 1976. Endangered and Threatened
Plants and Animals of Alabama. Bulletin No. 2.
Auburn University. 1979. Endangered, Threatened and Special Concern
Plants of Alabama. Departmental Series No. 3.
Beccasio, Angelo D., Nick Fotheringham, Alice E. Redfield et al. 1982.
Gulf Coast Ecological Inventory User's Guide and Information Base.
Prepared by Dames and Moore for U.S. Fish and Wildlife Service.
Washington, D.C. 191 pp.
California State Water Resources Board. 1985. Irrigation with Municipal
Wastewater - A Guidance Manual.
7-1
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The Center of Urban Policy. 1978. Fiscal Impact Handbook.
Chapman, Charles. 1968. Channelization and Spoiling in Gulf Coast and
South Atlantic Estuaries. IN: S.D. Newsome (id), Proceedings of the
Marsh and Estuary Management Symposium. T. J. Moran's Sons, Inc. Baton
Rouge, Louisiana, pp. 93-106.
City of Gulf Shores, Alabama. 1983. Planning Area Trends Analyses
Through 1983.
City of Gulf Shores, Alabama. 1984. Standards for Control of Erosion,
Sedimentation, and Stormwater Runoff.
City of Gulf Shores, Alabama. 1989. Gulf Shores Traffic Study.
Cowardin, L.M., V Carter, G. C. Golet, and E. T. LaRoe. 1979.
Classification of Wetlands and Deepwater Habitats of the United States.
FWS/CBS-79/31.
Geological Survey of Alabama. 1985. Groundwater Chemistry and Saltwater
Encroachment, Southern Baldwin County, Alabama. Bulletin No. 126.
Geological Survey at Alabama. 1988. Updated Groundwater Chemistry and
Saltwater Encroachment, South Baldwin County Alabama (Unpublished).
Geological Survey of Alabama. 1989. Possible Effects of Land
Applications of Municipal Wastewater in Gulf Shores, Alabama Area
(Unpublished).
Hubbard, R. K. and J. M. Sheridan. 1989. Nitrate Movement to Ground-
water in the Southeastern Coastal Plain. Journal of Soil and Water
Conservation.
Loehr, Raymond C., et. al. 1979. Land Application of Wastes. Van
Nostrand Reinhold Company. New York.
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North Carolina State University, East Carolina University, and University
of North Carolina at Chapel Hill. 1979. Ocean Outfall Wastewater
Disposal Feasibility and Planning. Report No. 79-1.
Novotny, Vladimir and Gordon Chesters. 1981. Handbook of Nonpoint
Pollution: Sources and Management. Van Nostrand Reinhold Company. New
York.
O'Neil, p.E. and M.F. Mettee, eds. 1982. Alabama Coastal Region
Ecological Characterization 2. A synthesis of Environmental Data:
Alabama Geological Survey Inf. Ser. 61.
R. S. Means Company. 1988. Building Construction Cost Data. 46th
Annual Edition. Robert Snow Means Company. Kingston, MA.
Simon and Dyer (1972) IN; Johnston, Sam A., Jr. 1981. Esturine Dredge
and Fill Activities: A Review of Impacts. Environmental Management.
5(5), pp. 427-440.
South Alabama Regional Planning Commission. 1983. The Economy and
Population of the South Alabama Region.
South Alabama Regional Planning Commission. 1986. Economy and
Population of South Alabama Region.
Stewart, B. A. 1976. Control of Water Pollution from Cropland.
Tetra Tech, Inc. 1984. Water Quality Modeling Study - Ifttracoastal
Waterway, Baldwin County, Alabama. Final report submitted to ADEM.
U. S. Environmental Protection Agency. 1978. Analysis of Operation and
Maintenance Costs for Municipal Wastewater Treatment Systems.
U. S. Environmental Protection Agency. 1979. Cost of Land Treatment
Systems.
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U. S. Environmental Protection Agency. 1980. Innovative and
Alternatives Technology Assessment Manual.
U. S. Environmental Protection Agency.
Treatment of Municipal Wastewater.
U. S. Environmental Protection Agency,
the Policy of Financial and Management
Treatment Systems.
U. S. Environmental Protection Agency.
Alternative Screening Report.
1981. Process Design Manual Land
1983. Guidance for Implementing
Capability for Publically Owned
1985a. Wastewater Management
U. S. Environmental Protection Agency, 1985b. Coastal Marinas Assessment
Handbook. Prepared by Applied Biology, Inc. for Region IV Environmental
Protection Agency. 904/6-85-132, pp. 4-19,20,21.
U. S. Environmental Protection Agency. 1989. National Coastal and
Marine Policy Statement.
U. S. Fish and Wildlife Service. 1985. Endangered and Threatened
Wildlife and Plants. Determination of Endangered Status and Critical
Habitat for Three Beach Mice. Volume 50, No. 109; 500FR, Part 17. pp
23872 - 22889.
U. S. Fish and Wildlife Service. 1986. Region IV Endangered Species
Notebook.
U. S. Geological Survey. 1988. Geohydrology and Susceptibility of Major
Aquifers to Surface Contamination in Alabama; Area 13.
U. S. Soil Conservation Service. 1963. Soil Survey for Baldwin County,
Alabama.
Van Nostrand Reinhold Company, Inc. 1982. Urban Planning and Design
Criteria.
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