PB95-156592
                                      Information to our
ENVIRONMENTAL IMPACT STATEMENT:  SLUDGE
DISPOSAL AND LAND  RECLAMATION IN FULTON
COUNTY,  ILLINOIS
(U.S.) ENVIRONMENTAL PROTECTION AGENCY, CHICAGO, IL
JAN 81
 national Technical Information

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REPORT DOCUMENTATION PAGE
Form Apftrovfd
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4. TITII AMD SU1TITU •• __
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9. SPONSORING /MONITORING AGENCY NAME(S) AND ADORE SS(ES)
USBR4
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fJOl MSf.f5W
UasiiutM. DC J0460
i. FUNDING NUMBERS
i. PERFORMING ORGANIZATION
RE POUT NUMBER
10. SPONSORING /MONITORING
AGENCV REPORT NUMBER
11. SUPPLEMENTARY NOTES
12*. DISTRIBUTION /AVAIL ABILITY STATEMENT
lib. DISTRIBUTION CODE
13. AiSTRACT (Mtxirr urn 200 words) ^
An walyils o* th» Mthodol ogles utiliiwl by th» M*tropol!tan Sanitary Olstrict
of Sr»attr Chicago CHSOGCI for ttw application of iludga on s^-Ip-«ina
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     FINAL PWHQNMENWL IW»CT STWEWEOT
     SLUDGS DISPOSAL WD IAND RECLAMATION
          w PULTON ocxwry, ILLINOIS
               Prepared by the
UNITED STATES ENVIRDWeWT'tfj PHDTBCTION AGENCY
         REGION V, CHICAGO, ILLINOIS
                            nal Administrator
                            Environmental Protection Agerxry
                       Jaruary 1981

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                                UNITED STATES
                     ENVIRONMENTAL PROTECTION AGENCY
                                   REGION V
                             230 SOUTH Of AfttOMN ST
                             CMKAQO. ILLINOIS MM04
                               JAN 16 1881
                                                                REPLY TO ATTENTION OF:
                  TO ALL nWSRBSTED AGENCIES, PUBLIC SOUPS
                                 AND CITIZENS

The Final Environmental Inpact Statement (EIS) for Sludge Disposal and
Land Reclamation in Fulton County, Illinois is hereby submitted for
your information and review.  This EIS has been prepared in compliance
with the National Environmental Policy Act of 1969, and the subsequent
regulations prepared by the Council on Environmental Quality and the
Environmental Protection Agency.  This EIS presents an analysis of the
methodologies utilized by the Metropolitan Sanitary District of Greater
Chicago for the application of sludge on strip-mined land in Pulton
County, Illinois and concludes after prolonged study, that there are no
significant adverse impacts associated with this project.

Upon publication of a notice in the Federal Register, a 30-day period
will commence during which this Agency will not take any administrative
action on this project.
   io ial Administrator

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                               SUMMARY SHEET

( )  Oraft

CX>  Final

U.S. Environmental Protection Agency
     Region V, Chicago

I.   (X) Administrative Action
     ( ) Legislative Action

2.   Dascr I pt 1 on of the Act I on

An analysts of the methodologies utilized by the Metropolitan Sanitary District
of Greater Chicago (NSOGCJ for the application of sludge on strip-mined  land  In
Fulton County, Illinois Is presented. Since the project Is already being  Imple-
mented, this statement uniquely presents the observed and projected  Impacts of
continued operations.  Digested sludge is loaded at MSOGC's West-Southeast Treat-
ment Plant In Stlckney, Illinois and barged approximately 200 miles  via the
Illinois River to Liverpool.  From the Liverpool dock tha sludge Is  pumped 10
miles via underground pipeline to the project holding basins for storage.  Dredge
equipment Is used to mix the sludge to a uniform consistency and solids content
of 6 percent or less before pumping from the basins Into the distribution system.
Sludge Is applied to land which had been previously drastically disturbed through
strip-mining activities.  The project began using spray application  methods.
Howavar, due to odor problems and public input, the current methodology being
utilized  Is tandem disk Incorporation.  Other methodologies are being explored.

Fields receiving sludge have been contoured to allow collection of runoff due
to storm events or application.  Environmental control systems are employed to
nonitor surface and groundwater, soli and sediment, plants and aquatic biota,
and the atmosphere.

'•  Environmental Impacts

    a.
Some contamination of surface water has occurred at the project site due to runoff
from sludge application to fields and release of affluents from field retantion
basins.  Some retention basins Mere found to have  Insufficient capacity and mere
therefore  Ineffective In removing suspended solids resulting In si Itatlon and
excess dissolved oxygen depletion in receiving waters.  Observation of the slta
showed that the situation Is being corrected. Many additional si Itatlon basins
have been  added to newer fields.  However, runoff from strip-mined areas and
eff lutnts  from Improperly maintained septic tanks and the sewage treatment plant
at Canton  also contribute to this pollution.  Water quality Is not adversely
Impacted by project operations.  Groundwater, as sampled at wells and springs,
has not been degraded by the application of sludge.

The MSOGC  has been In violation of water quality standards on numerous occasions
du* to breaks In the surface pipeline that carries sludge to the application fields.
The MSDGC  has entered Into a program to strengthen the pipeline In critical a< eas
where a break would cause serious water quality problems.  The primary cause of the
breaks has been expansion and contraction from changes In th* temperature.  This
program will continue as an Integral part of th» project operation.

                                     I

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    b.  Sgljs

Sludge has had a beneficial effect upon the physical properties of spoil soils,
The high organic content of sludge provides a matrix for formation of a stable
soil structure.  Incorporation of sludge Into soils by disking has decreased
the chance for runoff and erosion.   Increases In soil organic content and
Increased crop productivity have created beneficial economic and  land use  Impacts.

    c.  Odors and No Ise

Complaints of offensive odors have arisen from citizens within a  4 to 5 mile area
surrounding the sludge application sites and holding basins during the current
operations.  A reduction In malodorants has occurred due to the modification of
application to soil Incorporation.

Noise generated at the Liverpool dock  includes the noise associated with barge
maneuvering and booster pumping.  These activities  Increase the ambient noise
levels around the community of Liverpool.  Noise levels at the site are attributed
to tractors and sludge sprayers.  These noise levels can be detected at the perl-
meter of the project site.  The noise  levels are similar to existing agricultural
noises in magnitude and duration.

    d.  Hea]th_Effects

Among all methods of sludge application, pressurized spraying offered the  greaiest
potential for direct transfer of hazardous components to humans or animals.
Inhalation of sludge aerosols, possibly containing pathogens or toxic substances,
presents an opportunity for protracted and repetitive exposure.   The lack  of
reported cases of health effects from Fulton County operations indicates that the
level of risk associated with sludge application has been minimal.  As the project
developed, MSOGC has taken measures to avoid any potential health Impact.  They
have abandoned pressurized spray application practices In favor of Incorporating
the sludge Into the soil utilizing tractor drawn disking and chisel  plow equipment.
A distribution system and hoses allow the sludge to be placed in  the furrow.

Indirect effects are caused by the consumption of plants or animals that have been
contaminated by heavy metals.  The Interactions among sludge components and the
food chain are complex and Information concerning the ability of  each trophic
level to accumulate toxic compounds and pass them on to succeeding trophic levels
Is sparse and qualitative at best.  The mos+ likely suspects for  potential hazard
are arsenic, cadmium, lead, mercury, and selenium.  3oth sludge and soli at the
project site are high In cadmium, especially In relation to zinc.  Crop monitoring
by the MSOGC should decrease the risk that contaminated crops would reach  the
market place.  Row cropping with grain crops reduces the risk that human health
would b* affected.  Risk could be further reduced by using grain  crops to  produce
alcohol for gasohol.  U. S. Environmental Protection Agency (USEPA)  regulations
40 CFR 257.3-5 further outline a program to mlnlmlie th» effect of sludge  disposal
upon human health where cadmium levels may be a problem.

The actual Indirect hazard to humans would stem from the future use of reclaimed
strip-mined  land for cropping or livestock, grazing, possibly resulting In a
majority of a family's food Intake being contaminated by trace elements.   This
appears unlikely to occur due to land use constraints and availability of  better-
suited property.  Once again, compliance with 40 CFR 257 will Minimize this
problem because future land owners wilt be aware of sludge application sites
because of a stipulation In the land record or property deed.

                                     II

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     e.  Soclo-economlc Effects

The TKJS+ obvious short-term I scat tconotiic effect of the project- has been ta
create Jobs far approximately 120 skilled and unsKllled laborers who average
6 to 8 >noriths of employment yearly.

The sludge application project has also affected tne local public economy by
Increasing future market value of the  land and the tax base.

     f.  Land Lisa

Leveling and grading of strIp-nlned sections of the project site to prepare the
sludge application fields have Increased the suitability of the  land for agricul-
ture.  The renoval of surface racks and labeling of steep slopes have also
conslderaaly increased the area's suitability for recreational use  Including
playgrounds, campsites, roads and trails.  The project has put former agricul-
tural land back into productivity.

The Fulton County project has In essence reduced the area's recreational acreage
by some 15,000 acres, as the district  restricts access ;o property which was
originally open for public and private recreation.  This restriction is done  In
order to protect District equipment and pipelines.

4*   A|ternati ves Considered

The ^330 considered the following sludge handling systems prior to beginning
operations  In Fulton County.  The residents of Fulton County were exploring
ways to return the disturbed land back to some level at productivity.  * few
early attempts had been made to restore the land prior to tne MSDSC project,

    a •  SI udge DI sposa I Subsyste?ns

        (I)  Sanitary landfill

        (2)  Lagoon Ing

        (3)  Ocean dumping

    b•  Sludge Uti||zat|on_Subsystems

        (I)  Fertilizer production

        (2)  Composting

        (3>  Soil reclamation

    c•  SIudge Transpgrtat Ion Subsystems

        (I)  Truck transportation

        (2>  Rail transportation

        (3)  3arge transportation

        (4)  Plp»IIn» transportation
                                    III

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In ccincljsion, sljdge Is applied to  land >»hl:h had 'jeen previously  drastically
disturbed throojh strlp--nlning activities.  Tho project Segan using spray  appli-
cation rtethods.  Howsvar, due to odor problems and public  input,  trte current
mathodaIagy being utilized  Is tandam disk  incorporation.   Nelds  racelvlng sludga
hava been contaurad ta allow collection of runoff due ta storn avants or applica-
tion.  Snvtronmentil control systams ara amployad to monitor surface and ground
*at9r, soil and rack, plants and aquatic biota, «nd the atTosphare.
                                   Iv

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                           TA3LE OF CONTENTS
                                                                  gage

Summary                                                             I
List of Tables                                                      xi
List of -igures                                                     xv
Symbols and Aobreviations                                           xlx
                      I.  SUVMA^r AiJD CONCLUSIONS                   I-I

A. Drojoct History                                                  1-2

3. Pra-existing Conditions                                          1-3

   I . Climate                                                       1-3
   2. Topography                                                    1-3
   3. 3eology and Soils                                             1-4
   4. Hydrology and rtatar Duality                                   1-4
   5. Land Use and Economic Conditions                              1-5

C. Existing Project Conditions                                      1-5

9. Alternatives to the °roject                                      1-9

i_. Existing Policies and Recommendation of Federal
   Agencies                                                         1-3

   I. Food and Drug Admlnlstartion                                  1-3
   2. U.S. Oepart.ment of *gr I culture                                1-10
   3. U.S. Environmental Protection Agency                          1-12
   4. Council for Agricultural Science and
      Technology                                                    1-15

f. Environmental  Impacts                                            1-16

   I. Land                                                          1-16
   2. rtater                                                         1-17
   3. Mr                                                           1-13
   4. Health                                                        1-19
   5. Noise                                                         1-20
   6. Land Use                                                      1-20
   7. Economics                                                     1-20
G. Mltlgatlve Measures Needed to Ensure Environmental
   Compatibility                                                    1-21

   I. Land Management Measures                                      1-21
   2. Air Duality Management Measures                               1-22
   3. Health Management Measures                                    1-23
   4. Plans and Records                                             1-23

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Table of Contents Cont»d>

                     I!.  BACKGROUND MD IST-W-") JCT I DM

A, Project Background and Over view

   I . Benefits
   2. PDtanttal Problems

3. Project History and Issues                                      1 1 -4

   I, History and Policy Matters                                   11-4
   2. Envlronmantal Litigation                                     M-4

C. Salated Activities                                              11-5
   I. The 3ig 3luest9m °rogram and ^acreatianai 3enaflts           11-5
   2. The Fulton County Steering Committee                         11-5
   5. Recreational Areas                                           li-5

0. The Study Area                                                  1 1-5

   I. Basis for the Study Area                                     11-5
   2. Pollution Control Standards                                  11-5
£. Description of '-fiiDGC Treatnent Systems

   I. MSOGC Sewage Treatment ° I ants
   2, West-Southwsst Treatnant °lants
   3. Sludge Processing and Disposal
                     III. EXISTIM3 CONDITIONS

A. Climate and Topography                                          Ill-l

   I. General Meteorolagy                                          Ill-l
   2. General Topography                                           111-9

3. Seology and Soils                                               111-9

   I. Geological Characteristics
   2. Soil Characteristics

C. Hydrology and Water Duality                                     111-13

   I. Surface Water Hydrology                                      111-16
   2. Sroundwater Hydrology                                        111-16
   3. Water Quality                                                111-19

0. aiology and Ecosystems                                          111-24

   I. Fish and Wildlife                                            111-24
   2. Natural Vegetation                                           111-25
                                      vl

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Table of Con+ants (Con+»d)
                                                                    Page

E. Population and Economics                                         lli-25

   I. Demographic Character Is*Ics                                   llf-25
   2. Economic .Characteristics                                      111-29

F. Land USB Development                                             111-30

   I. Established Uses of Land                                      111-30
   2. Projected Uses of Land                                        111-35
   3. Land Development Potential                                    It 1-35

G, Environmentally Sensitive Areas                                  111-35

   I. Water Resources                                               111-38
   2. Land Resources                                                111-38
   3. Cultural Resources                                            111-38
                      IV.  THE CHOSEN ALTERNATIVE

A. Description of Project Features                                  IV-I

   I. Sludge Shipment and Supernatant Return                        IV-I
   2, Sludge Storage                                                IV-I2
   3. Sludge Application                                            IV-13
   4. Supernatant at +he Gale Farm                                  IV-28
   5. Land Purchases                                                IV-28

B. Environmental Control and Man I tor Ing Systems                     IV-31

   I, Holding and Runoff Basins                                     IV-31
   2, Environmental Monl+orlng Systems                              IV-33


                      V.  ENVIRONMENTAL IMPACTS OF THE PROJECT

A. Soils                                                            V-l

   I. Background                                                    V-2
   2. Erosion of the Project Site                                   V-5
   3. Chemical Effects on Soils at the Project Site                 V-6

8, *fa tar                                                            V-8

   I, Surface Wat«- Quality                                         V-6
   2. Groundwater Quality                                           V-50

C. Air                                                              V-36

D. Health Effects                                                   V-38

   I. Direct Health Effects                                         V-38
                                   vll

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Table of Contents (Cont'd)


E. Noise                                                           ¥-42

F. Significant Socio-economic and Land Use lupacts                 V-46

   I. Socio-economic Impacts                                       V-46
   2. Land Use                                                     V-51

                     VI.  ALTERNATIVES TO THE PROJECT


A. Disposal or Utilization Alternatives                            Vl-l

   I. Incineration                                                 Vl-l
   2. Heat Drying for Soil Conditions                              VI-3
   3. Sanitary Landfill                                            VI-4
   4, Lagoon Ing                                                    VI-5
   5. Ocean Dumping                                                VI-6
   6. Fertilizer Production                                        VI-6
   7. Composting                                                   VI-7
   3. Soil Reclamation                                             VI-8

3. Transporatton                                                   VI-12

   I. Truck Transportation                                          VI-12
   2. Rail Transportation                                          VI-15
   3. Barge Transportation                                         ¥1-15
   4. °lpellne Transportation                                      VI-17

C. System Alternatives                                             VI-18

                    VII.  MITIGATIVE MEASURES


A. Land                                                            Vll-l

3. Water                                                           VI1-2

C, Air                                                             VI1-4

0. Health Effects                                                  VI1-4

E. Recommended Nit I gat Ive Measures                                 VII-5

   I. Sludge Application Rates                                     VI1-5
   2. Land                                                         VI1-6
   3. Water                                                        VI1-6
   4, Air                                                          VI1-7
   5, Health Aspects                                               VI1-8
   6, Plans and Records                                            VI1-8
                                 vlll

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Table of Contents (^ont'd)

                                                                   facg

              VIII.  ENVIRONMENTAL CONSEQUENCES OF THE
                                                                   VIII-I

A. 'jnavoidaSle Adverse Impacts                                     VIII-I

   I. Olstrioution Systems                                         Vlll-l
   2. ^econtourtng                                                 VI I l-l
   5. Human Health                                                 Vlll-l

•3. .Relationship Between Short-tern Use and Lang-tern
   Productivity                                                    VII 1-2

C. Irreversible and Irretr isva&le Commitment of Resources          VI 1 1-2

9I3LIOG1APHY                                                       I

GLOSSARY                                                           3

LIST OF PREPARED                                                  15

DISTSI3UTION LIST                                                  17

APPEND I < A, IEPA mater Pollution Control  ?9rmit

APPENDIX 3, Comments Received on the 3raft EiS

APPENDIX C, Response to Comments
                               tx

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                           UST OF  TALES
        Max I mum Cumulative Sludge Metal  Applications
        for Privately Owned Land

        Composition of Frash,  AnaeroSlcal ly Digested
        Se*aga  S I udge                                               1 1 -2

11-2    <
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List of Tables Hont'd)

                                                                   123?

111-13  Population Projections for Fulton County                    IN-29

II1-14  Trends In Median Family Income 
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List of Tables (Cont'd)

                                                                    "ages

V-5     Water Quality of Reservoirs                                 V-20
                + NO,-N, MH3-N, Phosphorus, Iron,
               al Conform Content of Reservoirs f
V-6     The NO
        and Fecal Conform Content of Reservoirs for
        1971-1976                                                   V-21
V-7     Effluent Quality of Runoff Retention Basins                 V-25-29

V-3     Capacity of Runoff Retention 3aslns and Volume of
        24-Hour Storm Runoff                                        V-3I-33

V-9     The NO 2 *• MO 3 -N, NH 3 -N, and Fe Content of rtel I s
        II, 14, 7, and 17 for 1971-1975                             V-35

V-IO    Concentrations for Various Constituents In Groundwater      V-37

V-lI     Composition of Fresh, Heated, Anaeroblcally Digested
        Sewage Sludge                                               V-39

V-12    Noise Level In d3a of Various Noise Sources as a
        Function of Distance                                        V-42

Vl-l     Annual Capital and Operating Costs for Multiple
        Hearth  Incineration                                         VI-2

VI-2    Digested Sludge Application .Rates                           Vi-IO

VI-3    Land Spreading Costs                                        Vl-ll

VI-4    System Alternatives, System Requirements,  Construction
        Phasing, and Life of Facilities                             VI-20
                               xlil

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                                                                    °aje

l-l      Systam Oparations and Sludge clows                          1-9

ll-l     3roject Site and Surroundings

11-2     Available MSOGC Solids Systeti

1 1 l-l    Variations in Monthly Mean,  Maximum,  ind
        MinNum Precipitation at Peorla Airport Station              1 1 1-2

1 1 1-2    rtind 3os9 at Meteorological  Station 114342,
        ?9oria, Illinois, January 1964
        through December 1973                                       1 1 1-6
1 1 1-3   *Mnd ^ose at Storayo ?asins,  «SDGC
        Fulton County project Site                                  1 1 1-6

I I 1-4   Typical  Stratlgrapnic Profile In the °roject Area            111-10

111-5   Spatial  listr ibution of  Soil  Areas                          111-12

1 1 1-5   Illinois 3ivar and Tributaries Associated with
        the Droject Site                                            111-17

1 1 1-7   Pattern of 3roundwater Plow                                 111-13

111-3   Fulton County Township Population Change, 1960-1370         111-23

1 1 1-9   Fulton Ccunty Land Use,  1968                                 111-33

111-10  tfajor Environmental I y Sensitive Areas In Fulton  County       111-37

IV-i     Sludge Application Fields at  the Project Site and  their
        Runoff Detention 3asins                                     IV-2

IV-2     Unloading Oock, °ipellne Routing and Holding 3aslns         IV-3

IV-3     Past Sludge Shipments between West-Southwest Plant
        Lawndale Lagoons, and Holding Basins at Project  Site        IV-4

IV-4     Total Solids Concentration In Sludge from the lawndala
        Lagoons                                                     IV-7

IV-5     Volatile Solids Concentrations in Sludge from the
        Lawndals Lagoons                                            IV-7

IV-5     Volatile Acids Concentrations in Sludge fro-n the
        Lawndale Lagoons                                            IV-3

IV-7     Alkalinity Concentrations In  Sludge fron th* Lawndale       IV-8
        Lagoons
                                xv

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List of Figures (Cont»d>
IV-3    Tatal Solids Concentrations in Sludge from tne rfSW
        Plant                                                       l ¥-9

IV-9    Tatal Volatile Solids Concentrations in Sludge fr>-n
        the rfSrt *lant                               ~               IV-9

IV-IO   Volatile Acids Concentrations In Sludge fron tne rf3W
        3 1 ant                                                       IV-IO

IV-II   Alkalinity Concentrations In Sludge fron tne ciStf
        Plant                                                       IV-IO

IV-12   Typical Vertical Prof I las of Characteristics of
        Sludge in Holding 3asins I,  2, and 3A, April  1975           IV-I4-I5

IV-13   Traveling Sprayer Applying Liquid Sludge to a Corn Crop
        and Disk Incorporation with  Trailing Supply Hose            IV-IS

IV-14   Injection Unit Showing Three Injectors                      IV-17

IV-15   Periods of Sludge Application to Fields in Fulton County    IV-13

IV-IS   Typical Storm Runoff Detention 3asfn                        lv-32

IV-17   Drainage Control Features of a Typical  rield                IV-34

IV-13   dater Monitoring Locations in Fulton County                 IV- 33

V-l     Major  Interactions of Sludge and Soil  Constituents          V-3

V-2     Senaral Area Applied with Sludge and Water Monitoring
        Stations                                                    V-9

V-3     Variation of Fecal Coliform Concentrations with Time
        for Stations SI and S2                                      V-15

V-4     idater Monitoring Locations at Fulton County                 V-16

V-5     Reservoir Water Temperature and Level  of Dissolved
        Oxygen                                                      V-23

V-6     Sanga of Sound Pressure Levels from Pumps                   V-43

V-7     Single Vehicle Noise Output as a Function of Vehicle
        Speed                                                       V-44

V-3     Cownon Indoor and Outdoor Noise Lave Is                      V-45
                              xv I

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List of Figures Cont'd)

                                                                    ??3?
Yl-l    Surface Spreading Costs                                     ^1-13
VI-2    Truck Costs                                                 VI-14
VI-3    3ai I  Costs                                                  in-l:>
VI-4    System Operations and Sludge Flows                          vi-19
                                xv II

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                       SYH3DLS AND
u       ^u, nicro, uicro:i
*       less than
>       greater than
                        TECHNICAL A331HVI ATIONS

A I                 A luni nun
3OT               3i3CHemfcal oxygen demand
C                 Carbon
Ca                Calcium
CaCO 3             Calciun carbonate
Cd                Cadnlum
CEC               Cation exchange capacity
C I                 Ch I or i ne
Cl-               Ionized ch I or ins
Cr                 Chromium
Cu                Copper
d3a               Adjusted decibel
0,0.              Dissolved oxygen
dt/d              Dry tons per day
E.G.              Electrical conductivity
FC                Fecal col I forms
Fe                Iron
HCI               Hyrochlorlc acid
Hg                Mercury
<                 Potassium
Ib/ton            Pound per ton
•neq               *4! 1 1 laqui valent
•ng                in 1 1 I i gr am
VG                Mil Hon gallons
M30               Million gallons per day
mg/l              miligraTi per I  I tar
Mn                Manganese
N                 Nitrogen
M                 Normality (See Glossary)
Ha                Sod lull
fW 3 -M            Anmon 1 a n I trogen
Vi                Nickel
NOj + N03 -N      Nitrite and nitrate nitrogen
P                 Phosphorus
Pb                Lead
PC3               Poly chlorinated alphenyls
ppm               Parts per million
3&9               Research and development
Se                5el en I um
S0|               Sulfate ion
TOS               Total  dissolved solids
TLffl               Mean Tolerance Llwlt
TSS               Total  suspended solids
TVS               Total  volatile solids
Zn                Zinc

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                   .. •-jVi •:•  - - , - - . t,Tj
                   -• *-.f-t.* W:-3£
       Chapter
       Summary and! Concfu:
•» Vir W.

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                         I-    adk44Attf Atto C
Tne Pulton County  land reclanution project operated  u/  toe iletropolitan dan i tar/
District of Sceatep Cnicajo (&JD3C) is a unique and  d/nauuc  project.   rne pro-
ject oejan in 1)71 and continued today dd an sxatapie of one  id of tne J.3.
.nental Protection Ajenc/ (JSEPA) oas«i upon several  yeara  of  evaluation
field observations  at the project site.  It ia a unique experience to prepare
an Environmental  Iinpact Stateivent (dla) on an oajoi.ij project.   3oe to project
data collection and anal/sis, utaui/ in^icta biat would otuier^ise ^e noted as
theoretical are recorded in tai& docui
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*•   Project History

The first collective action resulting  from  the  long-standing concern of Fulton
County citizens over the adverse  effects  of strip mining on the agricultural
economy was taken in 1970, when the County  Board  of  Supervisors and the States
Attorney's office formed a special citizens committee to investigate the feasi-
bility of a strip-mine landfill and leveling project in Pulton County.   Mhen
it became apparent that some  measures  were  needed to modify the inorganic mine
spoil covering the landfill,  the  use of digested  sewage sludge solids was pro-
posed by MSDGC as a means of  soil rehabilitation  and crop fertilization,  \fter
many investigations, the County Board  approved  a  resolution proposed by the
•lines and Mining Committee to negotiate for a sludge utilization project.

Fulton County had over 45,000 acres of strip-rained land and was adding  to this
at a rate of 1,200 to 2,000 acres per  year.   The  reclamation and productive
agricultural reuse of this land proposed  by the MSOGC would be accomDlished at
no cost to the County, and direct involvement of  County government in the pro-
ject from its conception would offer strong local environmental controls.
Presumably, a project utilizing wastewater  byproducts from an urbanized area
would be tightly controlled by State and  Federal  agencies having the expertise
and authority to ensure environmental  and health  safety.  The County Board chose
to support the Sanitary District  proposal.

During the initial years—in  the  early seventies—of project construction and
operation, some members of the local community  sought injunctions against the
MSOGC and damages for alleged odor nuisance.  However, on February 26,  1976,
the Illinois Pollution Control Board rendered its final opinion in favor of the
MSDGC, removing a limitation  imposed by the Illinois Environmental Protection
Agency (IEP«0 on the amount of sludge  to  be stored in the holding basins.
While the outcome of the litigation is still pending, the MSDGC had discontinued
aerial spraying of sludge and substituted surface incorporation using soil
disking machinery.  The Pollution Control Board still has the Odor issue under
review.

Although the recent conversion to direct  sludge Incorporation into soil has
largely resolved the odor issue,  it also  caused the  reexamination of project
goals for recycling sewage sludge solids  through  crop fertilization. While
spray operations allowed application of sludge  to growing crops, tandem disk
operations pieclude the production of  crops during the year of sludge appli-
cation.  The normal cropping  practice  includes  one application of sludge prior
to preparing the seed bed.  After cropping,  the field would lie fallow  during
the next year allowing sludge applications  of approximately 25 dry tons per
acre.  %t six percent solids, this usually means  five or six applications
during the year.

Economic considerations have  further altered the  original thrust of the Fulton
County sludge utilization project.  Instead.of  returning all of the surplus
supernatant fraction of sludge stored  in  the holding basins to Chicago  sewage
treatment plants, as in the early years of  operation, most of it is now utilized
on the project site by large-scale application  through gated pipe to nay crops.
Nitrogen is removed from the  sludge application site by cropping hay.  Since
                                     1-2

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the sludge supernatant is very low  in sludge organic  solids  (0.1  percent
solids), it contributes considerably less  to soils  rehabilitation,  ^nother
modification to the initial land reclamation and crop fertilization scheme
is the utilization of sludge and supernatant for reestablishing an  original
Illinois tallfrass prairie rather than  for traditional agriculture,  This
effort is presently experimental, as is another activity  involving  reclamation
of unleveled strip-mine gob and slurry  piles by incorporating  sludge through
deep trenching and back-filling.

Ml project activities are under the close scrutiny of the Pulton County Steer-
ing Committee which was established in  1971 to provide public  participation.
The Committee is comprised of public officials, private citizens, and MSDGC
personnel.  Ample surveillance of project  development and operations is  pro-
vided through Committee membership  involving public agencies responsible for
environmental and health safety—the Illinois EPA and Pulton County Health
Department.  Organized citizens groups  also participate.

9.   Pre-existing Conditions

Prior to the strip-mining operations in Pulton County, the existing land use
was row crop production.  The site  was  then gently  rolling with rich deep
prairie soils which annually produced corn and soy  bean crops.  Some cattle
were probably raised in small areas.  Several farms were scattered  within
the site.  The strip-mining operations  destroyed these conditions.  The follow-
ing description of environment is based upon the drastically disturbed land
that was left behind.  Only part of the area was partially reclaimed prior to
purchase by the MSDGC.

    1.  Climate

The Pulton County land reclamation  project site is  located in central Pulton
County, which is situated in the upper  region of the  Spoon River watershed in
west central Illinois (see Figure II-l).   The climate of the project area is
typically continental.  The most probable  weather conditions are a  neutral
atmosphere (Pasquill Stability Class D) and southerly winds at 10.2  miles per
hour.

    2.  Typography

One consequence of the large-scale  strip-mining operations in Pulton County is
an extremely rough topography, presenting  a large challenge to full  land recla-
mation and reuse.  Strip mining has left steeply sloping spoil mounds which
may increase the capacity of storm  runoff  to carry  suspended solids  into
receiving waters.  Mining has also  resulted in a number of long, narrow lakes,
which probably have altered the distribution of thermal energy at the site
and, therefore, the microclimate.   One  early attempt at reclamation  was
carried out by Mr. William Sale.  He bulldozed several hundreds o£ acres of
land in an effort to run a cattle ranch. Another effort was made to  grow
trees on the unreclaimed spoils; neither of these operations greatly modified
the strip-mined land.  At the western perimeter of  the current site  a number
of gob ani slurry piles were left by the United Electric Company at  the
termination of mining operations.   This area is the only area where  acid
mine drainage occurs.
                                   1-3

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    3« Geology and Soils

During surface mining, the overburden soils and cao rock were removed,  the
subsurface of strip-mined areas consists of cohesive fine-grained  soils with
pockets and discontinuous zones of boulder-size rock. The rearranged  and  re-
distributed overburden soils have extremely low permeability, minimizing  the
potential for groundwater contamination from leaching of surface pollutants,
but increasing surface runoff and the potential for surface water  contamina-
tion.  Nevertheless, some zones or layers may consist of broken shale and
sandstone or blocks arranged in a way that increases permeability  to  a  rate
as high as 10-1 centimeter per second,  \lthough such zones are seldom
continuous for more than short distances, they are considered important near
reservoirs.

In areas where strip-mining has occurred, the glacial soils are covered by
loess.  This material has low permeability and is subject to erosion, depend-
ing on vegetative cover and other conservation practices.  Decomposition  of
mineral deposits such as black shale, which are exposed by strip mining,  create
high background levels of trace elements, complicating the assessment of  water
pollution from sludge.

While most strip-mined areas are characterized by acidic soils and surface
waters, Pulton County's calcareous soils are near-neutral to alkaline.  This
characteristic is highly significant because it leads to the immobilization
of many hazardous metals that might otherwise be available for plant  uptake
in an acidic environment.  Ttds is true both for heavy metals existing  in the
place land or mine spoil and for those added when sludge is applied.

    4.  Hydrologyand Water Quality

Most of the surface water at the project site is drained by Big Creek and Slug
Run to the Spoon River, a tributary of the Illinois River.  Steep  slopes,  -sparse
vegetative cover and poor soil permeability create high runoff volume and
velocity, promoting erosion and stream or lake siltation which can adversely
affect aquatic biota.

Determinations of baseline surface water quality before the sludge utilization
project began show the overwhelming influence of strip mining on the  quality
of water in streams and reservoirs at the site.  Pre-project levels of  sulfate,
copper, lead, iron and manganese in streams and reservoirs, which  violated
State standards, reflect the composition of runoff over strip-mined land,
High concentration of ammonia nitrogen and fecal coliforms in Big  Creek before
the project began, often in violation of Illinois standards, illustrate the
strong influence of pollutant sources upstream from the project site, includ-
ing effluent from the Canton aewage treatment plant.

Groundwater quality reports for the project area before the project began
operations indicated that concentrations of chromium, copper, iron, lead,
manganese, and nickel were within ranges found elsewhere in the United  States.
Baseline ranges of pH and zinc concentrations were close to national  values.
                                   1-4

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but those oC chloride, sulfate, calcium, magnesium, and  sodium were higher,
indicating high dissolved solids or salt concentrations, at  least with  refer-
ence to standards for groundwater used as a water supply.  The chemical
composition of groundwater was influenced by the geochemical characteristics
of abandoned strip mines, such as heavy metals  in exposed black shale.   It is
important to add that most municipal groundwater supplies in the project
vicinity are obtained from deep wells unaffected by surface  land disturbance.
Mao, low soil permeability makes groundwater resources  much less vulnerable
to sludge leachate.

    5. Landuse and Economic Conditions

\ccording to present trends, demand for farmland in Pulton County has
remained high.  Local agriculture is changing in composition.  Dairy, winter
wheat and poultry production is declining, while corn, soybean, swine and  beef
cattle production have increased.  Thus, future land  use in  the project area
will probably be centered more on forage crops, pasture  and  feedlots than  on
plant or animal produce.

Suitability of strip-mined land in the project  area for  various uses is affect-
ed by topography, soils, and drainage.  Problems of settlement with unconsoli-
dated soils in the strip-mined sections of the  project site  could make  it  more
difficult to build hard-surface roads, underground utilities, and residential
or industrial structures.  Nearby developments  on similar mined land, however,
demonstrate the feasibility of construction on  the MSOGC property.  Current  levels
of available plant nutrients and organic matter make  these soils unsuitable
for intensive agriculture.  Without land reclamation  utilizing sewage sludge,
any row-crop production on formerly strip-mined fields would depend on  liberal
use of costly chemical fertilizers, extensive soil conditioning, and rigorous
conservation practices.  Steep slopes and severe problems of access in  unreclaimed
strip-mining areas have caused failure of previous attempts  to manage timber
crops in Fulton County.

The recreation potential of the project area has been limited by poor accessi-
bility (at legist until the proposed Interstate  Highway is completed} and
competition from the diverse attractions in nearby Spoon River Valley,  along
the Illinois River, at Dickson Mounds State Park, and in the numerous former
strip-mined areas where recreation uses are of  particular interest.  Some
hunting and fishing activities have occurred.  One area  in particular contain-
ed potholes which attracted migratory waterfowl.  Recreational potential
for nearly all the MSDGC property is limited by the existence of an extensive
above-ground sludge pipeline system which is subject  to  vandalism.  That
vandalism has prompted the MSOGC to close all of their property other than the
"Fulton County Conservation Area" to public access.

Large tracts of equally available and suitable  land in Fulton County are
expected to keep land values low in the project area. According to tax
assessment records, reclaimed strip-mined lands which are used productively
have been valued only 25 percent more than unreclaimed lands.

C.  Existing Project Operations

Project construction began in January 1971.  Approximately 4,344 acres  of  the
15,529-acre project site (August 1977) have bean recontoured and graded to
create 43 fields suitable for sludge application and  row crop agriculture.
                                   1-5

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Sixty-one retention basins were constructed  to  contain stor:nwater  and erosion
including sludge runoff from application  fields.   Pour large holding basins
having a combined capacity of  8 million cubic yards  were constructed to
provide for the interim storage of  liquid sludge  and sludge supernatant.

To protect against environmental degradation possibly resulting from the pro-
ject, sludge h3lding basins were lined to prevent seepags to groundwater,
control berms and retention basi.13  were installed on sludga application fields
to contain all field runoff and control basin effluent quality, and the fields
were graded and provided with  siltation basins  to reduce runoff velocity,
erosion and sedimentation. The effectiveness of envirortnental control systems
and the environmental soundness of  projsct operations are monitored intensively
by the State of Illinois and the County.   Each  step  of the project is monitored
to assess impacts on the environmsnt.

The operations begin when anaarobicaliy digested  sewage sludge from the MSDGC
West-Southwest Treatment Plant or aged sludge from the Lawndale lagoons, or a
mixture, is barged approximately 130 miles from Chicago down the Illinois River
to the dock at Liverpool in Pulton  County.  In  1977, shipments averaged 200 dry
tons per day or one-third of the entire MSDGC sludg? output.  The  sludge is
pumped out of barges ana relayed 10 miles by booster pimps to the  project hold-
ing basins for storage.  Dredging equipment  is  used  to withdraw sludge from the
basins.  The withdrawn sludge  is pumped and  distributed to the application
fields at an average rate of 23 dry tons  per acre (1977), using a  modular pipe
network installed on the ground surface.   The pumped mixture usually has a
solids content of approximately 5 percent.  % major  portion of the sludge
supernatant previously was barged back to the head end of tha West-Southwest
Treatment Plant or to the Chicago Lawndala lagoons.   In 1976, the  MSK3C modi-
fied its procedures providing  for the large-scale application Df supernatant
to 17 additional fields at the project site, comprising 1,334 acres.   Maxiium
permitted rate of supernatant  application is 117,000 gallons per acre per year,
which provides 120 pounds of available nitrogen.   In practice, the soil hyirau-
lic capacity has been a more limiting factor.

Sludge that is shipped to Pulton County must meet standards set by the Pulton
County Health Department.  Prior to November 8, 1975,  the following standards
applied:

    1.  Volatile acids—no more than five 24-hour composite samplas taken
in a 30-day period shall exceed 300 milligrams  per Litar

    •*"  fUjtalinity—no more than 5  percent of the 24-hour composite samples
taken in ""a 'W-^ay period shall be lower than 2,590 milligram per liter

    3.  volatile solida—no 24-hour composite sample shall be more than 62
percent, of total solids

    4.  eg—no 24-hour composite sample shall be  less than 6.9.

%s of Nay 1975, sludge from the Lawndale  lagoons  complied with all standards
except for alkalinity, which was deficient 9.5  percent of the time.  Sludge
from the West-Southwest plant  complied with  the volatile acids standards, but
                                    1-6

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was iefiaiant 3.3 oaccant of tha  tine  for  total  volatile solids,  1.4 peccant
of the tina for alkalinity, and 1.3 -percent  of  tha  tina  foe  pH.

ay ?»vetib«c 1975, the Pulton County Health oeoactnent recognized  that sludge
storage for long periods of tine  casults  in  volatilization of innoiia and
consagusnt lecreasas in alkalinity, and existing regulations wars perhaps
too stringent in view of tha fact that sons  sludge  shipped to Fulton County
had been in storage in tha Lawndala lagoons  for  pariods  ranging up to 15
years.  %t that tine, thsrafora,  tha volatile acids and  alkalinity standards
wars changed to tha foil owl 13.

     *   If volatile aci3s ace lass than  100 nilligraffls  par  litar than
         the alkalinity cannot be lass than  1,500 uilliiciira oer  litar
         If volatile aciJs aKseal  130  mUi^rans  oec  liter  then tha
         alkalinity cannot be lass than  2,500  uilliirana  oer  liter.
Since the staniar3s ware amsitel,  thace have been  no  violations.   Sluice
^jality hsa actually  itiocove3  since 1974|  alkalinity  stanlarJs haJ not
tsean violate! since oecetibar 1,  1974? OH has naver been  Saficiant  sines
Novattoei 26, 1973; ani  tha standard foe total volatila soliis  has  baen  nat
since *t>venbec 14, 1)73.

Ite Fulton County Board repaalai thair ordinance on Sludge  HanJlinj in  July
1980 and no longer has  any type  of controls over sludga  handling x sludge
quality.

The sludie is aooliad to tha soil  by a tractor -drawn  tandsi disk incoroorator.
The 3isk incorporator applies  3lud|3 to the entire olow  layer  of tha soil,
using a disking •nachiie with a distribution nanifold  that iirects  sludge to
each disk while tilling tha soil.

Super natant is apolisd  through a gated irrigation  oipe.  "*Lth  the  gatad irri-
gation oioe, the oipa is laid  on high ground and siudga  supernatant is  pulped
through tha slots, fortiiig a downslooe shaat flow  across tha application fiaU.
Harvesting thcaa hay crops during  the or i nary growing samson ranovas aKcasa
nitrogen.

Annual sludge application catas  ware originally proposed to be 75  dry tons
par acra in the first year of  project operations,  tapering  down to 25 dry
tons par acre by the  fifth yaac  and continuing  at  that rats,   tta  actual  average
rate of sludjt application has incrsased  fro?n 2.7 dry tons  per  acra in  1972 to
23 dry tons get acre  in 1977.

In son* instances, sludge has  bean applied to original rjlaca land  at reclana-
tion rather than agronomic rates.  it»a illinais Bnvironnental  Protection
Agency (ISP&) defines agronotiic  rat 23 to ba approxinately 5-12  3ry tons par
acra per year.  This practice  is peruitted by tha  I SPA where there is adequate
environmental aonitoring.  In  application  fialds praviously strip  lined,
annual rat as of application reached 60 dry tons per acra in 1976.   9y lata
1977, only one application field designed  to utilize  sludge supernatant:
was in use; supernatant is required to ba  applied at  the nitrogen  agronoiic
rats for the hay crops harvested.

\ sludgs analysis program is designed to ensure adequate treat Tien t of sludge
bs for a shipment to "tha holding basins.  Tha water uonitocing systei includes
                                   1-7

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sampling from 26 walls, 1 spring, 11 stream stations, 10  reservoir stations,
and 61 runoff retention basins.  The soil monitoring program  includes  sampling
of the olow layer (0-5 inches) and soil boring to bedrock taken and analyzed
for physical and chamical parameters.  Sampling of aquatic biota  as well  as
crop leaves, grain, and tissues of livestock test herds is being  conducted
to determine effects of sewage sludge application.  In addition,  a portable
meteorological station was set up close to the holding basins to  measure
air temperature, wind speed and direction, relative tumidity, and rainfall.

Beginning in 1971 through the present, project operations have been performed
pursuant to permits issued by the Illinois Enviroonental  Protection Agency
and the Pulton County Health Department.

The Pulton County Planning Commission reviews all land use plans  and requests
.todifications or gives approval.

0.   Alternatives to the Project

The sludge processing and disposal methods practiced by the MSDGC represents
nearly the full spectrum of system alternatives.  Ten system  options were
derived by the MSDGC from various combinations of subsystems, foe sludge
dewatering, stabilization, disposal, utilization, and transportation,  The
ten systems chosen for analysis are presented in a cursory manner in Figure
1-1 because they are only peripherally related to actual  impacts  at the
site.  They do provide information concerning options and relative risks.

The cost-effectiveness of a system represents a balance between capital,
operating and maintenance costs, system reliability, environmental impacts,
and costs for measures to prevent or mitigate potential environmental  hazards
oc impacts.  The only component in this balance for which actual values can
be assigned is total annual costs.  Environmental impacts can be  assessed
only in terms of relative potential impacts from each system  alternative,
as the state of the art has not progressed to the point of reliably assigning
monetary or other exact values to environmental effects.

While either incineration and sanitary landfill of ash or direct sanitary
landfill of dewatered sludge might appear to be attractive alternatives
to land application, several overriding considerations are not highlighted
here.  The high energy requirements for incineration and  potential emissions
of volatilized hazardous substances such as cadmium tend  to outweigh the
lower costs; also, this alternative is effectively unavailable in the Chicago
region due to fuel and air quality restrictions.  New sanitary landfill sites
in the Chicago region are practically unobtainable, and they  waste the nutri-
nutrients in sludge which can be recycled safely and efficiently in a well-
designed, well-managed land utilization project.

E.  Existing golicea _and recommendation of	Federal	Agencies

    1.  Pppd and Drug administration

The Pood and Drug Administration (FDA) of the U. S. Department of Agriculture
                                   1-8

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                                                     or rill,
                                                     200 rt)
                                        200 i

 4    C*fitr1fufl« OtmUrlng  _> H«t Drying  ——^ Ftrtl 1 (j«r Ule

 $    CentrtfMW OfMUrli*  —^iBctBerrtlon  f^j-  „,, ^M
           (m

    ->C«titr1fu9« OtMttHnf	^ Ht*t Drying 	^ Fertilizer Slit

 7|—t>F

                                                       I HI /
   -^Ctntrtfugt D«Mt*r1ng - frNttt Drying - fcFtrtlltier Salt
           (4Sidt/ Fl suttWi-Cancfntrt tl M
        (1.143 dt/d)
                              Air Drying _
                              HI %tnt teds
        }
                                                       (truck)
                                                             -^UnlUry Landfill
10
            OlftStiM
         (93 M/d)
            D1|nt1on
        (Hi dt/d)
                            on S*n«l IMS

                            Air Drjrlng  .
                            on Und B«dS
C*ntr1fug*_|^

            (inick  '
	Jw rttl.
	^ZQOBI)
                                                                 UM
                                                                 Of DcMtirtd Jludjt
           (US «t/«)
                                         (bargt
                                         200 >1)
                                           (12? dt/d)
            OIltHtmtlan


       •Mind »wl(ci{1on of Liquid Sludge
                   («» dt/d)



           Uruekl*  S*-m" LIBdfn'
                  OmmrllH    > Heit Drying
            (4«««>
      Figure 1-1.   System Operations  and Sludge  Flows  (MSDGC  1975a)
                                       1-9

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has primary responsibility for ensuring  the safety  and wholesomaness of the
nation's food supply.  Specific FDA research  is directed  at  preventing levels
of sludge contaminants in soils and foods  from becoming sufficiently high
to subject consumers to unnecessary risks  or  necessitate  large withdrawls
of land from food production.  Specific  FDA concerns  and  recommendations are
summarized below.

The PDA has assigned first priority in its heavy metals program to mercury,
lead, cadmium, arsenic, selenium, and zinc in foods.  The PDA presently re-
gards cadmium and lead as the metals of  greatest concern, while more infor-
mation is needed on the content of  mercury, arsenic,  and  selenium in sludge
and food to properly assess their hazard.

Repeated application of cadmium-containing sludge causes  a build-up of cad-
mium in the soil, according to the  FDA,  and many crops, including the grains,
take up cadmium from the soil.  Because  approximately 23  percent of tha total
cadmium intake in the diet comes from grain and cereal products, the FDA
believes that an increase of cadmium in  grains could  lead to a significant
increase in the cadmium burden from our  food  supply.

With regard to pathogens as a possible hazard, the  FDA believes that the
development of a cycle with ascarid eggs (intestinal  worms)  in sludge is a
potential problem.  Such a cycle would begin  with increased  intake of ascarid
eggs by a community ingesting food  grown on sludge-amended soils, increased
pathogens discharged into the sewage system,  and increased numbers of eggs
surviving sewage treatment and re-entering the food chain through application
of sludge to agricultural land.  The PDA also states  that Salmpnella, other
bacteria, and pathogenic viruses, are a  cause for concern with siudgV-treated
soils and crops.

    2.  U.S. Department of Agriculture

The U.S. Department of Agriculture  (USDA)  states that the application of sludge
to agricultural land which may be'used for crop production,  must be accomplished
so that cropland resources are protected and  harmful  contaminant!! do not accumu-
late in the human food chain.  Specific  suggestions of the USDA have been incorpo-
rated in the development of the USEPA Technical Bulletin  on  Municipal sludge Manage-
ment.  This was published in final  form  on November 2, 1979  and its recommendations
are presented below.  Limits are based on  experiments directed at the determination
of heavy metal levels toxic to plants or absorbed by  plants.   These levels may
not constitute appropriate levels for human intake  and should be subject to revision
as new information becomes available.  Levels of metal additions apply only to
soils that are adjusted to pH 6.5 or greater  when sludge  is  applied, and managed
at pH 6.2 or greater thereafter (soil pH determined by 1:1 water, or equivalent
method).
-«_

        Sludges having cadmium contents  greater than  25 milligrams
        per kilogram or 25 parts per million  (dry weight)  should
        not be applied to privately owned  land unless their
        proportions of cadmium to zinc are less than  or equal
        to 1.5 percent.  This safeguard  is designed so that
        visible damage to plants from zinc toxicity would serve
                                   1-10

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as a warning of, or deterrent to, excess accumulation
of cadmium.  Sludge having a greater proportion of
cadmium as compared to zinc should not  be apolied on
a continuing basis unless there  is an abatement orogram
to reduce concentrations in the  sludge  to acceptable
levels.

\mual sludge application rates  on privately owned  land
should be the lower of the nitrogen requirement of
the crop (inorganic nitrogen + 20 percent organic nitrogen),
defined as 100 percent of the crop requirement when
sludge is incorporated into the  soil and 150 percent of  the
crop requirement when applied to the soil surface or the
cadmium loadings on land, which  should  not exceed 1 kilogram/
hectare/year from liquid sludge  or 2 kilograms/hectare/year
from dewatered sludge.

No greater amounts of sludge-borne ntetals may be applied
to privately owned land than those shown in the Coilowing
table.

               Maximum Cumulative Sludge Metal Applications
 Table i-l.    for Privately Owned Land (kilogram per hectare)

Metal
Lead
Zinc
Copper
Nickel
Cadmium
Soil Catioa
0-S
500
250
125
50
5
Exchange Capacity
5-15
1,000
500
250
100
10
(meq/lOOg)*
15
2,000
1,000
500
200
20
*Determined on unsludged soil by the method utilizing pH 7
ammonium acetate for a weighted average to a depth of 50
centimeters (milliequivalents per 100 grams)

On land dedicated to sludge application (such as publicly
owned or leased land, up to five times the amounts of
sludge is mixed into the 0-15 centimeter layer of surface
soil.  Where deeper incorporation is practiced, propor-
tionally higher total metal applications may be made.
If the sludge metal application rates on land dedicated
to sludge application exceed those maxima recommended
for privately owned land, metal analysis should be
                           1-11

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         provided to purchasers of marketed oroducts grown  there.

         Growing leafy vegetables on sludge-treated land  is not
         recommended without monitoring the metal contents  of  the
         crop.

         Sludge should not be applied to privately owned  land
         having soils with less than 50 centimeters of depth.

    3.   U.S. Environmental Protection ftgency

\s stated earlier, on November 2, 1977, the USEPA published the  final  version
of "Municipal Sludge Management* Environmental Factors."  This document  is a
Technical Bulletin for use in the USEP\ Construction Grants Program
and is to be used in an advisory manner.

Recommendations relevant to indirect health effects are summarized
as follows:

         Although absolute numerical limitations on heavy metals are
         not appropriate, the project should conform to any limitations
         established by the FDA or USOA.   If the sludge is  relatively
         high in heavy metals, it is prudent to pretreat  the contribu-
         ting industrial wastewaters, maintain a pH above 6.5  in the
         combined soil and sludge, grow grain crops as opposed to
         leafy vegetables, and intensify heavy metals monitoring in the
         sludge, soil and plant tissues.

         Sludge aoolication rates should be controlled so that the
         total amount of nitrogen added and available to  plants  is  no
         greater than twice their nitrogen requirements for  growth,
         including that mineralized from the soil, the inorganic
         sludge nitrogen, and organic sludge nitrogen based  on a
         mineralization rate of 15 to 20 percent for the  first growing
         season, and 3 oercent of the residual sludge nitrogen for
         three subsequent growing seasons  (volatilization of ammonia
         from surface-applied sludge should be taken into account).

         When sludge is used for agricultural purposes, it  is  necessary
         to achieve pathogen reduction beyond that attained  by stabili-
         zation.  Methods reported as successful include  pasteurization
         for 30 minutes at 70 degrees Centigrade (C); high pH  treatment,
         typically with lime, at a pH greater than 12 for 3  hours;  storage
         of liquid digested sludge for 60  days at 20 degrees C or 120  days
         at 4 degrees C; complete composting at temperatures about  55
         degrees C as a result of oxidative bacterial action and curing
         in a stockpile for at least 30 days.

         Because specific organisms may survive in the soil  for  extended
         periods, sludge-treated land should not be used  for growing
         human food crops to be eaten raw  before three years after  the
         last sludge application.  For orchard crops eaten  raw,  heat-
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         dried sludge can be usad provided the pro j act  is approved by
         the
         If direct contact occurs betwean sludge and a growing crop,
         sludge should be negative for Salmonella and tecaris ova
         if the crop, although normally cooked in the RomsTEefore
         consumption, is to be marketed without processing which is
         lethal to pathogenic microorganisms and parasites.

         Forage and pasture crops should not be consumed by animals
         while these crops are physically contaminated by sludge.
         Grazing animals should not be permitted on pastures before
         thorough removal of sludge, by rain or some other means.
         When there is a risk of direct ingest ion of the sludge by
         grazing animals, the lead content of the sludge should not
         exceed 1,000 milligrams per kilogram (dry basis) and the
         cadmium content should not exceed 20 milligrams per kilogram
         (dry basis).

New regulations addressing Cadmium loading rates, PCS concentrations, pathogen
levels, and public health considerations were published September 13, 1979.
Oititled "Criteria for the Classification of Solid Waste Disposal Facilities
and Practices", these regulations superseded the above-nentioned recommendations
in the categories that it addresses.  These regulations set forth the requirements
and criteria for applying municipal sludge to land for agricultural purposes.
Compliance with thesa criteria is mandatory under Section 405 of the Clean Water
*ct.  It should oe noted that those portions of the regulations dealing with
sludge application are designated as interim-final regulations.  This means
that they are legally binding but sub j act to change based upon additional public
comment.

\ summary of these regulations as they pertain to the land application of sludge
is presented below.

    40 era 257 - Criteria for Classification of Solid waste
    Disposal Facilities and Practices

        a.  Cadmium - The regulations put forth two approaches to cadmium control.

            (1)  this approach involves disposal site management controls and
standards governing cadmium applications.  It requires that the soil/si udge
mixture pH be 6.5 or greater at the time of each sludge application.  There is no
oH requirement if the sludge contains concentrations of cadmium 2 milligrams per
kilogram (dcy rate) or less.  For application of sludge to soils that will be used
for the production of tobacco, leafy vegetables, or root crops grown for human
consumption, a mass loading limit of 0.5 kilograms cadmium per hectare may not be
exceeded.

foe all other food chain crops the annual cadmium application rate may not exceed:
                                 1-13

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                                              ANNUAL CADMIUM
                                             APPLICATION RATE
                   TIME                     [KILOGRAMS PER HECTARE)

                Present to
                June 30, 1984                          2.0

                July 1, 1984 to
                December 31, 1986                      1.25

                Beginning
                January 1, 1987                        0.5

Limitation on cumulative sludge cadmium applications are as  follows:   5  kilograms
per hectare, where soil cation and exchange capacity (CBC) is  less  than  5 milli-
equivalents (meq) per 100 grans} 10 kilograms per hectare where CEC is between  5
and 15 meq/LOQ grams and 20 kilograms per hectare where CBC  exceeds 15 raeq/100
grams.  If background soil pH is less than 6.5, cumulative sludge cadmum limit
is 5 kilograms per hectare regardless of cation exchange capacity unless the pH
is adjusted to and maintained at 6.5 or greater whenever food  chain crops are
grown.

            (2) The second approach involving cadmium limits is known  as the "con-
trol site" or ''dedicated site".  This concept is analogous to  the Pulton County
project that is under the direction of the Metropolitan Sanitary District of
Greater Chicago.  Under this management scheme, there is no  cadmium mass loading
limit.  However, the owner or operator must maintain sludge/soil pH of 6.5 or
greater when the sludge is applied or when crop is planted,  whichever  is later?
this pH level must be maintained whenever food chain crops are grown.  Also, the
owner or operator of the site must develop a facility operating plan which shows
how animal feed will be distributed to prevent ingestion by  humans  and describes
measures to be taken to safeguard against possible health hazards from cadmium
in the food chain which may result from alternative land uses.  This latter aspect
is basically a requirement that future property owners are notified by a stipula-
tion in the land record or property deed stating that the property  has received
sludge at high cadmium application rates, and that food chain  crops should not  be
grown.

        b.  Polychlorinated Biphenyls (PCB's) - For municioal  sludges  containing
PCB's in concentrations greater than 10 milligrams per kilogram (dry weight), the
regulations require that such sludge be incorporated into the  soil.  Incorporation
into the soil is not required if assurance can be given that the PCB content in
the animal feed grown is less than 0.2 milligrams per kilogram or that milk from
animals grazed on land that has been amended with sludge has less than 1.5 milli-
gcam per kilogram of PCB.

        c.  Pathogen Levels - There are two land application approaches outlined
in this portion of the regulation, depending.on the type of  crops grown.

            (1)  Septage (solids from septic tanks) may be applied  directly to
agricultural land provided that public access is restricted  for 12  months and
that grazing by animals whose products are consumed by humans  is prevented
for at least one month.  Similarly, sewage sludge that has achieved a  level of
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pathogen reduction comparable to anaerobic digestion, may be applied directly
to agricultural land, provided that public access  is controlled  for at  least
12 months and grazing is prevented for at least one month.

            (2)  If sewage sludge or septage  is applied to  land  that is used for
crops directly consumed by humans, a stabilization process  equivalent to heat
drying or thermophilic aerobic digestion must nave been used.  This level of
treatment is not required if there is no contact between the solid waste and the
edible portion of the crop.

        d.  Other Criteria - It is imnortant  to remember that all of the criteria
and regulations found within 40 CFR 257 will  apply to land  application  programs.
The additional criteria describe performance  standards and/or operating techniques
to protect air and water quality, sensitive land and biological  resources, and
public health and safety.  For example, in flood plains, the criteria would oro-
hibit land application of sludge which would  restrict the flow of the base (100
year) flood plain, reduce temporary water storage  capacity, or result in a washout
of sludge that would threaten human life, wildlife, or land or water resources.
The criteria also address endangered species, oollutant discharges, underground
sources of drinking water, and open burning.

4.  Council for Agricultural Science and Technology

ha an aid in addressing questions concerning  heavy metals arising from  the
USEPA proposed Technical Bulletin, the USEPA  requested that the  Council for
Agricultural Science and Technology (C^ST) create  a task force to review
recent research on the application of sludge  to cropland and to  prepare a
consensus statement on the potential of hazards of heavy metals  in sludge
to plants and animals.  A report was prepared by a group of 30 scientists,
most of whom have been actively engaged in research on the  application  of
sewage sludge to agricultural land.  Conclusions and recommend**:ions con-
cerning specific metals evaluated in this report are summarized  below.

        Manganese, iron, aluminum, chromium,  arsenic, selenium,
        antimony, lead, and mercury produce relatively little
        plant accumulation or hazard to crop  production when
        sludge is applied to the soil because all  either have
        low solubility in slightly acid or neutral, well aera-
        ted soils or, as with selenium, are present in such
        small amounts that their concentration in  soils is
        quite low.  The availability of these elements to
        plants is relatively low, and little  uptake by plants
        occurs.

        Cadmium, copper, molybdenum, nickel,  and zinc can
        accumulate in plants and may pose a hazard to plants,
        animals, or humans under certain circumstances.

        In general, the increase in metal contents of plants
        is greater from the initial sludge application than
        from subsequent applications.
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CAST recommendations are as  follows:

            To limit cadmium accumulation  in food  supply
            from sludge treated  land to a  relatively  low
            level, maintain  soil pH at or  above 6.5,  grow
            crops which tend to  exclude cadmium from  the
            whole slant or from  reproductive tissue,  apply
            low annual rates of  cadmium and use sludges
            which have a low cadmium concentration, and/or
            grow non-edible  crops.

            Maintaining soil pH  at 6.5 or  greater  should
            also prevent zinc and nickel from posing  a
            threat to plants and/or the food supply.  While
            this results in  greater solubility and availa-
            bility of molybdenum than would occur  at  lower
            pH values, sludges are usually very low in
            molybdenum and that  element would probably not
            pose a serious hazard to the health of grazing
            animals.

            The long-term Litoact of repeated applications
            of sludge on iietal concentrations in the  food
            supply coull be  reduced substantially  by  growing
            corn and other selected crops  harvested for  their
            edible seeds or  fruits in place of forages or
            leafy vegetables,

Hie USEPA recognizes that these  recommendations are based upon applications to
agricultural lands which have not been strip mined.   In  the case of Pulton County,
where two goals are being addressed, land  application and reclamation,  the USEPA
proposes that the land application program be consistent with the Criteria for
Classification jf Solid Waste Disposal Facilities  and Practices to the  fullest
extent possible.  Should occasional variances occur,  access to land should be
controlled and both the site and crops monitored to detect potential adverse
impacts.  Compliance with the alternate cadmium control  procedures would  be
required.

P.  awir onmsnta 1 I gpact 3

    1.   Land

The effect of sludge aoolication to the spoil soils of Fulton, County in conjunc-
tion with laveling operations has a beneficial impact.   The positive effects to
the soil result mainly from  the  high content of organic  matter in the sludge.

Increased aggregate stability resulting from the addition of organic matter
results in decreased erosion potential.  Organic matter  also orovides a matrix
for ionic loading and water  absorption, and plant  nutrients for increased
agricultural productivity.
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Although increased soil organic matter  reduces erosion  potential,  the degree of
soil erosion depends to a greater extent on  the contour of  the  land.  Early
designs based upon spray operation required  convex shaped fields which  promoted
runoff, especially along field perimeters.   Redesign  and operational ^edifications
have rectified the initial deficiencies.   Uso, soray irrigation is no  longer  usad.

The MSOQC has been constructing supple-rental siltation  basins to retain silt-laden
runoff.  However, a lack of vegetation  on  control berns, in oraoerly structured
drainage channels and basin dikes ***•  "--tributed to  severe guiiv  eros'->".
accelerating siltation and therec, tto^,  g  this added  v.aoacitv ...r concLjt.'in-j
soil loss and sedimentation in runoff retention basins.  Available records
indicata only sporadic cleaning ci' siltation basinsj   it is difficult to determine
whether this reflects poor maintenance  or  poor record-keeping.   M30GC records  are
also sparse in documenting repairs to drainage pipes, which have on occasion become
damaged or clogged, obstructing discharge  from siitation basins into run-off reten-
tion basins.

High rates of disk incorporation of sludge contribute to soil erosion by necessi-
tating multiple passes of tha incorporator during the primary growing season,
obviating the Possibility of growing a  crop.  In alternate  ysars,  when  a field
lies fallow without even a cover crop and  sludgs is applied,  soil  erosion will
increase considerably.

It is uncertain as to what proportion of accumulated  toxic  metals  are actually
available and therefore detrimental to  crops.  Monitoring at  Fulton County has
shown that metal uptake by crops presently corresponds  more to  the amounts of
sludge applied in the current growing season than to  the amounts accumulated from
previous years.  Because the MSDOC no longer produces a crop in the alternate
years of sludge application, the availability of metals for uptake should be re-
duced considerably in the intervening years  when crops  are  grown.

    2.   Water

Pre-project investigations show that surface water quality  was  exceedingly poor as
a result of runoff and leachate from strip-mina spoil and,  in Big  Creek, upstream
pollution sources including effluent from  the Canton  sewage treatment plant.

High background concentrations of metals and nutrients, which are  not attributable
to MSDGC operations, may allow small contributions of sludge  constituents to be
masked and thereby go undetected,  At the  same time,  poor upstream water quality
vastly decreases the likelihood of such contributions resulting in the  further
deterioration of water quality.

        a.   Surface water impacts - Surface water quality  is monitored at
stream and reservoir stations as well as runoff retention basins.  A comparison
of Illinois water quality standards to  the quality of stream  and reservoir samples
during earlier and more recent stages of the project  shows  that surface water
quality has not significantly deteriorated.

The downstream station located on Big Creek  demonstrates better overall water
quality than tine station located upstream  on Big Ccsek before it enters  the pro-
ject area.  This indicates that dilution and instream purification occur in this
                                    1-17

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stretch of Big Creek.  Mthough increased levels of  sulfate and toted dissolved
solids occurs at 52, this has been attributed  to previous strip mining  opera-
tions performed at the site.  These operations brought  in new soil materials,
including pyrite, shale, and limestone to the  surface.

Observations at the site indicate that the greatest  shortcoming of the  runoff
basins is their inability to contain storm runoff and intermittent rainfall  of
approximately one to two inches per day which  may occur daily over a period  of
about a week.  These conditions lead to hydraulic soil  saturation, during which
time the soil cannot accommodate recycled runoff basin contents.  This  circum-
stance has sometimes led to emergency releases of runoff basin effluents  that
could not meet effluent standards.

Examination of the logs of runoff basin discharges reveals faulty operating  proce-
dures.  Basin discharge gates that have been left open during prolonged periods
of heavy rainfall, allowing the free flow of runoff, sometimes result in  substan-
dard effluents entering surrounding surface waters.  Records produce no mention
of backpumping retained runoff onto application fields, although this procedure
was intended in the project design and backpumping records were required  by  the
initial IEP^ operating permit.
Effects resulting from underdesigned and poorly maintained runoff basins are prob-
ably highly localized and confined within the project site.  Project operations
through 1977 do not appear to have made any significant  impact on surface water
quality.

        b.  Groundwater impacts - Trend analyses were made for nitrate  and
nitrate nitrogen, ammonia nitrogen and iron in  four wells selected  to represent
background groundwater quality ("without the project*).  Data were  examined  to
investigate possible seepage from the sludge holding basins and possible ground-
water contamination from sludge application. The data were found to indicate
increasing nitrite and nitrate levels in one well only,  and this was not attribut-
able to project operations.

Fecal coliforms, trace elements and other chemical concentrations in wells
remain close to the pre- project conditions.  The variations in groundwater quality
at most stations are comparable and are probably influenced by the  geochemical
characteristics of abandoned strip mines.  Groundwater quality has  apparently re-
mained unaffected at this stage of the project.  Therefore, soils appear to  be
functioning well as a biochemical filter for removal, conversion, and fixation of
sludge.

    3.   %it

Impacts on air quality may result from aerosol ization and volatilization of  sludge
constituents, possibly presenting odor problems.  This section summarizes odor
complaint data and the relative odor potential of the sludge holding basins  and
alternative application techniques.

Since project initiation, complaints of offensive odors  have arisen fro* citizen*
near the project site,  the Midwest Research Institute (MRI), under contract with
Pulton County Health Department, designed a program to verify the origin of  these
complaints.  The frequency of odor complaints has been found to be  decreasing each
                                    1-18

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year.  Although acne localized odors can be detected  under  special  conditions,
modified application techniques may have reduced  the  incidence of odor  generation.
This can be attributed to the elimination of  the  spraying operations.

     4.   Health

Stabilized sludge contains potentially toxic  substances  such  as heavy metals and
pesticides, and may also contain human and animal pathogens and parasites,  al-
though usually in very low concentrations.

The presence of animal virus downwind of the  sludge spraying  source during  active
application periodr was found not to be independent of background conditions.
There is evidence which indicates that the spray  application  was not the only
source of virus. Bacteria concentrations decreased exponentially with distance
from the spray source.  Wind velocity, temperature and relative humidity seemed to
have little influence on downwind concentrations  of bacteria  (USBPA, March  1979),

The spraying operations terminated in 1976, except for one  research field run by
the University of Illinois.  Therefore, this  source of potentially  harmful  patho-
gens has been substantially reduced.  Probably  the best  barometer of health effects
is lack of health-related problems associated with project  operators and local  citi-
zens within the county.

A major concern with the application of sewage  sludge to land is the possibility
of heavy metals being transferred indirectly  to the public  through  the  consumption
of contaminated vegetables and meat.  No indirect health effects are evident at
this time.  The nature of the project itself  precludes the  direct human ingestion
of crops grown on site.  Hay, corn, soybean and sorghum  are sold on the open
market.  They represent a small fraction of the total crop  produced in  Fulton
County and receive even greater dilution in larger markets.   There  is no evidence
that crops are directly consumed by humans.   Crops fed to animals consumed  by
humans add little to the existing burden.

On September 13, 1979, USEP
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Housing developments in the area apparently have  not been adversely Impacted
by water quality associated with the  strio-mining activities,  but indeed have
created their own pollution problems  in  non-oroject reservoirs (algae blooms
due to contamination from septic fields).

     5.   Noise

Sources of noise related to the project  include pumps and tractors.  Three pumping
or sludge distribution stations are located within project property,  and one
booster station is situated at the Liverpool dock.   The  pumping stations on the
project site are situated at least one mile from  the nearest farm.  The booster
station at the Liverpool dock and barge  pumps  are within 1/2-mile radius of
Liverpool.  Tractors and trucks are mobile noise  sources that  will be detected
only when in operation near the boundary of project property.

Considering the one-mile buffer distance and further dissipation of noise by
buildings, vegetation and topography, the  noise level of pumps is acceptable
for residential areas as recommended  by  the U.S.  Department of Housing and Urban
Development.  Noise generated from pumps at the Liverpool dock and by barge
pumps will somewhat increase the ambient noise level around the community of
Liverpool, but not significantly.

     6.   Land Use

Leveling and grading of strip-mined sections of the project site to prepare the
sludge application fields, and the removal of  large rock fragments from the surface,
have increased the suitability of the land for a  number  of uses.  Beyond the ob-
vious benefits to agriculture, leveling  has made  it possible to use farm machinery
bo control tree growth, instead of employing hand labor  which  is prohibitive in
cost.

The removal of surface rocks and leveling  of steep slopes have also considerably
increased suitability for recreational use, including playgrounds,  campsites,
recreation building sites, roads, and trails.

     7.   Economics

The most obvious short-term local economic effect of the project has  been to create
jobs for approximately 120 skilled and unskilled  contract laborers who average 6 to
8 months of employment yearly.  In 1975, the MSOGC paid  approximately $890,000 to
their contract employees and §300,000 to their full-time staff of 23.

The sludge application project has also  affected  the local economy by increasing
the future market value of the land and  the tax base.  In 19-73, the MSOGC paid to
Fulton County about $102,000 in real estate tax*s»  which amounted to  1.3 percent
of total tax revenues, and $34,000 in personal property  taxes  which amounted to
3.4 percent of the total.  Land reclamation and reuse could theoretically add
about $280,000 to the market value of the  4,344 project  acres  of strip-mined land
scheduled for sludge application.
                                  1-20

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Future uses of land will not be economically intensive  and would  generate little
on-site employment and  income.  Income due  to tourist-related retail and service
enterprises has occurred in the recent oast.   Agricultural reuse, especially
grazing, would have a small multiplier effect on local  emoloynent and income.
Peedlots could contribute  to the exoansion  of nearby meat oacking firms.  Full
reclamation and agricultural reuse could  theoretically  add 5100,000  to 5200,000
per year (1970 dollars) to the ultimate value of agricultural output.

G.   Mitigative Measures ?teeded to Ensure Environmental Compatibility

    1.  Land Management Measures

MSOGC should develop a Facilities Operating Plan as  outlined  in 40 CFR 257.3-5
(H)(l)(e).  %s promulgated, this cadmium  management  approach  sets forth require-
ments which will serve to  minimize the potential for many pollutants reaching the
aquatic environment or the human food chain.   This approach is more  fully dis-
cussed on page VII-5.  To  further reduce  the potential  for contaminants entering
the food chain it is reconmended that the crops grown on fields used for sludge
application be sold to alcohol producers  and used for gasohol production.

The MSOGC should evaluate  the optimum sludge application rate where  soil erosion
and siltation basin maintenance can be held to a minimum but  land requirements
do not get too large.  Tradeoffs should be  evaluated to keep  soil compaction at
a minimum and common agricultural techniques used to reduce associated problems.
Chisel plowing and dry discing could be utilized to  reduce soil compaction.

Where feasible, fields that are graded to drain laterally across  the principal
slope into ditches along the perimeter should be upgraded with a  broad, shallow
depression and retention dike at the base of  the slope  to add backup runoff  reten-
tion capacity on the field itself, thus eliminating  high velocity runoff, scouring,
and gully erosion at the edge of the field.

Terraces constructed across long slopes and maintained  in permanent  vegetation
should be provided, when practicable, for greater erosion control? drainage  chan-
nels or ditches, dikes, and berms should  be permanently grassed to stabilize the
soil.

Cover crops to stabilize surface soil should  be established and maintained on
fallow fields immediately  following seasonal  sludge  applications.  MSOGC has
indicated that they currently plant winter  wheat to  help satisfy  this condition.

Breached dikes or berms should be repaired  promptly?  carriers of  rock,  hay bales
or other material should be placed in ditches or runoff channels  containing  high
velocity flow to reduce scouring and gully  erosion.

Application fields should  not be worked with  sludge  incorporation machinery  when
fields are muddy and ponding of sludge is mast likely to occur.   Often the "pull11
on the incorporation hose  by the tractor  is the limiting factor to working in
muddy fields, but ponding  should be avoided where possible.

The effectiveness of past  soil conservation practices should  be carefully evaluat-
ed, and technical assistance should be sought from the  Soil Conservation Service
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through the Fulton County Soil and Water Conservation District  in planning the
needed conservation practices to assure that  soil  loss does not exceed tolerable
limits as defined by the Universal Soil Loss  Equation.

It is essential that combined soil and sludge p'i  in  all  fields  be maintained at
or above 6.5 continuously.

The MSDGC should extend the current practice  of building supplemental  siltation
basins, especially where soil loss and siltation of  retention basins is severe
and runoff retention capacity is marginal? also, there should be nore  frequent
cleanout of full siltation basins and mowing  of overgrown basins to  preserve
their function.

The prescribed practice of pumping from partially  or  nearly filled runoff reten-
tion basins back onto application fields should be employed where necessary to
avoid emergency releases of substandard effluent?  such recycling of  runoff should
occur before fields are saturated from rainfall and  sludge application combined.

Discharge control gates should be Kept closed during  a period of runoff from a
storm; prolonged periods when gates remain open should be carefully  avoided.

* refined water quality monitoring scheme is  required to differentiate the pollu-
tant contributions from project point sources (retention basin  discharges), com-
munity point sources (Canton sewage treatment plant),  and non-point  sources
(runoff over mine spoil).  Stream monitoring  stations in particular  are too few
to enable segregating these contributions, and community pollution of  Big Creek,
where most stream monitoring occurs, tends to mask the possible pollution of
minor contributions from project operations.

Quality of runoff retention basin effluents must be  upgraded and should be moni-
tored by analysis of 24-hour conroosite samoles or  by  averaging  the values of
samples taken at several intervals instead of using a single grab sample.   This
is to say that during a release event MSDGC should take  a series of  grab samples
over time, instead of one grab sample.  Several mobile composite samples could
be utilized by staggering release events.  The current Illinois EM  requirement,
which assumes relatively stable concentrations of  biochemical oxygen demand,
total suspended solids and fecal coliforms, has been  ineffective in  preventing
occasional release of contaminants whose concentration can fluctuate widely in
24 hours.  The IEPA should ensure that discharges  do  not cause  a violation of
instream water quality standards as required  in 40 CFR 257.3-3(a).   The sampling
scheme should be agreed upon with IEP4.

    2.  Air Quality Management Measures

Periodic regrading to remove depressions due  to subsidence of unconsolidated subsoil
or mine spoil should be performed as necessary to  prevent ponding of freshly applied
sludge which presents a potential for odor emissions.  Occasional unavoidable
ponding should prompt measures to control odor generation.  The  MSDGC has  applied
an odor control product to nonded areas, and  this  practice should be continued.
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The use of wind barriers such as  tall, dense  hedgerows  around  the holding basin
berms, could reduce surface turbulence and wave  action  which intensify odor
emissions.  The present requirement of a  4-foot  freeboard  from the sludge surface
to the top of the berm provides wind baffling only for  a short distance downwind.
h reduction in the overall size of the holding basins is a good measure for
reducing the basin odors.

    3.  Health Management Measures

Potential hazards to human health will greatly deoend on the types of crops grown
on the project fields.  Crops should be selected carefully to  avoid those which
favor the accumulation of metals  in edible plant tissues.  In  general,  grain
crops present a lesser heavy-metal hazard to  the food supply than do forages,
pasturage, and leafy vegetable (CAST, 1976).

Crops which may be eaten raw should not be planted within  three years of the last
sludge application (EP\, 1976).

The efficiency of wastewater treatment and improved industrial pre-treatment as
required should reduce the concentrations of  potentially toxic substances,
especially heavy metals, in MSOGC sludge.

    4.  Plans and Records

Steps should be taken to ensure that all  project maintenance activities are re-
corded on a regular basis in accessible documents.   Items  to be recorded should
include dates, locations and descriptions of  repairs to fields and basins,  berms,
dikes, drainage ditches and pipes, as well as significant  reseeding,  fertilizing
and mowing. Observations of conditions requiring correction, such as soil subsi-
dence and gully erosion, accelerated siltation,  overtopping  or breaching of
embankments, and overgrown or sparse vegetation  should  also  be recorded.  Where
necessary, maps or diagrams should be provided to  reference  the locations of
planned or completed activities.

Operations records also require improvement.   For  example, present records  con-
cerning the operation of runoff retention basins should be augmented to include
periodic reporting of the stage or level  of all  basins, discharging or  not,  so
that available capacity may be determined in  the event  of a  storm.   Ml emergency
discharges from retention basins  should be recorded along with the results  of a
water quality analysis of the discharged  effluent.   Recycling  of substandard
effluent by pumping back onto the fields, if  practiced  at all,  should be  recorded
in times and amounts.
                                   1-23

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                     II.   BftCKGapOgTO WD IHTRODUCriON

A.  Project Background and Overview

Sewage sludge disposal is a problem associated with the sewage treat-rent process
of most large cities.  In some cases, accumulation of large amounts can pose
severe problems foe ultimate disposal, given economic and land use constraints.
In cecent years, land application of sludge, when properly managed, has proven
to be an economic and environmentally acceptable method of ultimate disposal.
Land application, if propeciy practiced, has the benefit of turning the waste
product of sludge into a resource of fertilizer by utilizing the nutrient content.
Any successful program must recognize the environmental limitations of land
application as well as the needs and problems of both the urban and agricultural
coumunities.  Sewage sludge, when applied at an agronomic rate, will supply
nutrients to the plants as well as improve soil properties,  this soil improvement
capability has the potential to renovate depleted or barren land.  Benefits and
problems associated with the application of sewage sludge on agricultural and
old strip-mined land are discussed.

    i.  Benefits

        a*  Characteristics of Metropolitan Sanitary District of jjreater Chicago
(MSPGC| Sludge - The term "sludge", as applied to this project, rafees toan
anaerobically stabilized byproduct of sewage treatment.  Liquid sludge contains
dissolved, colloidal, and suspended solids.  Purely domestic waste is often
quite acceptable for land application programs.  However, in a large metropoli-
tan area, such as Chicago, the sludge characteristics are altered by the types
of industries contributing to the wastewater. mat sludges contain 2-5 percent
solids as they finish the treatment process.  The solid portion is composed of
approximately equal amounts of inorganic and organic materials.  Itie inorganic
portion is largely fine particles having the texture of silt and clay, and con-
tains mainly nitrogen, phosphorus, sulfur, chlorine, carbonates, and metal salts.
The organic portion is a complex mixture of constituents comprising organic carbon,
nitrogen, phosphorus, and sulfur.

Table II-I gives a range of the chemical composition of sludge and specifications
for a "typical" liquid, digested sewage sludge as it flows from the digester.
The composition of different batches of sludge can vary appreciably from the
values shown; these are given only as a general guideline.  Not all of the nitro-
gen in sewage sludge is available to crops during the year of application.  Soma
may be lost by volatilization or leaching, and the remaining organic nitrogen
•oust be mineralized before it can be assimilated by crops.  Also, nearly all of
the minor and trace elements can be toxic at some concentration; their availa-
bility to plants depends on soil properties, crop varieties, and many other factors
(University of Illinois, 1976),

        b.  Application Method and Rates - A sludge containing about 6 percent
solids or less canbe handled as a liquid; i.e., through pipes, carried in tank
trucks, barges and special pumps may be used to achieve the transfer.  Generally,
liquid manure spreading equipment can be used. When sludge contains more than 10
percent solids, special equipment is needed.  Mso, dewatered sludge may be handled
as a solid.


                                  II-l

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                                        Table II-l

                       Composition of Fresh, \naerobically Digested
                       Sewage Sludge (University of Illinois,  1976)

Element

Elements essential for
Nitrogen-organic
tfitrogen-aranonium
(Nitrogen-total )
Phosphocus-as P
(Phosphorus as P 0
Potassiuro-as K
(Potassium as K 0
Calcium
Magnesium
Sulfur
Iron

Sodium
Zinc
Copper
Manganese
Boron
Elements not essential
Cadmium
Lead
"tercury
Chromium
Nickel

Concentration
Range (1)
plants
2 to 5
I to 3
(1 to 6)
0.8 to 6

0.1 to 0.7

1 to 8
0.5 to 2
0.3 to 1.5
0.1 to 5
com*
800 to 4,000
50 to 50,000
200 to 17,000
100 to 800
15 to 1,000
for olants
3 to 3,000
100 to 10,000
1 to 100
50 to 30,000
25 to 8,000
Typical
Concentration


3
2
(5)
3
(6,8)
0.4
(0.5)
3
0.9
0,9
4
Dora*
2,000
5,000
1,000
500
100

150
1,000
3
3,000
400
Sludge (dry basis)
(t) Amount (Ib/ton)


60
40
(1005
60
(137)
3
(10)
60
20
18
80

4
10
2
1
0.2

0.3
2
trace
6
0.8
*ppm - Pacts per million
Note:  Values varying according to source, treatment and other factors.
Sludges held in storage lagoons for long periods may be considerably lower
in nitrogen content.

                                       II-2

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Although not a recommended pcactice,  liquid sludge can be  sprayed  through  larje
diameter irrigation nozzles.  Sludge  and  supernatant  also  can be allowed to
flow down furrows over a graded  field.  Land application of  sludge is  not  a  substi-
tute for irrigation if a problem of insufficient rainfall  exists.

In some present operations in Illinois, sludge  is pumped through a flexible  boss
to an injection plow traveling through the field.  *t the  plow, sludge flows
through a manifold which connects with outlets  at each plowshare or disk.  Sludge
can thus be incorporated immediately  into the soil.   It is necessary that  caution
be exercised in applying sludga  to sloping land to ensure  that resulting runoff
does not contaminate streams and other bodies of water.

JVcplication rates are expressed  in terms  of inches o£ liquid per acre,  tons  of
liquid per acre, or tons of dry  solids per acre.  \ layer  of liquid sludge ons
inch deep amounts to about 27,000 gallons (100  tons) on each acre  cover 3d.

In determining the correct application rate to  satisfy crop  requirements for
nutrients, many variables must be taken into consideration.   For sxampla,  the
percentages of specific nutrient concentrations that  are in  a form available
for plant uptake, the loss of alements from leaching  through the soil,  and the
nineralization or immobilization of elements after application must be determined.
%t application rate that is suitable  for  one constituent of  sludge night be
unsuitable for another, causing  either nutrient deficiency or  toxicity.  In  addi-
tion, the contribution of trace  elements, especially heavy metals, may  limit the
long-range utilization or disposal of sludge on agricultural lands (University
of Illinois, 1976).

Application rates must be specified according to the analysis of sludge  being
used, and sufficient sampling must be done to measure variability  in composition
over a reasonable period of time.  The University of  Illinois has  done  sufficient
research to indicate favorable crop response and increases in soil organic content
when sludge is applied to agricultural and strip-mined land.  (University of
Illinois, 1976).

        c.  Value of sludge application - Sludge provides  a  source of organic
matter that may lae beneficial in many soils, particularly  those low in organic
natter such as sandy soils or previously  strip-mined  lands.   Improved  structure
and water-holding characteristics result  from an increase  in soil  organic  matter
when it is at a low level (under 3 percent) (university of Illinois, 1976).

    2,  Potential Problems

Potential problems that iiust be  taken into consideration when  planning a land
application program include:

        a.  Odors from sludge application methods can be minimized by  incorporating
the liquid sludge.  Storage basin odors have caused the most complaints  in the
past.  Hie upper layer sometimes has  a high ammonia content.   Odor can be  reduced
by minimizing surface area and length of  tine needed  for storage.

        b.  "teny concerns about  long-term sludge application  have  centered around
trace metals in the sludge.  The elements of most concern  include  nickel,  zinc, cad-
mium, and copper but such concern extends to mercury, lead,  boron, chromium, cobalt
selenium, and molybdenum.  The fear is that these substances nay accumulate to


                                 II-3

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causa toxic concentrations  in the crops.   The  University of  Illinois has traced
the movements of heavy metals in the  food  chain.  Stadias  have indicated that
there is no indication of high levels  of toxic metals  in the soils or plants
where municipal sludges are applied at agronomic  rates.  (University of Illinois,
1975).

        c.  There has been  serious concern that sewage sludge might contain patho-
gens and that animal and human health  problems might result  from sludge utilization.
However, specific studies have shown  that  viruses are  unlikely to survive a period
of 15 days in a heated anaerobic digester, at  least in a condition capable of caus-
ing an infection,  lien the same situation was found for several Kinds of parasites.

        d.  In regard to nutrients, it was found  that  both the rate of nitrogen
transformed to nitrate and  the aovamant through soil are the same, regardless of
the source.  Phosphorus poses somewhat more of a  proble.it in  that phosphorus added
to soils as a sludge constituent appears to be highly  available to crops.   Hence,
it is possible for available phosphorus to accumulate  in soils to levels toxic to
sensitive crops if sludge application  rates are high.  Also, the levels of phospho-
rus in drainage water may possibly increase to the point of  posing a eutrophication
threat when drainage water  is returned to  non-flowing  surface waters.  fbwever,
thase ocoblams are not expected to result  as long as agronomic rates of sludge
application are not exceeded (University of Illinois,  1976).

3. Project History and Issues

    1.  History and Policy  Matters

Fulton County citizens have bean concerned about  the after effects of strip mining
in the County for years.  The first collective action  was  taken in 1970,  when the
County Board of Supervisors and the State  Attorney's Office  formed a special citizen;
committee.  This group directed the State  Attorney to  investigate the feasibility
of a land application project in Fultcn County.

It was apparent from other  studies that although  the nined area could be  effectively
leveled, some measures would havs to be taken  to  modify the  poor  inorganic mine
spoil material of the area,  it was then that  the use  of sawage sludge was proposed.

The >6DGC was invited to make a presentation to the Fulton County officials on
3epte.Tiber 11, 1970.  Several administrative approaches to  the project were discuss-
ad, but MSDGC purchased about 15,000 acres of  mined land which was being  used  for
pasture.  It was the intent of the MSDGC to grade the  land in order  to control run-
off, increase the organic content of the soil  by  large additions  of sludge and
restore the land to full agricultural  productivity.

    2.  Environmental Litigation

Several court cases were brought against N5DGC.   Also, MSDGC filed several  cases
against the Illinois Environmental Protection  Agency (IEPA).   A summary follows:

        a.  IEPA vs. MSDGC  - charged air pollution violations against MSDGC.

        b.  MSDQC vs. IEPA  - a permit  appeal.  The decision  was in favor of IEPA.
All permits ^stayed" until  a decision  in the above case was  reached.
                                  II-4

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        c.  MSOQC vs. IEPA - a mandamus action brought by  the district  to  conrael
the issuance of the Pulton County permits.

C.  Related activities

    1.  The Big Bluestern Program and Recreational Benefits

One reclamation program called for returning a 3,000-acre  segment of  land  to
original tall qrass prairie vegetation.  The principle is  that a tall
grass prairie may prove even better than crops and pasture in recycling
and reclamation. The orairie plants offer new possibilities for both
agriculture and land reclamation.  The idea of reintroducing wildlife
and *ttricting tourists was discussed.

    2.  The Fulton County Steering Committee

This committee was established to provide local public participation  for
the Prairie restoration program.  The committee was composed of public
officials, private citizens, and MSDGC staff personnel.

    3.  Recreational areas

Areas will be established and certain oothole areas preserved.

°-  The StudyArea

    1«  Basis for the Study Area

The study of socioeconomic and land use impacts employs three areas of  focus.
The largest area of study is regional, covering Fulton County and any influences
of Peoria.  \n area of more intensified study contains land surrounding the
project site and includes Canton.  The smallest area of study is confined  within
the boundaries of the project site (see Figure II-l).

The study of environmental effects of the project includes odor and noise  nuisance,
potential contamination of surface and groundwater and soil, possible health
effects of airborne pathogens, and potential biomagnification of toxic  materials
in food chains via crop and livestock production and consumption.  Mo definite
geographic boundary can be assigned to accommodate all effects.  For example,
problems associated with odors and airborne pathogens, which can travel great
distances, require a larger study area.  Related clinatologxcal features must
be examined not only locally but also regionally.

Generally speaking, the study area is extended to at least five miles from the
boundaries of the project property.  This area includes the communities of Canton,
Cuba, St. David, Bryant, and Lewiston (see Figure II-l).   Ml environmental  and
health effects resulting from the project are evaluated against the applicable
standards as discussed in the following section and confirmed with findings
fror similar studies in published aid unpublished literature.

    2.  Pollution Control Standards

The MSOGC must comply with four basic sets of regulations  to construct  and
operate the Fulton County land reclamation project.  There are effluent stan-
dards, as stated in the Illinois EP% Hater Pollution Control Permit, which reflect
the water pollution regulations of Illinois Rule 404, governing the concentrations

                                   II-5

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it.: -.-f r-r—'—"•   	y'   _!	r:
1 '  '  •'   '  • •  I     i •Til -T i y"  '	

-------
of total dissolved solids, biochemical oxygen demand  (9QD),  and  fecal  conforms.
The M50GC must construct, operate and maintain  the  project  so  as to maintain the
General Water Quality Standards  for  the  State of  Illinois.   Tn addition,  the
Pulton County Board of Health requires a permit for any sewage sludge  operation,*
it contains standards for the chemical composition, transportation, storage,
use and disposal of digested and undigested  sewage  sludge.   The  USEP&  regulations
pertaining to land application are published in the Federal  Register under  40 CFR
257.  These separate sats of standards ace examined in  turn  in this section.
Miscellaneous standards and special  standards applying  to gatsd-pipe application
of supernatant liquid and deep trench incorporation of  sludga  to specific proper-
ties are also covered.

        a.  Water Quality Standards  - The water quality standards for  the State
of Illinois are designed to protect  Illinois waters for aquatic  life,  agricultural
and industrial uses, and primary and secondary  contact  (for  recreation),  and to
insure the aesthetic quality for the environment.  Ml  waters  of the State  must
meet the water quality standards defined in  Table II-2. In  addition,  the follow-
ing standards must be met:

Vty substance toxic to aquatic life  shall not exceed  1/10 of the 48-hour  median
tolerance limit (48-hour TLm) for native fish oc  essential  fish  food organisms.

All State waters must be free from unnatural sludge or  bottom  deposits, floating
debris, visible oil, odor, unnatural plant or algal growth,  unnatural  color  or
turbidity, or matter in concentrations or combinations  toxic or  harmful to  human,
animal, plant, or aquatic life of other  than natural  origin.

There shall be no artificially induced temperature changes that  may adversely
affect aquatic life, that may disturb the normal  daily  and seasonal temperature
fluctuations, or that nay cause  the  temperature to rise more than 5 degrees
Fahrenheit (F) above natural temperature.

        b.  effluent standards - To  construct and/or  operate any water pollution
control facility In the State of Illinois, a permit from the Illinois  Environmen-
tal Protection Agency (IEP*) is  requited.  Each permit  is comprised of standard
conditions common to all such permits and a  number of special  conditions  based on
the specific case.  The Comprehensive Operating Permit  issued  to the J*SDQC contains
15 Special Conditions,  (see appendix).

According to Special Condition 19, effluent  discharged  from  any  runoff retention
basin must meet the applicable effluent  requirements  far discharge to  the waters
of the State as established by the Illinois  Pollution Control  Board Rules and
Regulations.  The point of discharge is  considered to be the overflow  structure
of each of the retention basins.

Special Condition HO states that certain contaminant concentrations are  to  be
considered background valuta, and that the effluent standards  are met when the
sun of the background concentration  and  the  allowable regulatory concentration
is greater than the measured concentrations  for the respective parameter.  The
regulatory concentrations applicable to  the  Fulton County site are defined  in
Chapter 3 of the Water pollution Regulations of Illinois, Rule 404(f), which
describes State effluent standards for streams  with less than  1:1 dilution,  basad

                                     II-7

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      Table II-2.   Water Quality Standards for the State of  Illinois
            Parameter
Standard (mg/U
Arnnonia nitrogen  (as N)
Arsenic
Barium
Boron
Cadmlup
Chloride
Chromium  (total hexavalent)
Chromium  {total trivalent)
Copper
Cyanide
Dissolved Oxygen
     minimum for  11 out of 24 hours
     minimum at any time
Fluoride
Iron
Lead
Manganese
Mercury
Nickel
Phenols
Phosphorus  (as P)*
Selenium
Silver
Sulfate
Total Dissolved Solids
Acidity-alkalinity
fecal coliforma**
     Geometric mean
     Maximum for 10% of samples
Radioacitivity
     Beta
     Radium 226
     Strontium 90
     1.5
     1.0
     5.0
     1.0
     0.05
   500.0
     0.05
     1.0
     0.02
     0.025

     6.0
     5.0
     1.4
     1.0
     0.1
     1.0
     0.0005
     1.0
     0.1
     0.05
     1.0
     0.005
   500.0
  1000.0
     1.0

     '6.5-9.0

  per 100 ml
     200
     400

 pCi/l**«
     100
       1
       2
     *In any reservoir or  lake, or  in any  stream at  the point of
      entry to any  reservoir or lake
    **Based on a minimum of five samples taken over  not more than
      a 30-day period
    ***Pico curies per liter
                                  II -  8

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based on the 7-day, 10-year low flow.  These allowable  regulatory concentrations
were defined to be the requirements for secondarily  treated wastewater.   The
numerical values of these standards are presented  in Table II-3.  After
negotiation between IEP% anJ MSOGC these discharge standards were relaxed to
be consistent with the requirements for a secondarily treated wastewater  dis-
charge. (Table II-3a)

        c.  Sludge standards - The Fulton County Board  of Health Sewage Sludge
Rules and Regulations require that any transportation,  storage, use,  or disposal
of sewage sludge or digested sewage sludge requires  a valid permit  from the  Board
of Health.  Ml sewage sludge transported for  storage or applied to land  must be
digested.

Tests must be performed by the permit holder on a  24-hour composite sample of
digested sewage sludge to be transported for storaga in Fulton County.  Weekly
results are to be submitted to the Pulton County Board  of Health, which retains
the right to independently sample the sewage sludge  of  any permit holder  in  Fulton
County.

\s of November 18, 1975, the Volatile acids and alkalinity standards  were changed
to the following:

If volatile acids are less than 100 milligrams per liter, then the  alkalinity
cannot be less than 2,000 milligrams per liter.

The Fulton County Health Department took into  account the fact that some  of  the
sludge shipped to Fulton County had been in storage  in  the Chicago  Lawndale  lagoons
for periods ranging up to 15 years.  Exceedingly long storage periods result in
volatilization of ammonia and consequent decreases in alkalinity.

        d.  Solid Haste Disposal Criteria - Criteria for the classification  of
Solid Waste Disposal Facilities Practices (40  CFR  257)  includes the latest require-
ments to ensure a safe sludge disposal operation.  These were oublished in the
September 21, 1979 Federal Register.

        e>  Miscellaneous requirements - tecording to the Fulton County Board of
Health Sewage Sludge Rules and Regulations, the use  and disposal of digested
sludge mist comply with the following standards:

    Cropping practices shall be such that soil loss  does not exceed tolerable
    liitits as defined by the Universal Soil Loss Equation for the soil type.

    Underground aquifers shall not be contaminated with digested sewage
    absorbed into all soils

    Spray applications shall be done so as to  contain the material  within
    the land-application area designated in the permit

    In addition, sewage sludge shall not be applied:

    Within 100 feet of a stream, lake,- well, or any  potable water supply

    Within 200 feet of m dwelling wit

    On root crops for human consumption


                                   II-9

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                             Table II-3
                  Effluent Standards for Retention 9asin
                    Discharge in the State of Illinois

Parameter

Total
Suspended Solids
(mg/1)

800
(mo/l)
Pecal
Conforms
(mg/1)
3ackground
Arithmetic Mean

Background
Geometric Mean

Water Pollution
Regulations of
Illinois Rule 404(f)
(Regulatory
                             61.7
mg/1 * Milligrams oar liter
2.75
                                                                   94.3
concentration )
Effluent Standard
(Total concentration)
5.0
§6.7
4.0
6.75
400.0
494.0
                              Table II-3a
                    Effluent Standards for Retention 3asir,
                    Discharge in the State of Illinois, Revised
Parameter
                          Total
                       Suspended Solids
                         (mi/I)
                                                  800
                     Fecal
                   Coliforms
Background
Arithmetic Mean

Background
Geometric Mean

Hater Pollution
Regulations of
Illinois Rule 404(f)
(Regulatory
concentration)
                             61.7
                             37
    2.75
    30
                                                                      94.3
                                                                     400.0
Effluent Standard
(Total concentration)
                                                     33
                     494.0
                                        H-10

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    In a flood plain, unless adequate pollution  control mechanisms are availabla

    To frozen or snow-covered  land

    Outside of the land-application area

        1.  Discharge Limitations - Water Pollution Control  Permits from the IEP4
were issued on June 19, 1975,  for sludge distribution on various project areas.
The permits are presented  in Atnendix A.  Agronomic rates of application, avoiding
steep sloping land, avoiding ponding, trying  to  avoid rainstorms, and not applying
on snow and ice were some  of the conditions placed  on the distribution process.

E.  Description of *6DGC Treatment Systems

    1.  MSDGC Sewage Treatment Plants

The JEOGC has seven wastewater treatment plants.  The West-Southwest (WSW),  Calu-
met and Northside plants are secondary treatment works, while Hanover, Streamwood,
Demont, and John E. Egan provide tertiary treatment.   The John  E. Egan water
reclamation plant has been operating since December 1975. The  Streaznwood Plant
was retired in September 1977.  The new O'Hare Water  Reclamation plant began
operation in mid 1980.

Presently, only the West-Southwest and Northside facilities  produce sludge to be
shipped to Fulton County for land reclamation (P6DGC, 1975).  As operations
progress at the O'Hare plant the possibility  exists that some sludge from the
facility may be shipped to the Pulton County  Site.  The Northside facility
has no sludge stabilization, recycling or disposal  systems.   After concentration,
sludge at approximately 1.3 percent solids is pumped  to the  West-Southwest facility
via pipeline.  In 1975, the Northside plant pumped  2.5 million  gallons per day
(133 dry tons per day) of  primary and secondary  sludge to the West-Southwest
plant («*5DGC» 1976m).  Sunmary performance data  from the J60GC  plants are presented
in Table II-4.

    2,  West-Southwest Treatment Plant

The WSW plant is comprised of  the West Side Treatment Works,  which is an Imhoff
facility, and the Southwest Side Treatment Works, an  activated  sludge facility.
The facilities of both treatment works can be divided conveniently into two
groups: sewage treatment systems and sludge processing systems.   The sewage  treat-
ment systems are briefly discussed below, followed  by a detailed description of
the sludge processing systems.

The west Side Treatment Works  consist of a grit chamber and  screen house,  skironing
tanks, Imhoff tanks for sewage treatment and  sludge stabilization,  and drying beds
for sludge dewatering.  There  are 108 Imhoff  tanks  arranged  in  three batteries
of 36 tanks each.  Digested Imhoff sludge is  dried  on 12 underdrained sand beds 80
feet wide and sludge is scraped from the beds and hauled to  a dump 3 miles west of
the plant.  Dried Imhoff sludge waa given away as "Mu-Earth",   in recent years the
"No-Earth" program has been curtailed.  As an 'option,  ImhofE  sludge may be screened
prior to either lagooning  or heated anaerobic digestion.

The Southwest Treatment Works  include aerated grit  chanters,  grit dewatering build-
                                   11-11

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                                    Table  II-4.   Performance of KSDGC  Plants (MSDGC,  1976 m
                    West-Southwest
                                        Nocthside
                                   Calumet
                                                                     Hanover
                                        Lsnont     Streanwood
                                                     Egan
Degree of
Treatment

Capacity   (HGD)

Flow Ranges in
1975 (MGD)

     Average Daily

     lowest Daily
Secondary

1200
  847.0

  744.0
     Highest Daily   1446.0

Average Effluent Con-
centrations (ppm) and
Percent Reduction in 1975
     BODS

     TSS

     Amcnia
   7 (94%)

   7 (97%}

   5.4
Secondary

 333
 330.0

 235.0

 401.0
 12 (87%)

 9  (91%)

 4.0
Secondary      Tectiary   Tertiary    Tertiary       Tertiary

220            6.0         1.2         3.0            30
220,0

160.0

330.0
25 (88%)

27 (90%)

11.9
 5.7

 2.6

11.7
 5 (97%)

 5 (97%)

 1.5
4 (96%)

9 (95%)

2.4
4 (96%)

5 (97%)

1.4
     (1) Plant expanded to handle increased Clow in May of 1975.
     (2) Plant operational December 1975.

-------
ing, -oreliniiary sattling tank-3,  oration tanka  Cot  tha  activated sludge orocass,
and final settling tanks fx 33*333  treatment  heat  drying  and haatad anaarobic
digestion are tha two sludge •orocessas  usad  at tha  Southwest "fteatuait  tforks.   1*12
W2t air OKiiation OCOC3SS has basn  Jissontinuea  3ua  to Doaratiirj probl=ns,
affscts fron f3cycie3 strsans, ani  safety consilecations.
    heat Jcyirrg orcx:333  incluias  scceeiin}  3f sludge  iy bar  aacaaas atvJ
tae «:cesnirig3 by faunae nil Is  ar»3  sludje Jawatafini  by 93  vacua n filters.
       oroiucei is soli  as fertilizer base  material.

    3.  SluJge Pcooesjsin^ and Disposal
In 1375, th» MS03C ocai'xaf aoocoxinat»ly  525  dry  tons  oar  lay (dt/d)  af
sludge.  Tte M90X iias a nunbar  of  systans availabla  fx  sludja hanilin-j,  stabili-
zation and 'lisposal , and is devalooiivj othacs.   ( nass  are  ocesantad  in Figure
II-2)  Ostailed discussions on t'le  systsns related to this  study are  liscussaJ
latar.  The sludge orocsssiig systans it tha wswr olant  are  sunnarizad  in Taola
II-5, which givss the tyoas of aystatis utilized  in 1375  and thair  caoacitias in
dry tons ner 3ay.

In suunary the Collowiag four sludge handling, stabilization,  ani  Jisoosal  schanas
ace utilized.

    1.  Heat drying and fartilizar  sal a

    2.  Haatsd anaerobic digastion  and lagooiing

    3.  'featad anaatobic digestion  and land aoolication  in
        Fulton County

    4.  Inhoff digestion followed by air drying on sand beds
        and subsequent distribution as "Mu-Earth".
                                   11-13

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          SYSTEMS
PRIMARY
SECONDARY
TERTIARY
IMHOFF
HEAT DRY
VACUUM FILTRATION
AIR DRY
SETTLING AND FLOTATION-CQNC
DIGESTION
;:ET AIR OXIDATION
LAGOONING
STOCKPILING
NU-EARTH
SELL HEAT-DRIED
LAGOON CLEANING  CONTRACTS
CALUflET AND  HANOVER  FARMS
FULTON COUNTY:
   SOIL  I .CORPORATION
   SOIL  INJECTION
   CROP  SPRAY
   FOREST SPRAY
   OVERLAND  FLOW
                                                                       DISPOSAL
STAIIIIZATION CONCINTRATION
                Figure II-2.    Available MSDGC Solids Systems (HSDGC)
                                        II - 14

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                                 Table II-5
                 West-Southwest Sludge Processing Systems,
                            1973 (MSDGC, 1976m)
        System	  Type	Capacity (at/d)

Imhoff Digestion,                   Stabilization               100
Air Drying on Sand Beds,            and Recycling
and Storage

Heat Drying                         Stabilization               380
                                    and Recycling

Heated Anaerobic                    Stabilization               300
Digest ion

Wet Air Oxidation                   Stabilization               190
Process (on standby
basis only)

Land Reclamation                    Recycling                   110
(based on land available
Cor application for
1975 season and a 20
dt/d/A  loading rate)

lagoons (requiring                  Stabilization                 0
periodic cleaning;                  and Storage
no long-term disposal
capacity available)
dt/d/A;  dry tons per day per acre
dt/d:    dry tons per day
                                    II - 15

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Chapter III
Existing Conditions

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                          III.  EXISTING CONDITIONS

This chapter provides a description of baseline information concerning climate,
topography, geology, soils, hydrology, water quality, biology and ecosystems.
Past and projected trends in local population and the economy are presented
along with the established and forecasted land patterns and land development
potential.  The chapter concludes with a discussion of natural and cultural
resources in Pulton County that are particularly sensitive to planned project
operations.

A.   Climate V>d Topography

Past and present climatic conditions and local meteorology must be determined  in
order to predict the most probable and worst conditions affecting project opera-
tions.  Potential air quality problems, and particularly odor transmission are
considered.  The area climate, which is represented by a record of numerous
atmospheric events, is defined by weather elements such as temperature, wind,
cloud cover, solar radiation, humidity, precipitation, and atmospheric stability.
Climatic data from two weather stations are used for analysis. Weather station
114842 is located at the greater Peoria Airport approximately 25 miles east-north-
east of the project site (National Climatic Center, 1974a).  The second weather
station was set up by the MSDGC at the project site (NSDOC, 1975b).

In addition to climate, local topography is summarized in terms of land-form
characteristics which could influence the microclimate and create susceptibility
to impacts on air and water quality.

    1-   General Meteorology

The climate of this area is typically continental, as is evidenced by the change-
able weather and wide range of temperature extremes. Meteorological characteristics
of the project area are discussed in the following sections.

        a.   Temperature and precipitation - according to 40-year observations at
the Peoria Mrport station, the average monthly temperature varies from 25 degrees
F to 75 degrees F, with an annual average of 51.1 degrees F.  Sub-freezing jniniMm
temperatures generally do not occur from late Hatch through mid-November.  Using
a baseline of 65 degrees F, there is an average of 6,200 annual heating degree
days and 943 cooling degree days {national Climatic Center, 1974a).

The annual rainfall, as recorded at Peoria Airport, averages 34.99 inches, with
9. maximum of 50.27 inches and minimum of 23.99 inches.  Variations in monthly
mean, maximum and minimum precipitation are shown in Figure III-1.  The monthly
maximum and minimum rainfalls are displayed for the Peoria Airport station,
while the monthly means measured at both Peoria Airport and the project site are
shown for overlapping observation periods.  In spite of the 25-mile distance
between these two stations, the precipitation pattern is quite uniform.  The
maximum amount of rainfall occurring in any 24-hour period was 5.52 inches in  May
1927.  The predicted 24-hour rainfall patterns for Fulton County at four recurrence
intervals (1-year, 5-year, 25-year and 100-year) are presented in Table III-1.
The cumulative amount of rainfall is estimated to be 6.53 inches for a 24-hour,
100-year rainstorm.
                                  III-I

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B
                                                                                           Monthly Maximum
                                                                                       (Peoria Airport, 1935-1974)
                                                                                             Monthly Mean
                                                                                       {PeoHa Airport, 1972-1974)


                                                                                            Monthly Mean
                                                                                       (Project Site, 1972-1975)


                                                                                             Monthly Mean
                                                                                       (Peoria Airport, 1935-1974)

                                                                                           Monthly Minimum
                                                                                        Peoria Airport, 1935-1974)
                     Figure  m-1   Variations  in Monthly Mean, Maximum, and Minimum Precipitation
                                    at Peoria Airport Station (National Climatic Center, 1974b)

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                                                     TrtUIII-1 Predicted 24-Hour Store Pattern for Fulton County (NSDSC. )975<)
                 •ecurrMC*
                                                                                        Hour
                  l«Ur*il  1     2     3     4     S     6     7     8     9     10    11     12    13    14    15    16    17    18    19    20    21    22    23     24
              i.
              I  100 years   .07   .07   .08   .09    .1   .11   .13   .14   .18   .23    .65   3.03    .36  .28    .16   .15   .12   .11     .1    .09    .08   .08     .07   .05

H            k   25y»rs  .035  .046  .046  .046  .058  .058  .061  .092  .138  .173    .58   2.74  .311  .219  .Hi  .104   .07   .07   .058  .046  .046  .046    .035  .035

 1             3    5 yein  .035  .035  .035  .035  .047  .047  .059   .07   .11  .129   .445   2.13  .246  .176  .094  .082  .059  .059   .047  .035  .035  .035  .00234 .0234
              •s
                            .02   .02   .02  .025  .03   .03   .04   .05   .07   .09    .29   1.39    .96   .11   .06   .OS   .04   .03    .03    .03    .02   .02     .02   .02

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The average annual snowfall  is normally  23,1  inches, with  a maximum of  42.3
inches and a minimum of 7.3  inches,   significant  snowfall  usually begins in mid-
October and ends in mid-April.  Mid-Oecamber  through February are freezing  months
during which snow accumulation is at  a maximum.

        b.   Wind vectors -  Wind data are recorded  for  direction and  speed. By
dividing the number ofrecorded wind  vectors  within a given sector of wind  direc-
tion and interval of wind speed by the total  number of  observations,  the frequency
of winds in that vector interval can  be  established.  Normally 15 wind  directions
22.5 degrees apart are chosen for this type of analysis, along with four wind
speed intervals (0-3, 3.1-6, 6.1-10,  and 10.1 mph or higher).   The average  wind
•/ector frequencies at Greater Peoria  Airport  between 1964  and  1973 are  given in
Table III-2.  Calm periods normally occur during  2.83 percent  of the  year.

The vector frequencies presented in Table 111-2 were used  to construct  a wind
"rose" as shown in Figure III-2,  The vectors in  this figure indicate wind  direc-
tions and contain four segments, each representing  a wind  speed interval with  the
lowest wind speeds beginning at the core of the rose.   The frequency  of wind in a
given wind speed interval and wind direction  is proportional to the length  of  its
representative segment.  This wind rose  indicates that  southerly winds  prevail in
this general area for all wind velocities. Winds  from other sectors are rather
uniformly distributed.  A wind rose representing  conditions at the sludge holding
basins on the project site was constructed and is shown in Figure III-3. Data
were available for approximately ? yaars only; therefore,  the  level of  statistics!
confidence in this case is not as high,  At the project site,  there is  a strong
southerly wind component as  there is  at  Peoria Airport.  However,  at  the site,
winds from the southwest and west-northwest sectors are similarly important.  The
difficulties between the wind roses are  believed  to be  due to  differences in local
terrain.

        c.   Atmospharic stability -  in  air pollution studies  concerning the dis-
persion of airborne materials, atmospheric stability, which is a measure of the
mixing capacity of the atTOSphere, is of major interest.   A stable atmosphere  has
a limited mixing ability and provides little  capacity for  the  dilution  of air
pollutants.  Pasquill introduced a system for the classification of atmospheric
stability (Turner, 1964).  Parameters considered  in this system include net solar
insolation, solar altitude,  cloud cover  and ceiling height, wind speed,  and the
presence of urbanization.  There are  seven stability classes:  Class A,  extremely
unstable; Class B, unstable; Class C, slightly unstable; Class D,  neutral;  Class
B, slightly stable; Class F, stable;  and Class 3, extremely stable.   Based  on
data collected at the Greater Peoria  Airport  station, the  annual and  seasonal
percentagas of occurrence for etch stability  class  are  summarized in  Table  m-3.
The predominant atmospheric  condition in the  area is Pasquill  Stability Class  D,
a neutral atmosphere, with an annual  frequency of 57.75  percent, or 211  days per
year.

        d.   Typical weather conditions  - Climatic  conditions  in the  Paoria area
are summarized in Table  III-4.  Tnsannual prevailing wind  is southerly with a
mean velocity of 10.3 mph.   Relative humidity  is seldom below 50 percent, ranging
between 62 and 83 percent annually.  The average number of  days with heavy fog or
visibility equal to or less  than  1/4 mile ranges from 1 to  3 days per month and
peaks during winter.  Nighttime radiational loss is believed to be the major fac-


                                  III - 4

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Table III-2,   Average Annual Frequencies of Kind Vectors by Percentage,
               Greater Peoria Airport, January 1964 through December 1973
                (National Climatic Center, 1974&)

Hind
Clrection
Noi'th
North-Northeast
Northeast
East-Northeast
East
East-Southeast
Southeast
South-Southeast
South
Sou th- Sou thwes t
Southwest
West-Southwest
West
Hest-Northwest
Northwest
North-Morthwest
Wind Speed (raph!
0-3.0
0.63
0.41
0.38
-.45
0.46
0.41
0.46
0.48
1.33
0.58
0.59
0.63
0.66
0.53
0.44
0.41
3.1-6.0
1.80
1.04
1.03
1.33
1.46
1.13
1.47
1.86
4.51
1.63
1.50
1.40
1.55
1.44
1.29
1.16
6.1-10.0
2.44
1.15
1.58
1.91
2.26
1.41
2.02
2.40
7.20
1.84
1.92
1.61
2.16
2.02
2.24
1.78
.2*10.1
1.87
C.57
1.14
1.27
1.16
0.68
1.18
2.08
5.44
1.35
1.28
1.18
2.95
3.86
2.43
1.16
All 4 Wind Speed
Intervals for Given
Wind Direction
6.74
3.17
4.13
4.96
5.34
3.63
5.13
6.82
18.48
5.40
5.29
4.82
7.33
7.85 |
6.40 j
4.51
All 16 Hind Direc-
tions for Given
Wind Speed Interval
8.85*
25.60
35.95
29.60
100.00
 •Cain periods account foe 2.83% annually.
                                         Ill - 5

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                                         0
                                         t
                                             10%
                                            xd
Calm = 2.83%
Figure m-2
Wind Rose at Meteorological -Station
114842, Peoria, Illinois,  January 1964
through December 1973 (National  Clima-
tic Center. 19?4a)
Figure IH-3   Mind Rose at Storage Basins,
               MSDGC Fulton County Project
               Site (HSDGC, 1975b)

-------
Table IIi-3.   Average Seasonal Atmospheric Stability by Percentage. Greater Peoria Airport
              (National  Climatic Center, 1974)

Pasquill Stability Class
Period
SPRING:
(March, April, i Hay)
SUMMER:
(June, July. & August)
FALL:
(September, October, & November)
WINTER:
December, January, A February)
ANNUAL
A
Extremely
Unstable
0.24
1.01
0.04
0.01
0.33
B
Unstable
3.51
10.53
2.57
0.42
4.28
C D
Slightly
Unstable Neutral
8.97 65.26
18.01 38.93
8.81 54.71
5.04 72.38
10.24 57.74
E
Slightly
Stable
11.30
11.36
14.70
11.71
12,26
F 6
Extremely
Stable Stable
7.95 2.77
13.56 6.60
13.76 5.40
8.07 2.38
10.84 4.30

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III-4 Starry of Cltatlc Conditions  in the Area of PeorU,  Illinois (National  CliMtie Center. 1974*. 1974b,  1975)




Prevailing wind
Period


SPRINC


SUHBt


FAU


MUTER


March
April
Niy
June
July
August
Seota«6er
October
Nov**er
DtcMfetr
January
February
Direction
MHH
S
S
s
s
s
s
s
s
s
s
MNH
SS
12. 3
12.3
10.5
9.2
8.0
7.8
8.8
f.S
11.2
10.9
11.2
11.6

Average Nufcer
of Days with
Rangt of Heavy fag or
Relative Visibility of 1/4
Muaildity
64-81
56-76
57-81
56-81
59-86
59-87
65-88
st-ss
66-83
73-83
68-78
66-7?
Nile or Less

2
1
1
1
1
1
1
2
2
3
3
3
Percent of Tine Each
Ceiling Height
Equal to or
Less than 400 ft.

0,37
0.09
0.20
0
0
0.12
0.16
0.35
O.S4
1.06
1.03
0.58

Light Winds

0.25
0.28
0.79
0.52
0.93
0.76
0.40
0.70
0,21
0.39
0.57
0.92
Year
Joint Frequency of
Height and Light Hindi

0.0116
0.0032
0.0187
0
0
0.0102
0.0094
0.0292
0.013?
0.0532
0.0739
0.044?
VEA*





LEWTH OF RECORD
                      10.3
                Jl
                                 62-83
                                  ts
                                                  21
                                                  31
                                                                                                           0.2678

-------
tor contributing to noor visibility.  Ground fog normally occurs during  the  night
and at dawn.  Periods of low ceiling height and light wind can  lead  to severe con-
ditions during which air pollutants accumulate at ground level.  The annual  joint
frequency of low ceiling height and light wind is 0.27 percent  which ig  equivalent
to only 24-hour s in a year.

    2-  Gener al "Bopogr aptiy

Strip-mining activities in the project area have left steeply sloping spoil  rounds
and a number of long, narrow lakes with abruptly sloping shorelines  scattered
about the project site.  Uneven settling of unconsolidated and  clayey soils  within
the mined sections hoa pcoJucad an almost undulating surface. In addition, the pro-
ject area is covered with rocks and potholes.  The application  fields have been
prepared for agricultural use by leveling and grading, filling  potholes  and  re-
moving cocks.  As a result, the application fields themselves have a level to
gently sloping topography.

The capacity of storm runoff to carry solids such as silt or  spoil fines may have
been increased by the steepened slopes resulting from coal stripping and piled,
abandoned spoil.  This is evidenced by several spoil downwashes on the project
site.  The leveling and grading accomplished for site preparation should have
significantly reduced the erosion problem.  Site areas not developed as  sludge
application fields may continue to erode, causing water quality problems.
B*  3eology ftnd Soils

Environmental impacts such as erosion or groundwater contamination, and  socio-
economic factors such as land development potential, will depend to a great degree
upon the geological and soil characteristics.  This section contains a discussion
of past and present geological conditions and a description of soil characteristics
in the vicinity of Pulton County.

    1.  Geological Character istics

The land surface is covered with unconsolidated Pleistocene soil deposits in this
general area which nearly obscure the bedrock except near the valleys of major
drainage channels.  A brief discussion of the bedrock and Pleistocene stratigraphy
is presented in this section, concluding in a description of the characteristics
of mine spoil.

Outcrops of bedrock reveal that the geological formation consists of shales and
sandstones, of the Pennsylvanian Age Carbondale Formation containing several strata
of coal and limestone beds.  Figure I I 1-4 shows a typical stratigraphic  profile.
A soft gray shale known as Canton Shale, approximately 40 to 60 feet thick, lies
inmediately beneath the surface soil deposits.  This shale is underlain  by 1 to 2
feet of gray, fossil if erous limestone known as Saint David Limestone.  Beneath this
stratum are 4 to 6 feet of black shale, which merges into a high-quality coal de-
signated as No. 5 or Springfield coal,  nils coal seam has a thickness of 4 1/2 to
5 feet and is located near elevation 580.  Die relatively shallow depth  and high
quality of this coal has led to considerable strip and shaft mining throughout the
general area,  the coal is underlain by soft clay to shale and several other thin
strata of limestone and shale,  these layers have a total thickness of approximately
                                  Ul-9

-------
20-30 ft.
10-20 ft.
40-60 ft.
1-2 ft.
4-6 ft.
4.5-5 ft.
5-8 ft.
* Surfaro





Tr^sr
<*>•£
*«>>
'.£•7=
=%{'.••
=™s*=


___ Loess
— Glacial drift and alluvial deposits
	 Canton Shale
St. David Limestone
	 Black Shale
•••1 No. 5 Coal

•••••i
i--5arj5=
y.T^l
-*.' 	 ! 	 ' L
ggj3Z=
v^PW?
^K_X_X_XL
"^l^^l
ZzFsz^z
	 Covel Conglomerate
Hanover Limestone
Black Shale
No. 4 Coal
Figure m-4   Typical Stratlgraphlc Profile 1n the Project Area
               (A&H  Engineering Corporation, 1971)
                           111-10

-------
5 to 8 feet.

The bedrock surface is covered by  a  30 to 50-foot mantle of glacial drift or drift-
related deposits.  The bottom layer  is composed of a  silty clay  to clayey silt
matrix resulting from glacial till during the Illinois Slacial Bra.   Illinoisan
glacial till is topped by a windblown silt material known as  loess, which often
reaches thicknesses of 20 to 30  feet in this general  area,  soil borings on the
project sita indicate a thickness  ranging from 3 to 40 feet,  averaging  about 20
feet.  Past coal mining operations have modified this stratigraphic profile.  The
uppermost bedrock strata and the unconsolidated sediments have been ranoved and
remolded into a generally similar but locally variable soil mass (A4H Engineering
Corporation, 1971).

    2.  Soil Characteristics

A study of the project site to identify areas with basically  similar  soil and
groundwater characteristics was  conducted L. T. Hooper (1971).

According to Hooper, the project site can be divided  into three  basic areas:

              . Area 1 — completely strip-mined land

              . Area 2 — virgin or  place land with a cover
                          of loess over glacial till

              . Area 3 — alluvial land within major  stream beds,
                          affected by mining activities.

The spatial distribution of these soil areas is presented in  Figure II1-5.

During surface mining operations, the overburden soils and cap rock in  Area i
were removed from the entire area to obtain coal.  Therefore, the  subsurface of
Area 1 consists of a heterogenous  landfill which is composed  of  cohesive fine-
grained soils with pockets and discontinuous zones of boulder-size rock.  These
rearranged and redistributed overburden soils are rather impervious.  Numerous
depressions were created, most of which have no drainage outlet,   large lakes
maintain nearly uniform levels which are controlled by culverts.   Mining activi-
ties have resulted in slightly different features in  parts of Area 1.   A sub-
classification of Area 1 and its description can be found in  the Subsurface
Investigation and Evaluation - Final aeport (Hooper,  1971).

Area 2 is the area in which no strip-mining activities have been undertaken.
Approximately 3 to 40 feet (averaging 20 feet) of loess, which is  comprised of
50 percent clay and 50 percent silt-sized particles,  covers the  glacial soils.
These materials have low permeability and, depending  on vegetative cover and con-
servation practices, are subject to erosion.  A groundwater table  at  a depth of
approximately IS feet is normal  throughout the area with the  exception of slopes
leading down to stream valleys.  It  is known that much of Area 2 has  been mined
underground by tunneling methods (Hooper, 1971).

Area 3 consists of alluvial soils within major stream beds, and  defines moat of
the continuous drainage channels.  These soils are relatively impervious to perco-
                                   111-11

-------
            Area 1

      F=i Area 2

      \1 Area 3
            Lake

          Land Slide Area
                spoil
0  14  1/2 3/4 1  mile    spoil
I   i.i   i H        oytwash
                                                                                                spoil pile
                                                                                                spoil outwash
                                                                                            lake
                     Figure III-5   Spatial Distribution of Soil  Areas  (Hooper,  1971)

-------
l?tion watar, but are roderataly perineabls to horizontal  flow,  h high groundwater
table is normal here.

Based on field pumping tests, laboratory tests, and anal/sis of existing ground-
water conditions, the permeability of the overall mass of mine spoil  is estimated
to be in the range of 10-3 to 10-5 centimeters per second (on/sec).   The vertical
permeability of soils was estimated by laboratory tests to oe from 10-5 to  10-9
cm/sec.  According to Casagrande's classification of soils by permeability, these
soils ara impervious, non-draining or poorly draining (Casagrande, 1943).   However,
some zones or Layers may consist of broken shale and sandstone slabs  or blocks
arranged in a way that provides a rapid path for water (A&H Engineering Corpora-
tion, 1971).  Such areas -nay possess a permeability as high as 10-1 cm/sec.
Although they ara seldom continuous for more than short distances, these zones
are considered important in reservoir areas.

There ara no published Soil Conservation Service soil surveys available for
Pulton County.  However, the Pulton County Soil Conservation Agent at Lewistown
provided highly useful information concerning the agricultural capability of
local soils (see Section F. 3, of this chapter).

Over 52 soil bocings were made to bedrock to determine the background characteris-
tics of soil and rocks.  Physical soil characteristics, such as permeability,
were used to examine potential groundwater contamination  from the project.

The chemical composition of both mining spoils and plane  land sampled from  a 0-6
inch depth is summarized in Table III-5.  Included are the mean, maximum and
•minimum values of exchangeable calcium, organic carbon, and hydrochloric acid-
extractable metals such as aluminum, cadmium, copper, chromium, lead, manganese,
nickel, and zinc.  In general, the spoil material and place land have approximate-
ly equal concentrations.  The mining spoils, however, contain significantly higher
levels of cadmium and copper,  increased Cadmium and Copper concentrations  in
spoil material probably arise from the black shale above  the coal seam which is
now dispersed throughout the overburden spoil materials.  The spoils  also contain
more exchangeable calcium but less organic carbon than place land.  Tns higher
organic carbon content of the place land indicates that it is more fertile. .

The characteristics of the calcareous mine spoil material have been analyzed sepa-
rately and are presented in Table III-6.  Clay species in the clay fraction of the
soil were investigated by the potash content, surface area, and x-ray diffraction
patterns of the soil particles.  Ill it? is the dominant mineral and accounts for
54 percent of the total clay.  Kaolinite was estimated at 27 percent, and chlorite
at 8 percent, vermiculite at 11 percent of the total.

C.  Hydrology tod Water Quality

This section describes the hydrologicai and water quality characteristics of the
project area.  The purposes of this review are to define  local hydrologicaL pat-
terns, establish baseline water quality information, and  define their interrela-
tionships.  Moreover, the background quality of ground and surface waters and
their respective flows will determine their vulnerability to project  operations.
                                  111-13

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               Table III-5  Metals, Exchangeable Calcium and Organic Content of Spoil Material
                            and Place Lands in Fulton County Prior to the Application of Digested
                            Sludge  (MSDGC, Spring 1972)

Mean
Minimum
haximuir
Mean
Minimum
Maximum
0.1N HCi Exti actable Metals
Exchangeable Organic
Mn Zn Cu Cd Cr Ni Pb Al Ca Carbon
(ug/9 of Oven Dry Soil (*) (1)
509 154 31.7 6.7 4.79 3.52 1.22 0.2 0.83 0.61
384 79 11.1 3.2 1.90 000 0.63 0.24
620 208 €9.4 10.0 19.1 8.50 3.40 1.36 1.12 1.56
S40 146.1 31.4 7.5 2.62 4.55 1.23 0.08 0.36 1.64
317 92.0 10.3 3.2 1.48 2.23 0.30 .0 0.20 0.92
741 258.6 68.7 12.7 3.73 7.94 3.17 0.66 0.72 4.55
THREE SUCCESSIVE 5-MINUTE EXTRACTIONS OP 1.5 CRAMS OF SOIL WITH 15 MILLILITERS OF ACID

-------
   Table III-6     Selected Characteristics of  the Fulton  County
                   Calcareous Mine Spoil Material  (MSDGC,  1974)
Parameter and Unit                                        Quantity
Spoil Material

     pH                                                        7.i
     B.C. umhos/cm                                             0.46
     1/3 bar watec (%)                                        26.72
     15 bar water (I)                                         12.49
     Cation exchange capacity  (meq/100 g)                     14.8
     Ammonium fixation capacity  (meg/100 g)                    5.2
     Silt content (I)                                         64
     Clay content (I)                                         28
     Sand content (I)                                          0
Clay Fraction Only

     Illite  (%}                                               54
     Kaolinite (I)                                            27
     Vermiculite  («)                                          11
     Chlorite  (%)                                              i

     Surface area  (m2/g)                                     138
     K20  (i)                                                   4.47
     MgO  (%)                                                   2.29
     CaO  (%)                                                   1.15
     Na2° (*)                                                  0-82
                                    III-15

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    1.  Surface^ Water Hydrology

    project site is located within the  Illinois  River Basin,   tost of the
surface water is drained by Big Creek and  Slug Run,  a branch  of Big Creek,  to
Spoon River, a tributary of the Illinois River.  The tributaries associated
with the project site, on a regional scale,  are  shown in Figure III-6.  The flows
of Big Creek and Spoon River have been  monitored at  these USGS gage stations.
Two stations are located on Big Creek at St. David and  near Bryant, and the third
on the Spoon River at Seville.  The daily  average, maximum and minimum discharges
at these stations  in 1972 and 1973 are  shown in  fable III-7.   (The detailed drain-
age pattern neac the project site is depicted in Figure III-7).

    fable II1-7         Daily Discharges at  USGS Sage
                        Station.? (USGS,  1972 and 1973)
                              1972                        1973

Sage Stations         Daily Discharge  (efs)*       Daily Discharge (cf8)
                      Mean  Maximum Minimum       Mean   Maximum  Minimum


Big Creek at St. David
(USGS Station 05570350)    16.9      137    1.9       39.4   700     7.6

Big Creek near Bryant
(USGS Station 05570370)    28.3      259    5.7       56.4   803    11.0

Spoon River at Seville
(USSS Station 05570000)   625.0     5150   37.0       —       —     —

*cubic feet per second


Based on a soil permeability of 10-5 cm/sec (as discussed in Section III-B), the
vertical infiltration rate ranges from 1.2 X  10-6  inches per hour  for  a rainfall
intensity of 1.01 inches per hour.  The amount of  rainwater infiltrating  the
soil surface is relatively insignificant when compared to surface  runoff.  This
poor soil drainage forces moat rain water to  be discharged to creeks or streams
as surface runoff.  Flood hazards are  generally confined to the  flood plains.

    2.  Groundwater Hydrology

Migration or drainage of groundwater is much  more difficult to define than for
surface water.  With the aid of well-water elevations and river  water  levels, the
groundwater flow in the general arts has been interpreted qualitatively.  The
water elevations in 22 wells within and around the project site  have been observed
monthly by M5DQC personnel.  After  some data  reduction,  all observations  are
expressed as an average value, accompanied by its standard deviation and  range
                                   111-16

-------
                 BU.XITVILLE
                      f
                       •IVTON      F1AI,
                                                                            met
                                                                             LAKE
                                                     ~ —

                                                     ftlttlMIL Illtl 1UI
                                                         ^^_ WOO* RIVER VMU.EY
                                                              SCENIC DMVE

                                                         	HMNKlllli

                                                           GO cmm Niumii •IIIEI

                                                           ra LS HKMWAV MARKER

                                                           0 STATE HKHIWW NARKER

                                                           A fPCClAL POtlNT OF INTEREST



                                                               Project Are§
                                     ANDEMSON LAKE
Figure  III-6.   Illinois  River and THbutarlts Associated with tht Project Site
                                   ni-i?

-------
9*~aA*t*  L*>**
^«f*»    *•!*»
        Ca«l» Rtt ,
 fc«R»8\:    I /
      i  '•<••>  ^/y
l.ncrmq^hjx' ^V
            Figure  m-'«  Pattern of Groundwater Flow (MSDGC 1372a through 1975g)
                                                lll-io

-------
of variation throughout tha observatisn  osriods.   Tha  results aca sunnac izei in
Table III-8.  (Ml water elevations  see  based  on  'JS3S  namn sea laval  with the
1929 adjustment.)  utilizing wall watsc  and  stream watsr  lavals,  tha  pattarn of
gcourdwatar flow can be approximated by  the  "streamline"  method.   This pattern
is displaya:! in Figure lli-7.

The intar actions between groundwatar  and surface  watsc  systems cannot be attri-
buted solely to soil percolation or  trans-migration because soils in  this aras
are relatively impermeable.  Therefore,  surface water  flow is ganarally Jarivsd
from upstraa® tributary flow, atom  runoff,  and snow melt.   Paths of  raoid flow
betwasn ground and ma face waters nay furnish  the mechanism for  grouniwatar
depletion.

3.  *atar juality

To ass33s possible impact on water quality fron project operations, surface  and
grounSwater quality prior to project inpiaaentation t»ust  be astablishei.   Using
1971 as tha baseline year, stream watsr  quality at nonitorinj stations 3i, 32,
and S3 (see Figure V-4) is suwnarizeJ in rable III-9.   Thase leasuranents were
then conparei to standards for the State of  Illinois whish aca presented  in  Chap-
ter II.  The 1971 oH values and the  chloride,  cadniu'H,  chroniun,  manganese,
Tiercury, niskel, and zinc concentrations weca  generally in confortiance with  water
quality standards,  ^vetage concentrations of  aulfate  ions (S34),  copper  and laad
were within or marginally close to standards,  although the standards  ware violat33*
occasionally, as evidenced by the 1971 naxinon concentrations which wera  all  Mjher
than allowed,  \mionia nitrogen (OTI -N>. ir?«s,  ir.3 Cscal  coliform concentrations
violated standard on nuuet^js occaiions, indicating oollution in  3ig Creelc.
      violations were not caused by  the  sludge application project,
Stations 31 and S2 on Big Creek constituta an  upstcsm-jownstraati  pair  relative
to tha project site.  Poor water quality  at upstcean station  51, which  carwot
be affected by the project,  is attributabla to 32wage  affluent  fron  the Canton
sewage treatment plant and other sources  of pollution  uostrean  from  si.  Sine-
rally, the strean at station 31 was  lower in quality than  at  the downstr3an
station 32 with respect to aitnonia nitrogen, chlorine, sulfmte  ions, copper  and
fecal conforms.  This indicates thtt clsansing and dilution  occurred along  the
approximately 6.5-mile stream reach  between the two stations,   tavels of  caJmiun,
iron, nickel, and zinc remained ralativaly constant at both stations.   Surface
runoff and leachates originating in  the strip-mi led area along  this  sagne.it  of
9ig Crsak nay contribute to  increased levels of chromium,  laad  and aanganssa in
tha downstream direction.

Sroundwatat samples wert collected from a number of wells  anJ one  spring.  Tha
measured ranges of all ground water quality parameters  reported  in  1971  and 1972,
prior to project operations, are presents* in  Table 111-10.   in this table,  the
welt associate] with naximua raailng of m given parameter  is  designated by paren-
theses.  Hells W2, i*4, W9, Mil, W12, and  W13 indicated high degrees  of  contamina-
tion. Variations in concentrations of nitrite  and nitrate  nitrogen
ml ammonia nitrogen at all monitoring stations ire suimarizaJ  in  Table
III-ll for 1972.
                                   111-13

-------
                          Ttole  HI-8 Htvitlons of Hell  Miter  (NSUC 1972 I through 1975 9)

M*11
Hun Elevation |ft.**1)
Stmdtftf
Range of
Deviation (ft )
»*rf»t1ori (ft.)
Obiirvatloro
HI W2 W3 H4 MS H6
	 617.9
78
	 24.0
0 0 0 0 0 18
U7
606.8
2 0
6.0
20
H8
632.2
3 i
9,9
11
M
S93.6
2 1
(.0
18
U10
621.3
6 4
20.2
18
Hll
624. 5
1 4
4.0
9
H1Z
628.1
j 7
4.0
19
M13
601.6
0 9
3.0
13
H14
638.4
1 5
S.O
16


(toll
HIS MIC Hi? U1B W19 U20
HZt
M22
H23
H24
H2S
H26
H27

Htm Elevation (ft.Ml)   656.7  614.8  625.3  632.0  608.0  600.0  572.0  571.4  601.2 675.7  647.7  CS9.fi  673.8
SUr*d«rt Deviation (ft.)   0.4    0.6    3.7   1.2   16.2     —     —    1.3    3.2   2.4    9.3    1.9    6.2
tang* of tarlttfM (ft.)   0.7    2.0   12.0   3.3   Cl.l     —     —    4.0   10.0   8.0   25.0    4.0   21.0
Observations               4     10     1C     $     14      1      1     10     20    21     20      7     19

-------
Table III-9   Surface Water Quality in 1971  (HSDGC,  1971)
Parameter
and Unit

PH


cr
(mg/l)
_2
so/
(mg/i )

WH,-N
(rag/1 )

Cd
(ing/1)

Cu
(mg/l )

Cr
("9/D
Monitorinq Station

mean
max.
min.
mean
max.
min.
mean
max.
min.
mean
max.
min.
mean
max.
min.
mean
max.
min.
mean
max.
rain.
SI
7.9
8.8
7.3
53
120
24
389
1,250
120
2.6
8.1
0.3
0
0
0
O.OE
0.13
0
0
0.18
0
52
8.1
8.7
7.1
28
72
4
381
879
80
1.8
6.6
0.1
0
0.06
0
0.02
0.06
0
0.02
0.28
0
S3
8.0
8.3
7.5
10
15
6
606
743
424
0.4
0.7
0.1
0
0.04
0
0.01
0.03
0
0.02
0.12
0
Parameter
and Unit

Fe
(mg/l)

Pb
(mg/l )

Mn
(mg/1)

Hg
(/g/i)

Ni
(mg/1)

Zn
(mg/1)
Fec?1
Col 1 forms
(1/100 ml)
Monitoring Station

mean
max.
min.
mean
max.
min.
mean
max.
min.
mean
max.
min.
mean
max.
min.
mean
max.
min.
mean
max.
min.
SI
1.5
4.8
0
0.05
0.2
0
0.7
0.98
0.06
0.05
0.2
0
0
0.35
0
0
0.2
0
7,500
34.000
270
S2
1.3
4.5
0.1
0.09
0.28
0
0.86
1.31
0.60
0
0.2
0
0
0.33
0
0
0.2
0
1,700
3,800
20
S3
0.3
0.6
0.1
0.08
0.2
0
0.47
0.96
0.24
0.2
0.6
0
0
0.31
0
0
0
0
920
4,000
80
                           111-21

-------
Table 111-10.  Ranges of Various Water Quality Parameters  1n  Well  Water,
               1971  and 1972, and U.S. Averages (MSDGC,  1972a through
               1975  g; Durfor and Becker,  1964)
Parameter
and unit
PH
Total P
cr1
S04-2
Alkalinity
(CaC03)
Conduc-
tivity
Al
Cd
Ca
Cr
Cu
Fe
Pb
Hg
Mn
Hg
N1
K
Ha
Zn
Fecal
Colifomis

mg/1
rag/1
mg/1
rag/1
jumho
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
jag/L
mg/1
mg/1
mg/1
"g/1
1/100 ml
1971
6.6-9.0
0.6.0 (W9)
2-500 (W4)
1-500 (W4)
4-1,650 (Wll)
90-1,050 (W17)
—
33-495 (yi2)
0-0.1 (H6)
0-0.39 (W6)
0-0.5 (W2)
0-118.7 (W9)
0-1.0 (W19)
21-390 (W12)
0-12.7 (W9)
0-20 (W19)
0-0.42 (W10)
0.1-24.9 (W4)
11.7-310 (W8)
0-390 (W12)
3-<100
Range 1n Quality
of Proundwater
Used for Water
,Q7? Supplies 1n 17
U.S. Study Areas
e.r-?.2
0-0.54 (W2)
2-488 (W4)
3-1,812 (M14)
100-1,000 (W11)
200-4,000 (W4)
--
38.5-883 (Wl)
0-0.22 (W2)
0-0.05 (W13; W18)
0-1.82 (W2)
0-182.6 (W13)
0-2.2 (W2)
23-410 (H14)
0-8.3 (W12)
0-2.8 (W7)
0-0.3
0-19.4 (W4)
7-646 (Hll)
0-140 (W10)
0-120 (M7)
6.7-8.7
—
2.0-92
0.8-572
—
108-1,660
2.9-83
3.2-121
--
ND-1.1
<0.8-15
1.1-6,600
ND-38
0.3-120
ND-340
—
ND-<15
0.4-30
6.1-129
ND-C470
— -.
NO • not detected.
                                  IU-22

-------
Table Tii-ll    Levels of Nitrite and Nitrite Nitrogen  and
               Ammonia Nitrogen in Well Maters in 1972
               (NSDGC, 1972a through 1975g)

Well
Ml
W2
M4
M5
M7
W8
W9
W10
Wll
Ml 2
Ml 3
M14
Ml 5
yi?
M18
Ml 9
N02
Mean
0,03
0.03
0.29
0.04
0.16
0.01
0.02
0.02
0
0,03
0.08
0.01
0.06
0.81
0.03
0.03
+N03-N (rag
Max.
0.11
0.11
1.51
0.27
0.28
0.05
0.09
0.09
0.02
0.13
0.21
0.07
0.28
2.50
0.11
0.13
/I)
Min.
0
0
0
0
0.04
0
0
0
0
0
0
0
0
0
0
0
NH
Mean
0.40
0.30
1.1
0.2
0.5
1.8
1.0
0.8
1.8
0.8
0.6
0.6
1.1
0.5
1.8
0.99
3-N (mg/1)
Max.
0.70
4.10
1.9
0.6
1.1
4.3
1.7
1.6
2.1
1.3
0.8
1.3
1.9
2.2
2.7
2.0

Min.
0
0
0
0
0.1
0
0
0,4
1.4
0.2
0.3
0.1
0.3
0.1
1.3
0.0
                           m-23

-------
The U.S. Departmeat of Interior conducted a survey of water quality  Crnm wells  and
infiltration galleries in more than 17 study areas throughout the United States.
The range in quality of ground water used for water supply  is sunwarized in Table
111-10 (Durfor and Becker, 1964).  Comparison of the baseline groundwater  in
the project area with that from the Department of the interior study indicates
that concentrations of Chromium, copper, iron, lead, manganese and nickel  in  the
project area were within the range found elsewhere in the  United States; the
ranges of pH and zinc concentration were close to the national values.  Concentra-
tions of chlorine, sulfate ion, calcium, magnesium, and sodium were  higher than
those found nationwide, indicating that dissolved solids or salt concentrations
were relatively high in the project area, at least with reference to standards
for groundwater used as a water supply.

The recommended maximum level of nitrate nitrogen for drinking water  is 10 milli-
grams per liter (mg/1) as nitrogen (U.S. Department of Public Health Service,
1962 and 1969).  If all ammonia nitrogen were oxidized to  nitrite or  nitrate, the
range of nitrite and nitrate nitrogen concentrations in the project  area would
fall between zero and 5.2 mg/1.  This range falls within the lower one-third of
the national range of 0 to 17 mg/1 as reported by Durfor and Becker  (1964).  The
maximum nitrite and nitrate concentration of 5.21 mg/1, recorded at  well W4 in
the community of Cuba, was well within the recommended drinking water standard.
The baseline quality of groundwater in the area of the project appears to be com-
patible with use for public water supply.  However, the high overall  concentration
of dissolved minerals, approximately three times the the U.S. standard of 500
pom could necessitate extensive hardness removal.  Most municipal groundwater
supplies in the project vicinity are obtained from deep wells unaffected by sur-
face land disturbance.

D.  Biology ftnd_ Ecosystems

Ihe following discussion of biology and ecosystems is divided into two sections:
fish and wildlife, and natural vegetation.  Within each of these are  discussed
major species, both past and present, and the rare and endangered species possibly
inhabiting the project area.

    I-  Pish and Wildlife

Fish abound in most of the local lakes, and are the most numerous vertebrates
in the study area.  The predominant fish are bluegill, green and redear sunfish,
black crappie, yellow and black bullheads, large-mouth bass, and catfish.

h great diversity of wildlife currently inhabits the project area.  Turtles,
frogs, water insects, and crustaceans ace abundant in lake Evelyn.  There are also
some black snakes and signs of beaver activity.  The steep-sided lakes formed by
strip mining have fewer crustaceans and water insects, but muskrats  and frogs
are abundant.  Land animals include dear, fox, raccoon, skunk, opossum, rabbit,
coyote, badger, groundhog, and weasel.  Water fowl include ducks, geese (es-
pecially the giant Canada goose), swans and an occasional  great blue heron.  Other
birds include crows, hawks, warblers, robins, starlings, sparrows, red-winged
blackbirds, bluejays, and finches.

Within historic times, other animals have populated Fulton County.   These prairie
                                  III-24

-------
aninals included populations of alk, buffalo, trumpeter swans, sandhill ccaneSf
aid th» priicie chicken, 13 well as large predators like the cougar, bear, and
wolf.  3ij alusstsu, * oroject aimed at re-creating a native prairie on cart of
tha «<50GC property (the 2,972-acre former Sale Fir*) Is planned to create habitat
           ss for a nuiiber of original prairie animals,
Six rara and endanger ad animal species are listed for the region containing Illi-
nois,  Fish spaciss ace the longjaw Cisco and th* blue oika.  didangered birds
ars the arctic peregrine falcon and Kir tl and1 3 warbler, and .mammals are the
Indiana bat and ths eastscn ti;*er *olf.  Wtevar, the "probability of any of thass
soecias b?ini txasent in the project area is extraualy fsnota, ard shouli there-
fore not ocssant a oroblea.

    2-  Natural vegetation

Tm two tyoss of vegetation in the projact area consist of cultivitaJ T»nocultutfss
( oreloTiinantly corn) in the sludge application fields, and the area's natural
vegetation.  Tha following is a cliscussian of this natural vegetation ani tha
locally car a and enian-gecei plant species which night occur.

The or edoninant geassaa sre brome, alfalfa, and teeJ canary grass.  "Drees aca
those generally propagate! by wind-blown seeds, including sin, cottonwool, and
willow.  «*33t 3f the lakaa in the project area ware famed from tha end cuts of
strio-nining operations, and have steeply sloping si lea and a small littoral zone.
This zone supports SOTO growth of Char a and Si tell a. Diatoms are the preSaiinant
alanktonic species.  »*> cattails or reeds are present.

^ £ew lakes have gently sloping sides ini a relatively large littoral zone,  lhass
lakas hav? an abundance of lake cattails and reeds. Diatons and lesser amounts
of green algae are the najor planktonic species.  Sybtoerged aquatic vegetation
includas atonaworts, Chara, 'aitella. Blpdea, Vallssenaria, an.1 sone of ths Potona-
getons.  Considsrabla miifcers o^ currant, raspberry, and blackberry bushes grow
along the banks.

Thare are three endangered plant species which vay axist in ths oroject area
(Federal Register, July 1, 1975).  One, an endanger ed woodland species, is fetar
chase i, a woodland astar.  Two endangered prairie species are Lesoedeza lepto-
stachya, a bush clover found on dry prairie, and p«t aloatenum fel loaim, a or air ie
clover founl near river banks.

E,  Population .tod Seonaiics

Tnis section is a description and interpretation of tha baseline data needed for
the assessneit of ths socio-economic and land use iipacts of the project.  What
is presantad here is a aelactive representation of a broad data collection effort
and contains only those data which are relevant to tha prediction of impacts.  The
two main topics discussed in this section are demographic and economic characteris-
tics.

    I.  Oeaoiraphic Characteristics

Population will be a najor factor in determining tha types of land use for which
                                  111-25

-------
there will be a demand in the project area.  The following paragraphs discuss
historic and recent demographic trends in Pulton County, and give population
projections developed from analysis of trends.  The section concludes with a
discussion of family income in the County.

        a.   Population trends - fable 111-12 shows historic population trends
in Pulton County,The County's population decreased from approximately
50,000 persons in 1910 to about 42,000 in 1970.  Slight increases in the popula-
tions of Canton, Lewistown and Farmington slowed the decline in total population
to 6.1 percent between 1940 and 1970.  However, an increase from 41,000 in April
1970, to 42,000 in July 1974, indicates that past declines may be reversed by
new factors which could lead to future population growth,  the general demographic
trend prior to 1970 was one of declining rural population, only partially balanced
by increase in local town populations.  approximately 30 percent of the population
was rural in 1910, declining to less than TO percent in 1970 (U.S. Bureau of the
Census, 1930 to 1970; Bnviro Control, Inc., 1975).  Rural population decrease has
been caused largely by national decline in the labor intensiveness of farm produc-
tion.

TOwnship population data (1960-1970) show that growth is occurring along a corridor
of townships which cross the County from Canton and Orion Townships on the east to
Vermont Township on the west (see Figure II1-8).  On both sides of this corridor,
township population is declining,  it is noteworthy that these declining areas
are largely agricultural.  The heavily strip-mined Townships of Putman, Canton
and Orion show significant population increase.  Thus, in terms of population
growth, economic development tends to coincide with mining activities.  During
this same period the communities of the County showed a pattern of population
change consisting of three components:

                  Major communities (Canton, Cuba, Lewistown, and
                  Farmington) increased significantly

                  Communities in the predominantly agricultural western
                  part of the County (Glltsville, Ipava, Marietta, and
                  Sroithfield) declined.

                  Other communities grew slowly

        D-   Population projections - Future population growth is predicted in the
most recent projections describing Pulton County and its surrounding water resour-
ces sub-region.  The 1972-E OBERS Projections predict a 43 percent population
increase between 1970 and 2020 for the 29-county water resources sub-area contain-
ing Pulton County,  The basis given is the expected expansion of manufacturing.
Increased opportunities in industry would facilitate the maintenance of the exist-
ing population, and would encourage population in-migration to the areas near new
industrial plants.  Consistent with the 1972-E OBERS Projections are population
projections for Pulton County which have been released recently by the State of
Illinois (see Table I11-13 below).  These 1975 projections by the Bureau of the
Budget, State of Illinois, predict a 29 percent increase in Pulton County's
population between 1970 and 2020.
                                  111-26

-------
teres
             Table m-12  Historical Population Trends in
                          Fulton Cou-ty (U.S. Census of Popu-
                          lation)
TMMhfp
As tor 1*
tanner
Eernadotte
Buckhjar:
Canton
Cast
Oeerfield
ElUsvlUe
Falrvltw
farmen
farming ton
Harris
Hsbel
Joshua
Kerton
Lee
Lewlstown
Liverpool
Orion
Pleasant
Putman
Union
Vermont
waterford
Woodland
teu«9 Hickory
Co.nmunity
Astoria
Bryant
St. David
Canton
NorHs
Smithfield
Elltcvltle
Filrvie*
table Grove
Farming ton
K*rf*tta
Lewd town
Ipav*
Cub*
Avon
Vermont
London Hills
Banner
Ouflftrvline
Liverpool
Land Area*
36.6
33,7
37.7
3S.1
35.7
38.7
34.8
13,8
36.4
35.7
36.2
33.8
29.5
35.8
27.3
37.2
3i.7
42.2
36.5
37.9
34.8
36.7
36.7
21.3
3*,7
24.3





















1970
1,738
694
333
1.770
15,837
819
424
230
923
498
3,993
520
300
641
178
404
3,252
844
898
1.018
2,115
1.387
1,399
238
596
869

1.281
326
773
14,217
3S9
318
137
601
469
2,959
169
2.706
603
1,581
1,013
947
612
235
282
218
1960
1,781
739
362
1,974
15,080
83$
476
280
921
561
4,052
589
348
707
195
475
3,163
932
776
1,128
1,791
1,443
1,423
266
700
957

1,206
346
862
13,588
307
329
140
544
400
2,831
201
2,603
623
1,380
996
903
-
247
284
184
1950
1,976
755
369
2,257
15,056
948
528
319
1,029
617
3,150
680
387
813
283
496
3,237
1,057
789
1,199
2,025
1,340
1.490
346
843
906

1,308
395
812
11,927
319
35$
157
S68
481
2.651
178
2,630
667
1.482
870
940
.
215
292
•
1940
1,951
690
671
2,320
14,162
1,018
56(1
423
1.065
$67
3,937
903
507
857
370
5P4
2,943
1,071
900
1.299
2,159
1.370
1,590
352
976
940

1,292
387
859
11,577
339
3S9
216
528
480
2.225
193
2.335
629
1.620
803
94S
_
172
«•
*"
19JQ
1,997
617
643
2.S89
13,937
987
630
331
1.113
976
3,941
813
460
874
338
627
2,884
95$
781
1,333
2,123
1,355
i.602
303
976
798

1,189
442
977
11,718
329
315
164
522
463
2,269
202
2,249
63S
1,479
799
$48
432
,.
_
—
                                m-27

-------
            UNION


           Avon
                   -56
              LEE
                  -71
                        S
                           OJ
    London
        Mills
      -88
      YOUNG
     HICKORY
  DEERFIELD


         -52
FAIRVIEW


 Fairview
 e£3   +2
                                          JOSHUA
       -6C
                                                       Farmington
                       O
                                                        FARMINGTON
                                                                  -54
               CANTON

            Canton
       r
   0 Ft. 16000
                                                  ORION
      +122
            HARRIS
              a
             Marietta
          -69
   CASS

        -16
   0
 Snrithfield
                                                +324
              i JCKHEART

                 J  P
            JJunfjririTine
            OBryant  -204
                                              Banner
BANNER
   -45
                 -63

           FARMER'S

         Table  Grove
          h	
                LEHISTOWN
BERNADOTTE
            VERMONT
                  -24
             Vermont
                         PLEASANT
                                 -110
           ASTORIA

          Astoria
  WOODLAND
                 -43
                                -104
                                       -17
                     Township Population Change, Plus (+) or Minus {-)
Figure OT-8    Fulton County Township Population Change,  1960-1970 (U.S. Census of  Populatl
                                           111-28

-------
Table 111-13     Population Projections  for Fultrn County
                 (Illinois Population Projections, 1975)
1970

Census     1975      1980      1985      1990      2000       2020

41,383   41,303    42,031    43,196    44,691    49,454    54,048


        c.   Family income - Median family income in Pulton County  is relatively
high when compared to other predominantly rural counties  (Griffin and Chicoine,
1974).  Principal causes for higher income art the availability of  nearby manu-
facturing employment and historic labor-intensive nodes of agricultural and
strip-mine production.  Much of the manufacturing employment  pays high union
wages.  Many other, less well-paid members of the work force  are able to supple-
ment their income by working shifts at the factories.  Fewer  people work on farms
or at strip mines at present, but the skills required to  operate increasingly
sophisticated equipment enable them to command higher salaries.

Table 111-14 shows that the median family income has been increasing at approxi-
mately the same rate in Fulton County as in the entire country.

Table 111-14     Trends in Median Family Income (in 1967  dollars)
                 (County and City Data Book, 1972, 1967,  1956;
                 Statistical Abstract of tha United States, 1974, 1977)
Geographic unit          1949          1959          1969           1970


Fulton County          $4,235        $5,981        $7,852         $8,619

United States          $4,603        $6,334        $8,486         $9,586
    2.  Economic Characteristics

A number of local economic conditions will  influence the overall  impacts of the
project.  These conditions are described  in the followi.ig section in terms of
historic trends and current and probable  future conditions.  The  analysis is
divided into two major topics.  The first consists of employment  and governmental
finances, including land values in relation to tax base.  These factors create a
                                   111-29

-------
fr r»awor k for in ansuinj description af tha agricultural, niaiig and manufacturing
and tha e stall and whoiasaia trada sectors of tha local aconony, which is th?
second topic.

        i.   Bnployaent and fiscal tr anja - rablt 111-15 sumarizas a datailad
history of anploynent in Pul tan County.  Savar al general trends ar» apparent
in thasa iati.  Large declines in enploynent hava occurred in ths agricultural
and mining sectors? littla change has occurcsi in ser/icas an3 wholasala tf»3»}
nanuf actur inj has fluctuatsJ? ani slight incrsasas hava occurrei in catail
traJs.

         rJsa \n
Lan3 uaa is one ohysisal nanifastation of sociil anJ aeons*!: valuss. In ths
following section, iata Jassri'oing oaat anJ current lard asa, is wall as ocojactsJ
social andl asononic tcsnJs, are uaaJ to pcojsst tutors Ian3 usa.

    I.  gstataUahe^^ses of Land!

Ihs following aiscuaston of lanJ usa is aiviJeS iato two -najor satsgoriaas

              .  Lard ass •oattacns

              .  US2 of strio-niiei Ian3.
        a.   Land use pattern - \ sounty-wiJs invantocy of lanJ usa was na3a in
1953 ( Har I an3 Bar thol otiaw ani 
-------
Table m-15  Employment Structure In Fulton County, Illinois
              (U.S. Census, County Business Patterns and Census
              of Government)
COMPONEHT
Agriculture
Manufacturing
Trade-Retail
Trade-Mho 'resale
Services
Mining
Contract Construction
Forestry & Other
Government^
Education3
Total
(Teachers)
For Class 1-5 farms
more.
2
Years
1950
43Q2
1953
2,601
1,726
276
467
1,268
133
7
1957
1,317
390
for wrker
1959
384?
1959 1964
919 2,683
612 1,715
IbS 180
195 828
837
265 134
20 10
1962
1,319
295
(229)
by number of days
1964
3922
1967
3,605
1,898
227
1,024
1,004
127
1967
2,177
505
(375)
worked —
1969
1231
1972
2,551
2,004
221
1,273
699
192
1972
1,913
955
(673)
150 days or
  Local  government employment and  payroll 1n  Individual city areas.
                             Ill - 31

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          Table m-16   Historical  Agricultural  Trends in Fulton County,  Illinois (U.S.  Census of Agriculture)
     Farms
     Land In Farms (acres)
     Average Size of Farms  (acres)
     Land in Farms (%)
     Farm Population
     Farm Operators on  Farms
     Hired Workers
     Absentee Farm Operators
                                                1940
1945
1950
1959
1969
3,199
501 ,867
156.9
89.7
HA
2,885
739
165
2,892
489,318
169.2
87.5
10,614
2,709
376
173
2,780
489,919
169.2
87.6
NA
2,621,
842'
131
2.314
496,427
214.5
88.7
NA
1 ,925,
680 '
176
1,772
464,314
262.0
82.7
5,890
1,323
NA
311
     Total  Cropland (acres)
     Total  Pastureland (acres)2
M    Corn (acres)
M    Sorghums (acres)
w    Oats (acres)
     Winter Wheat (acres)
     Soybeans (acres)

     Cattle and Calves
     Cow Milked
     Hogs and Pigs
     Chickens

     Value  of All Products (1967 dollars)     $12,646,440    $23,988,145    $23,826,590    $26,523,367    $31,483,785
251 ,635

106,985
63
35,334
33,832
24,916
41,789
12,395
79,753
209,967
269,964
189,129
132,621
48
29,264
13,348
46.783
54,109
11,762
122,229
252,613
261 ,894
183,518
128,421
41
45,678
13,348
31,037
47,836
9,953
161,982
187,980
293,928
164,126
148,893
365
27,795
19,071
39,451
61,933
4,002
204,669
125,604
302,083
129.482
145,884
380

12.578
56,302
55,674
902
120,332
59,770
     l
      Number of farms reporting  the use of hired  help.
          class 1-5 farms (greater than $2,500 sales).

-------
                                                        Mill
                                                   I^BK SPOON RIVUMUEV
                                                       SCENE tWIVf
                                                   --- ill nmm
                                                    GQ emu MMWIV MIIII
                                                               NAMWI
                                 ANOCIISON LAKE
                                                    0 STATE MK3HWW HMKU
                                                    A SKCMt PONT OF INTEUfST
                                                        Residential and
                                                        Comerclal areas
                                                        Strip Mitring
Figure Hl-9   F-jlton County Und Use, 1968
               (Harland Bartholtwew and Associates.  1969}
                               ni-33

-------
exhibit potential for future growth.

The predominant urban Land use is residential, accounting for almost  38 percent
of the total urban area (Barland, Bartholomew and Associates, 1969).  Most  indus-
trial activities are located in or adjacent to urban areas; remaining rural
industrial operations are mostly agriculturally oriented.  Strip-mining activities
are located in the. central, northeastern, and southwestern sections of the County.
Agricultural activities are located throughout the County.

Substantial, widely scattered forests are located along streams and in areas
where steep slopes have limited the use of the land.  Major conservation districts
are located along the Illinois River.  Parks and private recreation clubs occupy
many other scattered areas.  Hunting, fishing, and camping are the primary  recrea-
tional activities.  Mast recreation is seasonal and requires an extensive amount
of land per user.  Host regional recreation is concentrated at Dickson Mounds
State Park and throughout the Spoon River Valley.  Parks are planned  for several
sites near the Spoon River (Bordner, 1975).

The major land holders in Pulton County are the mining companies, incorporated
farms and owners of a number of large farms, as well as HSDGC.  Land  holdings
as of 1973 are detailed in Table 111-17, indicating that large portions of  the
County are owned by relatively few individuals and corporations.  Tue existence
of large tracts of land makes it relatively easy to buy land for recreation,
conservation, industrial development, or strip mining.

         Table 111-17.  Major Land Holders in Pulton County, 1973
                        (Pulton County Plat Book, 1973)
         Land Holders

Total County Land
Mining companies                         41,716.58             7.43
Incorporated Farms (9 companies)         25,382.90             4.52
Other Major Farms (IB owners)            12,576.05             2.24
rtSDQC                                     9,711.31*            1.73
State of Illinois                         4,266.33             0.76
Private Recreation                        2,912.28             O.S1
Banks                                     1,998.90             0.35
Major Developers                          1,676.44             0.29
Industrial Firms                            832.40             0.14
Total                                  101,073.19             18.01
* Acreage was 15,528 as of August 1975
                                  111-34

-------
        b.   Use of strip-mined land -  A 1973  survey identified land use in
currently and formerly strip-minedareas {Sandberg,  1973).   Table 111-13 sutmna-
rizes the existing use of reclaimed and unreclaimed  strip-mined lands,  unreclaim-
ed lands were defined as areas where no attempt  has  been made to reclaim stripped
land to a productive use.  Reclaimed lands were  defined  as  areas where the land
has been leveled to reasonable slopes and surface drainage  has been restored.
Fulton County contains about 21,600 acres of unreclaimed and 15,500 acres of re-
claimed strip-mined lands.  Most unreclaimed areas are in woodlands, light cover,
or no covet; lost reclaimed areas are in light cover, light pasture, or heavy
pasture.  In 1973, none of the unreclaimed mining sites  and less than 3 percent of
the reclaimed sites were used as cropland.

    2»  Projected Uses of Land

The 1990 land use plan for Fulton County designates  future  land use on the basis oC
1968 estimates of future demographic and economic change.   Since the anticipated
changes were minor, these future designations  are closely related to the existing
land use pattern (Figure III-9).

Residential uses are expected to increasingly  concentrate in and near the estab-
lished urbanized areas.  Major residential growth is expected to the east and
northwest of Canton? to the north, east, and west of Lewistownj to the west and
northeast of of Farmingtonj and around  Avon, Cuba, and Vermont.  Increases are
anticipated in the naiber of single-family, multifamily  and mobile home dwellings
in tract subdivisions, and decreases are expected in the number of farm residences.

Commercial uses are predicted to concentrate in  the  central business districts of
Canton, Lewistown and Farmington.  The  plan anticipates  major industrial areas
near Liverpool and in and near Canton,  Lewistown, and Farmington.  The anticipated
major new public lands are six reservoirs with adjacent  forest preserves (see
Figure III-IQ).  Conservation and recreation expansion would concentrate in the
surroundings of the Spoon River Scenic  Drive along the river from DicKson Mounds
to London Mills.

Most future strip mining is expected to occur  north  of Canton.  % major  emphasis
in the County's land use policy is the  reclamation of strip-mined lands.   Stringent
conditional use permits regulate the nuisance  aspects of strip-mining and require
substantial reclamation of the land.  Land use is also regulated on a County-wide
basis by a zoning ordinance, and Canton, Cifca  and Faraington hava separate ordi-
nances.

3.  Land Pevelogment Potential

The potential for actual land development depends upon the  interaction among land
suitability, accessibility and attractiveness, with  the  social and economic
factors of land use demand discussed earlier.  Hie suitability,  accessibility
and attractiveness of land are the physical components of developed potential}
they deal with the conditions of the site, its location  and aesthetics.

S. Environmentally Sensitive Areas

Pulton County has a number of environmentally  sensitive  land areas and resources.
                                  111-35

-------
TabltIII-18 Sn Land Ult S«r«»y af Strip-Hint lands t« Fulton County.  Illinois (Sandbtrf.
Ust *~ 	 .^^
A. *»dl*nd»
1. lljnt C«mr
C, HIM Pasturt
0. Wavy Pasturt
i. Cropland
F. Rti1tf«Kt
6. Co—area
H. Industry
I. landfill
J. Public taeroatlofl
K. PHvatt Kacnatlon
L. Public 1 Saalpubltc
N, eonstnat1on*M11dl1fa
H. unustd-W Caiwr
TOTAL ACRES
tALUE PCfl ACRE*

UnrtclalMd
lands
8518
6547
1011
.
-
-
-
222
IS
-
190
.
.
5068
21,S?1

Mint Mattr
Maitts Araas
-
-
247
-
-
.
.
3H
•
-
374
9
388S
m«
2, Ml 4,271
$2S» **
lands
192
40C4
stu
3123
40S
2S1
-
-
-
-
241
-
-
988
1S.4SC
$321
     * Vtlut Mr Acrt • 1001 «tlu* IK 1967 dollars
    ** hut not IncluJ* tk* «*1iM af nrlnlnf tqutpMnt ind itruetvrat ,
              1nelud*d dtmt. femMtf !•«*» nhcrt ttw f round surfic* MM not
 or rtnly »«•" In tht Mrl*1 pnotofriphlc Int«rpr«ut1on,
 B.  tight C8«tf tfMerlbM ir*tt irith turfic* cover af taat fen or athtr,
 usually irtitts. low ihrabi ind »c«turwl trtm,

 C,  llaht Nit»r» eftwi iiKludtd 1«11ar
 IMaramoporatloM.
'•
tM covt
             <* *" an* untrv wild xtttt nattrlils art biirltd tn a daw trcnck
            «ftk dirt.
                                                    or unit of local
 J-  ^' ^ Ucrtatlon Una* art OMHd by a public
 M* «r*«tJt avalTabla fer 1st by tkt pntraf public.
 K.  Pr1»aU
 and art wm
           fuepotion Arta« Includa golf cluka, prlwto rttorvts, ca^n and tht llkt
           labla to ••*tn or oww-s. not tkt lit art!  tidlllc.

L.  *utHe and Sartoidille U«d» includt schaoli, churchti. ctMtarlM, prill Ic f«**t
planUand ilMllar uaat.

1-  ContorinrtloiMHIdllft ArtM Includa Mttr ar*a* and  swrovndlnf lands «n1cft. by
vlrtw of proilvlty. crtata a Mbltat for «r1l
-------
                                                                        ' MICE
                                                                        '  LAKE
                                                            SPOON RIVER VALLEY
                                                            SCENIC
                                                                 MIVE
                                                            CONTI NltNVU M«IKH

                                                            US HIGHWAY MARKER

                                                            STATE HKHWW MARKER

                                                            SKCIAL POINT OF INTEREST
                                    ANDCRSON LAKE
linn Conservation Zones

V     Proposed Reservoirs
     and  Forest Preserves
Figure  ITI-10  Major Environmentally  Sensitive Areas  1n Fulton County
                (Harland  Bartholomew Associates, 1969)
                                    III-3-

-------
Ihese are depicted in Figure 111-10 and  identified  in  the ensuing discussion of
water, land, and cultural resources.

    1.  Water Resources

Surface water is a source for some public and  industrial watar  supplies  in  Pulton
County.  Six multi-use reservoirs (forest, conservation, recreation,  and water
supply) are planned to maximize future use of  surface  water  supplies.  Pollution
in the Spoon River or Copperas Creek watersheds would  severely  degrade the  value
of these resources.  The entire length of the  Spoon River is especially  valuable
because it is one of the last remaining  natural streams in the  State  of  Illinois.

Wetland areas comprise another environmentally sensitive local  resource; they are
located primarily in the flood plain of  the Illinois River and  are not directly
affected by the project,  Major wetland  conservation areas include Rice  and Ander-
son Lakes, which serve as habitats for large populations of  game and migratory
birds.  Lakes and ponds created by strip mining in  the project  area are  currently
important to a flock of Canada geese.

    2.  land Resources

Besides the flood plain wetlands, there  are four upland types of environmentally
sensitive areas in Pulton County,  the first of these, strip-mined land, is
particularly susceptible to damage by erosion.  Sparse vegetative cover, steep
slopes, and poor soil permeability are three factors contributing to  the erosion
of unreclaimed or incompletely reclaimed strip-mined areas.  Erosion diminishes
downstream water quality and accelerates sedimentation in downstream  reservoirs.

Prime agricultural land, watershed woodland, and tallgrass prairie are valuable
natural resources.  The prune agricultural lands in Pulton County are character-
ized by thick, deeply weathered loess soils, small  topographic  relief, and  few
stones in the uppar soil layers.  Large  fields of these prime soils are well
suited for highly mechanized methods of  agricultural production.

The main values of local woodland are its recreation potential  and ability  to pro-
tect the quality of surface water by stabilizing soils and reducing runoff volume
and velocity, which are key factors in erosion.  The local importance of surface
water in Pulton County intensifies the value of these  woodlands.  The most valuable
woodlands are found in the watershed of  the Spoon River valley  and in watersheds
upstream from each of the planned reservoirs.

Prairie, particularly tallgrass prairie, such  as that  being  planted as a part of
trie Bluestem Management Plan, is environmentally valuable for a number of reasons.
First, it would preserve a rare portion  of Illinois' natural history.  In addition,
such prairie can serve as a conservation area  for wildlife,  including such locally
rare species as the greater prairie chicken, sharp-tailed grouse, trumpeter swan,
and the sandhill crane.  Finally, prairie grasses, with tneir deep abundant roots,
provide excellent soil-building and erosion control characteristics.

    3.  Cultural Resources

Fulton County has numerous areas devoted primarily  to  outdoor recreation.   Local
                                   III-3S

-------
recreation needs of many residents are met by public park districts in Canton,
Lewistown, and Farmington.  Public recreation needs of a more regional scope are
served by a 400-acre tract of land which has been made available to the County
by the NSOGC.  Private recreation includes an area at Lake Wee-fia-TuK, several
private hunting and fishing areas on strip-mined lands, and campsites with trails
for use of oCf-the-road vehicles on private lands.  The most environmentally sen-
sitive recreation resources are those located adjacent to streams and lakes.

Fulton County has a number of historic and archaeological sites.  Old mansions,
"underground railway" stations, and early shaft coal mines are located throughout
the County.  An extensive prehistoric mound-building culture left over 800 mounds
in the area,  The most important of these, the oickson Mounds, are preserved as a
state museum.  According to National Register Assistant, rheodore Hild, no histo-
ric sites are affected by the project.
                                    111-39

-------
Chapter IV
Description of the Project

-------
                        IV.
The land reclamation prajest of th? *SOOC is locates centrally  in Fulton  County,
Illinois.  1*19 prajast site is iirnediataly saat of tha Viilaga  of Cubs  at  appraxi-
nataly 25 idles west-southwest of Peoria.  Most of tha site  is  between  the Cuba-
Canton Road (Illinois touts 5) and Illinois Route 100 near Canton to  the  northeast
and Lewistawn to tha south.  3ig Crsak flows southwesterly through the  praject
site ani nerges with Spoon Rivac, which is a tributary of ths Illinois  Rivsr, a
inajor navigable waterway.  ^ regional nap prepared Eton  a Is250,000 US33  
-------
Figure  W-l   Sludge Application  Fields at the Project Site
               and Their Rynoff Retention Basins (MSDSC, 1975d)
                               xy-2

-------
                                         MSD   N
                                    DECLAMATION PROJECT
                                                              IMIi IKK

                                                        __ SPOON RIVER VM.IEV
                                                              SCEMC MIVE
                                                        -—-•» pimm
                                                          5]  CHUT* mtiMf MIKEI
                                                          63  US MGMVftY MARKER
                                                          (7)  STATE HIGHUfW MARKER
                                                          .m  STCCIAL POINT or INTEREST
                                     ANDERSON LANE
• WKMC TRAIL

-•KE HOUT1

 nCNKXMG  C • CAMMMC
Figure  w-2    Unloading Dock,  Plptllnt  Routing, and Holding Basins.
                                     IV-3

-------
                                 1972
                                                                                       1975
Sludge barged from
the WSM Plant to the
project site
Sludge barged from the
Lawndale Lagoons to the
project site
Supernatant barged back
from the project site
to the WSW Plant
Figure
                                          Past Sludge Shipments between West-Southwest  Plant
                                          Lawndale Lagoons, and Holding Basins at Project Site
                                          (HSD6C, 1972 a,b» 1973 a through h, 1974 a through 1,
                                          1975 a through g)

-------
    fafcle lf-1,   teMinca of Sludge and Supernatant Barged Co and fro* the Balding B«iln*  la Pulton County
Sludge Barged from:
rUIOO USU Plant
10 6 Gallon* Wet Ton*
kth Quarter, 1972
l*t Quarter, 1973
2nd Quarter, 1973
3rd Quarter, 1973
4th Quarter, 1973
let Quarter, 1974
2nd Quarter, 1974
3rd Quarter. 1974
4th Quarter, 1974
let Quarter, 1975
2nd Quarter, 1975
3rd Quarter, 1975
4th Quarter, 1971
lat Quarter, 197*
2nd Quarter, 1971
3rd Quarter, 1976
4th Quarter. 1971
1st Quarter. 197?
April, 1977
•** Subtotal

•** total

164.3 490,065
137.5 577,427
145. 5 611,309
69.1 149,230
84.5 354,769
132.7 557,279
147.1 617,810
72.0 102,561
41.9 175,812
114.1 479.189
35.2 147,689
__ __
61.4 257,738
100.0 420,115
11,4 47,888
— __
50.4 211,596
20.0 84.101
__ __
1,387.1 5,684,598
•
Lawndal* Lagoona
10* G.I '.on. U*c TOM
~~ ~~
_
— —
1.53 6,427
8.13 34,129
_ __
5.08 21,321
6.82 28,650
—
— —
—
__
~
—
—
_ __
—
—
~ —
21.56 90,527

Both USW I Lawndale

	 , „_
	
__ __
—
47.0 197,317
— —
—
63.8 268,147
77.8 327,017
— —
37.3 366,519
84.8 356,308
22.2 93,362
- -
106.7 448,340
104.0 437.004
74.6 374,964
..
-— - —
668.2 2868,978

Supernatant Returned to:
HSU Plant . Lumdale Lagc^oa
106 Gallon* Wet Tom
	 	
—
-._ __
2.08 8,746
56.6 209,199
10.0 126,750
87.4 366,808
64.6 271,139
113.1 475,022
101.4 425,703
7.82. 32,851
—
65.3 272,783
6.2 26,221
~
— --
—
—
—
534.5 2,215,22;
106C«llon« Vet Ton*
.. «
—
__ _.
—
-- —
— —
—
6.75 28,360
2.52 10,587
__ __
36.2 181,229
70.3 295,114
23.3 97,655
— —
__
__ __
—
—
—
139.1 612,945
1
2,076.9 million gallona or 8,644,103 wet tone 673.6 Billion gallona or 2,828,167 v«t
	 • fnnm
* facludtng SepteelMr 1975
** bcli«ll«« October 1975
              Seetenber and October,
1975

-------
the total wet tons of sludge applied to the project fields, the cumulative fluid
volume of sludge applied was 244.8 million gallons through an application period
of 13 months, beginning in April 1972 and ending  in May  1975.  Daily composite
samples of sludge have been taken from the WSW plant loading dock  and the Mannheim
Etoad Terminal loading dock nest to the Lawndale lagoons.  Vie data on total  solids,
volatile solids and acids, and alkalinity are analyzed and plotted on logarithm-
probability paper in Figures IV-4 through IV-7 foe sludge originating from Lawndala
lagoons and Figures IV-8 through IV-11 for sludge from the WSW plant digesters.
Sludge drawn from WSW digesters is occasionally used to dilute sludge from Lawndale
lagoons to improve pumping efficiency. Mixtures of plant and lagoon sludges  are
regarded as sludge from Lawndale since there are  no data reflecting the mixture.
In these figures, the frequencies of sludge constituent concentrations, such as
total solids, volatile solids, volatile acids, or alkalinity, are  given in percent.

Figures IV-4 through IV-11 show the geometric mean, geometric standard deviation,
and number of observations, providing a general picture of the data spread or
fluctuation.  The plottings for volatile acids and alkalinity of sludges from both
the WSW plant and Lawndale lagoons approximate two straight segments with a  break
point.  Probably this is attributable to digester performance or to the different
ages of sludge in the lagoons.

Properly digested sludge generally has high alkalinity and low volatile acids.
Total solids and total volatile solids ace less sensitive sludge quality indicators
than are volatile acids or alkalinity.  Sludge quality was compared with applicable
sludge quality standards specified in the operating permit issued  to the NSOGC.
The applicable standards and the results of the comparative study  are summarized
in Table IV-3.  In addition to the four parameters cited above, the pa value is in-
cluded.  Based on the length of the monitoring period, the number  of samples, and
the applicable standards, the number of deficiencies permitted was calculated and
indicated in Table IV-3.  Compliance of sludge quality with applicable standards is
determined by comparing the actual number of deficiencies with the permissible num-
ber.  The frequency of deficiencies is summarized below  in Table W-2.

fable IV-2.  Compliance of Sludge Quality with Applicable Standards as of May
             1975 (MSDGC, 1972a through 1975g; Bivico Control, Inc., 1976)

                     Total
                 volatile Solids    volatile Acids    Alkalinity          pH	

Sludge from          Total              Total       Deficient 9.5%   Total
Lawndale Lagoons   compliance         compliance      of the time   compliance


Sludge from      Deficient 3.8%         Total       Deficient 1.4% Deficient 1.3%
WSW Plant        of the time         compliance       of the time    of the tine

The past deficiencies reported here are in some respects misleading.  In November
of 1975, the Pulton County Health Department revised the volatile  acids and alka-
linity standards to account for the fact that some of the sludge shipped to  Pulton
County has been in storage in the Lawndale lagoons foe up to 15 years.  Exceedingly
long storage periods cause a decline in alkalinity as a consequence of ammonia
volatilization.  This at least partially accounts foe the relatively high number
                                       IV-6

-------
»*
 o

   10
    9
    8
    7
    6
                                Total  Solids
   .512    5  10   20  30  40 50 60  70  80   90
   Occurrence of Concentrations  of Total  Sol Ids
                                                       95   98 99 99,5
                                                       the Stated Value (%)
       Figure IV-4    Total Solids Concentration 1n Sludge from the
                      Lawndale Lagoons (MSDGC, 1972a, through 1975g;
                      Envlro Control Inc.. 1975)
  100
   90
   80
   70
   60

5 5°
«£ 40
S 30
   20
                          Volatile Solids
10 .5  1   2     5   10    20   30 40 50 60  70   80    90
    Occurrence of Concentration of Vo'latile Solids

    Figure  iv-5
                                                       95   989999.5
                                                        . the Stated Value
                      Volatile Sol Ids Concentrations in Sludfe from
                      the Lawndale Lagoons (MSDGC, 19728 through 1975g;
                      Envlro Control Inc. , 1975)

-------
                               Volatile Acids
 u
 *
      200
   100
    90
    80
    70
    60
    50

    40

    30
 *    20
    10  1   2     5   10    20  30 40 50 60 70  80   90   95
        Occurrence  of Concentrations of Volatile Adds £

        Figure
                                                           98 99
                                                          the Stated Value (%)
                         Volatile  Adds  Concentrations  in Sludge from
                         the  Lawndale  Lagoons  (MSDGC, 1972a through
                         1975g; En viro Control Inc., 1975)
o
o
Ifl
 10,000
 9,000
 8,000
» 7,000
 6,000
 5,000

 4,000
3  3,000
    2,000
                               Alkalinity
    1,000  12    5  10   20   30 40 50 60  70  80   90  95   98 99
          Occurrence of Concentrations of  Alkalinity 4; the Stated Value (!)
          Figure  iv-?    Alkalinity Concentrations 1n Sludge from the
                         Lawndale  Lagoons  (MSDGC, 1972a through
                         1975g; Envlro Control Inc., 1975}
                               IV-8

-------
                                 Total  Solids
   10
    9
    8
    7
    6
TS
4-i
o
    1
     •2  .5  1   2   5   10   20 30  40 50 60 70 80   90   95  98  99 99.5 99.8
      Occurrence of Concentrations of Total Solids £ the Stated Value (%)
      Figure  IV-8   Total Solids Concentrations in Sludge from the WSH Plant
                     (MSDGC, 1972a through 197Sg;  Enviro Control Inc., 1975)
100
 90
 80
 70
 60
 50

 40
                             Total  Volatile SolIds
o
tS)
 v
£  30
    20
    10
     .2.512    5  10    20 30 40 50 60 70  80   90  95   98 99 99.5 99.8
       Occurrence of Concentrations of Total Volatile Solids! the Stated Value (X)
    Figure
                      Total Volatile Solids Concentrations in Sludge from the
                      WSM Plant (MSDGC, 1972a  through  1975g; Enviro Control  Inc.,
                      19754

-------
TOT
*^*
U
 U)

 u

 a.;
ym,

t->
 to

*o
     200
100
 90
 80
 70
 60

 50

 40


 30


 20
                             Volatile Acids
      10
        1   2    5  10   20  30 40 50 60 70  80   SO  95    98  99

         Occurrence of Concentrations of Volatile Acids & the  Stated  Value
         Figure  IV-10  Volatile Acids Concentrations in  Sludge
                        from the WSW Plant (MSDGC,  1972 a through
                        1975 g; Enviro Control Inc., 1975)
  10,000
   9,000
   8,000
-7,000
S 6,000
* 5,000

* 4,000
t~*>

i 3'°°°

5?
I 2,000
m
                               Alkalinity
    1.000
         12    5  10    20 30 40 50 60 70  80   90  95   98 99
          Occurrence of Concentrations of Alkalinity 6 the Stated Value (X)
          Figure  IW-U   Alkalinity Concentrations in Sludge from
                          the WSM Plant (HSD6C, 1972 a through 1975 g;
                          Enviro Control Inc., 1975)

-------
Tablt  iv-3  Co*Mrtson of Sludge Characteristics With Appl(cattle  Sludge Quality Standards  (mOGC, W?a through  1975g; Envlro Control, Inc.,  1976)
Sludqt Quality Parameter
Applicable Sludge QiMllty Standards
Itartxr of Saaoles
^iSLtr1" 6«>«itr1e (tea*
i Jimnt fieawtrlc Standard Oevlation
uguu ^ ef vtoution* iNrtHtlfd
Actual No. of VtoUtions
NMbcr of S«l>let ,
iludm froa Seonetrlc MMR
USN P)*nt GaoMtrlc SUmUrd Devtitton
*.. of vi»Utiom Pemlttwl
ActiMl No. of VtoUtions
ToUl Solids
Hot Ay*1 table
14?
	 	 "Mr~ '
	 TM 	
Not Apptttatile
Not Applicable
3%
	 377* •""
1.1
Not Applicable
Not Applicable
ToUl 	
Volatile So) ids
No 24-hr, coflposite
sanple my txceed
6?t of total ioHds.
130
511
1.1
0 ' " "
0
3fi7
w 	
1.1
0
S " "
Volatile Adds
(as Acetic Acid)
No nre than flv* 24-
hr, composite samples
•ty exceed 300 mg/1 In
30 days.
69
62.9/1
1.6
«5 	
0
241
45.Q/1
1.6 	
90
1
Alkalinity
(as CaCOj)
No inre than SI of
the 24-hr, composite
sanples In 30 days msy
be lower than 2,500 «q/l.
137
	 3.UO«g/t
1.1
" ' 7 '
?d
Z?Z
4.?60 m.n
	 	 l."2
11
	 14 	
PM T
No 24-hr, compos-
ite saaple mty be
less than 6.9 units.
141
?,4(Ar1MKtic Mean!
Not Applicable
0
a
394
8. 0| Arithmetic Mean
Not Applicable
0
	 5 	

-------
of alkalinity deficiencies of sludge taken  from  the  Lawndale  Lagoons.  With the
exception of alkalinity, sludge originating from the Lawndale Lagoons  has a gene-
rally higher quality than sludge drawn from the  WSW  Plant digesters, which is also
attributable to the aging of sludge in the  lagoons.  Sludge drawn  from the diges-
ters has occasionally been substandard in terms  of total volatile  solids, alkalinity,
and/or pH. Fulton County amended their sludge quality  standards  in November 1975
recognizing problems associated with alkalinity.  Since that  time  sludge segments
have met all applicable standards.  If the  standards had not  been  changed, there
would not have been much effect since sludge quality had improved.

    2. Sludge Storage

The average sludge storage time in these holding basins can be estimated by a
number of methods.  Because the holding basins were  never used at  full capacity,
a method for estimating the average storage time is  as follows:

       ts (months) - (fp - Fr )MG » (1397.5-477t4) x  106 gal    -  49  months
                     Ff *C/month   (244.8 x 10G  gal/13 months)

       Where ts = average storage time
             Fb = sludge barged to the holding basins
             Fr - supernatant returned to Chicago
         and Ff - sludge applied to fields

This estimation does not account for loss of sludge  water by  evaporatiin or increase
by rainfall.  * storage time of 49 months is considerably long,  and is a result of
low sludge application volumes during the development  stages  of  the project.

The application rate was originally proposed to  be 70  dry tons per  acre  per year
in the first year and taper down to 20 dry  tons/acre/year in  the fifth year of
operations (Dalton and Murphy, 1973).  These rates correspond to 726.5 and 207.6
million gallons of sludge, based on a 4 percent  total  solids  content,  applied to
Fields II through 138, having a total area  of 1,731.6  acres.   Accordingly,  the
mean storage capacity was provided for at least  a six-month storage or retention
time.

Assuming a 20 dry tons/acre/year application rate and  a 4 percent  solids content,
the basin could store sufficient solids for a maximum  development of application
fields of approximately 26,960 acres.  Presumably this surplus capacity  of the
holding basins was justified for the purpose of  stockpiling sludge  reserves during
the early years of project development or to maintain  operations during  years of
discontinuous sludge shipments.  More recently however, the 49 months  average
storage time and capacity foe applying sludge to 26,960 acres per year when only
3,700 acres per year are actually being used demonstrates that the  basins are
not designed as part of the project design  but rather  as a sludge storage area
for MSDGC sludge.  This demonstrates that the holding  basin volume  is  much larger
than any needs the MSDQC might have Cor flexibility  of operation.   This  situation
presents considerably more potential for odor than basins sized  only for staging
project operation.

During the storage periods, sludge solids settle to  the bottom oC  the  holding
basins, creating two layers of material.  The top layer ranges through most of
the basin and is composed of supernatant containing  less than 0.25  percent solids.
The bottom layer consists of settled and compacted sludge with solids  up to approxi-
mately 10 percent.  During periods of storage, it is estimated that approximately
one-fifth of the nitrogen in the sludge is  lost  to the atmosphere  in the form
of ammonia.


                                     IV-12

-------
Typical vertical profiles of  sludje cnaracteristics in the noldinj oasina are
snown in Figure IV-12.  Profiles ace presented for taree noldinj oasins a*vi seven
parameters.  In general, prl values  remain constant in tne top five meters and taen
decrease «ritn depth.  Because larje proportions of nitrogen and pnospnorus can-
pounds are associated with suspended solids wnicn settle in tae oasins, tne total
suspended solids, total nitrogen, and total phosphorus concentrations are niyhest
at tne oottom of tne holding  Das ins.  Tne same pattern of annonia nitrogen concent- ra-
tion, Wiucn  is constant in tne top  five meters and tnen increases witn deptn, ia
recorded for all three basins.   General!/ speakuv,,  tae total volatile solids and
volatile acids are silently enricned at the oottom of tne oasins.  Conventional
dredging equipment is utilized to witndra* solids from two of tne holding oasins.
Pne cutter nead mixes t.ie concentrated solids witn tne liquid fraction and pumps
tne resultant mixture of approximately five percent solids to the inain pun^aioj
station for  further distribution.

    3.  Sludge Application

Durin-j application seasons, tne sludje is pumped Iran tne noldinj oasins via a sur-
face land pipe distrioution .system  and applied to tne land oy a nutooer of tecnniques.
field application devices availaole at tne site include: traveling sprayer, center-
pivot sprayer, iioidjoard plow incorporator, a tanK true*, and, for supernatant only,
•lated irrigation pipe (MJDGC, 1975i).   Durinj tne first £e«r /ears of project opera-
tion, spraying */as tne irajor  application metnod.  It is no longer used.  Spraying
Mas accanplisned ay modular units consisting of pumps, an aoove--jro;nd neader system,
and a "aij jun" spray wenicle (Figure IV-13).  To prevent clojjinj, tne nouLe of
the spray u,un nad a 2-incn diameter or larjer.  Tne pressure and spray rate were 30
pounds per square  insn and 300 gallons per ioinute, respectively, and tne Horizontal
tnrow «ras approximately 120 to 250  feet (MSDGC, 1975i).

fwo types of tillage nacnines can oe used to incorporate sludge into soil — tae
RDldooard plow incorporator and tne tandem disk incorporator (Figure Iv~-ii aiows
tne latter).  Sludje is presently incorporated into aoil oy a tractor-dra^n tande.n
disk incorporator witn a distrioution manifold rfnicn directs sludje to eacn diSK
olade as it  tills tae soil.   Slud-je is tnereoy applied to tne entire cross-sectional
j-:ia of the  soil oeinq tilled.   Rie soil injector (Figure Iv*-14) ^orka on 'the same
principle as tne soil incorporator, except tnat an injector applies ^ladje to slots
formed in the soil by a tool  snank.

A^lication  fields were developed from 1971 through 1973 in taree stages, varying
in size £rao IS to 114 acres  (figure 17-1).  £acn field is provided witn runoff
oerms and one or more runoff  retention oasin to divert and contain storm run-off
and to control tne water quality of field effluents.
Sludje  is  applied  to the fields during tne ^rorfinj season*  periods of sludge
application  to various fields are ancwn scnematically in figure TV-IS.  >4orJc
hours are  approximately 8 hours per day at the oe jinn ing of tne application
season,  increase to a itaxmwi of 16 nours per day, and taper off to 8 nours per
day at  tne end of  tne season.  Afflication on one field of a jiven nodule is
generally  completed oefore oej inning on anotner field*  However, tmo fields of a
nodule  are sometimes applied simultaneously.   It takes approximately JO minutes
to complete  application an one acre of land (MSCGC, 197SJ).  Tne slud-je applica-
tion rate  in dry and wet tons per acre and total tonnage of sludje applied per
year on each field are summarized in Taole IV-4.


                                       IV-13

-------
   0
   1
   2

*e 3
r 4
+j
Q. c
flu "^
-o
   6
   7
   8
                                              &
       7,0   7.4   7.8   8.2
                                        pH
                                                      12345  6789 10  11
   0

   1

   2

S 3

5 4
01 £
•O 3

   6

   7

   8

0
1
2
3 3
f a
•*j *
Q.
-g 5
6
7
8
1 3A 2
; V'
\ \ \
: V \
\
         1000  2000   3000  4000
                                   5000 Total N(ppm) 36  38 40 42 44 46 48 50 52 54 56
                                                                             Total Vola
                                                                             tile Solid
                                                                               (ppm)
          Figure  W-12 Typical Vertical Profiles of Characteristics of
                        Sludge  in Holding Basins 1, 2 and 3A. April 1975
                        (MSDGC, 1975<0
                                         W-U

-------
0
1
2
5 4
o. .
« 5
•o
6
7
8













""""-•^
***"" ""^i,
\ """"""^
\ ^**-^ 2
I \
3A
600  800   1000   1200  1400  1600 NH3-N(ppra) 2  46  8 10
                                                                      14 16 Volatile
                                                                            Acids (ppm)
   0
   1
   2
S 3
5 4
Q.
-S 5
   6
   7
   8
      200
      600  1000   1400  1800  2200 Total  P(ppm)
                           Figure JV4.2    (Continued)
                                       W-15

-------
Flgure  IV-13
Traveling Sprayer Applying Liquid Sludge to a Corn Crop  (top)
and Disk Incorporation with Trailing Supply Hose (MSDGC,  1975n)
                                   IV-16

-------
Figure W- 14   Injection  Unit  Showing Three Injectors (MSDGC, 1975H)
                                  XV-17

-------
Ul
1
«r
O»
4
PI
s
*•*

-------
Table W-4    Sludqe Application Rates and Amounts
              {MSDGC- 1973 a through h,
                     1974 a through 1,
                     1975 a throuah o)

Field
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
26
27
28
30
31
32
t.
33
37
38
Field Size
(acres)
46
52
41
80
30
15
110
71
93
94
21
27
36
70
22
150
88
38
114
39
52
22
38
64
43
31
69
18.5
15
19
68.9
54.2
Year 1973
dt/acre
1.21
0.50
0.58
0.49
0.95
2.38
--
1.35
0.37
1.50
0.57
—
—
df
49.6
40.0
17.4
53.9
67.5
221.3
--
5T.3
42.2
58.5
29.6
—
—
Year
dt/acre
19.0
24.0
24.4
24.5
23.2
0.2
21.3
12.1
16.3
25.8
29.4
17.0
16.2
6.6
29.1
17.6
19.2
16.4
23.4
27.2
6.3
0.5
9.7
27.3
20.2
17.2
20.1
8.4
3.6
4.1
7.2
1.9
1974
dt
874,0
1,248.0
1,000.4
1,960.0
696.0
3.0
2,343.0
859.1
1,515.9
2,425.2
617.4
459.0
583.2
462.0
640.2
2,640.0
1,689.6
623.2
2,667.6
1,060.8
327.6
368.6
1,747.2
868.6
533.2
1,386.9
155.4
54.0
77,9
496.8
103.0
Year 1975
(Ma,y, June & July)
dt/acre
19.5
14.8
3.5
19.9
29.1
13.4
17.7
6.7
16.6
27.4
16.3
7.7
6.9
27.7
14.9
9.4
14.6
17.7
17.5
7,3
11.3
H
-,
dt
897.0
769.6
143,5
1,592.0
873.0
1,474.0
1,256.7
623.1
1,500.4
575.4
440.1
277.2
483.0
609.4
2,235.0
827.2
554.8
690.3
9TO.O
160.6
429.4
—
—

                       W-19

-------
TABLE IV-4 (Cont'd)  Sludge Application Rat*s and Amount*
                          1976
FIELD
NO.
1
1
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
SUB-
TOTAL
VOLUME
CU.YDS.
59237
68979
36636
97630
25131
0
14371
10098
44619
66970
26951
16701
14636
15890
59678
97069
30859
0
20187
48057
11898
27714
3698
0
0
847009
WET TONS
TONS
49918
58136
30848
82266
21177
0
12101
50647
37593
56404
22712
14075
12336
13393
50285
81791
26004
0
17000
40480
10018
23357
3114
0
0
713655
WET TONS
PER ACRE
TONS/ACRE
1084
1117
752
1028
705
0
109
665
428
598
1081
519
343
191
1142
544
292
0
446
355
256
448
141
0
0

DRY TONS
TONS
2474
2988
1526
4181
1079
0
657
2439
1779
2816
1110
732
638
707
2615
3911
1326
0
851
1981
561
1110
167
0
0
35648
DRY TONS
PER ACRE
TONS/ACRE
53.8
57.5
37.2
52.3
36.0
0
6.0
32.1
20.7
30.1
53.0
27.2
17.7
10.1
59.4
26.2
15.0
0
22.4
17.5
14.4
21.4
7.6
0
0

                                     MSDGC 1977 Annual Operating  Raport
                            1V-20

-------
          TABLE IV-4  (Cont'd)  Sludge Application Rates and Amounts
                                     1976
FIELD
NO.
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
VOLUME
CO. YDS.
64942
41228
31440
0
71505
2540
10811
19256
12388
76165
29040
10717
0
23009
47551
34508
101469
61865
12428
52105
0
16754
0
WET TONS
TONS
54736
34750
26501
0
60274
2138
9115
16232
10431
64167
24469
9024
0
19398
40088
29091
85544
52154
10478
43930
0
14126
0
WET TONS
PER ACRE
TONS/ACRE
855
807
854
0
873
115
608
854
145
486
489
130
0
462
498
529
528
884
308
301
0
471
0
DRY TONS
TONS
2807
1655
1309
0
3100
113
429
773
575
3001
1164
499
0
980
1986
1402
4292
2636
577
2172
0
735
0
DRY TONS
PER ACRE
TONS/ACRE
43.7
38.5
42.4
0
45.0
6.1
28.7
40.7
8.0
22.9
23.3
7.2
0
23.4
24.6
25.5
26.5
44.6
17,0
14.9
0
24.5
0
TOTAL   1,566,745    1,320,347
65,995
                                    IV-21

-------
TABLE iv-4  (Cont'd)  Sludg. Application Rates and Amount.
                          1977
FIELD
HO.
1
2
3
U
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
31*
35
VOLUME
CU.YDS.
0
45,431
0
53,028
0
0
68,560
0
28,441
61.419
0
15,227
30,882
45,639
39,680
62,242
73,995
0
16,911
43,588
23,194
8,822
11,273
0
41,887
67,167
36,415
0
0
91,654
11,354
0
0
42,262
56,244
WET TONS
TONS
0
38,253
0
UUf650
0
0
57,728
0
23,948
51,715
0
12,821
26,002
38,428
33,410
52,408
62,304
0
14,239
36,701
19,530
7,428
9,492
0
35,269
56,554
30,661
0
0
77,173
9,560
0
0
35,585
47,357
WET TONS
PER ACRE
TONS/ACRE
0.0
735.6
0.0
558.1
0.0
0.0
524.8
0.0
273-7
550.2
0.0
474.9
722.3
549.0
759-3
349.4
712.0
0.0
3T4.7
321.9
500.8
142.8
431.5
0.0
928.1
883.7
713.1
0.0
0.0
1,118.4
516.8
0.0
0.0
497.0
360.1
DRY TONS
TONS
0.0
1,869.4
0.0
2,397.0
0.0
0.0
3,159-9
0.0
1,102.5
2,914.1
0.0
703.7
1,291.2
2,016.8
1,792.3
2,812.6
3,299.6
0.0
701.6
1,628.7
1,080.8
388.2
513-9
0.0
1,925.3
2,969.5
1,602.4
0.0
0.0
3,883.9
510.1
0.0
0.0
2,063.4
2,278.2
DRY TORS
PER ACRS
TONS/ACHE
0.0
36.0
0.0
30.0
0.0
0,0
28.7
0.0
12.6
31.0
0.0
26.1
35.9
28.8
40.7
18.8
37.7
0.0
18.5
14.3
27.7
7.5
23- 4
0.0
50.?
46.t
37-3
0.0
0.0
56.3
27.6
o.o
o.o
28.8
17-3
                                    MSDGC 1978 Annual Op««timf R.port
                            W-22

-------
             TABU IV-4 (Cont'd)  Siudgt Application Rates and Amounts





                                    1977 (Cont'd)
FIELD
NO.
36
37
38
39
40
41
42
43
44
45
46
47
48
VOLUME
CU.YDS.
27,275
38,507
0
25,020
28,541
33,035
102,342
43,819
518
34,132
0
24,648
0
WET TONS
TONS
22,965
32,423
0
21,067
24,032
27,815
86,172
36,896
437
28,739
0
20,754
0
WET TONS
PER ACHE
TONS/ACRE
459.3
470.6
0.0
501.6
293.1
505.7
531.9
625.4
12.8
196.8
0.0
691.8
0.0
war TONS
TONS
1,441.0
1,647.2
0.0
1,119.0
1,060.0
1,550.6
4,657.1
2,051.0
19. 5
1,233.9
0.0
1,123.5
0.0
om TONS
PER ACRE
TONS/ACRE
28.8
23.9
0.0
26.6
12.9
28.2
28.7
34.8
0.6
8.5
0.0
37.4
0.0
TOTM,   1,323,150
1,122,510
58,806.7
                                          W-23

-------
TABLE IV-4  (Cont'd)  Sludge Application Rates and Amounts
                             197d
FIELD
NO.
1
2
3
i
>*
5
6
7
8
9
10
11
12
13
11*
15
16
17
18
19
20
21
22
23
1 -
2l*
25"
26
27
28
29
30
31
32
33
35
VOLUME
CU.YDS.
57,857
17,508
36,005
0
18,1*1*2
0
68,321*
1*8,517
63,560
60,096
23,397
0
17,065
57, 751*
8,651*
70,320
18,509
0
15,080
7k, 501
21,292
33,31*5
13,315
0
33,081*
61,293
3,552
26,01*8
0
17,009
12,71*9
10,181
19,366
1*5,870
86,21*9
WET TONS
TONS
1*3,715
It*, 71*1
3% 316
0
0,528
0
57,529
1*0,851
53,518
50,600
19,701
0
14,369
1*8,629
7,285
59,209
15,585
0
12,698
62,730
17,928
28,076
11,211
0
27,857
51,609
2,991
21,933
0
11*, 322
10,731*
8,572
16,306
38,622
72,621
WET TONS
PER ACRE
TONS/ACRE
1,059.0
283.5
739- U
0.0
517.6
0.0
523.0
575.U
611.6
538.3
938.1
0.0
399.1
694.7
165.6
178.1
0.0
331*. 2
550.3
459.7
539-9
509-6
0.0
733.1
8o6.lt
69.6
707.5
0.0
207.6
580.2
571.5
858.2
539. U
552.3
DRY TONS
TONS
2,388.1*
821*. 6
1,526.0
0.0
711.2
0.0
2,891.1
2,018.0
2,633.0
2,539.3
1,022.1
0.0
702.1*
2,31*9.3
380.7
2,894.5
71*1*. 7
0.0
633.8
2,957.9
1,01*2.0
1,363-3
51*6.7
0.0
1,W*1*.7
2,530.8
175-9
1,093-1*
0.0
695.7
560.1
505.1
829.3
1,865.6

DRY TONS
PER ACRE
TONS/ACRE
51.9
15.9
*S • 7
37.2
O 0
w « W
23.7
Of)
• \J
26.3
28.1*
30.1
27-0
1*8.7
On
• w
19.5
33-6
8.7
19-3
8.5
00
• \J
16.7
25.9
26 7
tu. f
26.2
2U.8
O 0
V • V
38.0
39.5
*JS " r
4.1
35.3
0.0
10.1
30.3
33.7
1*3.6
26.1
25.9
                                   MSDGC 1979 Annual Operating Report
                          IV-24

-------
          TABLE iv-4 (Cont'd)   Sludge Application Rates and Amount*
FIELD
NO.
36
37
38
39
1*0
1*1
1*2
«*3
1*1*
1*5
1*6
1*7
1*8
VOLUME
CU.YBS.
35,281*
39,815
0
20,7U2
53,865
25,32^
126, 9k8
32,577
35,060
101,782
0
25,338
0
WET f ONS
TONS
29,709
33,52l»
0
17,W5
^5,352*
21,323
106,890
27,1*30
29,521
85,701
0
21,335
0
WET tCKS
PER ACRE
IOIS/ACRE
59^-2
^86.6
0.0
M5.8
553.1
387.7
659.8
«*6l».9
868.3
587.0
0.0
711.2
0.0
B8¥ TONS
TONS
1,1*81*.7
1,752.8
0.0
812.8
2,179-7
1,129. fc
5,%30.5
1,390.9
1,539.6
l*,078.5
0.0
1,212.2
0.0
DRY TORS
TEH ACRE
TONS/ACRE
29-7
25.1»
0.0
I9.it
26.6
20.5
33.5
23.6
%5.3
27.9
0.0
liOA
0.0
TOTAL   1,535,670    1,293,01*0
                                    XV-25

-------
TABLE IV-4 (Confd)  Sludge Application Rates and Amounts

                           1979
FIELD
NO.
1
2
3
1*
5
6
7
8
9
10
11
12
13
1U
15
16
17
t ft
18
19
20
21
22
23
nl
2U
25
26
27
28
29
30
31
32
33
3!*
35
VOLUME
CU.YDS.
0
55,656
5,155
73,522
21,81*1*
0
0
1*1,177
0
61,323
23,385
23, M3
29,190
lit, 3**8
57,858
126,090
lOU, 91*1*
0
30,383
73,839
21;, 775
31, 7*
ll*, 879
0
10,675
10,813
3M12
1*1,221
0
80,232
11*. 865
7,505
23,805
1*0,581
83,693
WET TCtlS
TCKS
0
U6,863
U,3M
61,906
18,393
0
0
3^,671
0
51,63^
19,690
19,713
2U.578
12,o8l
1*8,716
106,168
88,363
0
25,583
62,172
20,861
26,771
12,528
0
8,988
9,105
29,312
3l+, 708
0
67,555
12,517
6,320
20,01*1*
3*1,169
70,1*70
WET TONS
PER ACRE
TOTS/ACRE
0.0
901.2
105-9
773.8
613.1
0.0
0.0
1*88.3
0.0
51*9.3
937.6
730.1
682.7
172.6
1,107.2
707.8
1,009.9
0.0
673-2
51*5.1*
531*. 9
511*. 8
569.5
0.0
236.5
11*2.3
681.7
1,119.6
0.0
979-1
676.6
1*21.3
1,051*. 9
1*77.2
535.9
DHY TOMS
TONS
0.0
2,1*91.5
251*. 2
3,356.9
1,005.7
0.0
0.0
1,81*5.9
0.0
2,650.6
982.1*
1,101.3
1,321.6
632.6
2,51*7.7
5,630.3
1*,683.8
0.0
1,266.1*
3,503.1
1,15k. 7
1,1*79- U
652.3
0.0
^55.7
1*82.6
1,586.2
1,872.1
0.0
3.5U0.1*
6U6.5
333.3
1,052.6
1,892.2
3,588.1*
DRY Tars
PER ACRE
TCCIS/AC?.^
0.0
1*7-9
6.2
1*2.0
33.5
0.0
0.0
26.0
0.0
28.2
1*6.8
1*0.8
36.7
9.0
^ • w
57.9
37-5
53.5
0.0
33.3
30.8
29.6
*•• y •>*
28.5
29-7
0 0
W • \J
12.0
7.5
^6.9
_/ -' • ~f
60. U
0.0
51.5
31?.-
JT^ • ^
22. ""
55. I:
26.1-
27.'
                          IV-26
                                          MSDGC 1980 Annual Operating
                                           Report

-------
           TABLE IV-4  (Confd)  Sludge Application Rates  and Amounts



                                     1979
FIELD
NO.
36
37
38
39
1*0
1*1
1.2
l»3
1*1*
i»5
1*6
1*7
1*8
1*9
VOLUME
CU.YDS.
28,1*73
50,227
0
27,538
53,1^3
U1*,915
196,791
59, 191*
36,203
12^,730
0
26,646
0
0
WET TOTIS
TONS
23,97^
U2,291
0
23,187
l*l*,7l*6
37,813
165, 6?3
U9.8U1
30.U83
105,023
0
22,1*36
0
0
WET TONS
PER ACRE
TONS/ACRE
U79.5
613.8
0.0
552.1
5!*5.Y
687.6
1,022.8
ff»U.8
896.6
719-3
0.0
71*7.9
0.0
0.0
DRY TOTS
TOItS
1,331.6
2,1*60.5
0.0
1,225.2
2,666.7
2,01^.9
8, 971*. 2
2,8li*.3
1,510.7
5,596.5
0.0
1,176.0
0.0
0.0
DRY TO::S
PER ACRZ
TOMS/AC??:
26.6
35-7
0.0
29.2
32.5
37.2
55.1*
1*7.7
1*1*. It
38.3
0.0
39.2
0.0
0.0
TOTAL  1,809,630    1,523,710
8l,8l8.2
                                  IV-27

-------
According to the Illinois Environmental  Protection Agency (LSPA), agronomic rates
£or sludge application  to cropland  are  rougniy in tiie range of five to twelve dry
tons per acre per year  depending on tne  crop grown.  In 1975, place land fields
31, 34, and 37 received 42.1,  31.1,  37.9,  and 23.9 dry tons of sludge par acre?
in 1976, Fields 19, 22,  35, 36 and  40 received 22.4,  21.4, 22.9, 23.3, and 24.3
dry tons per acre.  Tne rates  of application on place lai\J generally decreased
from 1375 to 1376.  It  is evident tnat  some  place lands nave received sludge at
"reclamation" ratner tnan "agronomic" rated.   Annual  .sludge application rates were
originally proposed to  oe 75 dry tons per  acre in tne first year, tapering down to
25 dry tons per acre oy tne fifth year and continuing at tnat rate.

    4.  Supernatant Application at  tne Gale  Farm

Toe original project design called  for  tne snipping of sludge supernatant from tne
holding oasins oaoc to  tne nead of  tne treatment plant.  Taole IV-1 (page IV-5)
snows tnat tnis practice has not occurred  since tne first quarter of 1978.  It was
recognized that tnis expensive practice  was  possioly  unnecessary, considering tnat
tne supernatant could oe applied to land at  tne project site to provide nutrients
for crops sucn as hay.

Tne property selected for supernatant application was tne 3,015.3-acre Gale Farm,
approximately 1,334 acres of wnien  will  eventually oe utilized.   Supernatant (0.1
percent solids) from two holding basins  presently storing supernatant only is
applied tnrcugn gated pipe at  agronomic  rates.   Tne supernatant flows tnrcugh
pipes and onto tne application fields through slotted openings at intervals along
tne pipes, creating a sneet clow oy gravity.   Tne system nas oeen in operation
since Septenoer 1976.   According to tne  Illinois Environmental Protection Agency
slater Pollution Control Permit (see appendix A), tne  agronomic rate is defined as
a rate necessary to supply a maximum of  120  pounds of availaole nitrogen per acre
which corresponds to 30,000 gallons of sludge at 4.1  percent solids or 117,000
gallons of supernatant  at 0.1  percent solids.

Fields wnere supernatant liquid is  applied tntrougn gated pipe are constructed
to oe closed drainage systems  not discharging to sourrounding surface water;
tnere is consequently no monitoring of runoff from tnese fields.  Supernatant
liquid is generally applied to these fields  to the limit of soil nydraulic
capacity.  Tne total amount of supernatant in wet tons, gallons and gallons
per acre applied on eacn field during 1977 tnrough 1979 is surnnarized in
Taole IV-5.

    5.  land Purchases
On August 8, 1974, MSDQC purchased  2,106  acres of  land in Fulton County formerly
owned oy tne United Electric Coal Company.  Approximately 901 of tne land nad
oeen strip mined.  On April 14,  1975, a land  use-reclamation plan submitted oy
riSOGC to tne Pulton County Plan  Commission  and County domed was approved.

This overall plan includes a program, to  reclaim and revegetate tne goo,  slurry
and acid lane area in tne southwest portion of tne property.  Tnis 200-acre site
is located on the former Cula Mine  19 refuse  area  and consists of 75 acres of
slurry and 85 acres of goo, roads,  dam  and  dumping areas.   A 40-acre, highly
                                  IV-28

-------
       TABLE IV-5  SUPERNATANT APPLICATION AT FULTON COUNT*

                             1977
FIELD
HO.
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65

FIELD
NO.
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
WIT TONS
(TOTS)
41,822.0
7,615.3
5,354,8
3M54.4
23,927.2
38,908.7
18,124,7
30,781.5
10,914.6
19,710.1
0,0
54,8l6.3
39*»,627.0
0.0
0.0
1978
WET TONS
(TONS)
37,204.2
8,275.1
5,558.6
54,207.6
30,737.1
46,580,5
19,1*29.5
38,276.8
8,049-9
11,651.5
5,301.4
30,206.6
1*97,716.0
18,^55.5
0.0
GALLONS
(lOOO'S)
10,024.7
1,825.4
1,283.6
8,306.7
5,735.4
9,326.4
4,344.5
7,378.3
2,616.2
4,724.5
0.0
13,139.5
9^,592.1
0.0
0.0

GALLONS
(lOOO'S)
8,917.9
1,983.5
1,332.4
12,993.6
7,367.7
11,165.3
4,657.3
9il75.0
1,929.6
2,792.9
1,270.8
7,240.5
119,302.0
4,423.8
0.0
GALLONS PEE
ACRE
99,550.5
81,490.5
147,534.0
149,400.0
155,852.0
140,670.0
89,9W.l
160,050.0
91,157.8
94,679-6
0.0
150,509.0
128,295.0
0.0
0.0

GALLONS PER
ACRE
88,558.6
88,551.0
153,1*9-0
233,697.0
200,209.0
168,406.0
96,423.4
199,023.0
67,232.1
55,969.2
36,726.8
82,938.4
161,810.0
68,585.8
0.0
TOTALS
811,650.0
194,553.0
                                XV-2»
                                                 MSDGC 1978 and If 79 Mutual
                                                           Rwport

-------
            IV-5 (COKt'd)  SUPERNATANT APPLICATION? AT n,T/TC« COITNTV




                                    1S7§
FIELD
NO.
18
29
50
51
52
53
5U
55
56
57
58
59
60
61
62
63
6U
65
WET TOHS
(TOTIS)
5«*,9U1.3
15,064.1
1*7, 695-0
22, 839- ^
Ik,k08.2
6,668.3
50,270.9
19.5H.U
39,725.3
15,51^.0
28.8J+7.1
8,859.3
28,375-?
8,295.1
J*8,U3^,5
580,838.0
25,567.1
6,216.0
GALLONS
flOOO'S)
13, 169- U
3,610.9
il,J»32.5
5,^.6
3,^53.7
1.596.U
12,052.3
«*,676.9
9,522.2
3,718.7
6,91^.7
2,123.6
6,801.7
1,988.3
11,609.8
139,227.0
6,128.14
1,^90.0
GALLQtIS PER
ACRE
119,722.0
128,959.0
73,»*26 A
5^,365-5
15^,181.0
183,723.0
216,769.0
127»089.0
11*3,622.0
76,991-8
1*9,992.0
73,992.1
136,306.0
57,1*66.3
132,937.0
188,833.0
95,01^.5
57,306.7
TOTALS
1,022,080.0
,993-0
                                               MSDGC 1980 Annual Operating Report
                                      IV-30

-------
acidic retention pond collects all  surface  runoff, and effluent from the site
drains into a trioutary of aig CreeK and eventually  into Spoon River.

Reclamation and re vegetation will be accomplished tnrough regrading tne land to
meet cow crop requirements (generally 5  percent  slope topograpny and tne incorpo-
ration of approximately 200 equivalent dry  tons  per  acre of liquid sludge (5 per-
cent solids) oy means of trenching,  ridge and  furrow,  continuous excavation,
irrigation, deep plowing and Dulldozing,  and/or  plow or disc injection.   Surface
flow irrigation will oe used for supplemental  maisture and nutrients after plant
material cover appears, at a rate of approxiioately 20 dry tons per acre annually.
Plant materials will oe selected on tne  basis  of suitaoility to ttte restructured
goo/slurry/sludge growtn medium* germination and growtn rate,  and effectiveness
for soil erosion control.

This project will serve as a full-scale  demonstration project  tnat can determine
tne engineering, environmental consideration,  and inetnodolo-jy  involved in using
sewage sludge to reclaim this type  of land.  A comprehensive report will oe puo-
lisned tnat will identify and assess experiments and studies tnat nave oeen
performed, and will provide accurate data in a design »wnual for tne application
of sludge to other gob slurry areas across  tne State.

a.  Bivironnental Control And jtonitoring Systems

To ensure against environmental degradation resulting from project operation,
some systems for protection were incorporated  into the project during tne
planning and development stages.  These  include  a compact clay lining of hold-
ing oasins to prevent groundwater contamination  from seepage or percolation of
sludge, control beans and retention oasins  to  contain runoff from each field and
to control water quality of field effluents, and terracing and grading of fields
to reduce runoff velocity, erosion  and sedimentation.   Tne effectiveness of these
control systems and the environmental soundness  of project operations have oeen
monitored using five systems pertaining  to  sludge, water,  soil and roue, plants
and aquatic oiota, and air*

    1.  Holding and Runoff Basins

Tne nolding oasins were constructed following  tne engineering  recommendations
wnicn concluded a suoeurface investigation  and evaluation (Aid fingingeering Cocp-
poration, 1971).  The interior of the holding  oasins were contoured to tatce advan-
tage of tne natural terrain.  No slopes  witnin the oasins are  steeper tnan 1:5.
A continuous compact eartn lining was constructed witnin ttie perimeter of tne
oasin enoaricment to prevent seepage.   The eartn  lining nas a minimum 2-foot thick-
ness of compact clay.  The degree of compaction  is specified in the subsurface
study report.

Tne fields were graded and reshaped and  retention oerras and desiltation areas witn
slotted standpipes were constructed at the  tops  of tne terrace underdrains.   Tnese
features were designed to retain storm runoff  in tne fields long enough to allow
most of tne silt to settle in toe fields ratner  tnan wash into the retention
oasins. A typical runoff retention  oasin is snown in Figure IV-16.   Runoff oasins
were designed to retain water so that it would not be released unless it meets

-------
N
           ASOUNOINB(OIPTM IM f[t!)
           WHIN »'IUI,HU

     Ecscani t «»*«
       Figure  IV- ig    Typical Storm  Runoff Retention
                         Basin (MSDGC,  1973n)

-------
applicaole water quality standards.  Project design included recycling of sucstan-
dard runoff oy pumping it oaclc on tine fields if there was not sufficient oaain
storage capacity to permit extended storage for purposes of improving water
gualityj records indicate that tnis practice never occurred.  In Figure W-17
retention beans and basins, terraces and dikes,, basin inlet and outfall, and out-
fall control structures are shewn for a typical field.  The original and modified
contours are also indicated.

    2.  Environmental t'tonitoring Systems

Extensive .ronitoring takes place in all aspects of tne sludge handling and land
application process — front tne digesters at the rfest-Soutlwest Chicago plant to
Fulton County.  Many elements of the environment could oe influenced by sludge
application, including crops, air and grourdwater (wells).  A monitoring program
exists at each place in the pathway wnere environmental elements could be impacted*

rfonitoriry of sludge, water, soils, crops and cattle, fish and algae, and air is
conducted at the site oy several agencies including the MSDGC, the Fulton County
rieaitn Department (FCHO), the University of Illinois (U of I), tne Illinois envi-
ronmental Protection Agency (IEPA), the U.S. Geological Survey (USGS), and the
food and Drug Administration (FDA).  Each of tnese systems is presented in capsule
form oelow, followed oy highlights of selected aspects of these programs.

        a. Sludge .tonitoring - There are 13 features in tne sludge monitoring
program

*  Weekly itonitorir*- of digester feed for cnenical and pnysical parameters and
   inetals
*  i4cntaly sampling of digester feed and draw for indicator organisms and patnc—
   gens (MSDX)

*  Daily sampling of all sludge shipped to Fulton County for pnysical and chemical
   parameters; inetals are analyzed weedy (>4SDGC)

»  Monthly sampling of digester feed, draw and sludge snipped to Fulton County
   for parasites (U of I)

•  Quarterly sampling of all sludge shipped to Fulton County for indicator orga-
   nisms and patnogens (MSDQC)

*  Selected sampling of sludge snipped to Fulton County for chemical and physical
   parameters and trace organics (FCHD)

*  Monthly profile sampling of the Fulton County holding basins for physical and
   chemical parameters (MSOGC)

*  Quarterly sampling of sludge in molding oasins for indicator organisms and
   pathogens
   Selected sampling of the Fulton County holding basins for physical and chemical
   parameters and metals  (FCHD)
                                  IV-33

-------
                                                                  N
Figure  W-17   Oriinage Control Features of a  Typical Field (MSDGC, 1973n)

-------
o  Weekly composite of daily sludge  applications to fields for cnemicai and phyai-
   cal parameters and metals (MSOGC)

o  Selected sampling of sludge applied to fields Cor pnysical and cnemical parame-
   ters, metals and traoa organics  (LJSG5, FCriO,  U of I,  IEPA)

a  Quarterly sampling of sludge applied to fields for indicator organisms and
   patnogens (rtSDSC)

o  Selected sampling of sludge applied to fields for parasites, cnemicai and
   pnysical parameters and  trace organics (U of  I)*

The sludge analysis program was mainly designed  to ensure adequate treatment
of sludge oefore it is transported  to tne holding oasins at tne project site.
Fur this purpose, twenty-four hour composite samples of  sludge oeing oarged to tne
project site are analyzed for compliance «ritn sludge quality standards.  In addi-
tion to measuring tne volatile acids,  pri value,  total alkalinity and volatile
solids, as required oy tne  project's operating permit,  total solids, total pnos-
pnorus, Kjeldanl nitrogen,  ammonia nitrogen, and electrical conductivity are
determined for eacn composite sample.   Concentrations of chloride, sulfate, and
14 metal elements are determined weekly.   Tnere  are daily grao samples of sludge
from tne pump station at tne Liverpool oarge depot,  tnontnly profile samples at
tne sludge holding oasins,  and «*eelcly composite  samples  from tne distribution
pump station,  tne supematants returned from tne nolding oasins are also sampled
and analyzed.  A typical data log is presented in Tabla  IV-6.

        b. dater monitoring - Tnere  are 7 features in tne surface and ground
water man i tor ing programs:

*  Sampling of all runoff oasins before and after discharge for cnemicai
   and Dtological parameters (M3DOC)

*  Selected sailing of runoff nasin discnarges  by IEPA  and TCHD for cnemicai,
   oiological, and pnysical parameters and trace organics

•  Selected sampling of streams, reservoirs and  runoff oasin disoiarges oy
   .4SOGC and suosequent analysis oy  U3G3 for trace organics

•  Monthly sampling of reservoirs and streams for cnemicai, oiological, and
   pnysical parameters and  metals
   Selected sampling of reservoirs  and streams for cnenical,  oiological,  and
   pnysical parameters, metals, and trace  organics (PCrff),  USG3,
   Monthly sampling and analysis of  *eils  for cnemicai,  physical,  and oiological
   parameters and metals
•  Selective sampling of tmells  for metals,  cnemicai  and pnysical parameters and
   trace organics  (U9QS, POD,  IEPA).

The water monitoring system includes Mater  sampling, analysis,  data reporting  and
data reduction,  rfater  samples  are tanen from 26  wells,  1  spring, 11 stream samp-
                                    IV-35

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Table
                              Fulton County Land Reclamation Project Sewage
                              Sludge Analysis, April 1975 (MSDGC, 1975g)



Total Solids %
Total Volatile Solids X
Volatile Acids** (mg/1)
pH
Total P ( mg/1}
Cl- (mg/1)
S04' (mg/1)
N-Kjeldahl (mg/1)
NHj-N (rng/1 )
Alkalinity as CaOh (mg/1)
Electrical Conductivity (umhos/cm)
Al (mg/1)
Cd (mg/1)
Ca (mg/1)
Cr (mg/1)
Cu (mg/1)
Fe (mg/1)
Pb (mg/1)
Hg (jjg/1)
Hg (mg/1 )
Mn (mg/1 )
HI (mg/1)
K (mg/1)
Na (mg/1)
Zn (mg/1)


HDL*




0.01
1.0
.0
.0
,0
0.1
.0
.0
0.01
1.0
0.02
0.01
0.1
0.03
0.1
1.0
0.01
0.1
1.0
1.0
0.1


4/3
3.72
52.62
67.00
7.40
980.00
292.00

2.849.00
1,344.00
3,900.00
7,300.00
220.00
7.00
1,200.00
93.80
48.00
1,370.00
30.40
151.00
500.00
13.20
13.00
220.00
110.00
115.00

Date
4/5
3.38
54.15
67.00
7.50
830.00


2,681.00
1,372.00
4,780.00
8,000.00






(no samples









4/6
3.37
55.68
45.00
7.80
1,010.00


2,513.00
1,421.00
4,920.00
7,500.00






taken)









4/7
3.42
54.62
90.00
7.60
890.00
404.00

2,632.00
1,435.00
4,940.00
8,000.00
200.00
7.00
1,010.00
86.90
48.80
1 ,652.00
32.60
140.00
490.00
14.80
13.00
200.00
150.00
98.00
 *MDL » minimum detection limit of laboratory.
**As acetic add.

  mg/1     - milligrams p*r liter
  umhO8/ctn - micrombos p*r centimeter
  ug/1     - microgrw per liter
                                           CT-36

-------
ling stations located on 3 creates or 3trea«ns, effluent  sampling  stations at run-
off oasins, and at a runoer of  reservoirs.  The  locations of sampling stations
are indicated in Figure IV-18.  /later quality parameters  anal /zed and reported
include:

•  Pn/sical parameters sucn as  total suspended solids  (IBS), total dissolved
   solids (rod), total volatile solids  (Wd) electrical conductivity, and
   temperature

•  Cnemical parameters sucn as  pH,  total alkalinity, dissolved oxygen (O.O. }»
   total pnospnorus (PJ, total  Kjeldanl nitrogen (N), amitonia nitrogen (rUQ-N
   nitrate and nitrite nitrogen
*  Anions such as color ine  (CD and  sulfate  (SO^)  and cations SUCH as potassium
   (K), sodium (Ma), calcium  (Ca), and magnesium (rig)

*  Trace metals such as zinc  (Zn), cadmium (Cd), copper (Cu)(  chromium (Cr),
   manganese (An), lead (Pb),  iron (Fe),  aluminum  (Al),  mercury (%), and
   selenium (Se)

•  Biological and microbiological parameters sucn  as  5-day  biochemical oxygen
   de»nand (SOD-) and fecal  col if onus.

In addition, ground«*ater elevations  have  oeen ooserved and  recorded monthly.
**ater samples are collected and examined  every  montn, and findings are summa-
rized in a aontnly report entitled Environmental Protection System Report for
Fulton County, Illinois.  Typical examples of data are given in Taoles W-7
and Iv"-8.  Tne forner taole reports  tne quality o£ well,  reservoir, sprinj and
stream waters; tne latter snows tne  quality  of  effluent fron retention basins.
Samples taken prior to project operation  constitute oaseline information for
tne "no-action" *ater quality sicuation.  Ciian^es  are revealed oy comparing
water quality resulting from  project operation  witn tne baseline data.

        c.  doll iTionitorinij - fne soil inonitorinj  prograa includes samplinj of
tne plo»r layer ( 0-S in. ) and  soil borings to oed rock taken and analyzed for
pnysical and chanical parameters oy  tne MSDGC.

Prior to project operation, 52 soil  borings  to  oedrock approximately 40 feet
deep Mere made to determine tne pnysical  and chemical cnaracteristics of soils
and code.  Physical tests included the penetration test,  strenytn test, density
test, compressibility test, permeaoility  test,  and field pumping tests.   Strati-
graphs of types of soils and  their geographical distribution Mere estaolished.
The texture, color, moisture  content, grain  size distribution,  and permeability
of the spoil material were  analyzed  (A&H  Engineering  Corporation, 1971).   Chem-
ical analyses included exchangeable  calcium,  organic  cartxn, and hydrochloric
acid-extractable metals such  as manganese, zinc, copper,  cadmium, chraniom,
nickel, lead, and aluminum, for Doth spoils   Td place land  (MSDGC, 1975).  It
was proposed that, 5 years  after project  initiation (1977),  another set of soil
oorings would oe made to cedrock to  investigate changes in  soil chemistry, if
needed [Dal ton and rfurphy,  1973).  To date,  no  manges have occurred in the upper
horizons of soil to necessitate repeating tne extensive soil boring program
(Dal ton, 1980 personal coamunication) .
                                     IV-37

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S19
P J i.-. r
?iaM2?,^h
i ctau L— 	 » ••
}R27
•••••••MMUMfli
S3!
« ca-




•— .1 IH2?"
!l
d i
L..
    »>
    _i(
County
Key:
W • Well
R • Reservoir
S • Stream
    Figure  w-18    Water Monitoring Locitlons 1n Fulton County  (MSOGC,  1975d)
                                     IV-38

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Table  W-?     Fulton County Land Reclamation  Project
               yater Analysis,  April  1975  (MSDSC,  1975g)
Well Data

Sampling Stations: *i vz
e*7i: «/ T 4/ 7 1
HOI." *
** 7.t» 7.40
TOTAL P M/L 0.01 0.15 O.J8
Ct- 1.0 15.00 21.00
»4« 2.0 192.00 67.00
N-KJELBAM. 0.5 0.80 1.38
H-NN3 0.1 0.70 1.10
N-W2*N03 0.01 0.01 0.00
AlK AS CAC03 1.0 290.00 120.00
CLCC.CONO. UHMOS C 700.00 650.00
K H« L 1.0 0.00 0.00
HA .0 12.00 12.00
CA .0 121.00 121.00
HC .0 60.00 $2.00
ZN .1 0,00 O.JO
W .01 0.00 0.00
CV .01 0.00 0.00 *
« .62 0.00 0.00
HI .1 0.00 0.00
MN .01 0.19 0.1$
N .01 0.00 0.00
n .1 1.40 7.40
M. .0 0.00 0.00
H« UC/L .1 o.oo o.oo
Si HB/L .2 0.00 0.00
FC «• 100 ML o.oo o.oo
0.0. MG/k O.S
TIKP. »C ,
STATIC H20 EL. CT.
MO M6/L
»MOLiK!HIKUH DETECTION tIMlf Of LABOHATOKY. t
THAN THESE ARC ftCMMTCO AS ZttO.


















*













LL

Reservoir- Data

HI «2 I
«/ 9 */ 9/j
T.80 8,10
O.Of 0.13
9.00 12.00
U5.00 «93.o&
1.50 1.50
O.*0 O.JO
3. US 2.&6
360.00 »70.00
825.00 950.00
3.00 3.00
20.00
135.00 165.00
7».00 72.00
0.00 .00
.00
r o.oo .00 Y
0.00 ,00
0.00 .00
0.04 .2*
0.00 .01
0.00 .00
0.00 .00
0.10 .40
o.oo .no
0.00 .00
11.40 11.50
3.00 4.00
2.00 3.00
•44.00 913.00
L VALUM LtSS

Stream & Spring Data

SPR Si S2
, 4/ ? 4/l£ 4/16
7.70 7.BO 7.80
0.10 0.56 0.33
15,00 29.00 27.00
1303.00 3(0.00 ioi.oo
0.80 2.40 2.30
0.80 1.40 0.90
0.09 3.16 3.»0
$00.00 2CO.nO 240.00
2600.00 900.00 1000.00
8.00 4.00 4.00
137.00 66.00 76.00
528.00 130.00 135.00
195.00 68.00 T&.OO
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
1,61 0,*2 O.«0
0.00 0.00 0.00
1.00 O.tO 0.70
0.00 0.00 0.00
0.12 0.10 0.10
0,00 0.00 O.OQ
0.00 7.2E*04 3900.00


10.00 37.00 1C. 00
1230.00 643.00 1010.00



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   Table  IV-8    Retention  Basin  Effluent  Quality
                  (MSDGC,  1975g)
    Field Runoff Basin Lo§ at  the District  Site  in
                Fulton County, Illinois

Basin number
Stage reading
Date opened/checked
R&D approval
Sampled
Date closed
No. days open
Discharge (HG)
Comments
4-1
35«
9:30 a.m.
4/15
Yes
Yes
3:00 p.m.
4/15
0.23
0.04

5-1
35%
9:45 a.m.
4/15
Yes
Yes
9:30 a.m.
4/17
2.00
0.31

7-3
6Q%
10:15 a.m.
4/15
Yes
Yes
10:15 a.m.
4/21
6.00
0.72

8-1
45*
10:30 a.m.
4/15
Yes
Yes
8:00 a.m.
4/16
0.90
0.42

Field Runoff Basins - Water Analysis and Discharges  at
            Fulton County During April  1975

Date Sampled
Source
TSS mg/1
BOO mg/1
FC per 100 ml
Date discharged
Quantity HG
4-15-75
B-2-2
43
4
<10
4-15-75
0.32
4-15-75
8-3-1
38
8
20
4-15-75
1.48
4-15-75
B-4-1
220
23
410
'4-15-75
0.04
4-15-75
B-5-1
33
7
410
4-15-75
0.31

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'/early plow layer samples are analyzed for prf, electrical conductivity available
pnospnorus, organic caroon,  excnanjeaole ammonium and oases, nitrate, cation
excaarKje capacity and acid-extractaole inetals.  Also, twice yearly tnere are
140 centimeter snallow soil  oorirvjs nude.

        d.  Crop anJ cattle  dDnitocinjj- Grain and leaf samples are taicen /early
and analysed for metals oy the  university of Illinois and toe i4aJGC.

The cnemical composition of  plants .jrown in sludje-fertilized fields and tnose
jrown on control plots are determined so as to evaluate tne plants' nutrient
uptake rates and to detect any  Buildup of chemical constituents.  The analysis
includes samples from stalky, leaves and yrain of tne fertilized plants.  A de-
tailed evaluation of tnis data  is  perforated in Chapter V.

Tne University 01 Illinois also monitors a control and experimental cattle nerd
for growth rate, parasites,  trace  orjanics and metals in various tissues ootained
eitaer ay surgical oiopsy or at slau-jnter.

        e.  Pisn and algae inpnitorin>j - Tne .MSOGC yearly cnecxs tne condition of
indigenous f isn populations  in  tne Pulton County reservoirs.  On a quarterly
oasis, the M3DGC detannines  tne nuncers and types of algae in tnese reservoirs.
An ecolojical st^d/  of  aquatic oiota in streams and reservoirs rfas initiated in
June 1971.  At tne start  of  tne project, oentnos sainples >«re taicen from Reser-
voirs R3, RIO and R12.  Fisn and plankton nave oeen sati^led, collected and
analyzed nontnly, and data reported quarterly.   Tne fishery study includes fish
population, diversity,  and tne ocdy condition or "well oeinj" of various fish
species such as  olue^ill,  larje tTDuth oass and green sunf ish.  Tne oody condi-
tion of tiie fisn population  is detennined and reported oy tne wei^nt-len^tn
factor or condition  factor K.   rne plankton study of reservoir water includes
plankton counts  and  population distrioutiaii atnaaj identified species.

Besides tnese ecological  data, ,nore than 3d pnysical, cnemical and oiolojical
parameters of tne sample  watar are analyzed for studies of pnenanena sucn as
lake eutrophication.  Tnese  include pil value, conductivity, alkalinity, solids
concentrations,  different fooos of nitrcyen canpounds, total piiospnorus, dis-
solved ox/.en, water temperature,  -rater transparency, 14 inetals, and several
catiooo (M3DGC,  19?2a Lircxi-jh 197Sj; Ca.npoell and Lind, 1969; General riater
Quality Standards for Illinois' Waters).  Control Reservoir 10 has oeen .na in-
tamed to differentiate cnan^es in conditions of fisn and plankton fron suai
conditions in the non-control reservoirs «micn receive discnaryes froia field
runoff aasins.

        f .  Me  monitoring - Tnere are six features in tne. air nronitorirvj program:

*  The HSOGC maintains  a  weather station on tne property to measure precipita-
   tion, wind, temperature,  and relative humidity

*  Atnoient ammonia levels are measured three times per week at the holding basins

*  The FCHD investigates  odor complaints and takes odor samples wnicn are analyzed
   oy tne Midwest Research Institute
                                      W-41

-------
•  Mi odor complaints to tne FCHD are  investigated by M»iXSC personnel

*  Odor samples are taken oy rtSQGC personnel and analyzed  oy (me Illinois Insti-
   tute of Technology Research Institute

*  Ambient air samples nave been anal/zed cor viruses oy tne US HP A.

To estaolish tne air quality situation  at tne site, a meteorological  station
was set up close to tne noiding basins  and an air  sailing program designed.
Air temperature, wind speed and direction, relative numidity and rainfall were
observed daily and compiled in a montnly report.   In addition to general  weather
Goservations, atnospneric aimonia concentration nas been monitored at the down-
wind oerm of tne nolding oasins on a oaten oasis.  During  amnania monitoring
periods, average wind speed and direction, air temperature,  dew point,  and vol-
ume of air sampled are measured.
                                   iy-42

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Chapter V
Environmental Impacts
of the Project

-------
             V.  ENVIRONHE»n"\L IMPACTS OF THE  PROJECT

This chapter will discuss the significant environmental  impacts of the
project and relate these impacts  to  available  options for  municipal sludge
disposal or utilization.  General background information is provided con-
cerning soils, land use, surface  and ground water,  and air; and a discussion
is presented on theoretical aspects  of the project  on health considerations.

The MSDGC project has had a significant beneficial  impact  upon the land use
and economic factors of Fulton County.  These  benefits have been the recla-
mation of land taken out of agricultural activity and the  production of
cash crops and jobs within the County.  Details on  these are provided.

During the project period, no significant adverse impacts  have been surfaced.
During early stages of the project,  odor and visual problems were encountered.
Through public input and advanced technology,  the MSOGC has responded to
several problem areas and modified their approach.   Several times during the
project period poor quality effluent was released from the retention basins to
surface waters.  Steps have been  taken to remedy  this situation both in opera-
tional procedures and redesign or restoration  of  3Kisting  structuras.

Several unanswered questions have persisted in scientific  and regulatory areas.
Tnesa questions concerning heavy  metal application  rates,  pathogens and PC3's
have bean addressed in USEPA regulation 40 CFR 257  published in September 1379.
In the "Criteria for Disposal of  Solid Waste"  prepared by  USEP^,  large land
application sites, such as Fulton County, would continue to operate, if accom-
panied by a well-organized monitoring system and  the other safe-guards rentionai
earlier.

The questions of total loading of heavy metals and  their impact on crops is
somewhat muted by the constituents of the unconsolidated soils at the project
area.  '4any of the contaminates found in sludge are also found in the project
soils.  The MSOGC monitors the surface and groundwatar and crops.  The results.
would indicate that only -moderate increases in heavy metals in crops are
associated with the project.

*.  Soils

The utilization of sludge solids on  land has both long and short term impacts
on soils.  Most of the generalized impacts on  soils have been noted in reports
prepared by the Council of Agricultural Science and Technology and USEP^ and
will be only referenced for this  text.
                                 V-l

-------
     1.  3aci
-------
         Sludge
                 Digestion
Soil
Atmosphere
                                      Ion  Exchange
                                      & Absorption
Organic
Matter
                    Soil
                  Solution
                                       Minerals
                 Removal.
 Leaching
                                      Plant


                                         I
                                       Cwmcdlties
 Figure v-i    Major Interactions of Sludge and Soil
               Constituents  (Lindsay. 1972).
                         V-3

-------
     of the 15,000 acres of land at the oroject  site have  bean significantly
impacted by previous strip-mining operations.  The results of stria Tuning
trees unoonsoiidited soils mi rock left in  an  unreclaimed  state.   Too soils
were either hauled away or "nixed with strip Tuning spoils  leaving  the surface
with materials low in organic matter.  While some early  attempts were made
to ceelaim parts of the land, nothing was successful.

Until such tine as the project land could be level and the organic content
of the soils increased, the soil could not  be  returned to  its farmer  use,
farming,  The H3D3C project was aimed at reclamation of  land  and soils by
using sludge sslids to build organic matter  in soils.

rhe physical effects of sludge application  to  strip-mined  soils are benefi-
cial.  The high scganic content of sludge provides a matrix for ionic loading
and water adsorption, contributing to increased  agricultural  productivity.

Increased aggregate stability resulting from the addition  of  organic  natter
results in increased infiltration and permeability rites,  increased aeration
porosity, and decreased bulk density,  fhese properties, in turn,  influence
soil erosion potential, the soil atmosphere, and the types of reactions oc-
curring in the soil.  Brosion potential decreases with increased water infil-
tration rates and stabilization of soil oarticlts, with  a  resulting decrease
in dialodgsment and filtration.  In addition,  a  surface  layer  of organic
natter reduces the energy af raindrop or spray droplet imoact.  Seduced ero-
sion may be among the most positive benefits derived from  sludge application.

The presence of organic tatter is chemically significant to the application
of sludge to agricultural land.  The trace  elements in municipal wastes may
occur largely in association with complex organic polyanions.  This interac-
tion between heavy metals and tunic, polymeric substances  in  the sludge and
soil nay have a profound effect upon the nobility and toxicity of  ratal ions
when sewage sludge is applied to agricultural  soils.  The  reactions of metal
ions in the soil include solution, oxidation,  reduction, precipitation,
adsorption, absorption, and compilation, all  of which nay result  in  a build-
up of trace fnetals.

Tha organic natter in Pulton County strip-mined  soils begins  at an  extremely
low level and increases on a long-term basis,  until it reaches a steady state
equilibrium   Like other soils, if sludge application ware  to  be discontinued
this steady state would not be maintained resulting in a decrease  in  organic
flatter due to decomposition.   Agricultural  activity could not  be economically
sustained at depressed soil organic matter  levels.  If ttv;  land were  to lay
fallow, a new equilibrium would be reached*   based upon the  level of bacterial
population changes.
                                  7-4

-------
rhece is a direct link between amount of  soil organic  natter  and cation
exchange capacity.  \s the organic matter in i  soil  increases so does
the CEC.  
-------
The currant practice at ths Pulton bounty  sita  Is to apply sludge  soiiis  to
approximately ana-half of the total  available agricultural acraage each
year.  This practice toes not allow  for crops to be grown on  these fields
due to ths repeated applications during tha normal growing season,  There-
fore, a field is cropped one year and  lies fallow the  naxt year  while
sludge Is being applied,  Raeords indicate that in reality cropping isy
occur oniy ones in three years.  The combination of compaction of  soils
and lack of a cover crop can greatly increase runoff and  soil arosion.

Faulty convex griding on the older of  the  five  application flails  inspected
was found to result in runoff being  channeled toward! the  fisld perimeters,
creating deep galleys.  Lack of vegetation in control  berns,  runoff channels
and basin elites were also seen to contribute to soil erosion, viewer fialds
wert observe^ to bt superior to older  ones in teras of proper grading and
related runoff control.  Concave grading of the newer  fields  creates backup
rasscvoirs foe use when the runoff retention basins ara filled.

Problams were noted in the gated pipe  operation on Field  161. rhe gated  pipe
delivers supernatant to field areas  which  are established in  grass and hay
producing vegetation.  This area was partially  reclaimed  prior to  MSOGC
purchase.  The MSDX has used the rolling  contour of the  land to tha
extent possible to create a gravity  flow of supernatant to increase hay
productivity.  Attempts hava bean uade to  balance the  flow of the  system;
however, dus b> the contour of the land, gheet  Clow is usually not accowlished.
The flow of supernatant is toward rills and gullies.   Ercraion has  resulted.
Pus may be corrected by construction  of control beriis and spreader ditches.
Another control nay be utilization of  vegetation that  is  nors tolerant of
large quantities of water thereby holding  more  water,

In 1975, repairs occurred on Fields  13, 9, 13,  16, 17, 26, 35, 37, 44,
45, and 47 to correct erosion conditions and improve field operations.
Conaidecmbls seeding for erosion control also took place,  including ths saed-
ing of about 270 acres of bernts.  Additional seeding was  performed in that
year on Fields 124, 3i, 51, 52, 57,  59 and 62 for soil erosion control and
hay production.  Proposed plans for  repair of ditches  and erosion  guliias
on Fields Kl and 63 include reshaping of  eroded areas to divert surface
runoff, revegatation, and in Field 161, construction of an earthen dan with
a control structure, construction of betas, rock picking,  chisel plowing,
fertilizing, tandem disk and drag harrowing, seeding,  and lulching.

It appears that probiuns of drainage control due to lass  than optimm grading
schsnes, especially with the older application  fields, will persist into  the
future and possibly be compounded by the new practice  of  cropping  only in
alternative years.  Further field modifications based  upon new operational
data and observations would reduce this intact.  This wock should  be done in
conjunction with cleaning out siltation basins  and bec« repairs.

     3.  Chemical Effects on Soilsat  tha  Project Site

Monitoring of project fields includes  the  determination of 0.1 Normal hydro-
chloric acid (4 QC1) axtractable *etsls in soils.  Zinc,  cadnlium,  nickel,
and copper concentrations of surface soils for  typical sludge amended vine
spoil and non-nined fields at Fulton County are shown  in  Table V-I.   The

-------

Field |



3
Mine-spoil I
field, cropped
4
Mine-spoil
^ fiexd. Fallow
•j

20
Non-Mined

Year


1972
1973
11974
1975
1976
1972
1973
1974
1975
1976
1972
1973
1974
field, c topped! 1975
1 1976
1 1972
36 1 1973
Non-Mined 1 1974
field. Fallow] 1975
1 1976
Sludge
Applied
Metric tons
hectare
dry basis
12.9
2.7
54.7
22.8
1.1
54.9
BS. 8
— •"
„
0.8
52.4
20.4
~ "
_—
—
—
—
84.9

Zinc
ug/g
dry basis

20.0
20.9
71.6
133
™ ' ~
10.9
93.5
125
10.8
—
13.5
72.4
124
__
—
8.0
6.8
96.6

Cadmiun
ug/g
dry basis

1.22
1.47
5.63
8.19
™—
0,43
7.63
9.04
0.28
—
0.36
5.12
7.33
•»
—
0.17
1.18
6.94

Nickel
ug/g
dry basis

0.59
2.58
8.20
11.4
— ™"
6.24
10.6
12.9
4.07
—
3.63
11.3
12.8
— —
—
4.72
3.15
7.15

Copper
ug/g
dcy basis

11.4
9.84
31. 6
42.2
_.
5.40
38.2
42.8
3.11
—
4.37
21.9
32.6
^ —
—
2.67
2.97
30.0
Table V-l.  Zinc. Cadmium, Nickel and Copper Concentrations in Surface Soils, and Annual



            Sludge Application Rates, for Typical Sludge-Amended Mine Spoil and Non-Mined



            Fields at Fulton County (Peterson etal; 1977).

-------
table shows that concentrations of 0.1 H SCL extractabls  zinc, cadmium, nlcteel
and copper in the selected application fields  increased with  each  year of
sludge applications.

The agricultural issues associated with long-tern soil contamination are
whether contaminated soils can support plant growth and,  if so,  whether the
crops grown on such soils will present a health hazard to consuming animals
and humans.  These issue? are related to the long-term availability of
metals that have accumulated in the soil, which is discussed  in  detail in
Section 0 of this chapter.  Experiments that have been performed using
recovery of extractable ratals from soils to indicate plant availability
have shown that heavy metals that have accumulated in soil can be  available
to plants for a considerable period of tine (Chaney, 1978).

B.   Water

Surface water quality is assessed at streams,  reservoirs  and  runoff basins
and groundwater quality is assessed at wells and springs.  Potential impacts
on surface and ground water are delineated separately below.

     1.  Surface Water Quality

There are 11 stream water quality monitoring stations and 10  reservoir stations
throughout the project area; these are designated, respectively:   SI, S2, S3,
S19, S20, S21, S27, 329, S31, S32, 533; and Rl, R2, R3, R4, R5,  RIO, R12, R27,
R28, R34.  Their locations are shown in Figure V-2.  Application fields re-
ceiving or scheduled to receive sludge are provided with  at least  one runoff
retention basin, the effluent quality of which is analyzed whenever there is
a discharge.  Water quality samples from these stations and basins are analyzed
and straarized.

          a.  Hater Quality of Streams - Water quality observations versus
violations of Illinois standards is summarized in Table V-2.  The  data separa-
tion into two time periods, a result only of the updating of  this  document,
provides a useful indication of whether violations have increased  during the
later years of the project,  trends in selected water quality constituents
for all stream stations are presented in Table V-3.

The pH values and concentrations of chlorine,  chromium, nickel md selenium
are within standards at all stations.  All stations show violations of total
dissolved solids and iron, while most exhibit  violations of sulfata ion,
copper and manganese throughout the monitoring period.  Most  of  these viola-
tions probably result from runoff over strip-mined land.  In  addition,
stations stations S20, 321, and S33 indicate numerous violations in standards
for ammonia nitrogen.
                                 v-l

-------
CdJlty file
                                       Key:
                                       U = Well
                                       S - Straaiv
                                       R = Reservoir
    Figure  V-2     General Area Applied with Sludge and
                    Water Monitoring  Stations (MSDGC, 1972a
                    through 1975g).
                                 v-9.

-------
Table V-2     Ratio of Violations »nd Observations Reported at Various Strew
               Stapling Stations, July 1972 to July 197S (NSOGC, 197?. through
               1975g;  General Utter Quality Standards for Illinois Haters)
^^^*-~^Cwita»1f(a*t
Stf»»B^-^_ _
SwoIiM Station — -^ *"
SI
S2
S3
S19
520
SZI
S27
S29
531
S32
S33
0/31
0/31
0/31
0/31
0/4
0/3
0/31
0/31
0/31
0/31
0/9
cr
0/31
0/31
0/31
0/31
0/4
0/3
0/31
0/31
0/31
0/31
0/9
S04'
S/31
13/31
IS/31
0/31
4/4
3/3
6/31
0/31
21/31
9/31
9/9
NH3-H
12/31
5/31
1/31
0/31
4/4
4/4
0/31
0/31
0/31
0/31
5/9
Cd
0/31
0/31
1/31
0/31
0/4
0/4
0/31
0/30
0/31
0/31
1/9
Cr
0/31
0/31
0/31
0/31
0/4
0/4
0/31
0/31
0/31
0/31
0/7
Cu
11/31
11/31
1/31
4/21
0/4
0/4
5/31
S/31
7/31
4/31
V»
F*
30/31
16/31
10/31
3/31
Z/4
4/4
14/31
4/31
5/31
6/31
»/9
Pb
3/31
3/31
5/31
4/31
0/4
1/4
1/31
5/31
7/31
5/31
1/9
"9
0/31
0/31
1/31
1/31
0/4
0/3
0/31
1/31
1/31
5/31
0/9
Mi
1/31
1/3)
1/31
0/31
1/4
4/4
2/31
0/31
20/3)
0/31
9/9
HI
0/31
0/31
0/31
0/31
0/4
0/4
0/31
0/31
0/31
0/31
0/9
Se
0/15
0/15
0/1 S
0/14
0/4
0/4
0/15
0/15
0/14
0/15
0/9
In
0/31
0/31
0/31
0/31
0/4
0/4
0/3!
0/31
10/31
0/31
3/9
TBS
6/10
9/10
7/8
2/9
4/4
3/3
7/9
1/8
9/9
7/8
7/8

-------
                                   Table V-2 ( Cont'd)
           pH  Cl" SQ|« NH3-N  Cd  Cr   Cu   Pe   Pb   Hg   Mn    Ni   Se   Zn   TDS
Sampling^
Station
SI
S2
S3
S19
S20
S21
S27
S29
S31
S32
S33
0/21
0/21
0/21
0/2]
0/21
0/9
0/21
0/21
0/21
0/21
0/21
1/21
0/21
0/21
0/21
1/21
0/9
0/21
0/21
0/21
0/21
0/21
I/
V
15/
0/21
15/21
6/9
9/21
1/21
16/21
2/21
17/21
3/21
0/21
0/21
0/21
18/21
1/9
0/21
0/21
0/21
2/21
5/21
1/21
1/21
0/21
0/21
,0/21
0/9
0/21
0/21
0/21
0/21
0/21
0/21
0/21
0/21
0/4
0/21
1/9
0/21
0/21
0/21
0/21
0/21
2/21
0/21
0/21
2/21
3/21
2/9
1/21
1/21
5/21
0/21
3/21
14/21
7/21
2/21
5/21
3/21
7/9
5/21
3/21
6/21
4/21
18/21
1/21
0/21
0/21
0/21
1/21
0/9
0/21
0/21
1/21
0/21
0/21
0/21
0/21
0/21
0/21
0/21
0/9
0/21
0/21
1/21
0/21
0/21
0/21
1/21
3/21
2/21
0/21
8/9
4/21
2/21
18/21
4/21
19/21
0/21
0/21
0/21
0/21
0/21
0/9
0/21
0/4
0/21
0/21
0/21
0/14
0/14
0/15
0/18
0/18
0/6
0/17
0/17
0/18
0/18
0/18
0/21
0/21
0/21
1/21
0/21
0/9
0/21
0/21
0/21
0/21
2/21
8/21
14/21
20/20
3/20
19/20
7/9
14/19
4/21
18/21
12/21
20/21
                               AUGUST 1975 - APRIL 1977
                                         V-1J.

-------
      Table V-3   The N02+NO,-N,  NH--N,  Phosphorus,   Iron,  and
      Fecal Coliform Content of  Streams for 1971-1976
        SI   S2
  {Zenz  et.al,,  1976,  Enviro Control,1977,  MSDGC)

S3   S19   S20   S21   S27   S29   S31   S32   S33
N02+N03-N (Nitrite and nitrate nitrogen)






1971
1972
1973
1974
1975
1976
2.65
2.82
3.12
2.34
1.99
2.62
2.22
2.48
2.57
1.87
1.85
1.83
.10
.11
.15
.12
.10
.07
_ «. _
1.79 -
5.13 -
3.46 -
3.20 .37 .57
3.47 .12 .95
«.
1.6
2.85
1.83
2.11
1.34
«.
5.95
10.08
7.36
8.00
5.46
_»
1.99
3.00
1.87
2.49
3.01
mm
1.6
2.86
1.53
1.91
1.49
_
_
_
_
.75
.87
Phosphorus






NH3-N






1971
1972
1973
1974
1975
1976
1.20
1.27
.89
.69
.70
1.20
.77
.67
.46
.44
.48
.70
.20
.25
.13
.09
.16
.11
_ «• _
.12
• Xo ™* "™
.15
.16 2.41 .19
.13 3.57 .22
—
.21
.19
.16
.11
.12
	
.15
.12
.10
.12
.21
—
.23
.13
.09
.15
.15
*
.08
.14
.12
.07
.13
—
-
-
-
.40
.30
(Armenia nitrogen}
1971
1972
1973
1974
1975
1976
2.6
2.5
.77
1.0
1.71
.76
1.8
1.13
.59
.60
.90
,30
.40
.33
.25
.20
.41
.10
_ _ _
.50
.15 -
.20
.35 4.44 5.50
.12 6.02 2.02
_
.32
.37
.30
.25
.15
-
.32
.15
.20
.17
.25
-
.33
.10
.30
.20
.22
-
.30
.15
.20
.25
.63
-
_
-
-
1.28
.87
F«cal Coliform*






1971
1972
1973
1974
1975
1976
-
-
8000
22,000
14,241
1060
-
-
4700
9564
3980
209
-
-
172
344
161
58
- - -
_ _ _
325
6758 -
397 1385 230
135 1420 42
-
-
1148
2175
813
361
-
-
315
1390
<204
249
-
-
173
185
300
227
.
-
100
349
<26
34
-
—
-
-
423
245
iron






1971
1972
1573
1974
1975
1976
1.50
1.91
1.21
1.20
1.98
1.58
1.30
1.84
1.10
1.10
2.02
1.55
.30
1.80
.87
.60
.50
.70
_ - _
1.07 -
.71
.52
1.98 .44 6.87
.48 .59 5.82
-
1.05
1.08
.99
.92
.64
-
.82
.82
.70
.68
• 65
-
.80
.43
.60
.53
.98
-
1.3
,5
.40
.59
.64
-
—
-
-
11.84
4.44
'Geometric mean
                                .v-12

-------
These stations might be influenced by the  surface  runoff  from a cattle
feedlot, effluents from failing or improperly maintained  septic tanks in the
community of Cuba, seepage from an oxidation pond,  and  landfill leachate
within the project property.  Some changes in experiiental  sample design
should be accomplished to provide information on suspected  sources of con-
tamination .

Comparing violations of Illinois standards during  both  tire periods shows
that the extent of violations has remained, for the most  part, unchanged.
This appears to indicate that stream water quality has  not  significantly
deteriorated as a result of sludge application.  This is  corroborated by
the trend analysis in Table V-3, which presents annual  average for nitrite
and nitrate nitrogen, total phosphorus,  ammonia nitrogen, fecal colifonus,
and iron in each stream station.  The table shows  no discernible trends in
any parameter foe any station, further indicating  that  stream water quality
has remained unaffected by sludge application.

The number of violations reported at 32  correlates with that at SI, and
water quality at both of these stations  is strongly influenced by pollution
sources upstream from SI, including effluent from  the Canton Sewage Treat-
ment Plant.  Data did show that there have been effluent  quality standard
violations at the treatment plant as well  as other  sources  in the Big Creek
stretch between station SI and the treatment plant. The  new Canton treatment
plant began operation in Nay 1976 and better quality water  in Big Creek
is expected.

The summary completed in 1977 indicates  that downstream station S2 demon-
strates better overall quality than station Si, indicating  that dilution and
instream purification occur along Big Creek between these two stations.
This cleansing is, however, insufficient to reduce pollutants at 52 to accept-
able levels.  It must be emphasized that project influences on Big Creek water
quality are difficult to assess because  of the strong influence of treatment
plant effluents, which tend to mask any  project contributions that may exist.
it can be stated, however, that because  the "existing"  water quality has been
so poor, potential contributions from the  project  are of  little concern.

The only parameters showing increased violations of standards in 1977 in 32
over SI are sulfate and total dissolved  solids (IDS).   Although increased IDS
may indicate that runoff basins provided for the sludge application fields
have not been effective in removing dissolved solids, numerous other  sources
may be responsible for this increase.

The monitoring program was not designed  to aggregate sources affecting
water quality and, as a result, no conclusion can  be made regarding this
observation.
                                 V-13

-------
The only biological watar quality parameter measured  at these monitoring
stations is fecal coliform concentration.  Fecal coliforms,  while non-
pathogenic, indicate that pathogenic organises of  fecal origin nay be
present in the water.  Annual geometric  mean  fecal  coliform  concentrations
are presented in Table V-3.  This table  shows that  fecal colifom counts
in inost stations have been high but have not  been  increasing.  High fecal
coliform concentrations are probably due to contamination by human or
animal waste in effluents from the Canton  Sewage Treatment Plant (SI ana
S2) and faulty septic tanks, and in runoff from cattle  feedlots.  The obser-
vation that thtse values have not been increasing  indicates  that sludge
application is not responsible for high  fecal coliform  counts.

Fecal coliform concentrations generally  decrease between stations SI and S2
as demonstrated in Figure V-3.  A natural  decrease  in S2 counts over high SI
counts (caused by pollutant sources upstream, including effluents from the
Canton Sewage Treatment Plant) is expected to occur from die-off and dilution.
The important issue is whether the observed decrease  is less than the natural
decrease would have been in the absence  of sludge application.  Mthough this
issue cannot be resolved because of the  many  other  sources of fecal coliforma
in that area, valuable insight can be gained  from a study performed by Lua-
aing gt al, 1977.  This study concerns bacterial levels in R3, 31, and S2 from
1972 bo~T§75.  Station R3 is located at  the discharge of Beservoir 3 which
drains approximately 2000 hectares of the  site, ultimately to the stretch of
Big Creek betv-een 31 aid 52.  The study  reports that  although total plate
counts increased at ail sampling sites from 1972 through 1975, levels of fecal
coliforns in R3 wers consistently one to one  and one-half orders of magnitude
lower than in Big Creek.  Drainage from  these 2000  hectares  could, therefore,
not have been responsible for poor water quality in Big Creek in terms of
indicator organisms.

Due to the span of tine between the printing  of the Draft and Final BIS,
water quality data from 1979 was reviewed  to  determine  if any changes had
taken place.  The data was taken from the  1930  3SDQC  operating report.   Host
parameters indicate that the water quality actually improves as it flows from
sampling point 51 (above the project site) to sampling  point 32 (below the
project site).  The only parameters to decline  somewhat were total dissolved
solids, calcium, sodium, chlorine and sulfate.  This  data is very encouraging
but may not reflect any rainfall events  or correlate  with sludge spreading
operations since the sampling was performed on  November 6, 1979.   % map (Fig-
ure V-4) and the data (Table V-4) follow.

The evidence paints to the conclusion that sludge application has not affected
stream water quality.

          b.  Water quality of reservoirs  - Reservoir water  quality is  first
generally analyzed} Table v-5 shows the overall minimum and  maximum for  all
water quality constituents, collectively for  all reservoirs.   This analysis
provides an indication of which parameters violate  Illinois  water quality
standards.  Table V-6 then presents trends in selected  water  quality constit-
uents for specific reservoirs.  Table V-5  shows that  pH values and ammonia
                                 ¥-14

-------
Figure ?-3      Variation of Fecal Conform
                Concentrations with Time for
                Stations SI and S2 (MSDGC, 1972a
                throuih 1975q).

                       V-15

-------
Figure Y-l*  W»t*r Monitorlruc Ltx»tioni at Fulton County
                        V-H

-------
          TABUE V-4
04« "
•I-K.JELnAHt.
*J — v* it i "
N — N02+*103 "
\LK AS CA003 "
P L . C " "IT . 'JM'fOS/C't
l- ^L
11 A **
•C \ lf
•to
?,*J "
r *> "
CO "
r ^ **
it "
Ml "
PI
yr, "
AL "
*tl .
1440.
R.
10.
110.
74.
0,
0.
n.
n.
0.
0.
0.
0.
0.
0.
0.
20.

5.
n-jq.
2
6
Ofl
00
00
nn
30
70
16
00
00
00
00
00
Of!
00
00
00
02
00
19
00
70
00
00
00
00

00
00
s
ll/
1.
0.
14.
1313.
0.
0.
0.
333.
1700.
7.
«U.
210.
UO.
0.
0.
0.
0 .
0.
1.
0.
I.
0.
0.
0.
4.

2,
2174.
3
11
30
01
00
10
30
01
0*
00
in
00
or>
30
00
00
00
00
l}f>
30
27
20
00
00
30
00
00

00
00
*M»)L-MI.1IMOM
THAN i'»r.SK A1F.
       LIMIT  OP LAROn.\TO»!Y .
       )  AS 55EHO
AU,  VALtJES LESS
             V-17

-------
TABLE V-4
(Cont'd)
Flit



i NUMB
OATIS SA'IPLEOj

PH
TOTAL P
Cl.-
<5tU-
•^-KJELBAHL
H-SH3
1-M02+H03
AH AS CAC03
•!L.COM1. 'J'HO
V.
tIA
CA
MC
2*1
cn
cu
ex
MI
>iN
P»
FP
AL
no
SE
r. coLifoxM/in
10!>
TSS
fOS
T1H CO'TMTY LANn R EC1. AM ATI 0«J "HO^
'JAT


r.R:


Mrt/L
ft
fl
M
1*
it
»f
S / C f t
Mfi/L
•t
•I
n
M
n
n
"
n
ti
ii
n
n
UC/L
MC/L
10 ML
HG/L
n
n
F.R ANALYSIS
STREAM \170



•mL*
0.01
i .0
1.0
O.I
O.I
0.01
5.0
I
1 .1
t.o
1 .0
1.0
0.1
0.01
0.01
0.02
O.I
o.oi
0.01
O.I
1.0
0.1
0.2
2
0,5

I
IECT

- FIJLTO'J COTPITY
SPRTMC
11 B P. R 1 0
S !•>
ll/ 5

a . 13
n .13
9 .on
536.00
0 .Rfl
fl.OO
0.05
200.00
120.00
4.00
20.00
110.00
79.00
0.00
0.00
ot
ll/ 5

7.90
0.16
19.00
1 l«»fi.OO
1 .20
0.20
0.45
3<>! .00
1400.00
6.00
74.00
140.00
100.00
0.00
0,00
0.00
fl.OO
0.10
0.15
o. n
n,*0
1.00
0.00
0,00
0.00

6.00
1508.00


S31
ll/ 5

3.10
0 .04
31 .on
670.00
O.RO
0.00
0.21
212.00
2000.00
2.00
52.00
230.00
120.00
0.10
0.00
0.02
0.00
0. It)
0 . 30
0.00
1.70
I. 00
0,00
0.00
430.00

4.00
2344.00
              nSTECTIO!! LIMIT OF LABORATORY.
THAS THIS! A*E  HBFOUTEO 4S ZERO
ALL VALUES LESS
                              V-18

-------
TABUS V-4
(Cont'd)
FULTO'J COUNTY LAN!) RECL AM VT TO1* PROJF.CT
UATHR A?1.VT,YSIS - F'Jt.TO'1 CO*n3 "
ALK AS CAC03 "
EL.COH1, 'JMHO5/CM
X W./L
Mi "
C.I "
'If,
2*j »t
en "
cv "
CR "
HI "
1't "
p«
rn "
AL
MG HC/L
SB HC/t
F. COLIFORM/100 ML
800 '1R/L
TSS "
vne ft
•nt-

0.0 1
l.O
1 .0
0,1
0.1
0.01
5.0

l.O
l.O
l.O
l.O
fl.l
0.01
0.01
0.02
O.I
0,01
0.01
0.1
1.0
O.I
0.2
1
0.5


S12
III 5
« .0.0
0.00
17.00
1225.00
0.50
0.00
0.25
753,00
2700.00
0.00
150.00
110.00
90.00
0.00
0.00
n.oo
0.00
0.10
J1.02
0.00
0.30
1. 00
0,20
0.00
0.00

l*> .00
27«1 .00 -
S31
ll/ 5
"*. 10
0.11
17«>.00
1232.00
0,80
0.00
0 ,*6
302.00
2500.00
5,00
?20 .00
200,00
no. 10
0.10
0.00
o.oo
0.00
0.10
2. «•»
0.10
0,60
0.00
0.00
0.00
250.00

7.00
2477.00
*:iT)L«MI«!IMnM TIRTlCTtnif  LIMIT Of LABORATORY.
THAW THBSB AR^ R».PORTF.O AS 2RRO
ALL
LESS
                               V-li

-------
Table V-5  Hater Quality of Reservoirs (MSDGC, 1972a through 1975g;
           General Water Quality Standards for Illinois'  Waters)
                     Reservoir Samples
Illinois Surface
Water Quality
Parameter and Unit
PH
Total P (mg/1)
Cl (mg/1)
804 (mg/1)
N-Kjeldahl (mg/1)
HH3-N (mg/1)
HOj+NQj-N (ng/1)
Alkalinity
(as CaC03) (mg/1)
Conductivity (mho)
Ca (ng/1 )
K (ag/1)
Na (mg/1 )
Al (ng/1)
Cd (ng/1)
Cr (mg/1)
Cu (mg/1)
P« (ng/1)
Pb (ng/1)
Mg (mg/1)
Mn (mg/1)
Hg (ug/1)
Hi (mg/1)
Zn (mg/1)
T.S.S. (mg/1)
«;0.S. (mg/1)
Fecal Col i forma
(1/100 ml)
D.O. (mg/1)

1971
6.9-10.1
0-1.2
1-30
4-1508
0-23
.1-1.5
0-1.1
70-580

120-2500
9-360
2-12.7
1-535
—
O-.l
O-.ll
0-.15
0-3.6
0-.31
10-483
0-1.19
0-.9
0-.38
0-.6
—
— —
<2-4000

6.2-20

1972
6.9-10.0
0-1.20
1-30
4-1,508
0-4.4
0.1-1.5
0-1.10
70-580

120-2,500
9-360
0-13
1-535
-_
0-0.1
0-0.11
0-0.16
0-3.6
0-0.31
10-483
0-1.19
0-0.9
0-0.38
0-0.6
—
— —
0->7,000

6.0-20.0

1973
7.3-8.9
0.02-0.73
5-20
16-781
0-2.4
0-1.07
0-8.30
80-500

300-3,340
45-367
1-8
9-229
0-3.77
0-0.02
0-0.02
0-0.13
0-1.9
0-0.33
34-132
0-1.22
0-0.8
0
0
—
— —
0-7,600

5.6-15.6

1974
7.3-9.0
o-2.ro
2-312
13-1,160
0-4.5
0-2.0
0-6.30
55-530

570-2,300
45-550
2-10
9-265
0-4.0
0-0.03
0-0.03
0-0.08
0-9.2
0-0.27
35-162
0-1.55
0-3.0
0-0.1
0-0.4
0-231
422-2,092
0-1,500

8.4-15.3

1975
6.9-9.0
0-1.1
2-130
13-1013
0-7.6
0-5.7
.01-15.50
30-900

300-2000
20-418
1-10
9-219
0-6
0-.02
O-.l
0-.02
0-22
0-.13
20-137
0-1.23
0-3.2
0-14
0-.2
1-350
189-6940
0-4100

4.9-14.2

1976
7.1-9.0
0-.32
3-52
0-1057
0-4.7
0-4
0-7.9
49-490

250-2900
35-250
.1-11
4-241
0-4
0-.05
0-.12
0-.15
0-4
0-.6
17-155
0-3.48
0-2
0-.2
0-.9
1-141
302-2467
0-5600

6.5-17

Water Quality
Standards
6.5-9.0
£0.05
£500
£500
— —
£1.5
—
__

—
—
_ _
—
—
<0.05
fCr(-f-6)<0.
£0.02
11. 0
£0. 1
__
5
(anytime)















05











mean)



-------
                Table V-6  The t»2-H«:H»* Mfj-N, Phosphorus,   Iron,  and Fecal  Coliform
                           Content of Reservoirs for  1971 -  1976
                           (Z«nz etal., 1976; Bwiro  Control,  1977; MSDQC )
Constituent
Year
Rl
R2
R3
R4
RIO
R12
R27
R28    R34
N02 + N03-N





Phosphorus





NH3-N





Fecal
Col iform




fe
(ton)




1971
1972
1973
1974
1975
1976
1971
1972
1973
1974
1975
1976
1971
1972
1973
1974
1975
1976
1971
1972
1973
1974
1975
1976
1971
1972
1973
1974
1975
1976
.16
.07
.05
.17
1.48
.60
.20
.10
.12
.06
.08
.10
.30
.20
.13
.10
.27
.26
*•••
—
5
10
5
3
.16
.4
.2
.2
2.07
.27
.32
.17
.35
.69
.92
.39
.26
.09
.09
.07
.11
.10
.3
.3
.14
.20
.17
.11
•*••
— .
19
38
5
5
.2
.3
.34
.3
.24
.27
.16
.09
.48
.65
1.26
1.26
.29
.13
.30
.09
.18
.14
.4
.2
.3
.4
.42
.24
7
5
6
18
7
5
.4
.4
.3
.1
.32
.33
„ m
.04
.24
.05
1.27
.22
— i-
.12
.16
.09
.22
.13
--„....
.4
.3
.2
.18
.12
.
—
34
56
18
7
«MM>
.9
,9
1.1
1.12
1.32
.09
.09
.11
.30
.27
.08
.1
.07
.15
.06
.06
.08
.4
.2
.08
.2
.21
.09
«"•••
__
11
17
6
6
.28
.2
.34
.3
.43
.34
.08
.11
.35
,70
1.17
2.50
.16
.06
.12
.06
.05
.08
.5
.3
.16
.4
.22
.16
rcmurc
— -
11
85
3
6
.1
.5
.26
.3
.43
.29
^P,,
.09
.13
.07
.08
.16
imam
.08
.17
.29
.08
.11
_„ 	
.2
.10
.10
.16
.19
«•••
—
18
24
8
5
-r:m
.3
.38
.17
.29
.57
*»**
—
.09
.04
.16
.11
^_
—
.11
.07
.06
.09
^T-
_
.06
.10
.13
.14
«^«
—
5
5
3
2
-
—
.30
.12
.23
.39
trmm
.94
2.85
2.90
3.51
1.96
mom.
.48
.21
.17
.16
.16
mmL_
1.0
.59
.7
1.11
.66
m 	 L
__
196
620
371
63
^^
2.0
1.3
1.6
1.68
1.06
                                        V-21

-------
nitrogen levels in these reservoirs generally conform to Illinois water
quality standards.  Concentrations of chlorides and ratals such as cadmium,
chromium, nickel and zinc are normally within state standards.  Vie reser-
voirs do, however, exhibit high levels of total phosphorus, suLfate, copper,
iron, lead, manganese and mercury which violate Illinois standards, as well
as occasionally elevated levels of inorganic nitrogen.  A comparison of these
violations to those recorded in 1971 and 1972, before significant amounts of
sludge were applied, reveals that the sane parameters have shown consistent
violations daring both tine periods.  These violations cannot, therefore, be
attributed to sludge application but rather to surface runoff over strio-

-------
3 20
ID
3
&
  20 -
  15
I 10
5  5

I
                      Reservoirs
                                        R2
                                        R3
                                       'Average Saturated Level-of Dissolved Oxygen
                _L
                                                             .  t
                                            M A N J J U  b A* J" M I
J J A SO N 0 0  F M  AHJJASOM  0 J  F H

           »),  ,  „  •  1973	•'}*	18?4
                                                                         1975'
           Ftgurt V-S      Reservoir Water  T«raptratura »nd  Le«1  of
                            Dissolved Oxygen.(0.0.) (NSDGC,  1972a  through
                            1975g; and Envlro Control, Inc.  1976).
                                     V-23

-------
data indicate, D.O. levels ace generally higher than  the minimum standard of
5 milligrams pee liter.  The D.O, levels of. all three reservoirs font a  typical
seasonal pattern, with D.O. peaking in winter and at  a minium in summer.   Dili
cyclic pattern is, as expected, opposite to the seasonal variation of reservoir
temperature. D.O. levels are close to the average theoretical  saturation
values, and are therefore predominantly influenced by water temperature  and the
reservoir mixing characteristics.  Die reservoirs probably have not received
large inputs of oxygen-demanding pollutants such as carbonaceous and  nitro-
geneous organic materials.

During Nay 1973 and Ally 1975, D.O. levels dropped below 6 milligrams per
liter in reservoir Rl, which receives runoff basin effluents from sludge
application fields 126, 127, 128, and 130.  Sludge was not applied to these
fields until August 1974.  Runoff retention basin B-30-2 discharged into
reservoir Rl after the reservoir water *AS sampled on July 9,  1975.   Therefore,
no connection between observed low D.O. concentrations in  reservoir Rl and  the
project operation can be established.

The reservoir data for 1979 indicated that st no time did  the  D.O.  level fall
below 5 milligrams per liter.

During the summer, when ambient temperatures are high and  D.O.  saturation
levels are low, nighttime D.O. levels nay be much lower than daytime  levels.
This is attributable to the continued depletion of 0.0. by olanktonic respira-
tion while photosynthetic oxygen regeneration is absent.   Nighttime monitor-
ing of D.O. is therefore essential to complete the assessment  of  possible
environmental impacts resulting from project operations.
        c"  ^ater quality and capacity of runoff basins - More than 50 runoff
retention basins hive been constructed within the project property as of July
1975.  With the exception of field 138, on which sludge was applied in October
1974, all fields receiving or scheduled to receive sludge are provided with at
least one basin.  Each runoff basin is coded with the same number as the field
it serves, with a sub-number when more than one basin is provided for a par-
ticular field. for example, basin B-20-3 represents basin 13 of field 120.

     Effluent quality - The criteria for field runoff basin effluent discharge
was developed by the Illinois ERA (IEPA).  The IEPA operating permit issued in
1974 was appended with the following two conditions which regulate the effluent
quality from retention basins.

   (1) SPECIAL CONDITION #9:   The effluent discharge from any retention
       basin approved under this permit must meet the applicable effluent
       requirement for discharge to the waters of the State as required by
       Illinois Pollution Control Board Rules and Regulations Chapter 3.
       The point: of discharge to the waters of the State is considered to be
       the overflow structure of each of the retention basins.

   (2) SPECIAL CONDITION »10i  this permit is issued with the condition
       that the following contaminant concentrations are considered to be
                                 V-24

-------
       background values and the numerical effluent standards shall be
       considered met at the designated effluent sampling point described
       in Special Condition f9 when the background concentration plus the
       allowable regulatory concentration is greater than the measured
       concentration for the appropriate parameters!

       Illinois EPA background Concentrations for Field
       Runoff Retention Basins Discharges at the District
       Site in Pulton County, Illinois




Arithmetic Mean
Standard Deviation
Geometric Mean
Total
Suspended
Solids
{mq/D
61.7
87.3
-


QOD
(mg/1)
2.75
1.48
-
Fecal
ODliform
(counts)
100 ml
^
-
94.3
The applicable effluent standards by which the District is currently
operating these field runoff retention basins, therefore, are 1SS
rag/1, aoo •! 33 rag/1, and fecal coliforra  S.494 counts/100 ml.  The average
quality of the effluent from these basins must conform to these criteria
to qualify for release.  These values are arrived at by adding the background
values (above) to the "secondary treatment* effluent requirements of 37 nq/l
TSS, 30 ing/l BOD, and 400 counts/100 ml.

Effluent quality of a runoff basin is analyzed whenever there is a discharge.
The discharge of effluents fran the runoff basin is necessary to reduce the
water level even in the absence of sludge application.  The arithmetic'or
geometric mean, maxiiaum, and minimum levels of TSS, BOD, and fecal collforms
in each runoff basin are presented in Table V-7.

Discharge from runoff basins occurs intermittently and rarely more than
once a month.  Therefore, the effects of a discharge upon the receiving
reservoir or creek probably diminish to  insignificant levels when the
subsequent discharge is made.

     Storm runoff capacities  - Runoff basins were constructed to provide
a retention capacity for runoff from a 100-year storm.  The purpose of the
basins is to retain runoff from application fields for the length of tine
required to meet standards before the runoff water is discharged.  Project
designs called for the recycling of substandard basin water by pumping to
the application field, but records indicate this has never been done.  One
way in which the effectiveness of runoff basins in containing 100-year
storm runoff can be calculated is by comparing the design capacity of the
basins with the anticipated volume of storm runoff.  The 24-hour runoff
volumes for 25-year and 100-year storms are calculated using SCS runoff
                                  ¥-25

-------
                                                               Kbit V-7
[fflvtnt Quiltty of Runoff RcUfltlon MstM  (MSOGC,
19721  tkramk 1975fi «nd tn.lro Control,  Inc., 1976!
f
firiMtir

5|5
T

Ro. of OMOTMtiont
B>. of Vlelittoot
MM (M/1)

MnfcMi ta/t)
•o. of OMtrwttOM
Ro. of Vtolittom
if 1 H»M (M/1)
i
•-
ii
NutMB («t/l)
Ml.ta. (M/1)
Ito. of DMinwtlam
Ho. Of Vc*»4
414.3 per
1W-1
Runoff Rettntlon dsln
8-1-1
S
0
22.2
36
t
S
I

13
4
S
0
23
«0
<10

4
0
9
1*
4
4
1
7.3
16
2
4
0
14
40
CIO

1
1
35.*
43
10
1
3
9.1
2*
2
1
0
U
20
<10

*
?
33.3
82
1
8
1
4.5
8
2
9
0
22
130
2

2S
7
49.1
353
1
!»
9
12.9
M
2
26
t
74
2.000
2

16
1
13.7
220
1
12
6
10.9
a
\
12
0
12
IK)
410

1
0
10
,.
..
1
1
21
.-
..
1
0
80
..
.-

14
2
86. S
644
1
13
10
11.2
32
1
13
1
31
1,300
2
8-6-1
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1
78
184
8
2
0
2.S
3
2
2
1
31
1300
2
8-7-1
2
t
92 * 5 •
93
92
—
--
—
—
—
1
0
180
--
--
8-7-2

*
21.3
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1
4
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7
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b
4
0
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130
<10



l_
3 12
"r


i
?M
III
•



*'*
s
	

MriMMr
MB. of Oktorvttlont
io. of 1lol»tton»
NoM (w/11
Niilaa (M/1)
m««Mi (n»/1)
No of OkHrmttoM
Ito. of VIoUtlOM
MM* (M/1)
HutaHi ("1/1 )
M1«taHl (M/l)
Ro. Of ObMTMtlMS
•i. of VtolatiMt
too. No» (1/100 •!)
NKtMH f 1/100 •!)
Hid !• (1/100 «1)

StMd«r«
ArlUwMc HMH
of TSS thill
M.7 •!/!


Arfttantlc •»•
Of M» IM11
«.7S B|/l


GtCBitrtc MM
of ftul
Mull not
o«co*4
100 •!

1-7-3
1Z
t
32.6
127
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f.3
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rz
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0
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8-8-1
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i-a-2
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122.1
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130
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21
0
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64
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8-1-2
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94
11
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tlon l»1
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77.3
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8-10-1
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7.7
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8-10-2
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8-12-1
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8-13-1
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190
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-------
                                                                    Tifelt V-?    Contlitvtd
f
                                                          Effliieiit
                                                          SUnddrtl
                                                       AritNwKc MM
                                                       of TSS «MU
                                                       not tiered
                                                       M.7 m,n
                                                       Art Mm Ic BtM
                                                       of 800 dwll
                                                       tot ««re*d
iMMtrtc
of ftcil
conform
jh.11  not
                                                       4M.3
                                                                100 •!
                     16

                     2<
                                                                            33
                                                                           1M
                                                                                   i-ii-L
                                                                                             35. S
                                                                                             76
                                                                                             10
                                                                                             a.z
                                                                                             17
                                     H
                                                                                           5,000
                                                                                                         Runoff Retention Mtln
                                                                                                    -16-1
                                                                                                     IS.]
                                                                                                     30
                                                                                                     10.3
                                                                                                     20
                                              22
                                                                                                    160
                                                                                           £10
                                                                                                             1-17-1
                                                                                                              153
                                                                                                               3.5
                                                               Jii.
                                                                                                                       40.1
                                                                                                                       11.7
                                                                                                                       SO
                                                                                                                              -11-1
                                                                                                                              (3.1
                                                                                                                              100
                                                                                                                              -za_
                                                                                                                               7.S
                                                                                                                              12
                                                                                                                              70
                                                                                                                                      -20-1
                                                                                13
                                                                                                                                       59
                                                                                                                                       10
                                                                                                                                        (.3
                                                                                                                                       10
                                                                                15
                                                                                                                                       80
                                                                                                                                               108.6
                                                                                                                                               312
                                                                                       _!/_
                                                                                                                                               18.1
                                                                                                                                               73
                                                                                        32
                                                                                                                                                        34.7
                                                                                                                                                        37
                                                                                                 21
                                                                                                                                                       1 ,000
                                                                                                                                                                 2«.3
                                                                                                                                                                 K
                                                                                                          36
                                                                                                                                                               2.MO

I
lip
*l*.
"Zc-a
sn
?Kl
III
•


*1
S
rw^tUr
H». of OMtrwttoM
M. tf HsUtlwii
MM* ten)
Hnfaa te^ll
MtutaB (piyi)
to. tf »1elittw»
NMHta/11
NUtaM (M/l 1
NliitaM ta/1)
to. * VMttlam
CM. mm [1/100 «ll
Hula* (1/100 •!)
NtotaMi (1/100 •))
ffflomt
StwMtr«
Arlt tattle MHI
of TSS ihill
not t>ct*4
M.7 «f/1
Artttattlc MM
of KB shtll
t. 7$ HI/I
r«i»itrte "twi
of ftcil
collforvs
stall Mt
txctM
4*4.3 ptr
100 Hi
bwwff Retention tosln
I-22-I
20
0
16.4
34
4
11
7
».S
11
I
1*
0
It
320
2
1-22-2
12
4
11. t
m
2
(
3
7.2
11
3
11
0
4f
400
410
1-23-1
p
..
	
—
..
0

„
,.
.,
0
...
^_
	
"
I-2S-I
3
0
IS 3
2S
f
3
0
5.7
I
S
_J_
0
<10

--
1-21-2
1
0
1
.„
-
1
0
4
..
..
1
0
<10
,„
-
I-2C-1
S
0
2|.S
41
3
S
2
».*
11
4
S
0
12
20
ifO
•-2C-2
<
0
17
»-
8
i
3
6.8
M
4
•
0
»
100
£10
8-27-1
4
0
11.8
»
5
4
0
S
5
S
4
1
71
2.COO
<10
l-27-i
4
9
13.3
>»
1
4
0
1.75
7
4
4
0

-------
                                                      Table  V-7
Continued

*.
ai-
*"t»«?l
m
Biologic*!
Oxygen
Demand
Fecal
Conforms
Paraaettr
No. of Observations
HO. of violations
Mean (ma/13
Maximum (aig/1)
Minimum fmq/1)
(to, of Observations
No. of Violations
Hem (ni/1)
Maxflnum (ir.q/1)
Minimum («g/ll
No. of Observations
HO. cf Violations
G*o. Hear, (1/100 ml)
Maximum (1/100 *1)
NinlMjH (1/100 «1)
effluent
Standard
Arithmetic mean
of TSS shall
6fi,7 «g/l


Arithmetic mean
of BOD shall
not exceed
6.75 rag/1


Geometric mean
of fee*!
conforms
s ha 1 1 not -.
exceed
494.3 ptr
100 nil 	 i
_ Rut off Retention EaS'n —
B-30-2
6
0
16.5
28
6
6
2
6.3
9
4
6
0
<10
..
—
6-31-1
0
..
	
—
,.
0
..
_,-
-.
-.
0
—
—
—
..
B-32-1
0
-.
._
..
._
0
.„
,.
._
—
Q
—
—
—
..
B-33
0
,.
_.
..
«-
0
	
—
..
	
0
—
--
-.
—
8-34-1
0
.-
«_
_-
--
0
	
—
..
..
0
.*
..
—
..
B-34-2
0
—
._
—
__
0
__
—
—
—
0
	
.-
—
—
-£iJSJ_
0
..
_-
—
«.
0
..
.-
,_
	
0
«-
—
—
r--^-
e-?f,-i
0
..
..
—
— -
0
_.
--
..
«„
0
..
..
..
-
B-37-1
0
—
—
—
..
0
,.
...
-.
—
0
-~
».
..
--
5-39-1
3
0



3
1



•y
0



£-«-!
2
0



2 !
f



I
0



f
M

-------
T«b1t V-7   Continued

_!„
513
' kf
Is?
ss?
oSl

i
II
Pirjneter
Ha, Of Ob$*r»*tlofu
tio. of »1aUt1sns
Xean (rj/lj
Miilnwi !ng/1)
Kfniwi (»5/I]
*». of Wiltrvatlotij
So. of KtelttlOM
yein !«s/ll
»K«r-j« (PSHI
Klnlwm (na/1)
NO, 0' 0&$*r»aHors
fe. of Violations
Geo. Vtm (1/100 ill)
Hwlrnr (1/100 ml)
HinfTWi (1/100 nl)
Cffluert
5t«ndird
ArltHmttc netn
of TSS stall
not e»ceed
66.7 m/1

Arlthmttc MM
of BOO shall
not e«c«ed
6.75 »Q/1

Gtonetrfc ««M
of f«c«1
col If oral
sluil not
exceed
4?4.3 per
too «i


8-41 -1
3
1



J
1



J
0



B-42-1
2
0



f
1



2
0



S-4J-2
4
0



4
2



*
0



Runoff Retention Basin
B-43-1
3
0



3
2



3
0



8-44-1
S
2



5
1



5
0



6-45-1
J
0



3
0



3
0



B-47-1
1
0



J
1



9
0






































































-------
curve nutbec 38, assuming low soil permeability and no conservation prac-
tices, evapotranspiration or depression storage,  Mthough assumptions
cesuit in slightly overestimating storm runoff, the evaluation of retention
basin effectiveness also assumes that the basins are coupletsly empty
ocior to each storm, and that the basin capacities are not diminished by
sedimentation of suspended solids from previous stom runoff. The effective-
ness of a runoff basin is seriously impaired whan a storm occurs before the
basin is entirely empty.  Bnptying the basins before a predicted storm nay
cause bottom sediment contaminated with sludge particles to be discharied
to the receiving water.

Table v-8 summarizes the design capacity of each retention basin and cal-
culated storm runoff voluw for 25 and 100-year storms.  From these cal-
culations the retention basins for fields 3, 14, 20, and 21 appear unable
to contain the 25-year storm runoff and basins for fields 4, 7, 11, 12, 19,
22, 25, 26, 29, 30, 39, 40, 42, 43, 44, 45, and 47 are unable to contain
the 100-year stom runoff.  Actual field observations indicate that these
Bay not be the worst case events.   The worst case may occur when basins
are partially full prior to application, the ground becomes saturated by
application and then intermittent heavy rainfall occurs within several
days.  This was observed in September 1977.

Some deficiencies between correlation of calculated retention basin capacities
and observed deficiencies can be explained in terms of variables ranging from
characteristics of storm to the condition of the soil at the time of storm.
However, the most likely explanation lies in the applicability of the SCS
method to the project site.  The SCS uethod as used here provides the
aTDunt of runoff that can be expected on the basis of "average sits
characteristics".  Ideally, a different runoff curve should be applied to
each field, depending on local hydrologic conditions of the soil, soil
type, soil depth, type of crop grown, conservation treatment, and many
other factors.  These factors must be considered at Fulton County, where
each retention basin is tailored to the runoff volume expected from
a particular field.  Other sources of error can likely be found in predicting
the portion of a field draining into each of its retention basins, as explained
above with respect to field 12. Runoff basins with inadequate capacity for
containing 100-year storm runoff as well as runoff from recurring, high
intensity storms, are particularly ineffective in removing suspended solids
from storm runoff.  Numerous violations of effluent standards for total
suspended solids and biochemical oxygen demand show that the runoff retention
basins have been ineffective.  Prolonged violations could result in siltation
and excess dissolved oxygen depletion in receiving waters.

     2«   Groundwater quality

Gtoundwater quality was assessed from samples collected from 26 wells and
one spring during a six year period.  The ideal approach to groundwater
analysis would have included a designation of background wells measuring
natural parameter variations and a trend analysis among remaining wells
before and after sludge application.  Unfortunately, this could not be
accomplished in a comprehensive fashion for Fulton County.  First, this
                                 V-30

-------
Table v-8  Capacity of Runoff Retention Basins and Volume of
           24-Hour Storm Runoff (MSDGC 1972c through 1972g and
           19731 through 1973k; Envico Control, Inc., 1976)

       Runoff Retention Basins
Field
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
19
20
Basin
B-l-l
B-2-1
B-2-2
B-2-3
B-3-1
B-4-1
B-4-2
B-5-i
B-6-1
B-7-1
B-7-2
B-7-3
B-8-1
B-8-2
B-9-1
B-9-2
B-9-3
B-10-1
B-10-2
B-ll-1
B-12-1
B-13-1
B-13-2
B-14-1
B-15-1
B-16-1
B-19-1
B-20-1
B-20-2
B-20-3
Capacity
Per Basin
(acre-ft)
24.4
21.5
4.1
2.9
12.9
25.9
6.2
15.3
6.6
5.9
16.0
17.0
25.2
6.4
43.2
13.7
4.9
21.5
23.0
8.0
11.0
9.5
39.5
14.3*
10. 5
70.3
14.2
15.0
11.2
8.8
Capacity
Pec Field
(acre-ft)
24.4
28.5
12.9
32.1
15.3
6.6
36.9
31.6
61.8
44.5
8.0
11.0
48.5
14.3
10.5
70.3
14.2
35.0
Calculated 24-Hr. Runoff
(acre-ft.)
25-Yr. Storm 100-Yr. Storm
15.0
16.9
13.3
26.0
9.8
4.8
35.8
23.1
56.9
30.6
6.8
8.8
5.1
22.8
7.2
48.8
12.4
37.1
19.6
22.1
17.4
34.0
12.8
6.4
46.8
30.2
74.4
40.0
8.9
11.5
15.3
29.8
9.4
63.8
16.2
48.5
                              V-31

-------
Table V-8 continued
Field
Number
21
22
23
25
26
27
28
29
JO
31
32
33
34
35
36
37
38
39
40
41
Basin
B-21-1
B-22-1
B-22-2
B-23-1
B-25-1
B-25-2
B-26-1
B-26-2
B-27-1
B-27-2
B-28-1
B-29-1
B-30-1
B-30-2
B-31-1
B-32-1
B-33
B-34-1
B-34-2
B-35-1
B-36-1
B-37-1
NA
B-39-1
B-40-1
B-41-1
Capacity
Per Baain
(acre-ft)
4.5
13.7
7.9
14.9
6.9
7.5
13.8
8.8
17.5
7.1
13.5
14.9
7.2
20.1
9.3
15.8
*
26.4
12.3
14. 2«*
78.8
35.7
HA
14.6
30.7
23.3
Capacity
Per Field
(acre-ft)
4.5
21.6
14.9
14.4
22.6
24.6
13.5
14.9
27.3
9.3
15.8

38.7

93.0
J5.7
NA
14.6
30.7
23.3
Calculated 24-Hr. Runoff
(acre-ft.)
25-Yr. Storm 100-Yt. storm
12.7
16.9
7.2
12.4
20.8
14.0
10.1
12.7
22.4
6.0
11.1

23.3

59.0
22.4
17.6
13.7
26.7
17.9
16.6
22.1
9.4
16.2
27.2
18.3
13.2
16.6
29.3
7.9
14.5

30.4

77.1
29.3
23.0
17.9
34.9
23.4
                               V-32

-------
     Table V-8 continued

Field
Number
•••^^^•^^B
42

43
44
45
47


Basin
B-42-1 .
B-42-2
B-43-1
B-44-1
B-45-1
B-47-1
Capacity
Pec Basin
(acre-ft)
33.3
24.4
23.1
11.6
48.1
12.5
Capacity
Per Field
(acre-ft)
57.7

23.1
11.6
48.1
12.5
Calculated 24-Hr. Runoff
(Acre-ft
25-Yr. Storm
52.7

19.2
11.1
47.5
9.8
.)
100-Yr.
68.9

25.1
14.5
62.1
12.8

Storm






Note:  NA - Not Available
        *Field 133 drains its runoff to Retention Basin B-32-1 of Field 132.
       **Pield 135 drains its eastern portion of runoff to Retention Basin
         B-36-1 of Field 136.
        *Field |14 drains some of its runoff to basins serving fields
         113 and #16.
                                      V-33

-------
would have required a highly detailed  and  presently unavailable tracing  of
groundwater flow.  Secondly, sludge application was initiated at aifferent
tiles and rates on each field, making  a clear cut definition of "before  and
aft-ii* L-nposaibls.  Technology currently exists to  neasure groundwater  flow
and direction.  This could be utilized if  it beoxnes  necessary to isolate a
groundwater pollution source.

While this type of analysis couli not  be conducted  comprehensively,  certain
wells were selected to reprasent a cross section of thosa in the nine spoil
area of the site, an analysis of which was not constrained by the above
problems.  It -oust be emphasized that  this analysis does not at this stage
provide a long-range conclusion, because extremely  low soil oeriKability
vastly lengthens the tine needed for sludge to interact with groundwater.
*n exception is the case of direct fissure flow, the  effects of which becone
apparent Ttuch nors quickly.

          a.  Chemical trends in selected  wells - The locations o£ wells and
springs are shown in Figure V-2.  The  four wells chosen for illustrative
purposes are Mil, W14, W7, aid W17.  Well  Mil should  reflect seepage originat
ing from the holding basins.  Well H14 is  located in  field 19, which has
received sludge at moderate rates since 1972, and Tiay also be affected by
Fields *6 through 8 (sludge application initiated in  1973) and *7 (1974).
Well W7 is likely to be affected by fields 120 (1973) and 126, 28, and  30
(1974)  These two wells should reflect the effects  of sludge application.
Well W17, locatad in an area receiving no  sludge as of Oeceriber 1976, is
a background well.  The constituents selected for analysis are those present
in the digested sludge at levels sufficiently high  to serve as a tracer
material for for direct fissure flow:  nitrite and nitrate nitrogen and  iron
("GOGC, 1976).  Table V-9 shows the respective concentrations in each well.

Well Wll shows no trends towards increasing nitrate,  nitrite or airoonia
concentrations. Iron levels have fluctuated and would appear to be showing
an upward trend, but 1976 data are unavailable because of well relocation.
In the absence of further data, this trend v. nnot be  substantiated.   It  is
highly unlikely, however, that substantial seepage  would occur through the
clay-lined holding basins.
      W14 and W7, potentially affected by  sludge application,  show no  upward
trends  in either nitrite and nitrate nitrogen or atraonia nitrogen.   Tha  same
is true for iron in well W14. Iron concentrations  in  well 'if} show an upward
trend while those in well W17, the "control," remain  relatively constant.
The upward trend began in 1972, however, and sludge application on the
associated fields did not begin until 1973 or 1974.   Iron increases are  there-
fore noat likely attributable to sources unrelated to the project.

These data indicate that sludge application has not significantly affected
groundwater quality at the site.  Because  of the significance  oC potential
ground water contamination, certain aspects are examined  in closer detail
below.
                                 V-34

-------
Table V-9   Th« NO2 + NO3 - N,  NH3  - N,  and  Fe Content of hells 11, 14, 7, and 17 for 1971-1976




            (MSDGC, 1976 and Enviro Control,  1977)

Constituent
NOj + NO3 - N
iNH3-N
Fe (Iron)
Year
1971
1972
1973
1974
1975
1976
1971
1972
1973
1974
1975
1976
1971
1972
1973
1974
1975
1976
Hell 11
Mean Range
{•g/1) (mg/1)
0.07 0.03-0.15
0.0 n. 0-0. 02
0.07 0.0-0.42
0.04 0.0-0.14
0.04 0.0-0.09
1.9 1.7-2.4
1.8 1.4-2.1
1.35 0.5-1.7
l.€8 0.9-2.2
2.07 1.6-2.60
5.9 2.4-10.5
15.3 4.8-36.1
10.6 2.7-27.3
15.2 4.7-59.0
22.8 4.0-46.2
Well 14
Mean Range
(mg/1) (mg/1)
0.08 0.0-0.19
0.01 0.0-0.07
0.03 0.0-0.07
0.03 0.0-0.06
0.04 0.0-0.11
0.02 0.0-0.06
0.7 0.2-2.3
0.6 0.1-1.3
0.78 0.2-1.2
0.60 0.4-0.8
0.73 0.4-1.3
0.52 0.0-1.0
28.9 6.5-63.8
54.7 32.9-90.8
60.6 15.0-193.0
34.6 20.4-49.6
36.5 13.2-78.9
27.2 10.9-77.0
Well 7
Mean Range
(mg/1) (mg/1
0.1 0.0-0.25
0.16 0.04-0.28
0.73 0.18-1.61
0.26 0.01-0.54
0.2? 0.06-0.76
0.06 0.0-0.2
0.5 0.1-0.9
0.5 0.1-1.1
0.57 0.2-1.8
0.52 0.2-0.9
0.64 0.5-0.9
0.5 0.1-1.1
2.1 0.3-4.0
15.9 3.3-40.4
47.2 11.3-78.8
63.0 35.8-92.9
83.1 56.7-107.0
101.7 69.3-130.0
Well 17
Mean Range
(mg/1) (mg/D
0.41 0.04-1.68
2.5 0.0-0.11
0.40 0.03-0.73
0.21 0.0-0.79
0.23 0.9-0.63
0.13 0.0-0.2
0.6 0.1-2.1
0.5 1.3-2.7
0.21 0.0-0.4
0.22 0.1-0.7
0.18 0.0-0.4
0.18 0.0-0.8
12.3 1.0-22
11.6 13.0-181
14.5 9.0-19
16.2 10-22
13.1 9.7-16.4
14.0 9.5-27.1

-------
        b.  Nitrite and nitrate  trends  in all wells - The  nitrite  and nitrate
nitrogen concentration in each well or  spring was analyzed fran August 1973
to April 1977.  Chly wells W8, W10, and W21 reported concentrations in
excess of 10 milligrams per  liter, which  is recommended  as the maxinum level
by the U.S. Public Health Service (U.S. Public Health Service, 1962,  1969).
Well W8 has consistently low levels of  nitrite and nitrate nitrogen,  with
the exception of a spite between January  and May  1975.

Wells showing possibly increasing nitrite and nitrate nitrogen levels are Wl,
W4, W12 and W22.  Of these,  Ml and W4 are located upstream from the project
site and are unaffected by project activities.  Increases  in nitrite  and
nitrate nitrogen levels in wells W12 and  W22,  and fluctuations in  nitrite
and nitrate levels at the other  wells,  do not seem to correlate with  project
activities.  In addition, the levels are  generally lower than 0.2  milligram
per liter, except for well W10 which possesses consistently high values.
These findings suggest that  a large portion of nitrogen  in the applied sludge
is fixed by soil molecules,  converted and released as ammonia gas,  or taken
up by crops for bio-synthesis.   Apparently,  little soluble nitrogen is leaching
into the groundwater system.  In addition to Wll, wells  W12 and W13,  conceivably
vulnerable to seepage from holding basins,  have generally  shown less  than
1.2  milligrams per liter of nitrite and  nitrate  nitrogen.   This further indi-
cates that the clay linings  in the four basins have been effective.

The possible effects of increasing application rates or  accumulation  of
sludge in the fields on jroundwater nitrogen levels cannot be assessed at this
stage of project development.  Data are not sufficient for analysis of trends,
and long-term monitoring of  groundwater quality is required to establish the
relationship between project operations and the nitrite  and nitrate nitrogen
level.

        c.  Trace element and other concentrations - Variations in  groundwater
constituents are shown in Table  V-10.   The range  of variation is given for
seven calendar periods, either before or  during the sludge application season.
The well reporting the maximum level of a given constituent is indicated in
parentheses.

The pH values, alkalinity, conductivity,  and concentrations of total  phosphorus,
sulfate ion, calcium, potassium,  sodium,  aluminum,  iron, magnesium, manganese,
mercury, nickel, selenium and fecal coliforms remain close  te the 1971 and  1972
baseline conditions (see Chapter III).  Recent concentrations of cadmium,
chromium, coppnr, lead and zinc  are lower than the baseline concentrations.   In
1971 and 1972, 40 percent of the wells  tested contained  excessively high levels
of chemical constituents.  When  retested  between  1973 and  1975, after the pro-
ject had begun, the statistic was the sane.   Groundwater constituents are,
therefore, probably influenced by sources unrelated to the  project.

C.  Air

Impacts on air quality may result from  aerosolization and volatilization
of sludge constituents, perhaps  presenting odor problems or health  hazards.
Potential health hazards are discussed  in section D,  "Health Effects".
                                 V-36

-------
                                         T«kt«  V-10
                                                                      of Mrtwn ComtltutMs tn SrwintfMt*r (H506C. 1972 • through 1975 |J
                   first Quarter
                       1171
                  (ktfir*
                                       August
                                        1971
                                 (during 1973 slydgc
                                 «BBllMtll» jMttm)
                                                                              August
                                                                                1974
                                                                         (during 1974 tlutfai
                                                                                    it**!*)
                                                                                                  Ap?n—
                                                                                                    1975
                                                                                            (before  1975 ilutfgt
  Ivjter QutlUj
farceur •* ».U
       1*74
(before 1974 siudgi
ippllotlon tBiMB]
       1974
(during 1974  slirfgt
iK»l lltlltll* Si«HiBJ
                                1i7s
                          (during  1175 stud*
                          JBBllCiHl
M
•ul r
:r
»«'.
             ml}
 (n C*CO,}
 1,9-1,9
0.04-O.M
   2-392
  18-1.048  (MM.

 227-1.107  (Mil
                                   0.07-0.46

                                      t-1.546  (HI2)

                                    150-1.120  (M2t)
   6.6-8.1
  0.04-0.87  (M24)
     2-390   (101)
    SJ-1,706 (Mil)

   150-1,ISO (M26)
  7.1-7.8
    0-0.29   (M10)
    1-401    (W
    0-1.293  (Mil)

  210-940   (Mljj
                                                                            6.J-7.7
                                                                           0.02-1.80
                                                                              0-381
                                                                             40-1,999
                                                                                             129-1.1*0 (K2t)
(Ml)
 »4)
(11D
 (.9-8.1
0.07-0.38
   0-374
   0-1,439
                                                                                               210-1.300 (Hit)
 7.1-8.3
0.05-8.73  (HZ
   0-404   m
   0-1,479  (W

  88-788   (MIS)
     tlvlty
             4/1
             •8/1
                   412-3,413
                    58-534
                     8-412
                     0-4.9
                  425-3,450 (H4)

                    1-11    (H)
                                     600-5.500 ltd}
                                      14-141   (Mil)
                                      0-30    (W7
                            flS!
                                      12-612   (Kf)
                                       0-10
                                                                         4(0-1.900
                                                                          24-S49
                                                                           0-17

                                                                           s-uo
                                                                           0-4.0
                                         S20-2.3BO (HI)
                                          S2-39f
                                           1-1*
                                           8-700
                                           0-7.0
                                mr
                                (B;
                                N2I)
                                (««5
                                («!>
         420-3.200
          48 627
           0-1*

           ?-«»
           o-t.o
                    400-7,500
                     38-405   (M9)
                      0-19    («)
                      t-(25
                      9-3.0
                                                                                                                                             (K2i)
             mt/\
             •8/1
   0-0.02  (Mil

   0-0.01  (M12;

fl.01-0.0i  (HI

 B.2-I3S   (M13
   8-0.4*  (0
                    0-0,02  (M13)

                    0-0.01  (H2S)

                    0-0.0*  (KID

                  O.I-I3S   (M9)
                            tea)
                                      0-0.40
                                                         0-0.03  (1113)

                                                         0-0.0*  (M2S)

                                                         0-0.12  (JCZ)

                                                       0.2-119   (H9)
                                                         0-0.31  (iti)
                                                                           0-0.OJ  (H13)

                                                                           0-0.02  (M12;
                                                                                   MT1J
                                                                           o-o.i*  	
                                                                           0-123
                                                                           0-0.7*
                                                                                                       isr
                                           0-0.16   (Hl£)

                                         0.1-171    (»)
                                           0-O.M   (BTl)
                                           0-0.02  (H4;
                                                   (1(13)
                                            0

                                           0-0.2   (Mil)

                                           0-107   (M7J
                                           0-0.12  (W
                               0

                               0-0.03  (M2i

                               0-8.22  TJilZ;
                                      •HT
                             0.1-83.S  TTOI
                               0-0.25  (Mil)
             •I/I
  31-3*0   (M12
•.01-7.44   (M
   0-0.4   W
             •*"
                    0-410   (Mil)
                    0-8.05   I.W12)
                  0.2-0.9   B4T
                    0-0.2   IMD
                                                        34-171  (H
                                                         0-9.1*   M
                                                         0-4.4  (B
                                                          0
                                                          0
                                                                                              30-375
                                                                                            0.01-7.10
                                                                                               0-0. S
                                                                                                0
                                                                                                0
                                                             12-430
                                                              0-8.95
                                                              0-9.*
                                                               0
                                                               0
                                                                                                                                    25-34S   (H13J
                                                                                                                                     0-0.3
                                                                                                                                      0
to           M8/1
Ftctl Ullform
         1/100 Bl
                   0-49.*   (ill)

                    0-2     («3)
                                       0-30

                                        0
                                                                (MID
                                                                           0-11.5  	

                                                                           0-W    (H7)
                                           0-61.5  (B3I

                                           0-14    (KO)
                                           0-11.8  («)

                                           0-2     (H)
                              0-19.2  (11131

                              0-350   (CO)
    •  Mil irttfe auliMi caneantntlgii.
    *  Mil twttkljr iffkct«4 tsr itvdti  aBpllcatlni.

-------
Ihis section discusses odor In teems of theoretical considerations, odor
conplaint data fron the project site, and the relative odor potential of
the sludge holding basins and alternative application methods.

D.  Health Effects

Sludge solids may contain pathogens, chemicals and metals that are poten-
tially harmful to humans and animals.  Extended exposure to these components
may result in adverse health impacts.  While there are several routes by
which humans or animals can be exposed to sludge, the main routes are di-
rect ingest ion or inhalation of airborne sludge particles.  Indirectly,
heavy metals and some chemicals may be ingested when plant tissues are
consumed by animals.  The U.S. Department of Agriculture, the Council of
Agricultural Science and Technology and others have reported on the hazards
and impacts of heavy metals and expected health impacts from sludge appli-
cations.

     1.  Direct Health Effects

Direct health effects can result from the inhalation of sludge aerosols,
the severity of the effect depending on concentrations of hazardous materials
in the sludge, the amount of sludge aerosolized, the extent to which the
airborne particles are inhaled, and many other variables.  As stated in the
discussions of odor, sludge aerosolization does not occur with surface
spreading (overland flow and infiltration-percolation) or surface penetration
(soil incorporation and soil injection).  Although white-capping in the
holding basins can cause aerosolization, pressurized spraying offers the
greatest potential for direct transfer of hazardous components to humans or
animals.

Pressurized spraying has been discontinued as an application method in
Pulton County, and it is unlikely that significant amounts of aerosols would
result from white-capping in the holding basins.  Therefore, significant inha-
lation of aerosols (and associated potential health effects) is not likely
to occur at this stage of the project.  Because pressurized spray has consti-
tuted a large proportion of past application methods, however, it will be dis-
cussed in this chapter.  Mitigative measures will not be presented because,
as long as spray application is not practiced, inhalation of aerosols will
probably be negligible.

        a.  Background - Although very few pathogens survive wastewater treat-
ment, saimonellas, Hycobacterium tuberculosis, and many enteroviruses (viruses
of the gastrointestinal tract) may even survive chlorination in low numbers
and it has been shown that the absence of col if onus does not necessarily
indicate virus inactivation (Allen et al., 1949} Sorber, 1973; Kruze
et al., 1970; D'ltri et al., u/d).  The microbial population of sludge is
greatly reduced by holding for a few weeks, but is not eliminated com-
pletely,  it should be emphasized here that high-rate anaerobic digestion
followed by lagconing practices which are employed by the MSDQC, are
considered by the UBEPA to be sufficient for pathogen control.
                                 V-38

-------
Pathogens may b« present in sludge in minimal numbers even after Tenths of
lagooning.  h major factor influencing their presence and quantity is the
community's discharges into the system, which may be expected to be highly
variable.  Sources are human and animal and they include slaughter nouses,
the meat products industry, poultry and egg processing plants, tanneries,
and many others (McCoy, 1971).  It is evident that the nature and! concentra-
tions of pathogens entering and potentially surviving treatment must vary
widely from place to place and time to tine.  Evidence from places other than
Fulton County are therefore of little predictive value, and samples taken in
Fulton County at one point in time will not necessarily be valid for other
tines.  For example, midday counts of B. coli Mere 5.5 in January 1970 and
0.18 in September 1970, and midnight countswere 0.3 in both tenths (McCoy,
1971).  Futhermore, E. coli are the overwhelmingly dominant bacterial species
in domestic waste; diseases of seasonal and epidemic character would show
much wider fluctuation.  It may be noted that bacteria, which are sizeable
compared with the droplets, will not inhabit all droplets; this is also true,
especially, for larger amebic cysts, helninth eggs, and so forth,  dissolved
substances, in contact, are present in all particles.  Treatment plants hand-
ling a substantial proportion of industrial waste are liable to have a conside-
rable burden of toxic substances in the sludge.  Thorne, Hinesly and Jones'
data are reported in Table V-ll.

     Ttole V-ll.  Composition of Fresh, Heated, Viaerobically Digested
                  Sewage Sludge (Thocne et al., 1975)

                            Dry Sludge Basis
                                       typical             Typical
                  Concentration     Concentration          fcnount
                  Range (pom)*          (pom5*             (Ib/ton)

Cadmium (Cd>       3 to 3,000           150                  0.3
Chromium (Or)     50 to 30,000        3,000                    6
Lead (P )        100 to 10,000        1,000                    2
Mercury (tig)       1 to 100               3                  0.006
Nickel (Ni)       25 to 8,000           400                  O.S
*Nercury units expressed in ug/1

Foe comparison, data available from Fulton County reveal an average of about
450 pp* for cadmium, and a maximum concentration of 1,125 ppm.

It muBt be cBtchasixsd that the input rate for such materials at the treatment
plant is likely to vary widely, even during stable conditions of industrial
production with discharges occurring, for example, at one step in a batch
process or during periodic cleansing.  Whan processes change or new processes
are introduced, further variations in the effluent may be expected.  Conse-
quently, a few grab samples widely separated in time may give a highly mislead-
ing indication of average concentrations.

     b.  \irborne Transmissions - Constituents of sludge can become airborne
and o« transmitted ~ to downwind receptors,  m the case of Fulton County,  there
                                 V-39

-------
were two main sources that were Investigated,  the first MBS the transmission
of constituents when sludge was sprayed by rainguns on fields.  The iupact
and probability of direct health effects would be indirect relationship to the
amount of aerosolization and distance from the source.  Downwind concentrations
will depend on variables in transit.  The concentration is inversely propor-
tional to windspeed, which determines the downwind particle spread.  Die par-
ticles are also spread out vertically and across the wind by turbulent nixing
of the air.  Another factor is deposition. For example, a 50 micron particle
of unit density has a settling rate of about 10 centimeters per second and
will fall through 1 meter of still air in 10 seconds.  However, some particles
will remain airborne much longer in a turbulent atmosphere.

Another form of physical depletion, impaction on surfaces, is not a signifi-
cant factor in the present context.  For this to occur, particles must be
relatively large, windspeed must be high, or the obstacle must be very narrow;
otherwise, the particles simply slip by the obstacle in the streamlines.
Therefore, vegetative barriers cannot be expected to effect any substantial
depletion in particles of respirable size.

Pathogens are subject to another form of depletion which can be extensive.
Most pathogens are affected by desiccation and exposure to the atmosphere,
and are also highly susceptible to sunlight or even diffuse daylight. This
response is extremely variable.  Other sludge ingredients may have a large
retarding or accelerating effect or loss of viability.  (Webb, 1959, 1960a,
1960b).

Variables at the receptor are also complex.  A breathing human is an active
receptor (as opposed to a passive obstacle), "sampling" the air and trapping
particles of different sizes in various parts of the respiratory tract.  The
rate of "sampling" depends upon the degree of activity and can vary by one
order of magnitude or more.  An average figure of 15 liters per minute,
corresponding to light activity, will be used in this analysis.  Efficiency
of retention varies from 100 percent for larger particles to about 25
percent for those least retained.  However, most of the total mass of
airborne material will be in particles for which 100 percent retention
is an acceptable approximation.

Account will not be taken of the effect of particle size on the infsctivity
of some microorganisms.  The number of microorganisms required to infect
exposed subjects will vary greatly with particle size.  Experiments performed
with bacterial agents in animals have shown that the infective dose is much
less for 1 micron than 10 micron particles, the transition occurring at
about 5 microns and corresponding with a transition from deposition in the
lower to the upper respiratory tract (Harper and Norton, 1953; Dtuett et
al., 1953).  Particles less than 5 microns in diawtK are frequently spoken
of as being in the "respirable" sin range, and many recent papers, including
several on sewage aerosol hazards, are written as though larger particles
ware not hazardous,  ftowaver, there is evidence that the difference is small
in some cases (e.g., foe Pasteurella pestis in the ftoesus monkey), and it
may be supposed that enterovirusas, impacted in the upper respiratory tract
                                 V-40

-------
and subsequently swallowed, can infect via the gastrointestinal  tract.  Further-
more, we ate also concerned with toxic substances for which the  portal  of entry
may bear little significance.

From data obtained at this site, stability classes, receptor response and
calculated intake of sludge particles, it appears that sludge aerosol inhala-
tion is not likely to present a health hazard in terms of heavy  metals. It
should also be mentioned that the World Health Organization's daily  intake
limits have been established for worst case conditions where a subject  is
likely to be daily exposed to aerosols.

The impact from airborne pathogens are much harder to assess.  The survival
rate of pathogens is quite unpredictable except in the most robust species.
environmental conditions would greatly determine the viability and infeeta-
bility of bacteria or viruses.  Hie best barometer of impact on  human health
is the lack of verifiable health problems at the site or generally at waste-
water treatment plants across the country.  (Ihis discussion was included as
background information.  MSDQC no longer uses spray irrigation at the Pulton
County project).

During the period of 1976 to 1979 USEPA did an extensive investigation  of the
health impacts associated with aerosols from wastewater treatment plants.
Ihis study was prompted by the construction of a large facility, the NSOQC
O'Bare Hater Reclamation Plant, in a densely populated area.  After  extensive
testing described as "thorough, critical, of a sensitive nature, and represen-
ting the feasible limit of scientific and economic capability,"  there was no
indication of a direct or indirect health hazard resulting from  exposure to
aerosols,  (USEPA, 1979)

     c.  Human Health Implications - Any evaluation of direct health hazards
at Fulton County must be based on indirect evidence,  llie most useful indirect
information concerning the Fulton County project is the absence  of reported
health effects.  As this situation continues, the probability of serious
trouble clearly diminishes.  lack of evidence concerning health  effects is
apparently based on absence of conspicuous ill effects rather than an active
medical search for indicators.  Fbr example, serological evidence of immune
levels might point to subinfective exposure, medical records night show abnor-
mal incidence of respiratory disease in the vicinity, or occupational health
records might reveal cases where exposure at home had tipped the balance of
response by auimenting occupational exposure to an Industrial chemical.
Despite these reservations, the missing evidence is encouraging  and  correlates
with experience elsewhere (Viraraghavan, 1973; Sorber, 1973; Benarde, 1973;
Krishnaswami, 1971; Dixon and NeCabe, 1S54; Anders, 1954? Browning and  Gannon,
1963; Ladbetter et al., 1973; Illinois Advisory Committee, 1975).

Another possible mode of transmission that could affect both man and animals
is by insect vector.  Any operation resulting in standing water  containing
pathogen-contaminated sludge presents a potential hazard (Sorber, 1973).
There are no data to support an evaluation of this risk for Pulton County,
but it may be surmised that the risk is snail or negligible.  The Initial
                                 V-41

-------
concentration of any pathogen would not be high and would be likely to decay
rapidly In exposed shallow water.  In addition, the stagnant water ia unlikely
to remain for long periods of time, 90 the chances of infecting vectors are
low.

E.  Noise

The project is located in a remote rural area.  The closest communities are
Canton, Cuba, St. Davis, and Bryant, with a combined population of less than
15,000.  The ambient noise level is similar to that of typical rural areas
and is estimated to be not more than 45 adjusted decibels (dBa) 90 percent of
the tine, which is designated the 10-percentile noise level.

Sources of noise in the environment of the project include tractors on the
adjacent farms and occasional notor vehicles on highways and local roads.
Because the traffic is light, these sources do not contribute significantly to
the ambient or background noise level.  Sources of noise related to the project
include pumps, tractors, and sludge sprayers.  Three pumping or sludge distri-
bution stations are located within the project property, and one booster sta-
tion is situated at the Liverpool dock.  The pumping stations on the project
site are at least one mile from the nearest farmstead.  lawever, the booster
station at the Liverpool dock and barge pumps are within a half-mile radius of
Liverpool, which had a population of 218 in 1970 (U.S. Bureau of Census, 1972).
Tractors, trucks, and sludge sprayers are mobile noise sources.  This equipment
will generate noise detected by sensitive receptors only when in operation near
the boundary of project property.

The typical ranges of sound pressure levels from pumps and vehicles are shown
in Figures V-6 and V-7.  ha a conservative estimate, the noise level for an
unenclosed pump is about 95 dBa 3 feet away from the pump, and about 80 dBa
25 feet from a tractor and sprayer.  The noise levels at different distances
from these sources are derived from the dissipation law of sound pressure and
are shown in Table V-12.  these values were calculated assuming the absence
of sound barriers such as buildings, dense vegetation, and terrain with high
relief.  For comparison, examples of common indoor and outdoor noise levels
ace listed in Figure ¥-fl.

         Table v-12  Noise Level in dBa of Various Noise
                      Sources as a Function of Distance
                      (Enviro Control, Inc., 1976)

                       Distance iron Noise Source
Noise Source  3 ft.   25 ft.  100 ft.  800 ft. 1,^00 ft. 3,206 ft.  5^2*80 It.

Pump without
Enclosure     95       86      80       71       68        64         63

ft actor
and Sprayer   —	80      74	65	62	59	57

Noise impacts from the pumping station ace minimized because of a one-nile
                                 V-42

-------
IUU
N
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t 90
Z
4.
t.
ffi 80
Z
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• 7A
.J 'U
Ul
or
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Ul
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n Rn
O
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0
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^ oo
00
Ul
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31.5 63 125 250 500 1000 2000 4000 8000
        OCTAVE BAND CENTER FREQUENCY  IN  Hi
Figure v-6     Range of Sound Pressure Levels from Pumps
              (Measured at 3 ft.)  (Curves Represent Upper
              and Lower Boundaries of Range),  (U.S. EPA,
              1971a).
                        V-43

-------
       90
CM
 2

 o
 CO
 •o


 •11
80
 5
 o>

 I
      50
                                                Highway Buses
                                      Passenger Can
                     J	L
                                        Mean Levels
                                              J.
               To    20     30   40    50    60    70


                              Speed - Miles per Hour
                                                   80
            Figure  v-7     Single Vehicle Noise Output as a

                            Function of Vehicle Speed (U.S. EPA, 19716).
                                   V-44

-------
COMMON OUTDOOR
NOISE LEVELS
Jet Flyovtr at 1000 ft


Gas Lawn Mower at 3 ft

DitMl Truck at 5O ft

Noisy Urban Doytims
 Commercial Area
 Heavy Traffic at 300 ft


 Quiet Urban Daytime


 Quiet Urban Nighttime
 Quiet Suburban Nighttime


 Quiet Rural Nighttime
NOISE LEVEL
    (dBA)

   -r-110
  - -KX>
   - -9O
   - -80
Gas Lawn Mower at 100 ft       - - 70
   - - 6O


   - - 90


      40


      3O


      20


       10


       0
COMMON  INDOOR
NOISE LEVELS

Rock Bond
Inside Subway Train (New York)


Food Blender at 3 ft

Garbage Disposal at 3ft
Shouting at 3ft

Vacuum Cleaner at K) ft

Normal Speech at 3 ft

Large Business Office

Dishwasher Next  Room


SmaH Theatre. Large Conference Room
(Background)
Library

Bedroom at  Night
Concert Hall (Background)


Broadcast and Recording Studio


Threshold of Hearing
          Figure v-e    Common  Indoor and Outdoor Noise Levels
                        (U.S. Department of Transportation, 1973)
                                 v-45

-------
buffer distance between the station and  the closest  far* families.   Consider-
ing further dissipation of noise by buildings, vegetation  and  topography,  the
noise level of pumps at a one-mile distance should be less than  60 dBa.  Bits
level is acceptable for residential areas, as recommended  by the U.S.  Depart-
ment of Housing and Urban Development (1971 and 1972).

Noise generated by pumps at the Liverpool dock and by barge pmps will some-
what increase the ambient noise level around the community of  Liverpool.
Impacts from this intermittent noise cannot be quantified  in the absence of
noise data; however, they should not ba  severe.

P.  Significant Socio-economic and Land  Use Impacts

Since the project has been in progress for nine years, there are several fac-
tors that can be readily measured.  Precise impacts  of the project are
described in the text below.

     1.  Soc io-economic impacts

Baseline information was provided in an  earlier chapter.   This discussion  will
address population trends, employment and income land value, agricultural
activity, and future mining activities.

         a*  Population - Recent national rural-urban trends predict future
population growth inareas such as Pulton County.  These demographic trends
include both historic trends and more recent factors which are expected to
influence future trends.  Past declines  in agricultural and strip-mining
employment have been instrumental in causing decline in the overall  population
of Pulton County and increases in the populations of Canton, Lewistown and
Farraington.  Brpected future declines in agricultural and  strip-mining employ-
ment will continue to affect the future  population sisse and distribution.

(tore recent trends, such as the spread of industry to the  exurban fringe of
cities, will increase employment opportunity in many rural  areas.  Some of
this manufacturing employment will encourage in-migration of skilled labor.
Less-skilled labor can come from the existing rural  labor  force.  Expansion
of industry to the west and south of Peoria can be expected to enhance employ-
ment opportunities for the current residents of Pulton County  and increase the
in-nigration of skilled laborers and their families.

& national survey has indicated that aaany city residents prefer nearby, or
even remote, rural or small town residence to living in a  large city (Beale,
1975).  Considerable demographic data have shown that, since 1970, nonmetro-
politan areas are not only retaining people but are  also receiving a net
migration (Beale, 197S).  Factors associated with migration to rural areas
include the growth of state and community colleges and the  development of
rural recreation and retirement places,  as well as the decentralization of
manufacturing.  Fulton County offers both recreational and  retirement  oppor-
tunities such as the Nee-Na-Tuk Hills development adjoining the land recla-
mation project.  Oonnnity colleges, such as the Spoon River Community College
near Canton and adjacent to the project  sit*, often cooperate  with local busi-

-------
nesses in providing appropriate skills for new enterprise.

Itiis evidence clearly suggests that the population of  Pulton County can be
expected to grow.  The major  influences on the growth  rate  are  the  develop-
ment of new manufacturing in  Pulton and southwestern Peoria Counties  and  the
accessibility of existing and potential residential areas to these  manufactur-
ing plants.  When such factors affecting growth are considered,  the total
future population of Fulton County is expected to significantly exceed  the
population forecast by the Bureau of the Budget, State of Illinois.   Future
population is expected to be  increasingly concentrated in Canton, Lewistown
and Faming ton.  Substantial growth can also be expected in the  northeastern
quadrant of the County toward Peoria.

If the project is abandoned in its present state, current MSDGC  employees
would have to seek new employment.  Manufacturing growth along the  Illinois
River should provide employment for many of the seasonal employees -(forking  on
the Prairie Plan project.  Most of these employees are either current resi-
dents of the area or utilize  the project as summer employment.   Some  of these
employees can be expected to  relocate their families.  Most of the  23 perma-
nent MSDGC employees would be expected to relocate their families outside of
Fulton Cotmty.  Hie projected net impact is minimal because machinery performs
more work.

Reclamation and reuse of the project area to produce crops  or livestock would
increase population only marginally, because it is estimated that 708 acres
of pasture or 360 acres of tow crops are needed to support  one family
(Schmitz, 1974 and Muehler, 1975).  Conservation and recreation  reuse would
attract transient tourist populations.  Bie existing recreational center  is
used by many local residents  for summer trailers.  If  this  area  were  enlarged
a small additional population may be served.

        b.  Employment and income - Continued declines in employment  can  be
expected in the agricultural  sector.  The most recent  declines reflect  the
influence of advanced technology in replacing labor with capital-intensive
methods of production.  Such practices increased training and abilities of
the resident labor force while importation of certain  skilled labors  occurred.
Even though the number of employees in agriculture will decline, increasing
skills will enhance average incomes.

Under expected future conditions of higher labor mobility and increasing
skills, the median income in Pulton County is expected to gradually converge
with that of the U.S. (U.S. Hater Resources Council, 1974).   The higher
average income and purchasing power in Pulton County should  increase  the
strength of its service and trade activities.  Etowever, higher local  wages
contained with low unemployment is not especially attractive  to new manufac-
turing, although the proximity of underutilized urban  labor markets and
higher labor mobility should enable a new manufacturer to import labor or
attract commuters.  Host of the new industries can be  expected to have  small
labor requirements and to be tied to the production of metal  and machinery.

The land purchased by NSDQC originally supported an estimated 37 full and
                                 V-47

-------
part-time jobs, tostly held by local residents  {Kelly,  1974).  While  these
jobs were lost after the purchase, the  increasing amount of  agricultural
lard needed to support a farm worker indicates  that, without the  MSDGC
purchases, the land in the project area would have supported progressively
fewer workers.  Tte increased number of jobs created by the  Sanitary  District
absorbed approximately 120 skilled and  unskilled contract  laborers who
average 6 to 8 months of employment yearly.  Host of the skilled  labor cane
from a multi-county region surrounding  and including Pulton  County, but
most unskilled labor originated within  Pulton.

When the project site is fully developed, several additional full-tins
employees nay be necessary to effectively manage the farming enterprises.
Howeverr the amount of seasonal and contractual laborers would decrease.
Development of initial fields and basins is labor intensive, while land
application and cropping decreases this need.   If the NSOGC  abandoned the
site, it is expected that many of the full-time farm operating jobs would
be lost.  Attempts to farm the poor, unconsolidated soils  would continue
to provide a few jobs.

The area now provides a few less intensive economic activities such as recrea-
tion, hunting and fishing, and livestock production.  Hiis is not anticipated
to change.  B»ae uses would generate little on-site employment and income.
Visitors to the regionally attractive conservation or recreation  sites
created by the project would add some local income in tourist-related retail
and service enterprises.  Bawever, poor access to the project area from lar-
ger population centers, due to distance and lack of a high-speed  link, will
limit this potential, until the proposed Interstate Highway  (Peoria-Kansas
City) is completed.  The use of strip-nine soil for grazing  would have a
small multiplier effect on local employment and income.  Peedlots could
contribute to the expansion of nearby meat packing firms.

     c.  Land values - future land values in the project area will be govern-
ed by the growth of Canton, competitive position in land speculation,  and the
economic intensity of future land uses.  Expected future growth of Canton
would slightly increase the value of all land within its geographic sphere of
influence.  Speculation in coal extraction and marketing might affect values
in the project area should it become economically feasible to mine the thin
seam of coal underlying the strip-mined surface layers.

The availability of competing land at least equally suitable for development
is the major determinant of local land values.  Large tracts of equally avail-
able and suitable land in Pulton County should keep land values low in the
project area.  Mach of the project land is highly unsuitad for building con-
struction.  Residential or industrial buildings may require  expansive  struc-
tural modifications where they are built on the disturbed, unsettled soil of
a strip-mined site,  if a priority is developed foe claw one agricultural
land preservation, more emphasis on the use of strip-mined land will occur.

In Land Use Survey of Strip Mines, Pulton County, Illinois,  unrsclaimsd lands
art defined as 'areas where no attempthas beenmade to reclaim stripped land
to • productive use.*  Using this definition, unreclaimed  lands have been
                                 V-48

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estimated to be worth $259 per acre or  $64 per  acre  less  than  reclaimed strip-
mined lands which are used productively.  Land  reclamation and reuse could,
therefore, theoretically add about 3278,016  to  the market value of  the 4,344
acres of strip-mined land scheduled for sludge  application (MSDOC Land Project
Development Schedule, revised August 1974).   For the period of sludge applica-
tion, the 4,344 acres of stripped land  and 1,181 acres of place land (formerly
row-cropped), which comprise the current  and planned sludge recycling fields,
continue to be worth to the MSDGC the paid value of  $378  an acre  (Kelly,  1974).
The last parcel of land that comprises  the Fulton County  site  was purchased by
MSDGC on March 20, 1975.  Up bo this date the total  amount paid for land was
$5,961,367.30.  On January 1, 1978 the  Fulton County Assessor  valued the MSDGC
holdings at $14,223,609.

     d.  Public finance - Two major influences  are expected to significantly
improve the ability of Fulton County to attract and  accommodate future growth,
and thereby expand local public finance.  One is the Central Illinois Light
Company (CILCO) power plant, now nearing  completion.  When the CILCO plant is
operational, it will double the total tax base  of Fulton  County (Sandberg,
1975).  The expanded tax base is expected to yield the local revenues necessary
to enhance public facilities and services so as to facilitate  growth.  The
other influence is Federal and State funding of public works,  such  as the cur-
rently proposed road improvements between Peoria and Canton, which  are expected
to substantially improve the regional attractiveness of Fulton County.

Contributions of the reclamation project  to  local public  finance would be minor
as compared to the projected huge tax revenues  fron  the CILCO  plant and poten-
tial outside public funds for road or other  improvements.   Discontinuing the
project will result in lost county revenues.  In 1975, the MSDGC paid to Fulton
County roughly $180,300 in real estate  taxes and $53,423  in personal property
taxes.  In 1977, these figures were $237,341.56 for  real  estate taxes and
$109,976.86 for personal property taxes.  In  1978, the MSDX paid $243,245.52
for real estate taxes and $116,810.59 for personal property taxes.   Most of
this revenue would be lost if the project is abandoned and the land is not
reused.  According to a statutory requirement,  those formerly  strip-mined
portions of the project area would be assessed  at rates applicable  to their
uses prior to strip-mining.  Other portions  would be assessed  as unproductive
agricultural land.

Most feasible reuses of the land would  produce  much  smaller public  revenues
than were gained from MSDGC tax payments.  Even prime agricultural  land in
Fulton County (and very little of the project site can be considered as such)
is assessed at only $380 to $570 (1975  estimates, Fulton  County Tax Assessor).
Public recreation or conservation uses  would generate no  tax revenues.

     e.  Agricultural activity - The soils and  topography of northern Fulton
County, and of West Central Illinois in general, are well suited for agricul-
ture and support highly productive principal crops such as com, •soybeans, and
hay.  Future productivity of local agriculture  will  be influenced by the  rich
loess soils and the generally level topography, as well as by  changing methods
of agricultural production.  Average farm size  should increase while farming
should continue to become more capital  and less labor intensive, causing con-
                                 V-49

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tinued decrease in farm employment and population.  At the same tine, trends in
fan production will increasingly favor the use of larger, mare level fields
farms.

The impact of the project on agricultural activity in Fulton County hinges on
the potential productivity of the 4,344 acres of formerly strip-nine:! Land used
for sludge disposal,  it is assumed that sludge application to the 1,131 acres
of place land will only marginally affect the productivity of these presently
fertile fields.  Other portions of the project area are only marginally suited
to agricultural uses.  Calculations based on 1970 data show an average annual
net return per acre from farmland in Fulton County of approximately $85 for row
crops and $31 for pasture.  These figures may be slightly lower as the 1980's
begin.  Peedlots have a considerably higher return.  This suggests an ultimate
agricultural value added per year by the project of approximately $200,000 to
$300*000 (1970 dollars) due to reclamation and agricultural reuse. (1969 data
show a county-wide produce value of $33 million on commercial-sized farms, or
farms with sales of over $2,500 per year.)  These estimates of dollar return
should be viewed only aa crude indications of the potential lost value of
agricultural productivity should the project be abandoned or full reclamation
not be achieved.  Ihe values of agricultural production fluctuate considerably
from year to year.

In its present state, land in the project area could be used primarily for
grazing and row-cropping,  ftowever, without reclamation utilizing sewage
sludge* any row-crop production on formerly strip-mined fields would depend on
liberal applications of costly chemical fertilizers, extensive soil condition-
ing, and rigorous conservation practices such as crop rotation.  Continued
sludge application can be expected to enhance the nutrient and organic content
of the soil considerably, and this would favor more intensive row-crop farming
over the grazing of livestock.

     f.  Mining andmanufacturing - The future importance of strip
mining in Fulton County may OR determined by three factors:

     Increasing national consumption of coal for power generation

     Vertical integration of na^or coal consumers

     targe amounts of strippable reserves in Fulton County.

Increasing coal consumption, interacting with air pollution regulations, land
reclamation requirements, and future improvements in sulfur removal from coal
or coal combustion gases, will govern demand for high-sulfur coal such as
exists locally,  The vertical integration of major coal consumers, such as
mine ownership and operation by a power company, could make large amounts of
capital available Cor the continued mining of Fulton County's coal reserves.
Previously (mined, yet strippable coal covers over 54 percent of the County
(Griffin and Qiicoine, 1974).

Clearly, the enormous reserves, the availability of capital for their extrac-
tion and increasing us* of high-sulfur coal would exert great pressure to
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further exploit this resource.  Nevertheless, coal mining  is not  likely to
be a future land uae in the project area itself.  The  remaining thin, deeper
seams of coal below the project site ace not nearly as well suited  for future
extraction as are other reserves nearby.
    major industrial firms in Fulton County are the  International  Harvester
Company and the Central Illinois Light Company.  Other large  industries  in-
clude J. C. Schaefer Electric, Inc. and Astoria Pibra Steel,  Inc.   Mich  of
the influence of industry on local employment is applied by firms  located
in southwestern Peoria County,  (tew industries would be more  inclined to
locate along the Illinois River than at the project  site where  road access
is comparatively poor and cheaper water transportation for high bulk, low-
value cargo is unavailable.  The water supply at the project  site  is inade —
quate to support many industries, and low local unemployment  rates indicate
a low labor supply.  Industrial location, both along the river  and at the
site, is favored by large land holdings, low land prices, available railroad
transportation, close proximity to central markets,  and the availability of
coal.  Impetus for new industrial and commercial development  will  be redirect-
ed to the new Interstate Highway (Peoria-Kansas City) bisecting the County
and tangent to the Prairie Plan site.

The provision of internal access roads and the leveling of strip-mined areas
have lowered construction costs for industrial buildings in the project  area.
However, wastewater disposal problems and highly mineralized  water supplies
discourage industrial development there.  Mao, unstable soils  add significant
costs and uncertainties to the construction of building foundations, hard-sur-
face roads, rail spurs, and underground pipelines.  Thus, the project site is
neither physically nor economically adaptable for future manufacturing uses.
MSDGC does not, however, have industrial zoning classifications within any of
its approved land use reclamation plans.

        g.  Retail and wholesale trade - Future retail and wholesale activities
in and near Canton depend on the progress of road improvements.  Non-neighbor-
hood retail business and most wholesale activities in Canton  could be affected
adversely by increased accessibility of the Peoria market. Service activities
should continue to increase in Fulton County, tampered by the location in
Peoria of most highly specialized services.

Discontinuing the project would cause some temporary decline  in the volume of
local trade and services due to lost purchasing power of current employees of
the NSDQC or its contractors.  Reuse of the project land would  be  economically
unintensive.

     2.  Und use

The analysis of land use opportunities and constraints focuses  upon the  com-
bined effects of socio-economic demand and physical land suitability on  the
future reuse of project land.  Of course, land reuse is not assured by success-
ful reclamation; there must be actual economic demand.  Once  demand by society
is established, the available land must be physically capable of accommodating
the desired land use.
                                 V-51

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Sludge application fields which were formerly strip-mined  (4,344  acres) would
be attractive for added row-crop faming.  While the addition of  nutrients
and organic matter has been limited so far, the leveling of  steep slopes,
removal of large rock fragments from the surface, and the  installation of
erosion controls has increased the adaptability of these fields to row crops.

Cattle grazing is not an economically competitive use in those areas which
were formerly row-cropped.  Growing pasture, however, would  be a  nor* likely
alternative than row-cropping on the 4,344 acres of formerly strip-mined land.
Hie major benefits from the project for pasture use are the  leveling of strip-
nine spoil and the addition of nutrients and organic materials.   Leveling
makes it passible to use farm machinery to control tree growth instead of hand
labor which is prohibitive in cost.  Small portions of the project area *re
well suited for the development of feedlota.  Major on-site  capability tor
feedlots has been provided by systems installed to control and monitor
pollution from stormwater runoff.  Such systems are necessary for environmen-
tally sound management of feedlots.

        a.  Patential for ayicultural uses - Present and  future  feasible usts
for agricultural land in Fulton Countyinclude cow cropping, pasture, feedlots,
and forest management.  Available information suggests that  the future
economic demand for increased amounts of farmland will be  small.  Besides
shifting toward larger individual farms and increasing mechanization, local
agriculture is changing its composition.  Dairy, winter wheat and poultry pro-
duction have declined, while corn, soybeans, swine, and beef cattle production
have increased.  Increases in beef and pork production have  been encouraged by
expanding local and regional meat packing facilities, notably Oscar Mayer.  A
trend toward feedlot production can be expected to be matched by  increasing
production of corn for feed.

Steep slopes and severe problems of access in unreclaimed  strip-mining areas
have caused failure of previous local attempts to manage timber crops, the
steep slopes of the strip-mined portions of the project area have been leveled
and many access roads have already been built as a part of the MSDGC project.
However, there would be a long time lag before the first timber harvest, and
considerably more local land would have to be planted with trees to provide
enough continuous supply to support a local lumber products  industry,  One
attempt at beef ranching was also tried prior to the NSDGC project.

Continued sludge application followed by reuse of the project site could have
a major beneficial impact during the entire application period.  The project
could serve as the principal site in the U.S. for evaluating the effects of
various application methods in different agricultural activities.  The experi-
ment would be highly valuable in assisting other communities in designing and
managing their sludge disposal systems.  Continued sludge application would
also affect the eventual reuse of the project site.  The future productivity
of the formerly strip-mined areas can be expected to increase significantly
with the continued application of sludge, possibly making  row-crop production
economically feasible.

        b.  Residential uses - Future demand for housing in Fulton County will
                                 V-S2

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primarily reflect projected population increases and replacements of the exist-
ing housing stock.  This housing demand will concentrate in central places
(primarily Canton, Oswistown and Farmington) and in eastern portions of the
County which have easy access to developing industrial employment in Peoria-
Pekin and along the Illinois River.  Although the population of Canton can be
expected to increase, the size of this increase will be limited in two ways.
first, employment centers and regional facilities in Peoria are presently
relatively inaccessible to the Canton population.  Second/ the trend in
suburban expansion of Peoria demonstrates that the outer ring of this expan-
sion is not likely to reach Canton in the foreseeable future.

Two independent methods are used to calculate future housing demand.  One is
based on population projections; the other is based on trends in the issuance
of building permits.  Population projections by the State of Illinois Bureau
of the Budget (1975) predict a countywide population of 42,031, for 1980 and
44,691 for 1990.  Assuming 3.5 persons per household, this population increase
would add nearly 460 by 1980 and a total of over 1,300 units by 1990.  Con-
sidering all factors, the total number of new units might exceed 600 by 1980
and 2,000 by 1990.  Building permit data substantiate these projections.  Data
from 1972 to 1975 show that building permits were issued for an average of 98
single-family homes and 48 mobile homes each year.  The average number of
building permits issued per tenth significantly increased from 1972 to 1975.

There are major constraints to residential uses in the project area.  These
relate primarily to water quality and the problems of building on unconsoli-
dated materials.  Local groundwater is too highly mineralized to be suitable
for drinking water.  The naturally clear, deep blue local lakes are attractive
to residential development.  However, this clarity results from deficiencies
of nutrients necessary to support algae growth.  Experience in Wee-Ma-Tuk
Hills demonstrates that even well-maintained aerobic septic systems with a
sand filter and chlorinated discharge cause nutrient over-enrichment and con-
sequent aesthetic degradation of the lakes.  These systems are the most
feasible for the project area, yet they cost $1,500 more than a conventional
anaerobic septic system (Nuehler, 1975).

Building on the unconsolidated materials of strip-nine spoil adds other
premium costs to home building.  Settling problems force homes to be built on
reinforced slabs that average $1,000 in cost above conventional foundations
(Mushier, 1975).  Potential settling also adds significantly to the cost of
providing and maintaining pipelines and hard-surface roads.  Despite such
serious constraints, improvements made by the MSOQC to the formerly stripmined
portions of the project site have increased its suitability for residential
use.  These improvements do not, however, counter-balance the constraints
which, together with the availability of numerous competing home sites through-
out the county, make future residential development highly unlikely.

        c.  Recreation and conservation uses - Poor accessibility will be a
major limitation on the number of visitors to a recreation facility in the
project area.  Poor road conditions compound the difficulty in getting to
the project site from interstate highways or major population centers.  Of
                                 V-53

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course, poor accessibility hinders but does not preclude large numbers of
travelers.  Past records have shown more than 100,000 visitors to Dickson
Mounds State Par* and 100,000 visitors attended the foar-day Spoon River Drive
Fall Festival (Bordner, 1975; Shields, 1975).

the attractiveness of a regional recreation facility in the project area would
be enhanced by the divei.se attractions in nearby Spoon River Valley, along the
Illinois River, at Dickson Mounds State Bark, and in numerous formerly strip-
mined areas.  They ace often used for hunting, fishing, camping, and driving
off-the-road vehicles such as trailbikes and snowmobiles.

Probable recreation and conservation uses in the project area include hunting,
fishing, camping, native prairie and wildlife and an outdoor ecology labora-
tory.  Tha NSDQC's past and future alterations of the project site can be
expected to exert important influences upon each of these activities.  Qxi-
tinued sludge application would add organic material and mineral nutrients in
quantities sufficient for the growth of a greater diversity of plant species
than are normally found in unreclaimed strip-mined areas,  increased plant
diversity generally leads to increased diversity in wildlife.

The pH values, alkalinity, conductivity, and concentrations of total phospho-
rus, sulfate ion, calcium, potassium, sodium, aluminum, iron, magnesium,
manganese, mercury, nickel, selenium and fecal coliforma remain close to the
1971 and 1972 baseline conditions (see Chapter IV).  Recent concentrations of
cadmium, chromium, copper, lead and zinc are lower than the baseline concen-
trations.  In 1971 and 1972, 40 percent of the wells tested contained exces-
sively high levels of chemical constituents,  tfcen retested between 1973 and
1975, after the project had begun, the statistic was the same.  Qroundwater
constituents are, therefore, probably influenced by sources unrelated to
the project.
                                 V-54

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Alternatives ta the

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                      VI.  ALTERNATIVES TO THE  PROJECT

The Draft EIS presented a more thorough discussion of  sub-alternatives to the
complete system, such as dewatering, digestion, and drying  systems.   This dis-
cussion is not presented here.  Only the volume reduction or  disposal alterna-
tives are presented.  It should be kept in mind that digestion processes are
not needed for incineration, but are mandatory  for land application  alterna-
tives.  It became ntcessary to update costs  as  presented in this Chapter.
Periodicals and EPA manuals were reviewed to determine recent capital and
operation and maintainance costs for various sludge disposal  processes.  How-
ever, the literature did not present costs in a manner that could be applied
to update the costs used in the discussion below.   There was  no way  to compare
the costs accurately without making some assumptions and changing some of the
sludge quantity parameters.  In order to be  consistent, costs used in the dis-
cussion below remain unchanged from the Draft EIS. Following each category of
sludge disposal, the costs have been updated to 1980 by using the EPA Sewage
Treatment Plant Construction Costs index.

The ratio of the March 1980, EPA Construction Cost Index for  Sewage  Treat-
ment Plants to the base year cost index was  used in the cost  updating
process.  As an example, the cost index for  March  1980 is 357.5.   The cost
index for - 1972 cost is 172.0.  The ratio of indices  indicates the  magni-
tude of cost increase to construct or operate wastewater treatment plants.

A.  Disposal or Utilization Alternatives

    1. Incineration

Dewatered sludge cakes from vacuum filters and  centrifuges  can be sterilized
and reduced in volume by incineration.  Incineration destroys organic matter
in the sludge and dewaters the sludge by evaporation.  The  two types of
incinerators most applicable to sewage sludge are  multiple  hearth and flui-
dized bed incinerators.

The multiple hearth furnace consists of a circular steel shell surrounding a
number of stack-up solid refractory hearths.  Partially dewatered sludge is
continuously fed to the upper hearths, where the sludge is  heated and vapo-
rized at roughly 1,000 degrees P.  Openings  in  each hearth  allow sludge
particles to crop to the next lower hearth.   A  high-temperature ccmbustion
zone between 1,600 and 1,800 degrees F is formed in the intermediate hearth,
where volatile gases and solids are burned.   The bottom hearth serves as a
cooling zone.  Ply ash is removed from the exhaust gases by wet scrubbers.

The fluidized bed incinerator consists of a  combustion reactor or bed of
fluidized sand which is supported by upward-moving air.  Intimate contact
between the sludge particles and oxygen is achieved by rapid  mixing  of the
fluidized sand grains.

Because of the large surface area provided by the  sand particles,  heat
exchange between gases and solids is extremely  rapid.  Sludge is burned in
the combustion zone at 1,400 to 1,500 degrees F.   Auxiliary fuel  is  usually
required when secondary sludge is burned.  However, after start-up,  dewatered


                                   VT-1

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caw primary sludge may be burned without this supplementary fuel. The  resi-
dual ash particles are removed from the reactor by  the upward movement of
combustion gases,  Ash particles are removed from the gas phase by wet
scrubbers.

From the study of a model city with 10,000 people contributing 2,530 tons
of solids per year, the capital and operating costs for multiple hearth
incineration aie given in Table Vl-1, Annual Capital and Operating Costs  for
Multiple Hearth Incineration  (Quirk, 1964).  The  total annual capital, operat-
ing and maintenance costs for a plant handling more than 500 dry tons  of
sludge per day are less than  $15 per dry ton, based on the 1972 dollar (Stan-
ley Consultants, 1972).  Utilizing the 1972 base  index of 357.2, the 1980 cost
would be $31.20.

fable VI-1.   Annual capital  and Operating Costs  for Multiple Hearth
              Incinera',
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Factors affecting the cost of sludge incineration ares

    *  Nature of the sludge

    *  Amount and type oC chemical used in sludge
       conditioning before mechanical dewatering

    *  Degree of mechanical dewatering

    *  Costs of fuel, water and power

    *  Extent of air pollution control required

    *  Size and design of the treatment plant

Environmental considerations for incineration are centered around air and
water pollution.  Air oollutant emissions include particles, odors, sulfur
oxides, nitrogen oxides, and volatile trace metals such as mercury.  Wet
scrubbers are efficient in removing fly ash but ineffective in capturing
hazardous sub-micron particles (diameters between 0.1 and 1.0 millionth of
a meter can lodge permanently in the lung).  The wastewater from the scrub-
bers requires treatment to avoid water pollution problems.

Odor problems associated with incineration are of constant concern.  Incom-
plete combustion or partial breakdown of organic volatile molecules is the
major cause of odor.  Maintaining an exit temperature of 1,200 to 1,500 de-
grees F is effective in destroying odorants.  This measure, however, requires
auxiliary fuel and burners.  High solids dewatered sludge cake (35 percent
or greater solids) made by heat treatments and/or high pressure filtration
requires no additional fuel.  Volatile trace metals which escape the scrub-
bers have some adverse impact on the environment.  Economical means for
removal of these emissions are not available.  The relatively high fuel con-
sumption for incineration, as opposed to other sludge processing methods,
creates an impact on the envitorment and non-renewable resources.

    2.  HeatDryingfor Soil Conditioners

Heat drying removes moisture from sludge, thereby providing for efficient
incineration.  Heat drying also prepares sludge for conversion into fertili-
zer.  Drying is necessary in fertilizer manufacture to permit grinding and
to reduce the weight of the sludge.

Dewatered sludge is mixed with dry sludge to reduce moisture content and
particle size.  The mixture is then fed into a flash drying system.  In the
system, sludge is passed through a high-teraperature-and-turbulence zone for
a few seconds, reducing the moisture content to 2 to 5 percent.  Heat-dried
sludge is separated from the gaseous phase in a cyclone separator.  After-
burners at a temperature of 1,400 degrees f or higher are frequently required
to deodorize stack emissions.
                                 ¥1-3

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A study of the economic aspects of heat drying in a medium size plant, hand-
ling 2,530 dry tons per year, revealing that the annual capital and operating
costs approximate $37 per dry ton with stack gas deodorization and $29 per dry
ton without deodorization (Quirk, 1964).  These costs do not account for the
sale of dried sludge as fertilizer or as a soil conditioner.  The cost index
for 1964 is 110.0.  The 1980 cost would be $120 and $94, respectively.

Heat drying consumes more fuel than incineration processes.  It also contri-
butes to air pollution by emitting suspended particles, nitrogen oxides, sul-
fur oxides and trace metals.  However, heat drying has less air pollution
potential than does conventional incineration, which requires combustion tem-
peratures.  Cost of air pollution abatement of exhaust gases can be substantial.

    3.  Sanitary Landfill

Sanitary landfill can be used for disposal of sludge, grease and grit, stabi-
lized or not, if a suitable site is available.

The landfill is most beneficial if it is also used for disposal of refuse and
other solid wastes.  Liquid sludge acts as a wetting agent which increases
compaction of the landfill; sludge cake or incineration ash mixed with refuse
increases the density.

Sanitary landfills can be divided into two major categories—area landfills,
which are on relatively flat terrain, and depression landfills, which utilize
natural or man-made depressions in the landscape such as a quarry or gravel pit.

Sanitary landfills have traditionally operated at low unit cost.  Capital
costs for landfill include investment in land, site facilities, and equipment.
A general capital cost cannot be estimated because of the wide variability in
land prices.  Annual operating costs for sanitary landfills were reported to
vary between $0.50 and $2.00 per wet ton (Stone, 1962).  The cost index for
1962 is 107.0, yielding a range of $1.67 to $6.68 for the costs, updated to
1980.  These figures are very low compared to other landfill data.  Therefore,
overall costs are largely determined by hauling costs and land prices.  Exclud-
ing land investment, the total capital, operating and maintenance costs are
estimated to range downward from $1.80 to $1.20 per wet ton of sludge per year
for operations of 1,000 to 10,000 wet tons per day, respectively (Stanley
Consultants, 1972).  Increased emphasis on environmental effects may elevate
costs of sanitary landfills.  The cost index for 1972 is 172. The range,
expressed in 1980 costs would be from $3.75 to $2.50.

Poor management of sanitary landfills can result in adverse environmental
effects.  Dewatered sludge and other solid wastes in landfills degrade chemi-
cally and biologically to produce solid, liquid, and gaseous products.  Micro-
biological decomposition of landfill material initially occurs aerobically,
and then anaerobically when oxygen is depleted.  Characteristic waste products
of aerobic decomposition are carbon dioxide, nitrate, and nitrite.  Migration
or leaching of nitrate and nitrite can cause groundwater contamination.  Typi-
cal products of anaerobic decomposition are methane, carbon dioxide, water,
organic acids, nitrogen, amnonia, inorganic salts, and hydrogen aulfide.  Some
of these products are odorous.  Acidic products can lower the pH value of the


                                   Vl-4

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landfill and cause mobilization of trace metals which may affect the quality
of surface and groundwater.  Nuisance conditions  such as odors and  flies  can
be minimized with daily coverage of the waste, but cannot be avoided altogether.

In most areas* available land conveniently located is becoming increasingly
scarce and old sanitary landfills are now being used for development.   In
general, this reuse was not contemplated during the construction of the origi-
nal fill.  Uneven settlement and poor bearing strength of fill materials  pee
sent foundation problems which significantly increase construction  costs.
Total failure of structures built on landfill sites has been reported.  There-
fore, it may be desirable to build landfills so that future development can be
undertaken at reasonable cost (Sowers 1968).

The Northeastern Illinois Planning Commission has noted in their 208 studies
that landfill sites in Northern Illinois will be  practically non-existent
within the next ten years.

    4.  Lagooning

Lagooning has been the most popular sludge disposal method for industrial
wastewater treatment plants; lagoons are also used at municipal plants.
Lagooning can be used as a contingency method of  sludge handling and storage
while other sludge processes are temporarily overloaded or out of service.
Lagoons can be divided into three classes: thickening, storage, and digestion
lagoons; drying lagoons; and permanent lagoons.

Digestion of sludge in the first type of lagoon is a lengthy process which
creates multiple nuisance problems.  Drying lagoons certainly compete with
the use of sand drying beds.  Hie sludge must be  digested before entering the
lagoon.  Removal of dried sludge, which must be disposed of by other means, is
necessary to maintain the effective capacity of a drying lagoon.  Multiple
units and supernatant decanting devices are required in the first two types of
lagoons, as the supernatent is always returned to the head of the plant.  A
permanent lagoon, one from which the sludge is never removed, in an ultimate
disposal site similar in function to sanitary landfills has proven  to be  the
most economical method of sludge disposal where suitable sites still exist.

Variables in lagooning operations are land availability, climate, subsoil
permeability, groundwater table elevation, sludge characteristics,  and sludge
loading rates.  Land available adjacent to the treatment plant substantially
reduces sludge hauling costs.  Good climatic conditions, which enhance evapo-
ration of sludge water, are necessary for efficient performance.  Soil permea-
bility and groundwater elevation affect lagoon performance by determining the
rate of drainage and the potential for groundwater contamination.   Raw sludge
generally requires less lagoon capacity than digested sludge.  One  cubic foot
of lagoon can handle 6 pounds of raw sludge per year as compared to 2.3
pounds of digested sludge per year.  Construction costs of sewage stabilization
ponds in the Midwest were reported to vary between $1,000 and $3,000 or more
per acre.  The cost index for 1972 is 172.0.  Die range expressed in 1980 costs
would be from $2,080 to $6,240.  Lagoons constructed in depression  areas can be
significantly cheaper (Bowells and Oubois, 1959).  Excluding land investment,
the construction costs of lagoons were estimated  to range downward  from $28.62


                                   OT-5

-------
to $12.70 a year per acre-foot for lagoon capacities of 10 and 100 acre-feet,
respectively.  The costs are amortized using a 1 percent discount rate over
20 years and are based on the 1972 dollar (Stanley Consultants, 1972).  The
cost index for 1972 is 172.  The range expressed in 1980 costs would be from
$59.52 to $26.42.


Literature reviews show that the operating and maintenance cost of sludge
lagooning range from $1.00 to $3.50 per dry ton of sludge per year (Dubois,
1962, Caron, 1964, Burd, 1968).  In 1972 dollars, the annual operating and
maintenance costs were reported by Stanley Consultants to be approximately
$5.00 per dry ton for a plant producing 100 dry tons of sludge per day.
Costs will increase if the sludge is transported long distances for lagoon-
ing.  The oast index for 1972 is 172 and the costs can be updated to $10.40,
in 1980.

Lagooning of raw sludge creates nuisance problems such as poor odor emission
and insect infestation.  Nuisance problems associated with lagooning of di-
gested sludge are less severe.  To minimize these problems, adequate buffer
distances roust be provided between the lagoons and the nearest sensitive
receptors.  Seepage and percolation of sludge water through permeable soil
can present groundwater pollution problems.  Lining the lagoon can prevent
groundwater contamination, but this will increase both initial and operating
costs; artificial drainage may be required due to loss of subsoil drainage.

    5.  Ocean Dumping

Ocean disposal of industrial and imnicipal sewage sludge has been commonly
adopted by municipalities close to the sea.  Some of the largest cities in
the United States, including Boston, Hew York, Philadelphia, and Los Angeles,
dispose of their sludge in this fashion.  Ocean disposal was an economical
solution for cities located along the coasts.  However, ocean dumping has
created severe environmental and public health problems.  This method will
be phased out soon and no further discussion is provided here.

    6.  Fertilizer Production

Sewage sludge has been used as fertilizer and soil conditioner for many years.
The use of liquid sludge has been rather limited because of handling difficulty,
but dried sludge reduces this problem significantly.  Preparation of these
sludge products can be achieved by air drying on sand beds, mechanical
dewatering, or heat drying, as discussed previously in this chapter.

The value of sludge fertilizer is determined by nitrogen, carbon, phosphorus,
and potassium contents.  Hence, the value of sludge as a fertilizer is limited
because of low concentrations of nitrogen, phosphoric acid, and potash.  Bow-
ever, the high content of organic material in sewage sludge provides for
excellent soil conditioning.  The phosphorus content of municipal sewage sludge
was significantly increased with the use of phosphate detergents (Anderson,
1956).  Of course, this may not be as true currently because of the development
of low phosphate detergenta.  Of particular interest to agronomists is the car-
bon-nitrogen ratio pf sewage sludge.  K study of sludge characteristics in five


                                   VT-«

-------
municipalities Indicated that the nitrogen content ranged from 2.0 to 6.0
percent; carbon 21 to 4? percent} phosphoric oxide 1.0 to 11 percent; ash
content 24 to 52 percent; and humus 33 to 41 percent (Anderson, 1956).   In
general, digested sludge has a lower fertilizer value because the nitrogen
content is reduced 40 to 50 percent by the digestion process.

In the past, many treatment plants with heat drying equipment converted  from
fertilizer production to sludge incineration oc landfilling, because the
sludge fertilizer market could not be successfully developed.  This trend has
been reversed recently because of the high-energy demands of incineration and
the scarcity of landfill sites.  Based on potential sales revenues and the
concept of recycling nutrients, fertilizer production may gain more public
acceptance.  For example, Milwaukee, Chicago and Houston have successfully
marketed large quantities of heat-dried activated sludge for many years.  The
price has depended on the nitrogen content of the sludge and has varied  from
$12 to $18 per ton (Burd, 1968).  The cost index for 1968 is 123.6.  The range
in 1980 costs is between $34.71 and $52.06.

Over 200,000 tons each year were sold by these cities for application to
crops, golf courses, and park land.  However, most cities have donated sludge
dried on sand beds in order to dispose of it off the plant site.

The major environmental concerns over the utilization of sludge as fertilizer
or soil conditioner deal with possible health hazards from pathogenic micro-
organisms and trace metals and non-point source water pollution.  Pathogenic
microorganisms are destroyed by heat drying, but pathogens in air-dried  or
mechanically dewatered sludge might contact food plants or fodder and be
ingested by humans or livestock.  Trace metals such as zinc, nickel, copper,
cadmium, lead, chromium, and mercury may be selectively concentrated or
biomagnified through the food chain, presenting health problems to domestic
animals and man.

Uncontrolled application of dried-sludge fertilizer may also contribute  to
non-point source water pollution, which is extremely difficult to confine
and regulate,  when assessing the benefits of stabilized sludge used as
fertilizer, potential consequences to the environment must be weighed.
Perhaps controlled distribution, mandatory sterilization, and limitation
of dried-sludge fertilizer application to plant species having low rates
of uptake and concentration of harmful substances would render this waste
product safe enough.  The costs of pretreatraent or advanced treatment
of industrial wastewater, using carbon absorption or other means to remove
heavy metals, might be offset by the increased value of safe sludge ferti-
lizer.

    7.  Composting

Composting is defined as the aerobic themophilic decomposition of organic
wastes to a relatively stable humus by microorganisms.  The product of compost-
ing can be used as a soil conditioner.  Traditionally, composting has been
used to stabilise solid refuse.  Sewage sludge has only occasionally been used
in solid refuse composting.  Composting systems generally fall into three cate-
gories: pile, windrow, and mechanized oc enclosed systems.


                                   VI-7

-------
Composting consists of three stages; mixing, composting and maturing.   Solid
refuse is sotted by screening and magnetic separation, and is pulverized  in
a grinder.  Sewage sludge is then mixed with the pulverized refuse.  The  mix-
ture is placed in windrows, pits, or silos for decomposition and  stabiliza-
tion.  The compost row or pile is normally turned daily for 2 weeks or  longer
with a coraposter, except during periods of rain. Under proper composting  condi-
tions, temperatures in the windrow range from 130 to  150 degrees  P, falling
into the thermophilic range wherein the rate of decomposition is  the highest.
Hie heat generated as a result of thermophilic microbial oxidation creates  a
convection current, supplying air to the microorganism.  High temperature
also can provide for efficient destruction of pathogenic organisms and  weed
seeds.  For effecient composting, the optimum pH of the material  should be
neutral.

After decomposition, the compost row or pile is flattened for further drying.
Material removed from the composting system is cured  for at least 30 days,
which provides further stabilization.  Besides solid  refuse, other bulking
agents such as sawdust, shredded paper, or wood chips can be used for sludge
composting *

The Agricultural Research Service at Beltsville, Maryland, has studied  sludge
composting for several years.  The capacity of the compost site is approxi-
mately 100 to ISO wet tons per day.  Their experience suggests that the major
problems associated with the operation are adverse weather conditions and
odors.  The study concluded that the annual capital and operating costs for
composting 200 wet tons per day of digested sludge with 20 percent solids is
approximately $7.31 (1980: $12.03) per wet ton or $30.00 (1980: $49.SO)
per dry ton of sludge.  The operating cost alone accounts for $4.10 (1980:
$6.7«) pec wet ton or $16.80 (1980s $27.72) per dry ton.  Wood chips contri-
bute over $2 per wet ton to the costs, most of which  is for hauling.  The
cost estimate does not consider benefits from sale of the product,  toddle
and Scott reported that compost has been sold for $2.00 (1980: $5.78) to
$90.00 (1980: $260.10) per ton (Surd, 1968).  The smaller figure  was the
price of large quantities of raw compost; the large figure was the price
for small specialty markets such as gardens and golf  courses.

The environmental problems associated with composting are odors and attrac-
tion of insects.  Odor nuisance seems to outweigh insect problems,  if  the
compost system is too large, dense, or wet, anaerobic conditions  may set  in
and produce undesirable odors.  Enclosing the system  is beneficial but
increases cost.  Distributing composting products as  soil conditioners  pro-
vides revenue, but nay cause the same environmental problems as pertain to
fertilizer production, discussed previously in this chapter.

    8.  Soil Reclamation

Application of liquid sludge to land is a practice dating back to antiquity,
especially in England (Benarde, 1973).  In the United states, disposal  of
sewage effluent or digested sludge on farmland has not been widely practiced,
due partly to the past availability of inexpensive and conveniently handled
inorganic fertilizer.  However, higher costs and environmental risks with
other methods of sludge disposal are making them less attractive.  This fact


                                   VI-6

-------
prompts many wastewater management organizations  to  seriously consider  the
alternative of land application.

St. Mary's Pennsylvania, has disposed of digested sludge on hay fields,  pas-
ture, corn stubble and athletic fields,  the application rate for  pasture  is
about 64 wet tons per acre per year with 3.71 solids.   Raw sewage  from  Itiske-
gon, Michigan is pumped to a series of aerated  lagoons.  The  effluent from
the lagoons, whose quality is equivalent to that  from  secondary treatment,
is sprayed on farmland.  The projected capacity of the system is 43.4 million
gallons per day (MOD), including an industrial  flow  of 24  HGD (Chaiken,
Poloncsik, and Wilson, 1973).

Digested sludga has normally been utilized for  land  application, because raw
primary and activated sludges decompose and create a nuisance.   Liquid  digest-
ed sludge can be applied to fields by spraying, soil incorporation,  soil
injection, ridge and furrow irrigation, and infiltration by shallow  impound-
ment.  Each method has specific advantages and disadvantages  in terms of
workability, reliability, and environmental effects.  Transportation of sludge
to the application site can be accomplished by  tank  truck, railroad  tank car,
enclosed barge, or pipeline, depending upon transport  availability,  site loca-
tion, and cost-effectiveness.  Detailed discussions  of transportation are
presented in the following section.

The rate of sludge application to land is determined by a  number of  factors,
including climate, topography, hydrology, and soil and sludge characteristics.
Literature review indicates that a wide range of  application  rates up to
several hundred dry tons per acre per year have benefited  soil  and crop
growth (Table VI-2., Digested Sludge Application  Rates, Burd, 1968;  Swing
and Dick, 1970).  Upper limits are not yet recognized;  ultimately  they will
be determined by the build-up of nutrients and heavy metals in  the soils
and future land use.

The land application process recycles inexpensive and  useful  organic and
inorganic materials back to the land, conserves non-renewable resources  such
as inorganic fertilizers, and eliminates costly sludge thickening  and dewater-
ing.  The capital costs for land application include land  acquisition, access
roads and fencing, site grading, sludge storage facilities, distribution
systems, and application equipment.  Operating costs include  sludge  transpor-
tation, sludge application and crop cultivation.   Systems  to monitor  and
control environmental effects further add to costs,  and should  be  accounted
for and weighed against those for other alternatives for sludge disposal or
utilization.  Table VZ-3., Land Spreading Costs (Burd, 1963; Dalton  et al.,
1968), presents reported unit costs associated with  land spreading of sludge.
                                   VI-9

-------
                  Table VI-2   Digested Sludge Application Rates (Burd, 1968; Ewing and D1ck» 1970)

Reference

Kershaw and Wood
Merz
< California State
7 Mater Pollution
8 Control Boards
Nusbaum and Cook
Mo If el

Troeeper
Hinesly and Sosewitz
Approximate
Solids
Year Type of Sludge Concentration
W
1952 Digested primary 4,0
and activated sludge
1955 Digested primary
sludge 6.5
1957 Digested
1360 Digested
1964 Digested primary 4.1
sludge
Digested primary and
activated sludge or
trickling humus
1965 Digested primary
and activated sludge 6.0
1968 Digested 3.0
Approximate
Dry Solids
Loading
(ton/acre/yr.)
2.5*
10-100
100-300*
1 ,000*
3.0*
2.0*
61
8-29*
Remarks

England.
San Diego; 25 tons/
acre equivalent to
commercial fertilizer.
California; high to
low rainfall areas,
respectively.
San Diego; land re-
clamation.
Pennsylvania; well be-
low commonly reported
application rates.
Nine Pennsylvania com-
munities; well below
commonly reported ap-
plication rates.
Springfield, Illinois;
average application ral
Chicago; soybeans and
                                                                                                corn  responded  favorably.
*No Indication of annual  repetition,  so units may  be ton/acre.

-------
   T*»le VI-3.  Lan3 Spreading Costs  [Burcl,  1368?  Dalton et _al.,  1953
     Reference
Year
Scanlon
Nusbau.ii and Cook
Musbaui and Cook
Daltoo et al.
Bur 3
 1357
 1959-1960
 1960
 19S3
 1953
Dperat ing Cast
$/ton of 3ry solils

       $7.50



      $10.00


        4.00



      $20.00-23.00



       $4.00-30.00
                             Retiarka
                          law York,  ibout
                          tha sane aa
                          barging to sea.
                          San
                          21-nile haul.

                          San Diego,  $1.50
                          Ear oLpaline
                          tr ansfer .

                          Chicago Sanitary
                          District preli-
                          minary estiaats.

                          3<>nefal range
                          with $10/ton
                                   VI-11

-------
The wide range in costs is due to the various  hauling distances reported in
aaeh of the studies.  The construction cost, amortizes  capital  cast,  ooet-
ating and maintenance cost, and total cost, excluding land  amortized  at ?
persent over 20 yeaes art presented  in Figure  ¥1-1. » Surface Spreading Costs
(Stanley Consultants, 1972), based on the  1972 dollar.   Par  a project capa-
city oC 1,000 dry tons per day, the  total  annual cost is approxi'nately $7
par dry ton of sludge.

The tiajor oroblen associated with land application is public acceptance.
Potential environmental problems include transmission of odors  ani  airborne
pathogens, build-up of nutrients and heavy rnetals in the soils,  surface
water and ground water contamination, and bio>nagnification of toxic  substances
in food chains or transfer of pathogens by ingestion, if agricultural produce
is raised on tha application fields,  proper choice and control  of  sludge
application nethods, rates and periods, and proper nonitoring and pollution
control should eliminate or niriiiiza sone  of these anviranvental problems,
Sludge transportation is an  integral part  of  slud-ge  disposal  or  utilization.
Transportation frequently exerts a significant  influence  upon overall  costs.
Dptinization of sludge handling and disposal  or  utilization requires exami-
nation of the reliability, costs, and environmental  effects of various sludge
transportation nodes.  There are four identified:  truck,  rail, barge,  and
pipel ine .

    I,  Truck Transportation

Hauling of sludge by truck offers the advantage of flexibility In routes ani
destinations.  Liquid sludge can be hauled by trucks from one treat neat plant
to another for furthar treatment or disposal,   oewstered  sludge  is co>%fiortly
hauled by trucks to landfill sites for disposal, or  to  stockpiles for  subse-
quent utilization as fertilizer and joil conditioner.   Hauling distance can
range fron a few miles to several hundred  miles.
          of trucking sludge is determined  by hauling distances  and  sludge
characteristics.  Unit costs increase with  increasing solids content and  haul-
ing distance.  \ comparative study of the costs of  transporting  3.5  percent
solids by pipeline, tank truck and railroad tank  ear indicates that  truck
transportation is the nost economical node  for distances  up to 150 ailes  and
for a treatient plant size of approximately 1.5 13D. Truck hauling costs  per
wet or dry ton of sludge are presented  as a function of sludge hauling  dis-
tances and solids content in Figure VI-2.,  Track  Costs  (Riddell  and  Cor nick,
1963; Stanley Consultants, 1972).

The Blue Plains treatient plant in the  District of  Columbia in 1973  used  its
digested sludge for reclaiiing marginal soils. Truck hauling and final  dispo-
sal of sludge sake (20% solids) were handled by a private contractor  at a cost
of $6.85 per tist ton.  In 1974, the contracted ories was  up to $3.25 per  wet
ton (Cassel and Mohr, 1974).
                                   Wl-12

-------
 1000
    oc •
   100
    o>
—  00
 e  !•»
 o  *o
4->
    LT>
U)  «^
4J
I/I
O

«  10


    00

    «

    LT)
                345 67890
                	I
   1.0


     10
                                    345 67890
                                   1—IT
                                           -mr
234 567890 100
       I  i  i I
                                                                    o>
                                                                    in
                                                                    u>


                                                                    ro


                                                                    10
                                                                    £   °
                                                                         10


                                                                         *0
                                                                         o
                                                                         o
                                                                    1.0
                                                                    00   7j
                                                                         2
                                                                    D.I
            2    345 67890     2   345 67890      234 567890
                           100                 1000                10,000

            Dry Solids (ton/day 1n processing capacity)
      Notes:

      1.    Minneapolis, March 1972, ENR Construction Cost Index of 1827.
      2.    Amortization at 7% for 20 years.
      3.    Labor rate of $6.25 per hour.
      4.    Application rate of 25 dry tons per acre per year.
      5.    Sludge diluted to a sol Ids content of 2t for spray distribution.
      6.    Storage lagoons, dilution wells, pumping station, piping and
           spray distribution equipment Included.
     Figurevi-1    Surface Spreading Costs (Stanley Consultants, 1972)
                             VI-13

-------
 1000,
  800'
  600
  400

— 200
— 80
| 60
J 40
 t.
a.
 fe 20
 § 15
 £> 10
a   g
 si
°-   6
                                     I	|    I  i
                                                                    •	j...m i
100
 80
 60
 40
 20
 15
 10
  8
  6
                                                                               1.0
                                                                                ,8
                                                                                .i
                                                                                .4

                                                                                .2
                                                                                    L.
                                                                                    >e
                                                                                    o
                                                                                    T3
                                                                                    O
                                                                                    1.
                                                                                    01
                                                                                    a.
      1      2      4   6  8 10     20     40  60 80  100     200   400 600 800 1000
                           Distance to Disposal  Point  (miles)

  Figure VI-2   Truck Costs  (Riddell  and Cormlck,  1968; Stanley Consultants, 1972)
                                         VI-lJ*

-------
Health hazards and odor nuisance associated with sludge hauling by trucks
are nininized by the use of special trucks with a sealed tailgate and taroau-
lin cover or, In casa liquid sludge is hauled, a sealed tank.  Howsvac, the
roisa and air pollutants generated by the trucks en routs to iisoosal or
utilization sites are generally unavoidable.

    2.  Rail Transportation

Railroads are an attractive nods for sludge transportation whan tracks sea
near the origin and destination of tha sludge and long distance hauling is
required.  Liquid sludge can be hauled by rail tank cars, and dewatsred sludge
in either open or closed hopper cars.  Major structures required for railroad
transportation ace loading and unloading facilities.

Recently, sone attention his been given to the unit tnin concept as a neans
of hauling sludge and refuse.  The technology is available and under conside-
ration by several netropolitan districts.  The unit train in this instance
light be comprised of 30 cars or vehicles.  Bach vehicle is a 20,000-gailon
tank car with special fittings, and can handle a load of 80 tons of sludge.
The train could naka journeys of several hundred niles.  indoor or outdoor
systems could load sludge either through the top of the tank or through a
loading connection at the bottom.  Completely autoaatsd systems could load
400,000 gallons of sludge into 20 cars in less than 3 1/2 hours with a three-
nan crew.  9f Increasing ouvping rates, the facility could load $00,000 gal-
lons of sludge in 2 1/2 hours,  fc two-nan crew could unload the sludge in
approximately 2 hours.  Basel on a 200-mile journey, tha 30-car unit train
would have an overall turn-around tine of 43 hours (Kostalich, 1973).

Based on a daily handling rata of 7,000 wet tons, the hauling cost Cor a unit
train would be less than $2.00 per ton of wet sludge containing S percent
solids (Kostalich, 1373).  The unit cost of hauling sludge by a regular train
is higher and depends on the rate structures, which vary with geographic loca-
tion.  On reviewing the hauling contracts for Philadelphia and San Francisco,
unit costs were found to be $5.39 per ton ana $6.25 per ton, respectively.
Tha Earner figure includes final disposal; tht latter does not (Stanley Con-
sultants).  The unit coat per dry ton of sludge as a function of hauling
distance is given in figure VI-3., Rail costs (Riddel1 ani Coriick, 1963;
Stanley Consultants, 1972).  For distancas greater than 150 alias, rail
transportation is tore economical than trucking for treatrent plants of 1.5
4GD.  3enerally, the cost of rail transportation could be reduced in half if
the unit train concept were utilized (Saston, 1)70).

The environmental hazards of hauling sludge by rail are similar to those for
truck hauling,  antsver, in the event of an accident, environmental iipacts
could be worse because of the vastly increased aaount of sludge.

    3.  Barge Transportation

Barging of sludge nust be considered as an alternative «ode of shipping when
navigable waterways are available between origin and Jestination.  Large
quantities of sludge can be transported efficiently, and often barges can
be rented.
                                   VI-15

-------
 1000


  800



  600




  400
  200
a
"O
I 100


2- 80
fe  8°
a.

**

8  40
    20
      10
                                    J	I
               20
    40     60  80 100


Distance to Disposal  Point (miles)
                                                                60
                                                                 ftr
                                                                         100


                                                                          80



                                                                          60



                                                                          40








                                                                          20
                                                                              in
                                                                              o
                                                                              •a
                                                                           10  o
                                                                            i  M
                                                                            4  o
                                                                               o
  i
t>00
   F1pre 71-3   Rail Costs (R1«Wtll  and Cortrtck,  1968; Stanley Consultants, 1972)
                                       72-16

-------
    cost of barging 250 tiles  from 'Washington D.C., has been reported as
$3.50 (1930: $10.12) pec wet ton (Smith, 1963). The barging of  sludge 139
tiles on the Illinois River from Chicago coats $1.80  (1990: $5.20) per net
ton, based on • shipping rate  of 9,000 tons per day (Stanley Consultants).

Environmental considerations in barging sludge are eomplettly different from
those for truck or call hauling.  Accidental spills of sludge from barges
couli cause severe short-tern  irreversible impacts such as fish kill or
destruction of local benthos.  However, the probability of this occurring is
very snail.

    4.  Pipeline Transportation

Pumping of sludge and waste slurries through pipalines his been practiced for
nany years.  Short distance pumping of sludge exists  in most sewage trait tent
plants,  Transporting sludge pipelines has also become a popular mode for
intermediate and long distances.

Whan assessing this alternative, the main factor to consider is the hydraulic
characteristics of the sludge.  Sludge containing  5 percent solids flows as
ftfcwtonian liquid, which is similar to water with respect to friction and power
requirements.  Sludge with greater than 6 percent  solids possesses plastic
properties, requiting a prohibitive amount of energy  for long distance pumping
(Sparr, 1971).  A minimum flow velocity oust be maintained to prevent solids
fro* settling and to sustain the flow during turbulence.  Other problems asso-
ciated with sludge pumping are grease buildup and  pipe corrosion.  Depressing
ths sludge prior to pumping and installing protective pipe lining could avoid
these prcMena.

% study was cot die ted to determine the feasibility of pumping sludge from
Cleveland via a 92-mile, 12-inch dimeter pipeline for disposal on strip-tined
land i.i southern Ohio, and of  pumping sludge* fro*  the Washington-illtinore
area 30 miles Say pipeline to an ocean outfall (Bechtel Corporation, 1969).
Capital and operating costs in the first case ware estiaatsd to be 125 (1930:
$67.35) oar dry ton or $0.27 (1930: $0.73) per ton-tile, assuming 3.5 percent
digested solids,  the costs in the latter case wsre estimated to be 523 (1930:
$75.43) per dry ton or $0.35 (1930: $0.94) par ton-mils.  Based on t popula-
tion of 2,000,000, digested sludge with 5 percent  solids could  be pumpad 100
miles at a cost of $7 or $3 (1930: $20.95 x $23.92)  par dry ton, or approxi-
mately $0.05 (1930: $0.15} pec ton-mile, to reclaim marginal or strip-mined
land (Rand Development Corporation, 1967).  These  costs do not  include acqui-
sition of easements along pipeline routas.  the use of pipelines dots not
become economical Cor transporting sludge 25 lilts away until the plant site
reaches approximately 10 NOB.  K 300-mile pipeline cannot be economically
justified'until plant sise reaches approximately 25 W» (Riddel1 and Coraick,
1968).

Short-term environmental effects during pipeline construction include air
pollution from traffic Jam caused by the disruption  or interference of traf-
fic, especially in urban areas.  Proper insulation of lift and  booster stations
will minimist impacts on surrounding areas.
                                   Vl-17

-------
C. System Alternatives

Ten system alternatives for sludge processing and disposal were developed on
the basis of experience gained from plant operations and research on various
technical topics (MSDGC, 1973a, 1974a, 1974b, 1974c).  Each system alterna-
tive has a planning period of 25 years, an average sludge production rate
of 1,236 dry tons per day.  Each alternative consists of a combination of
several subsystems! namely, dewatering, stabilization, disposal and/or
utilization and transportation subsystems.  The system alternatives and
sludge flows for each alternative are presented in Figure VT-4, System
Operations and Sludge Plows (MSDGC, 1975a).  The costs, system requirements,
construction phasing, and life of facilities for each system alternative
are sunraarized in Table VI-4 (MSDGC, 1975a).

The MSOGC considered the total scope of their disposal needs and decided that
the best alternative was one that had flexibility within the system and more
than one final option.  Therefore, System 10 was chosen.  Of the total 1,236
dry tons of sludge per day, 439 dry tons per day goes to the Fulton County
project.  While alternative 10 is not the least cost alternative, credit must
be given on a wholistic basis for energy savings, reclamation of land that
otherwise might not be in productivity, and employment of full and part-time
persons to manage and operate the Fulton County site.  The 1979 Operating
Cost for Fulton County was $190.00 per equivalent dry ton.

This project can be considered a major milestone in reclamation of drasti-
cally disturbed land,  the MSDGC has endeavored to involve different interest
groups to the maximum possible in the design, operation, monitoring and redi-
rection of the project.  This highly dynamic project has been modified to
utilize the most up-to-date equipment and techniques.  Its basic premise was
to take two difficult problems, unusable land and enormous amounts of munici-
pal sludge, and realize the beneficial constituents of sludge for soil building
and nutrients to return land into agricultural productivity.  There was very
little state-of-the-art when the project began, so the MSDGC had to experiment
with application methods, piping systems and crop rotations.  Their chief
problem in early years was that they were not farmers.  This led to criticism
by some local citizens.  While there still is some local opposition to the
project, the County Board and most advisory groups support the project.

The project has provided opportunity for research by the University of Illi-
nois, The County Extension Service, and Spoon River Community College.  Much
of the data on ingestion of pathogens and metals from sludge was conducted by
the University of Illinois.  Several researchers that have monitored the
project since start-up are still associated with the project, providing the
first long-term study data on sludge application projects.  The Soil Conser-
vation Service has provided timely input into the project.. Many of their
conservation measures have been built into the project.

This does not mean that the project is without probleas.  Earlier noted
erosion problems have been addressed in many cases.  Gully erosion problems
along the perimeter of some field may take longer to rectify.  Most of these
problems are contained within the site and don't necessarily add bo the exist-
                                   VI-18

-------
       F^Utlon-Conc.ntr.tlon ->



       Fl.Ut^n-C.nc.ntr.tl.n -+
                                                      or rail,
                                                      200 m)
    Ctntrtfugt DmttiHng

    Ctntnfugt DfmliHns
  6 r-»flottt1on-Conctntrit1on
            (781
    — !>Ctntr1fu9t DtM
            (4SS dt/tf)
                                         200 Hi)

                                H«it Drying  - »> Fertilizer Sile

                                Ixlneritlon   tru
                                       .Centrifuge        >. Sinltiry
                                        DawaUi-iig  (truckT  Landfill
                                              > Fertilizer Salt
                            Heat Drying


         (7ardt/.~!r


—•> Centrifuge Dmaterlng	|>HMt Drying	^FertlHier Sill
        (4SS dt/d)
                                                                         Lindflll
      •iBhoff
         (116 dt/d)
                                          r

                                Olgeitlon'H  ^Jj1^


                                          l*Centr1
                                            (127 dt/d)
                                                        0iltr1i"'ttoB
                                                      ApplTitian of  Liquid Sludge
                                                            (439 dt/d)
                                                        (truc»
I— l»«Kuwi FllUr 0«MUr1nf
^      (4S5 dt/d)
                                       Drying
                                                  F«rt1llMr Salt
Flqure VI-U    System Operations  and Sludge Flows  (MSDGC,  1975a)
                                     VI-19

-------
            T*fcl«vt-4
 Attrmativei. SystM
), JBJ Life of rac
Jdnrttted* 	 Jysta» Rtqylrtneiits and ><;
***«" Capital DIM Total Construct!* Basing *
(»)" flr nr 	 ~~ 	
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concentration faci titles. <
4- 100 dt/d digester batteries with
concentration facilities.
17 - 21.9 dt/d centrifuges ta sup-
plement existing vacuum filtration
facilities. <
10- 21.9 dt/d centrifuges.
Additional 152 dt/d flotation-con-
centration facilities.
2 11.84 tt.22 SO.OC* Sane at Syjta. 1. i
47.70»» Und dtvelopaent (25,000 acres).
Application equipment.

3 10.45 14.S3 44.W 7- loo dt/d digester batteries »ith
concentration facilities. •
4- 100 dt/d dl|ester batteries with
concentration facilities.
Und development (25,000 acres),

4 S.M 26.J2 u.H 48- 21.9 dt/d centrifuges »itn flo-
tation-concentration facilities.
14- 21.9 dt/d centrifuges Kith flo-
tation-concentration facilities.
40- 12.000 Ib Hater/hour drying
lines.
10- 12,000 1b water/hour drying
Tines.
S 5.12^ 22.71 Jl.il 48- 21.9 nt existing vacua filtration
facilities.
18-21.9 dt/d centrifuges.
Additional 152 dt/d flotation-con-
centration facilities.
• 13. M 3§*9$ 49.91* Saaie as Sy.tem 8.«
47.MM (.end development (25,000 acres)
Application equipment.

10 J.si 11. ai is.it 3- 100 dt/d digester batteries Mitk
concentration facilities.
2- 100 dt/d digester batteries with
utntentritlon facilities.
27- 21. * dt/d centri fun« .
Land pureMse and development
(2.700 acres).
Application Mulpment.
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                                  VI-20

-------
contamination from strip-mine runoff.  This  is  evident  from water  quality
investigations showing that water quality  is better  in  Big  Creek downstream
of the project.

Local farmers have seen benefits from  utilizing sludge  as a soil amendment
and fertilizer and have inquired about obtaining sludge for their  own lands.
With the rising costs of commercial  fertilizers, sludge applications become
more attractive.  Also, the state-of-the-art is being improved,  thereby
reducing the relative risks associated with  the project.

Reliability factors that were considered for the project included  landfill
availability in Northern Illinois, small scale  land  application  on private
lands, low sludge application rates  and land requirements,  fertilizer markets
and energy requirements.  On most of those factors,  the Pulton County project
rates very well.  The establishment  of a privately held site  that  is well
monitored should allow the continuous  implementation of land  application,  ^s
further acreage is developed, weather-related problems  would  be  reduced in
that lower application rates on fields could be accommodated  and a variety of
field conditions would allow greater flexibility.

While some critics still remain, they  have not  provided a better alternative
solution to the growing amount of sewage sludge.  Given the full line of con-
straints associated with incineration  and  giveaway programs for  large munici-
palities, the HSDGC project provides more  benefits than risks.   It is expected
that as further data become available, the project will respond  to techniques.
                                 VT-21

-------

-------
                                 MITI3ATIVE MEASURES

A.  Land

Two major areas of concern at the Pulton County project site are soil erosion
and long-term soil contamination.  Soil erosion depends to a great degree on
the design of the fields as well as the level of maintenance of drainage control
features.  While available records suggest that considerable work is being done
in regrading fields and revegetation, dikes and berms, field observations indicate
that maintenance procedures are not entirely effective.  The major impacts of
erosion and siltation are on the internal basins,  very little runoff ends up  in
natural waterways.  However, proper maintenance is recommended to ensure that
this remains so.  A positive aspect of the project is that the leveling activities
have decreased the possibility of erosion in general areas.

Drainage control appears to be superior at the newer application fields compared
to those designed and constructed initially.  Grading of some of the newer fields
has provided a shallow concave profile, creating backup reservoirs for use when
the runoff retension basins are filled.  Fields graded with a convex profile
cause runoff to be channeled along the field perimeter, resulting in high velocity
and scouring.

The MSDQC has sought a remedy by constructing additional siltation basins to retain
silt-laden runoff.  However, a lack of vegetation on control berms, drainage chan-
nels, and basin dikes has contributed to severe gully erosion, accelerating the
rate of siltation and thereby reducing the added capacity for runoff control.  This
has increased the need for frequent desiltation operations.  Available records
however, indicate only sporadic cleaning of siltation basins.  It is difficult to
determine whether the apparent failure to clean existing basins is actual or «ere-
ly reflects poor record-keeping.  Mao, field investigation demonstrated the exis-
tence on unrecorded, newly constructed siltation basins.

MSDGC records are sparse in documenting repairs to drainage pipes.  Field observa-
tions indicated some instances of pipes being damaged by farm equipment and pipes
clogged with silt, obstructing discharge from siltation basins into runoff reten-
tion basins.

With few exceptions, on fields where sludge is applied by disk incorporation,
applications are made considerably above the nitrogen agronomic rate.  Such high
rates of application contribute to erosion of the soil in several ways.  1b incor-
porate large amounts of sludge, multiple passes (5 to 6) of the disk incorporator
are required during the primary growing season, obviating the possibility of
growing a crop.  Thus the HSOQC has recently resorted to planting crops only in
alternate years on most of these fields.  In years when a field lies fallow and
bare while sludge is applied periodically, soil erosion will increase considerably.
lack of a crop also prevents evapotranspiration.  Recently, the MSOQC has planted
a sacrifice crop at the end of the application year to help control erosion.  This
practice has been helpful.

Several unrecorded measures nay combine to decrease the erosion and siltation
effects at the project site,  the MSOOC should document all redesign and new
construction to credit their mitigative measures.  When older fields were recon-
                                   VII-1

-------
toured fot tractor operations, the events ware not recorded, nor were  the cleaning
of siItation berms and basins.  It is extremely important to completely document
such measures, especially if sludge will continue to be  applied at rates higher
than nitrogen requirements for crops,  it must be kept  in mind that one specific
goal is to raise the organic matter content of the spoil lands thereby increasing
agricultural productivity.

A rather persistent question arose concerning the introduction of heavy metals to
the land.  At the Fulton County site the soils are generally unconsolidated mix-
tures of former soils and parent materials.  Ihe basic constituents of the mine
spoil include heavy metals and chemicals similar to constituents in sludge.   It
would be hard to assess the total impact of metal loading on the Pulton County
site.  However, if the MSDGC were not applying sludge to the soils the land
would not have been reclaimed to any extent.  The fact that MSDGC owns the land
and controls access, reduces the possibility of contact  with adverse conditions.
Some experiments using aeid-extractability to indicate long-term plant availabil-
ity have shown that these metals can be available to plants for a considerable
period of time.  Fulton County data acquired using actual field dates  seem to
indicate that metal levels in crops do not reflect cumulative applications over a
number of years.  Further data should be provided to substantiate this finding.

B.  Water

The analysis of water quality impacts in Fulton County is complex.  Background
investigations show that the quality of ground and surface water at the project
site was exceedingly poor before project operations began.  High background con-
centrations of sulfate, copper, manganese, iron, lead and total dissolved solids
in surface waters (streams and reservoirs) are probably  due to leaching of atrip-
nine spoil.  The water quality of Big Creek, both before and after sludge appli-
cation, has been strongly influenced by sources of pollution upstream  from the
project site, including effluents from the Canton Sewage Treatment Plant upstream.
If low-levsl contributions of sludge constituents to surface water were to result
from sludge application, it would most likely be masked  by high background levels
of metals and other constituents.  While this situation  may allow small contribu-
tions of sludge constituents to go undetected, it also vastly decreases the
significance of potential contributions in tsrms of water quality deterioration.

A refinement of the sampling design should be considered to try to distinguish
various sources of contaminant input to Big Creek.  While this might be costly,
it would help provide detailed answers to sources of total dissolved solids.

A comparison of violations of Illinois water quality standards  in the stream and
reservoir stations during early and recent project stages indicates that surface
water quality has not significantly deteriorated.  Trend analyses for  nitrite and
nitrate-nitrogen, total phosphorus, anmonla-nitrogen and fecal coliforns in stream
and reoervoir stations indicate no increasing trends with the exception of increas-
ing nitrite and nitrate nitrogen in R3 and R12 which can be attributed to any of a
number of sources.  Nitrate levels in both reservoirs, although increasing, have
consistently remained within drinking water standards.   Pecal colif orm concentra-
tions in all reservoirs are generally low,, indicating that the applied sludge has
been low in fecal conforms and/or that the runoff basins have been effective in
retaining fecal bacteria.  Fecal coliform counts have been high in most stream
stations but have not been increasing and arc probably not due to the  project.
                                  V1I-2

-------
lovar focal col ifori levels in R3 than  in  3ig Cceek  Into  which  the reservoir
drains indicates that sludge application on the 2000 hectaras of land  draining
eventually into R3 could not be responsible for high levels of  indicator  organises
in Big Creek.  Higher concentrations of sulfate and  total dissolved solids in Big
Creek station 32 over upstrean station  Si  can be  attributed to  a nunber of sources,
none of which can be singled out.

SUE face water quality at the project sita  depends in part on the design operation
and maintenance of the runoff basins.   Calculations  show  that basins for  21  fields
are triable to contain runoff fro* a 24-hour, 100-year  storm.  «
-------
ties.  Furthermore, with the exception oC W10, nitrite and nitrate nitrogen levels
are generally lower than 0.2 milligrams per liter (as opposed to the drinking water
standard of 10 milligrams per liter indicating that little soluble nitrogen is
leaching into the groundwater system.

Fecal coliform, trace element, and other chemical concentrations in wells remain
close to baseline conditions.

Apparently, most groundwater constituents have been little influenced by project
operations at this stage of project development.  The variations in their concen-
trations are probably influenced by the geochemical characteristics of abandoned
strip mines, such as heavy metals in exposed black shale.  The variations in ground-
Miter quality at most stations are comparable.  Therefore, soils are either func-
tioning well as a biochemical filter for the removal, conversion, and fixation of
sludge constituents or are not permeable enough to allow sludge constituents to
percolate into groundwater.  It must be noted that the likelihood of this project
significantly affecting ground and drinking water resources is extremely small
because aquifiers providing drinking water are deep and are covered by impermeable
strata,  water quality data are, however, insufficient for long-range projections
of groundwater quality.

C.  Air

The only two potentially significant odor sources at the project site are the
sludge holding basins and sludge ponding in the application fields.  Mthough the
strength of odor emissions from surface-applied sludge is equal to that from the
holding basins, the consequent odor problems are short-term because most odorants
are released into the atmosphere within the first week.  Surface penetration meth-
ods do not generate aerosols and evaporation of malodorants is small.

It has been shown that ammonia concentrations at the sludge holding basins, even
during the most unfavorable meteorological conditions, are less than the threshold
value reported by Leonardos et al. (1969).  Confirmed sludge odors during months
when no sludge was applied, however, suggest that odors were arising from the hold-
ing basins.  Malodorants other than ammonia therefore reside in the sludge, which
act synergistically to generate a sewage sludge smell.

Within the past several years, decreases in odor complaints can probably be attri-
buted to the decrease and final elimination of spraying activities, and a reduction
in the surface area of sludge storage lagoons.  This reduction in stored sludge
volume is attributed  o continued sludge application while barge shipments from
Chicago were tempor *ily halted, thus diminishing supplies on hand.  New problems
will result from sludge application if soil incorporation techniques continue to
be used, provided that sludge ponding is kept to a minimum by better management
practices.

D.  Health Effects

Because spray application constituted a large proportion of past application tech-
niques, the extent of aerosol inhalation was estimated from a dispersion model.
The calculated respiratory intakes were found to be low when compared to World
Health Organization (WB3)-recommended maximum daily intakes, suggesting that past
inhalation of sludge aerosols was probably not dangerous,  this is supported by
the absence of reported health effects in Pulton County.


                                   VII-4

-------
While some indirect health impacts tiay vise  from  the  ingestion of plants or  ani-
mals contaminated with sludge constituents, tost of these  Upsets will be con-
trolled by monitoring of croca produced.  Secondly, dilution of crops into  the
market will reduce the impact to any particular animal or  person.  Crops could
go into gasohol production.

The MSOQC should continue to monitor soils, plants and animals on the project
site to provide infornation concerning heavy  natal uptake.  Special  interest  in
cadmium and polychlorinated biohenyls by regulatory organizations warrants  these
continued studies.

In terns of human health, the future land use of the area  would dictate the future
impacts.  Listed below are the worst and best cases concerning land  use and honan
health impacts:

                                   worst Case

     Sale of lard to farti operators who live  on the previses and raise
     their own food with no monitoring or controls.  Rral housing
     developnent where residents garden with  no monitoring controls.

                                    Best Case

     Land remains in hands of the MS03C with  rental to farmers,
     providing management and nonitoring controls.  Land developed for
     outdoor recreation, prairie preservation, and tree farts.

E.  Recorcnended Mitigative teasures

    I.  Sludge Application Rates

1SOGC should develop a Facilities Operating Plan as outlined in 40 CFR 257.3-5(9)
(l)(e).  *s promulgated, this cadmium management approach  sets forth four require-
ments which will serve to mininize the increase of cadmium in the human food  chain.
First, only aniual feed nay be grown under this option.  The likelihood of  signifi-
cantly increasing individual or general dietary cadmium levels through aniial feeds
is negligible.  The second control to assure  proper management of the facility is
the requirement that the solid waste and soil nixture have a pH of 6.5 or greater
at the tine of solid waste application or at  the tins the  crop is planted,  which-
ever occurs later.  This pH balance is important where cadnim application  is unre-
stricted.  The third requirement calls for the development of a facilities  operating
plan.  The purpose of this plan is to demonstrate  how the  animal feed will  be
distributed and what safeguards are utilized  to prevent the crop from becoming a
human food source.  The fourth requirement is a stipulation in the land record or
property deed which states that the property  has received  solid waste at high cad-
mium application rates and that food chain crops should not be grown, due to  a
possible health hazard.

In lieu of growing the crops for animal consumption, the rising market foe  crop
products for alcohol production nay be the safest  way of assuring that the  crops
do not enter the human food chain.  Recently, the  demand for alcohol for gasohol
production has greatly increased.  Furthermore, a  distillery in Peoria may  be a
good market for MSOOC crop products.  This corn, etc. would then be used as a
renewable energy resource.


                                   VI1-5

-------
The MSDQC should plant cover crops as soon as possible after  sludge  application.
\ttampts should be nads to increase the solids content of  sludge  applied  to
reduce the number of applications.  This should lessen tha sail compaction
impacts.  Further information should be provided concerning the criteria  for
reclaiming spoil.  Test results  for organic natter content in soils  should be
provided for analysis of the first Civs years 3* operation,

    2.  Land

Where feasible, fields that ire  graded to drain laterally  across  the principal
slope into ditches along the pec lister should be regraded  with a  broad, shallow
depression and retention dike at the base of ths slope to  aid backup runoff re-
tention capacity on the field itself, thus eliminating high velocity runoff,
scouring, and gully erosion at the edge of the flail.  This is mainly  for ths
older fields.  New fields are bettar designed and do not show some of  the aspect?.


Terraces constructed across long slopes and maintained in  permanent  vegetation
should be provided when practicable for greater erosion control*  drainage channels
or ditchas, dikes, and berns should be permanently grassad to stabilize ths soil.

Braachad dikas or barns should be repaired promptly; barriers of  rock, hay bales
or other material should be placed in ditches or runoff channels  containing high
velocity flow to reduce scouring and gully erosion.

    3.  Mater

The MSDQC should extend the current practice of building supplemental  siItation
basins, especially whers soil loss and siltation of retention basins is severe
and runoff retention capacity is narginal; also, there should be  nora  frequent
cleanout of silted basins and •flowing of overgrown basins to preserve their func-
tion.

The prescribed practice of pumping fro-n partially or nearly filled runoff reten-
tion basins back onto application fields should be employed where necessary to
avoid emergency releases of substandard effluent; such recycling  of  runoff should
occur bsfors fields are saturated front rainfall and sludge application combined.

Discharge control gates should be kept closed during a period of  runoff fron  a
storm; prolonged periods when gates remain open should be  carsfully  avoided.

Poor water quality flowing into  tha project site is not a  license to further
pollute, h refined water quality monitoring scheme is suggested to differentiate
tha pollutant contributions fro* project point sources (retention basin discharg-
es), comunity point sources (Canton sewage treatment plant),  and nonpoint
sources (runoff over mine spoil). Stream monitoring stations  in particular are
too  few to enable segregating these contributions, and comunity  pollution of Big
Creek, whars most stream monitoring occurs, tends to mask  tha possible pollution
of minor tributaries from project operations.  Pollution sources  and problem  areas
should be identified and mttigatlve measures taken to alleviate water quality
problams.

Quality of runoff retention basin effluent aust be upgraded and should be monitor-
                                   VII-€

-------
ed by analysis of 24-hour conposite sanples oe by averaging  the  values of sauries
taken at several intervals ins t 2 ad of using a  single grab  sample.   The current
IEP\ requirement, which assumes relatively stable concentrations of biochemical
out yen demand, total suspended solids and  fecal californs,  has been  ineffective  in
or eventing occasional releass of contaminants  who 33 concentrations  can fluctuate
widely in 24 hours.

Analysis of the nutrient concentrations in effluents from  runoff basins should be
performed to determine nutrient inputs into receiving waterways  and reservoirs.
These data will aid in estimating the eutrophication potential in receiving  waters.

Since written records have not provided a complete picture of operations and ,main-
tenance activities, periodic inspection of the project  lite  by the  U.S.  and  Illi-
nois Environmental. Protection fcgencias could establish  a constructive basis  for
reducing undesirable impacts of the project on water and air quality  through
improved procedures for soil nanagament and drainage control.  Vi inspection teat
might inciudle a soil sciantist, agronomist, agricultural engineer,  hydrologist,
and pollution control engineer.  "V local  soil  conservationist and comunity
health sanitarian could provide additional insights and constructive  recounenda-
tions.

N50QC should revise their groundwater wnitoring  program to  da tar nine the direc-
tion and rate of flow? therefore being able to iatemine if  the  sludge applica-
tion is having an adverse inpact on groundwatsr.   A groundwater  flow  neter,
recently developed, will sonewhat sinplify this analysis.  3roundwater  nonitoring
should continue to identify if a pollution "breakthrough"  to an  aquifer  would
occur .
Periodic regrading to remove depressions due to subsidence of unconsolilatsd sub-
soil or nine spoil should be performed as necessary to prevent ponding of  freshly
applied sludge which presents a potential for odor emissions.

Occasional unavoidable ponding should instigate control nethodologies for  odor
control.  The >GOGC has applied 74Q7, an odor control product of Pollution
Sciences, Inc., to ponding areas, and this practice should be furthsr evaluated
and continued if warranted.

Recognizing that the storage lagoons are an occasional source of odor, efforts
should be nade to Unit the anoint of sludge stored at the Fulton County site.
Limiting sludge storage to the anoint of sludge necessary for the staging  of
land application practices would reduce lagoon surface area and prevent odor-
producing lagoon turnovers.

Tha MSDGC Comprehensive Par nit is currently under appeal and there is currently
an enforcement action concerning odor violations, pending before the Illinois
Pollution Control Board.

'4e will work with the ISPA to optinizs the operation and environmental compati-
bility of the Pulton County project.
                                   VII-7

-------
The use of wind barriers such as tall, dens* hedgerows or  fences around tha  hold-
ing basin betas, or perhaps floating baffles within the basins if this could be
developed to be economically feasible, couii reduce surface turbulence and wive
action which intensify odor emissions.  The orasent requirsneat of a 4-foot  Eras-
board Ccofl the sludge surface to ths too of the bem provides wind baffling  only
for 3 short distance downwind.

    5.  aaalth _%soect_8

The feasibility of developing lands at tha project sits for outdoor recreation,
prairie 
-------
                      VI11.  ENVIRONMENTAL CONSEQUENCES
                                OF THE PROJECT

A.  Unavoidable Advecse Impacts

    1.  Oistr ibution Systems

In a pcoject as large as the MSDGC Fulton County pcoiect, thece ace many unavoid-
able impacts.  However, when the impacts ace viewed in terms of viable options
available and the relative cisles of each alternative, the risks appear to Call
into the acceptable range.  Undoubtedly, some sludge generated in Chicago will
spill into the waterways of the State of Illinois due to loading and unloading
operations at the Chicago and Liverpool barge facilities.  The magnitude and
frequency of spills should be controllable to some extent.  Sludge entering the
waterways will have adverse impacts on fish resources, general water quality
and benthos.  These impacts should be short term and infrequent.  Runoff from
fields and overflow from retention structures on the project site nay contaminate
streams and lakes on the project site.

Hie pipeline from Liverpool to the site could break due to natural or human forces
causing pollution of land and groundwater resources.  The walls of the storage
basin could be ruptured.  The distribution pipe on the project site has been
vandalized in the past.  This could happen again.

    2.  ttecontouring

Secontouring the land to improve the capabilities of existing fields or raw fields
to receive sludge would generate short-terra disruption in traffic flow c.ijng local
roads,  these construction activities produce noise that would disrupt the exist-
ing conditions.  However, moat noise would be in the interior of the site and
therefore would not greatly impact humans other than construction and farm opera*
tors.

Thece would likely be a loss of potholes and surface waters if recontouring con-
tinues.  Soil erosion and siltation would occur until cover materials could be
established.  The NSDQC has used some soil conservation practices in the past,
strict adherence to these same fundamentals in the future would decrease the
severity of new site development,  ftedeveloping the strip-mined land would also
decrease iarxi available for wildlife.  Although there are no endangered species
on the site, several rare plants and many of the animals could be further dis-
placed.

    3.  Human Health

Mthough the risk is extremely small, both livestock and human health could be
adversely impacted by continued operations.  This could be either direct, such
as the death of a farm worker in a tractor incident, or indirect by ingest ion of
pathogens related to sludge.

further odors could arise from the project site that would adversely affect human
activities such as church, recreation and farming.
                                   vm-i

-------
B.  Relationship Between Shoet-term Use and Long-teem Productivity

The MSDQC project has had a very positive  impact on Fulton County.   It  has  in-
duced employment, raised tax money and abated runoff from strip-mined areas
that may have resulted in better stream water quality.  Ihe  project  has result-
ed in establishment of row crops on the site.  However, much of the  terrain was
so disturbed that much of the site has not been recontoured.   Land has  also
been set aside for conservation, recreation and environmental  protection.   The
long-term effects of the project will be enhanced soils,  decreased dependence
upon chemical fertilizers for row crop production, and enhanced land use with
improved employment and tax base within the County.  For  Chicago residents  the
project is an innovative, productive method to utilize sludge  solids.   It will
help to decrease our dependence on oil and natural gas supplies for  incincera-
tion and fertilizer production.

C.  Irreversible and Irretrievable Commitment of Resources

The project has committed many person-years of construction, monitoring and
operational time.  The MSDQC has committed millions of dollars to the operation
and research of this project.  This has led to major modifications to improve
operations and environmental controls.  A  huge commitment of vehicles,  piping
and fuels for construction and operation have been made.  This commitment for
fuels has decreased now that farming operations are the predominant  activity.
The land may be held into perpetuity by MSOGC for the now existing usage.
                                 VHX-2

-------
                                   BIBLIOGRAPHY

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-------
Chalken, E. I., S. P»Ion-slk, and C. D.  Wilson, Muskegon Sprays Sewage Effluent
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Da I ton, F. E.  and R. R. Murphy, "Land Disposal V:  Reclamation and Recycle,"
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   Water Pollution Control Federation, V. 36, No. 8,  1964.

Druett, H. A., et a I.. Studies on respiratory Infections  "The Influence of
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Durfer, C. N. and E. Becker, Geological Water Supply  Paper, U. S. Department of
   the  interior,  1964.

Easton, J., Transportation of Freight In the Year 2000, Report for Detroit Edison
   Company, September 1970.

-------
Envtro Control Inc., Draft Environmental  Impact Statement, Sludge Disposal and
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Ewlng, 8. 8. and R. I. Dick, Disposal of  Sludge on Land, Mater Qualify  Improvement
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Howelis, D. H. and 0. P. Dubols, "The Design and Cost of Stabilization  Ponds  In
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Krlshnaswaml, S. K.r "Health Aspects of Land Disposal of Municipal Mastewater
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-------
Lue-HIng, C., at a I., "Chicago Prairie Plan - A Report on Eight Years of Municipal
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McCoy, J. H.; "Sewage Pollution of Natural Waters," MlcroblalAspects of Pollution,
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Midwest Research Institute, Studies of the Fulton County, Illinois Land Spreading
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   Quarter, 1972a.

MSDGC, Environmental Protection SystemReport for Fulton County,  Illinois, Fourth
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MSOGC, Contract Plans for the Site Preparation for landReclamation, Stage I,
   Zone  I,  I972c.

MSDGC, Contract Plans for the SitePreparation for LandReclamation, Stage 2,
   Zone  I,I9f2d.

MSOGC, Contract Plansfor the Site Preparation for Land Reclamation, Stage 3,
   !972eT

MSDGC, Contract Plans forthe Site Preparation for Land Reclamation, Stage 4,
   1972?:

MSOGC, Contract Plans for the Site Preparation for Land Reclamation, Stage 5,
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MSDGC, Enylronipntal Protection System Report for Fulton County,  Illinois,
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MSDGC, Environmental Protection System Report for Fulton County,  Illinois,
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MSDGC, Environmental Protection System Report for Fulton County,  Illinois,
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MSOGC, Environmental Protection SystemReport for FyI ton County,  IIilnols,
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MSOGC, Contract Plans for the Site Preparation for Land Reclamation, Stage §,
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MSDGC, Contract Plantfor the Site Preparation for Land Reclamation, Stage 7,
   1973 j:

MSDGC, Contract Plans for the Site Preparation for Land Reclamation, Stage 9,

-------
MSDGC, Contract Plans for the Site Preparationfor LandReclamation, Stages
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MSQGC, InylrgnnientalProtection System Report for Fulton County,,  111 Inols,
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-------
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Webb, S. J., Factors affecting the viability of airborne bacteria: "The Role
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absorption!

adsorptions


aerobic;


agronomy:



anaerobic:

aquifer;
bacteria:
berm:
benthos:

biochemical
oxygen demand
(BOO):
biota:

B00§ :


calcareoust

catIon i
                 GLOSSARY

The penetration of one substance  Into or through another.

The attachment of the molecules of a 1Iqu'd or gaseous
substance  Into or through another.

Refers to  life or processes that occur  only In the presence
of oxygen.

The principles and procedures of soff management and of field
crop and special-purpose plant Improvement, management and
production.

Refers to  life or processes that occur  In the absence of oxygen,

A geologic stratum or unit that contains water and will allow
It to pass through.  The water may reside In and travel through
In-numerable spaces between rock grains In a sand or gravel
aquifer, small or cavernous openings formed by solution In a
limestone aquifer, or fissures, cracks, and rubble In such
harder rocks as shale.

Any of a large group of microscopic plants living In soil, water
or organic matter. Important to man because of their chemical
effects as I.; nitrogen fixation.

Refers to a narrow ledge or shelf used  to control the runoff of
water from a field.

The plants and animals that inhabit the bo+tom of a water  body.
A measure of the amount of oxygen consumed In the biological
processes that decompose organic matter In water.  Large amounts
of organic waste use up large amounts of dissolved oxygen;  thus,
the greater the degree of pollutlon, the greater the BOO.

The plants and animals of an area.

See "biochemical oxygen demand."  Standard measurement Is made
for 5 days at 20 degrees Centigrade.

Resembling, containing, or composed of calcium carbonate.

A positively charged atom or group of atoms,  or a radical which
moves to the negative pole during electrolysis.
cation exchange
capacity
(CEOi         the sun total  of exchangeable cations that  a  soil can  adsorb.

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co11 form
bacteria:
col I form
organism:
con post:

cur te:

deciduous:
dissolved
oxygen
(O.O.):
dredging:



ecosystem:


effluent:



eros Ion:
Members of a large group of bacteria that flourish in soil.
In the feces, and/or Intestines of warm-blooded animals.
Including man.  Fecal col I form bacteria enter water mostly
In fecal matter, such as sewage or feed-lot runoff.  Col I form
bacteria apparently do not cause serious human diseases,
but these organisms are abundant In polluted waters and they
are fairly easy to detect.   The abundance of fecal collform
bacteria In water, therefore. Is used as an Index to the
probability of the occurrence of such disease-producing
bodies (pathogens) as Salmonella, Shi gel la, and enteric
viruses.  These pathogens are relatively difficult to detect.
Any of a number of organisms common to the Intestinal  tract
of man and animals whose presence In wastewater Is an  Indicator
of pollution and of potentially dangerous bacterial  contamination.

Relatively stable decomposed organic material.

A measure of radioactivity.

The term describing a plant that periodically loses all  of
Its leaves, usually In the autumn.  Most broadleaf trees In
North America and a few conifers, such as larch and cypress,
are deciduous.
The oxygen gas (Og) dissolved In water or sewage.  Adequate
oxygen Is necessary for maintenance of fish and other aquatic
organisms.  Low dlsso.ved oxygen concentrations sometimes are
due to presence, In Inadequately treated wastewater, of high
levels of organic compounds.

To remove earth from the bottom of water bodies using a scooping
machine.  This disturbs the ecosystem and causes silting that
can kill aquatic life.

An ecological community together with Its physical  environment,
considered as a unit.

Wastewater or other liquid, partially or completely treated, or
In Its natural state, flowing out of a reservoir, basin, treat-
ment plant, or Industrial plant, or part thereof.

The process by which an object Is eroded, or worn away, by the
action of wind, water, glacial Ice, or combinations of these
agents.  Sometimes used to refer to results of chemical actions
or temperature changes.  Erosion may be accelerated by human
activities.
                                   10

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evapotransplratlon:

               Discharge of a water from the earth's surface +o •'•he atmosphere
               by evaporation from lakes, streams, and soil surfaces and by
               transpiration from plants.

fecal
conforms:     See "Col (form Bacteria."

forage:        Food for animals.

gob:           The refuse or waste left  in a mine from which coal has been
               worked away.

groundwater:   The supply of fresh water under the Earth's surface that
               forms a natural reservoir.

groundwater
runoff:        Groundwater that  Is discharged  Into a stream channel as spring
               or seepage water.

leaching:      The separation or dissolving out of soluble constituents from
               a rock or sediment by percolation of water.

lagoon:        A shallow pond where sunlight, bacterial action, and oxygen
               work to purify wastewater.

littoral  zone: Of or pertaining  to the blogeographlc zone between the high
               and low water marks.

loess:         A buff to gray,  fine-grained, calcareous silt or clay, thought
               to be a deposit of wind-blown dust.

malodorant:    A substance causing bad odor, stench.

mho:           Unit of conductance reciprocal  to the ohm.

mil I(equivalent
tmeq):         One-thousandth of a compound's or an element's equivalent weight.

normalIty (I,e.
normal
solutlon,
abbr.  N):     Measure of the number of  gram-equivalent weights of a compound
               per IIter of  solution.

percolation:   The downward  movement of  water  through  pore spaces or larger
               voids  In soil or  rock.


permeability:  The property  or  capacity  of porous rocK, sediment, or soil
               to transmit a fluid, usually water, or  air; It  Is a measure
               of the  relative  ease of  flow under unequal  pressures.

-------
planktonlc:    Of or pertaining to plant and animal organisms, generally
               microscopic, that float or drift  In great  numbers  In  frash
               or salt water.
polychlorinated
blphenyIs
PCS's):
runoff:




Silt!


slltatlon;


sludge:



slurry:


spoI  I:



strata:

stratif icat Ion 5
A group of toxic, persistent chemicals used in transformers
a.:d capacltators.  Further sals or new use was banned  in
1979 by law,

Water from rain, snow melt, or Irrigation that flows over the
ground surface and returns to streams.  It can collect
pollutants from air or land and carry them to receiving watsrs.

A sedimentary material consisting of fine mineral particles
Intermediate In size between sand and clay.

The deposition or accumulation of stream-deposited silt that
Is suspended In a body of standing water.

A semi 11 quid waste with a solid concentration in excess of 2500
parts per million, obtained from the purification of municipal
sewage.

A thin mixture of a liquid, especially water, and any of several
finely divided substances such as clay particles.

Oirt or rock that has been removed from Its original location,
destroying the composition of the soil in the process, as with
strip mining or dredging.

Beds or layers of rock having the same composition throughout.
strip
mining:
               Separating Into layers.
A process that uses machines to scrape soil or rock away
from mineral deposits just under the Earth's surface.
supernatant:   Floating on the surface.
suspended
solids:
synerglsm:
Undtssolved particles that are suspended In water, waste-
water or other liquid, and that contribute to turbidity.
The examination of suspended solids plus the 300 test constitute
the two main determinations for water quality performed at
wastewater treatment facilities.

The action of two or more substances, organs or organisms
to achieve an effect of which each Is Individually Incapable.
                                     12

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terracing:


thermophlIIc:


topography:
toxic
substances:
trophic:

vertebrate:

volatile:
Dikes built along the contour of agricultural  land to nold
runoff and sediment, thus reducing erosion.

Requiring high temperatures for normal development, as
certain bacterla.

The physical  features of a surface area Including relative
elevations and the position of natural and man-made features.
A chemical or mixture that may present an unreasonable risk
of Injury to health or the environment.

Of or pertaining to nutrition or to the nutritive processes.

All animals with backbones, from fish to man.

Evaporating readily at normal  temperatures and  pressures.
                                   13

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Nam*

Jack Evan 3raun


Douglas Ehorn


Gregory Vanderlaan


Gerard Kelly



Joel Soden

Robert Cutler
Organjzat|on

USEPA


USEPA


USEPA


MAPORA



MAPORA

MAPORA
                                      LIST OF PREPARERS
                                     Experience
Project Assignment    Education      Years	
Project Officer/
Author

Project Officer/
AdvIsor

Project Advisor
Environmental
Scientist
Air Scientist

Senior Afr
Scientist
M.S. Olology)      5


M.S. Olology)      8
M.S. (Environmental  4
Studies)
M.S. (Public
Hea I th )
M.S.. P.E.
8


5

10
   (Some preliminary work on this Final EIS was performed by Enviro Control, Inc.,
    Rockvllle. MO)

                                        Project History
The Draft Environmental Impact Statement was published In June 1976.  Many unanswered
questions existed In that document and many comments were received during the public
review period.  During the preparation of the Final Environmental Impact Statement,
we have tried to Incorporate the many changes in sludge management regulations and
have made the best effort possible to Improve the quality of this document over the
Draft Environmental  Impact Statement.  Many of the new requirements developed through
the Implementation of the Resource Recovery and Conservation Act have also been taken
Into consideration in this document.

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APPENDIX A:  IEPA Miter  Pollution  Control  Permit
                    Ar-1

-------
                ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
                     WATER POLLUTION CONTROL PERMIT


  Permit Number:  1974-DB-444-OP                        DATE ISSUED: March. 7  1974
                                             PROJECT LOG NUMBERS: 3686-73,3687-
  SU3JECT: FULTON COUNTY - Metropolitan Sanitary  District    3688-73,174-7
                          of Greater Chicago  Sludge Disposal  175-74
                          Project  - Comprehensive Operating Permit

PERMITTEE TO OPERATE:  Metropolitan Sanitary District of  Greater Chicac
                         100 East  Erie Street
                         Chicago,  Illinois    60611

     Permit is hereby granted  to the above  designated permittee
to operate water pollution control facilities  described as  follows:
     The sludge transportation system, sludge  storage facilities and
sludge application  fields previously approved  under Permits I1971-DA-4"
S1971-DA-487-1, I1972-DA-215,  S1973-DB-1460-OP, S1973-DB-1460-OP-1,
§1973-08-1492, *1973-DB-1492-1,  U973-DB-1682,  U973-DB-1682-1, #1973-1
1752,  f!973-DB-2185 and f 1974-DB-45-COP.
     This Operating Permit expires on March 7,  1975.
     The Application for Operating Permit and  supporting  documents
approved by this Permit were prepared by Metropolitan Sanitary District
of Greater Chicago  and are identified in the records of the Illinois
Environmental Protection Agency, Division of Water Pollution Control,
Permit Section by the log numbers designated in the subject above.
     This Permit renews and replaces Permit Numbers f 1971-DA-470,
S1971-DA-487-1, I1972-DA-215,  I1973-DB-1460-OP, f 1973-DB-1460-OP-1,
U973-DB-1492, I1973-DB-1492-1,  #1973-DB-1682,  #1973-03-1682-1,
I1973-DB-1752, I1973-DB-2185 and 51974-DB-45-COP,  which Were
  READ ALL CONDITIONS CAREFULLY:     (continued on  Page 2)
  iTAHOAEO ronaiTlONj                         Plruunnf «m, u connnici.ox v
                                         I.  Turn iota b* ft Ovuiwm htm Ik. i».,«rU dun <*d MM
                                      .l««iw» UM«I «MM pu»i. IMC.I.NI.MI. M ««!.»•** OuH 1.111 kMb*M
                                      «ibn»ntd m it« iiw
       OlXIMf •« •*•*» 1H« CO«Mn(C1<«OM

       ^»l*-l> «.<•«•••<»> IK. C>
                                                  ti «>K«m»t mum «i HM irmmm iMrt« !«»•«<
                                            •* •••*•••«".

                                         •I  At IMM 90 ««v* ff"** I* IH* ••PMM^A «M* •! th* MirHUn
  This permit is issued in «ccord«nct with th* Illinois Envircmmontal Protection Act of 1970 «nd the Chipttr III XVitcr
  Pollution Regijlttiom adapted by the Illinois Pollution Control Board in March of 1972.
        * \ 1
 cctGrants c Tax,  Region II  t  III       Div.siON op WATER POLLUTION CONTROL
 Fulton Co. Health Dept., Fulton Co.      ..»:.
 Ed.  of Supsrvisora, MSDGC-R.Riirkus      i /•?'*?<.• 2-C*^>
                            K.KcI-Iillan   William H. Busch
                            J . Br axton    Manmnr. Par mit Section _

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                                March 7, 1974

FULTON COUNTY - Metropolitan Sanitary District of Greater Chicago
                Sludge Disposal Project - Comprehensive Operating Permit


issued for the herein permitted facilities.
     The Standard Conditions of issuance of this Permit are itemized
on Page 1.  (Special Conditions applicable are itemized below).

This Permit is issued subject to the following Special Conditions.
If such Special Conditions require additional or revised facilities,
satisfactory engineering plan documents must be submitted to this
Agency for review and approval for issuance of a Supplemental Permit.

SPECIAL CONDITION II;  Upon termination of the sludge transportation
activities, the Sanitary District shall be responsible for the proper
removal and disassembly of non-permanent equipment for which this
permit is issued.

The proper disassembly includes, but is not limited to, the cleaning
of the pipeline so no sludge residue will escape to any area other
than the properly permitted holding basins.

SPECIAL CONDITION J2;  This permit is issued on the basis that any
surveillance activity by the staff of this Agency does not relieve
the applicant from sole responsibility for establishing and continuing
a surveillance program for monitoring and detecting any discharge of
waters which do not meet the applicable provisions of the Environ-
mental Protection Act or the Rules and Regulations of the Pollution
Control Board.

SPECIALCONDITION §3;  The sludge transported to the Fulton County
site shallTSe"adequately digested and suitable for land application
based on  the parameters presented in Table 2 of the report entitled
"Quality  of Digested Sludge Suitable for Land Application" prepared
by tne Research and  Development Department of the Metropolitan
Sanitary  District of Greater Chicago, dated July 23, 1973.

SPSCIM;COHOITKai -Hi.  This Permit does not relieve the District of
sole responsibility  for the existing discharges .to the waters of the
State  which may have occurred  through mining activity or any other
past activity in this area, which do not meet the applicable provisions
of  the Environmental Protection Act or  Illinois Pollution Control
Board  Rules and Regulations.

 SPECIAL  CONDITION  jSt  The District shall maintain a minimum of  four  (4)
 feet  freeboardin  the  lagoons  at all times.

 SPECIAL  CONDITION  16;  The District must submit to this Agency,  in
 addition to the quarterly reports currently submitted, a monthly report.
 Tha operational information  to be contained in the monthly report must
 be satisfactory to the Agency  and the  report must be submitted in
 triplicate within  20 days of the end of the month covered by the report.


                            A-3

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                                March 7, 1974

FULTON COUOTV - Metropolitan Sanitary District of Greater Chicago
                Sludge Disposal Project - Comprehensive Operating Perr


SPECIAL CONDITION 17;  Op to date sampling data and operational in-
f or mat ion to be used in the monthly reports mast be available for
inspection by this Agency's personnel at the Fulton County Site.

SPECIAL CONDITION 13;  If for any reason the District abandons this
project, it is required that the sludge holding basins be emptied of
sludge and the sludge be disposed of in a manner which will not cause
pollution»

SPECIRL CONDITION f9;  The effluent discharged from any retention bas
approved under this Permit must meet the applicable effluent reguirem
for discharge to the waters of the State as required by Illinois Pol-
lution Control Board Rules and Regulations Chapter 3.  The point of
discharge to the waters of the State is considered to be the overflew*
structure of each of the retention basins.

SPECIAL CONDITIOW ilOi  This Permit is issued with the .condition that
the following contaminant concentrations are considered to be back-
ground values and the numerical effluent standards shall be considers
met at the designated effluent sampling point described in Special
Condition §9 when the background concentration plus the allowable
regulatory concentration is greater than the measured concentration
for the appropriate parameters
                       Total Suspended                    Fecal
                       Solids                 BOD         Coliform
                                                              FC
                                                             100 ml

 arithmetic
 mean                     61.7                 2,75

 std. dev.                 87.3                 1.48

 geometric
 mean                      -                    -             94.3
 SPECIM. CONDITION Illi   In order to provide storage for the capture c
 a 160 year frequency storm,  the District  shall remove waters from the
 retention basins as soon as practicable after a  storm.  This Agency
 shall require that records be kept of precipitation and the approxim;
 amounts of runoff pumped back to the fields or discharged and  that
 these results be submitted along with the monthly operation reports.

-------
                                March 7, 1974

FULTON COUNTY - Metropolitan Sanitary District of Greater Chicago
                Sludge Disposal Project - Comprehensive Operating Permit


SPECIAL CONDITION $12^  The District shall maintain at least one
control plot on which crops are grown without the application of
sludge in order to provide a continuing source of data regarding
the runoff from such fields.  The runoff from the cont.roi plot shall
be monitored and the results submitted to this Agency as a part: of
the monthly operation reports.

SPZCrKL CONDITION §13;  The District shall restrict its procedures
of land application to subsurface injection or ridge and furrow
application whenever practical.

SPECIALCONDITIOtf 114;  The District shall monitor the metals content
of the cropsharvested from the sludge application fields and shall
submit the results to this Agency in the monthly operation reports.

SPECIAL CONDITION 115;  This Permit includes the construction of the
supernatant piping around the sludge holding basins*
                               A-5

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                              tooeniix B
                  Ccmraents Received on the Draft
The following pages include a reproduction of the written coaaents
that wete recsivei on the Drift EIS.  Many of these contents havs
besn incotoocitsa into this Final EIS,
\ooendix C contains out taaoonsas to these cownents.

-------
Tjku
v       •
                   J Wf&UIN »« HUf lSt**0 l
 Auguat  IT,  1(76
 Mr. 0«ry Schema 1. Acting chief
 planning Branch
 legion V
 Mitel It*tee Environmental Protection Agency
 3JO couth Dearborn Street
 Chicago, Illinoi* 60604

      lamark* Concerning Fulton county Sludge Diapoul md Land
      ~  "  »tlon Draft to th* Public Bearing - Auguat IT. 1976
 Aa president of th* Illinoi* Wildlife Federation,  and having been
 involved with tha Metropolitan Sanitary Diatriet of Greater Chicago'*
 deeire to diepoee of leg aludge ainee NBDOC** first attempt In 1967
 to aogulr* land in Kankakee County, Southern Mill county,  ana Grundy
 County, I would like to make the following non-technical and non-
 aciantific remark*.

 1.  The university of Illinoi* was awarded a grant to conduct a
     •tudy in Hill county to determine the feasibility of tha plan.
     In ra*dint tha draft I do not find tha raaulta of thia atudy.
     TMl (tody ahouLd ha** baan uaad ao that tha facta gatharad
     on a taat in Illinoia uaiag tlodqa fraai USD, rather than a
     •tudy in aOBa othar atata or county with aany  diffarant
     charactariatica.

 2.  It ia a aattar of raeord with tha Pulton County Board  that thia
     proarav ^^^ to ba a fiva-yaar axpariaMntal prograa). and that  if
     than wara any undailrable affacta on tha anvirona in  thia araa,
     oc if there war* any ill affacte on tha •nvirorment, tha proqraa
     weald ba diacootinned.

 >.  It ia a aatter of record in thia draft that it ia difficult
     to aa in tain «p»ality control of alud9e vhen «aate vcter traat-
     •ent plant* are aubject to tha diapoeal of heavy awtala,  and
     all af UM oyproducti of paatlcida* and herbicide*, and all
     the net of tha nodealrable aad long-livad •an-iaada chaaticala.
     Indnatrial vaetm cannot b* elialaated froai KSDOC collaction
     •yttam.
                       NAllONAl WIUX.IM MOEMIIQN AFflUAIl
                                                                                      :,

                                                                                      6.
                                                                                      7.
     It waa auggaated by the writer at ipacial meeting* by th* KSDOC
     that they uae the 30, 000 acree of laud in the Cook county araa
     owned by tha Cook County Foreat Preeerve Diatrict for eludge
     diapoaal.  J feel thia i* *till a viable consideration.

     I have vieited the pulton area and aai faniliar with tha operation.

     Run off Ircei the application araa ia docuawntad aa a proble*
     to tha natural watervaya in the area.  The effluent fro* thia
     ar«a awat neet the avndatc* in the USEM Ragulat iana ,  A«
     • tatcd on 1-9 the concentration* of certain avta'la and othar
     cheaiicala have exceeded th* Regulation*.

     laee line ground water ahowad exceaaive concentration* of
     di**olved aineralm. three tiaca th* U.S. atandard.  Kith tn-
     creaaed application the condition can ba expected to incraaaa.

     Piah and wildlife in thi* area have not been itudied through
     the National Fi.h and wildlife Service, and a* atated on 1-10
     it can be expected that fiah and wildlife will pick up toxic
     aubatance* through the food chain.

     Of Major concern ftre the concentration* of heavy Bjetala, air
     pollution froat aludge Malodorant*, turface and ground water
     contamination, and huaiaji health effect* fro* pathogen*, a*
     documented by actual violation* of our enviro
                                                                                                                                                ,
                                                                                                                                         ental (tandarda,
)C.  Run-off baiin* that were to have been con* true ted and to have
     controlled the 100-year atorra were not te**ible,  *o no run-off
     control i* preaently in operation.  Thu* the nutrient level*
     in receiving (treaaw will cauae evthropication and will threaten
     aquatic life.

11.  Nith uM coabination of natural heavy *wtal* and  aludge leaching
     it* heavy aatal*.  an increase of the*e natal* can be expected to
     increa** to a point that uae of local wella will  be prohibited.

12,  Ua* of a forage crop will cau** a «ignli leant problem in animal*.

13.  Effect on bud life-eating worm*, who will h«v« high concentration*
     of cadaiium,  can be expected to be effected.

14.  ** atated on rage  125 and 126,  .lodge atandard* cannot be main-
     tained or a**ured. and aa *tated a procedure ehould be implemented
     to guarantee only  good quality iludge to be ahipfwd to Pulton
     county,  and elimination of direct drawdown of the digaeter at
     the N.s.N, Plant.

 In concluaion and enamiiry :

 The Prairie  Plan and Sludge Diapoaal ahould not be put together >• a
 plan.

 The Pulton County  experimental plan ahould be monitored by an outatde.
 independent  teeting laboratory.

-------
This E1K should not be accepted until after a full five-year
experiasintal  period.

Evaluation  of this  document indicate* there are  more detrimental
items to be considered than beneficial.

Strip mine  reclamation into usable recreational  land doe a not need
sludcj*. ai  i* documented by the 2S privately owned recreation areas
in  the •raidvood-Coal City area of Will and Grundy counties, catering
to  50,000 msmbers.

The National  fish and Hildlif* Service should have some  input into
thia subject  because of the far-reaching  implications  in the wildlife
food chain  and thai  nutrients that  enter our stream*.

The tIS should be ratitled and exclude the land  reclamation concept,
because the addition of and concentrations of heavy metal* could mean
land destruction.

Respectfully  Submitted,
rrajnk ». Gostschel,  President
Illinois Wildlife Federation

ro/ij
                                                                                                                 COUt&l Of AGIKUUUtf  5ff*lf«MNI Of
                                                                                                                                        August 16, lift
                                                                                                      Mr, Gary Scheniel, Acting Chief
                                                                                                      Planning Branch
                                                                                                      U.S. Environaenta] Protection Agency
                                                                                                      Region V
                                                                                                      210 South Dearborn Street:
                                                                                                      Chicago, 11  eCHXH

                                                                                                      Dear Mr. Scheaxcl:
                                                                                                      1 siibeit tlie following coamenta on the Craft riiflrnneanril  lepact Staceeent
                                                                                                      for Sludge Dliposal and Land leclautton in Fulton CouitY,  Illinata.  Then
                                                                                                      ace concerned prl»«rU> with Section  It lackfrouai and I»[toductloa.  Section
                                                                                                      II qua llb«r«lly from A«iimc_y  fact SneeC SM-29:  Ut 11 Hat lor of Senate
                                                                                                      Studse on Aarteult»ral Land.

                                                                                                      THtr* are a few direct quotation!  ulth Ene eoitrce acfcaavleaead.  there ar*
                                                                                                      •any earagraelia la Section [I vltn worrilat quite « taller to chat In Fact
                                                                                                      Sneec SM-29 of Milch I ea one of the  author*.  Thi* fact Sheet uai revt»4
                                                                                                      in February 1*?6 to correct *eee error* Itt T*bl* 1 and to Include li?5 field
                                                                                                      data of Vnl«araitjr oi Illinois research.  1 ae attaching 2  copies of the
                                                                                                      ffebruary 19?e varateu end have aarltad the paaas in Se«tie«t  II of the draft
                                                                                                      tIS «iher« worillnl is itnllar.

                                                                                                      Oa* error in cserlai frosi M-2t us* noted.  In the last paragraph on page
                                                                                                      11-1 the following appear*;  " ..... •  rate equivalent eo a aooera izrigation.
                                                                                                      ...... *  The first paragraph of SN-29 states:  K....e rate  equivalent to a
                                                                                                      eederate Irritation (about eve inches) ....... "  If the author, of the US
                                                                                                      ead* Cns coasclotas sybstitutton of "Baden*1* for *fsx>d»rac<*' , they saoyld ba
                                                                                                      snrs apeclflc ss Co vhat is the eaoiait of a "solera" irrigation.

                                                                                                      Pag* II-J of the IIS state* In the neat to last paiagraph:   "With iludge
                                                                                                      application, there la the option of going directly into row crop production
                                                                                                      after th* levdllag of atrip nine  apoll hank*."  Page 1-13  itate*:  "The
                                                                                                      future fertility of cnas* fields caa  be sxpectad to Increase significantly
                                                                                                      with the continued application of  sludge, possibly ejHng row-crop production
                                                                                                      economically feailblt.'  One of thaas ststeaents i* fulte poaltlfe. th*
                                                                                                      ather conditional.  Ef the page Il»S  atatssent wars cheated to reed:  " .....
                                                                                                      there eay be ch* option ---- ,,** It  would t»* eor* nearly correct aad the two
                                                                                                      would he Sjar* consistent.   I 4o not believe it has y*c been »Teannarritid
                                                                                                      that row crop production on th. strip aiaad land* receiving sludge is
                                                                                                      economically faasllil*.  If there have been aatltfactor; row crop ritld*
                                                                                                      .her. Ireshly levelled apoll benka hevs had sludge applied,  I *• not aware
                                                                                                      of elicit.   I believe chie will be established If "normal" iprlag wsathsr is
                                                                                                      experiencad sad'  If edequata levela of crop end soil einagseanl ar* achieved.
                                                                                                      So far as I *• aware, this il Mill ahead of us, not behind us,

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**•* 2
Mr.  Gary Schtnz«l
        1*. 1976
                                                                                                                         MUCKS   CCUfOi Of M*ftlCUt,lU*f
         AGIONOMY  FACTS
On p*§* I~l  it  1* mtmtud that 45.O06 •€!•»» or &6Z  of  tt># land in Fulton
Ca«yBtjf h*a be*B «*lp-»in*d.  On §NK§* IV~H. atrip nined lands are reported
Co b* 21,600 «cr«i «»recl*i»*4  and IS, 100 ***«« r«£ laired, or * total  of
37,100 acr*a itrlpptd  fa tin county.  TaHa IV-22  Hats local county  land
ft* 561.152 *cr«»,  ftMH  1 co»put» S.OI or 6.61 of  th# coumy  hag been
•tripped, depending cm which aeraagt **|ur« 1* uced for »t ripped lands.

On pag* II- 50  It fc« stated that  KSDCC produced 1250 dry Eons  of sewage
•ivd|« 9*f <**Y  In M7J.   AC I he  hearing  in Canton,  I  b*ll«»e  the MSDCC
•taCMMet indicated J50  dt/d.  The NSPCC draft docuwent , "Envlroo««ici 1
AftMCBBMEa  of  th« Prairie Pl»n"- Fulton County, II line. U (no d«t€
lwlic«c*d( prob«bl]F 1973) states la tti*  iotrodoction  that NSDCC collecc*
120 dry toa» of organic  «oiidc per si*)*,   CaBMla*iaKt-i  Alter  Ira Ccmpust
Sei*mc* N»y~JuBfl 19 ?5  r*port« 5|»1 dry tons of s^Hda  produced dally.   U
«oul4 IM lutlpfui tf HSDCC could  b« nor*  c«n»l» te.it  in reporting how mich
•ludc* IK produc*» |wr day.  la  the 1250 too* ptr  day reported In the  EIS
tlM eorr«ct  fiturt for tbi prevent ti«tf

I l«>p« tlMME gueaiiai'ita  will b* useful co  you in prep*rin§ the  final EIS for
cba fit It on Cawaty Project.
*/
y
                                       Sincerely,
                                       H. D, Thornt
                                       Exccftilon Agroaoaist
          .kiju.ii-w rr.v,.->,.- K, prm

          Miluii^nirr i> J lr»«p rum.
                                                                                                                                 Jiifur, thlorin.'. carhoiiaif, ^i.i mill  *j|t*  ITw {iriiaM^ |»'ftt-
     T.  B. ain..li
     1.  L. J«M»
     n.  u. ivtrrt*4ft ils ciwct
                                                                                                                                                         fo
                                                                                                              awn] to dry ttwri-. H liquid sludge i« incarporited into the sail pra«' after appiti*tio»i (o the
                                                                                                              ace or if  it is injected directly into th* soil , »M of th« *^«i,» nttr^«r is -J^«i-h«sf hv t>»c »
                                                                                                              he wanniuH nitrogen is thuiged tntc the nitrate for* in the wil, where it MV he •bsortwil by the S.
                                                                                                              r >wr bv subject  to I^*thn^  TTic organic nitrogen in >lud^r wi*l tvr •uirraliznl hrfore il C«n Ew •A
                                                                                                              Utesl by crops.

                                                                                                              ttiwvrsitr  thcr»  S**«jjc ilodgc
                                                                                                              os-e* Most  of it*  wMDrifMn ttttrag«n ui fto dryifm process, so no»t of tM- nitrogen ,n Jrimi •vlu^i* t~
                                                                                                                        ? of  HiliK>i& ct^hluc'ied r*-i*arrh with Jn^i it-»agi- *,l,iti/r it"  * nmtrr af vejt^
                                                                                                                         -xM^ /**'f  ^s^#t -ff-Js, isiiMMl ID  (159,  sutn "RrsylU to 4jTr imJKdie thdt .

-------
  Bpv he eWW" te*l If*  i •*»:•*- turd vi. I'l i ^^fisvS -.ii"itl ir 11> tip -«> <•'-I.«(.,<•-! *-i I i  f ,11 • i -H  !«•. t
  tra.fr.   if.is ftintKvM*  it.jt  rait«  I.-IA-  ,,»»u,t«. of »J.:J^c  M,,.!.: t   ,  :,it. J  .- i  ;.  •• ,,ort
                                                                                                                                                                            the aannr of nutriams
too to i.ooo
 HJ to y»,aoo
HO !0 I'.Mil
I0Q to 14)0
 IS to 1,000
                                           5 to i.OOO
                                         100 to 10,000
                                           1 to 300
                                          SO to MJ.tiOO
                     ...,,,,,..  £i to l»0«a

                      Ifafy a«cor3i t)§^~so«r^*T^*'tliia«'m7^^
                     long pcfiods mtf be cenBiik'fa$ly lo«r IB


      _f  sludge* aty contain relatively large quantities of »i nor ml trace i
     c- of fnrsc vltjwflts art essential u* plant and JHIIM! nutrition,  but  nearly  .
                    , copper, nickel, catfciu*. wcfCMry, and lead «**  oec'
' affpct  plantft and Mils. fb» availability of a anal in the soil i*  m~
 at pit,  organic witter, content af ait*er •rta.lit, type of claj- ninrful,  «
 *sri«ty « crop fjPMt, and Many other factors. flw aMarption  of •et.il>
 Hmtml pM, a* k#t*i*g tlw pM n#»r ? will help prevent profelcua (Ml night  arise  fron s-s.cfsi.ivp a»t
 i* sludge.
3
1
e.'i
•
?.(Mx)
s.ooo
l.ooo
iou
lye
l,;l
1,000
J
i,(#0
*00
rJctorT-MuJV
$*.•« content ,
trace L-lciwnts,
but nearly j) 1
occur iti n*Mni
influenced hf
I, OElOii *Si'h.
(rft
^(1
IS
M
4
la
I
1
0,i
fl-.i
2
Ii-,<
b
9 »
"s W FJ la" ^.tdi agf

;i-v iik.lic.itnl in l.il.l
1 Ct« be tovu at *«•
"ilic? suffn inn to
«otJ tM^>pertii>s »i».
JTLSS^t'l'nT ?
.jRlNr large HiWllt a< water £tat ••*« be haniled In oraV-i  to provide rhe plant nutrifnts. required f=ii a
              '        	•'-tit*tUMft en Uke u** Of  liquid  s-Iirige and oo  fhe «-thotiN of  JfipHt-iI son-
       	„,	,	J BCfOMtt solids «*B hi  lyMiled a* *  lisjMid, iwnped througfe pipM, anJ carried
       I tr«t», railroad tank cart, ami tuifas.  IHere are «*e luitt^tiom art the typn of puaa^t «s**l;
           illy,  ftludgar CM b» hawflarf by lh» MMW type* of eoulparnt as used fot £i«uiJ annurc. If sludge
 |i ttarwl in tnjoom or tanJu, solid* Kill  Mltli IB tiir botlon and special provision for aj it it ion will
 he n»JiJ in «rd#r Co ptaap it fr«M the latPM agnin. Sludgr* with tore than 10 percent solid* konra a wry
 •iff* vi*C«ity, pnd apettaltxed n^ipMent Milt bf nee for mtro»-r'n  (i»l
   Mgtanai Mill bt ncMdr4, In a*titi SlMlgc* will « **!i* c«MMHl ill e«e»* af nheut I |*rcent will dry tauite slowly on tar
                                                                                           aiksJ per application

                                                                                           liquid sls^few tftft be spread on  thr sot! by Uttfc Irwcks  IV distance cf site Hiul Mi SOM obvious lu
                                                                                           tions  bec*»« of the Urg* wtifM ei *«ter fe b« handled.  !n sane Urge scale operation* now ynderw
                                                                                           IlltfiuiS  sltitee s* l*aii imorporated unto the soil uMnhaiely.
                                                                                                                                sludge to s
                                                                                                                                                             •  sure i he  runoff uter doei not i
                                                                                                               m term of  inches of liquid i
                                                                                                                                    *ppuum&* wits
                                                                                                                                                                                      is for rein or irrigation *

                                                                                                                                    lloc'tonsl on each acre co*er«d.  If  the sludge h«  S percent K>ltd*. J ton* of dry solids Milt  1
                                                                                                                                    each a^rr by each I inch ipplicatiun. At  S-percent nitrogen and i-percent p*»*|*iuru>.  this  »iuJgv *ill
                                                                                                                                    Si43p!v 3«e pounds of total nitrogen  and 1M pouml* of phosphDrus per acre.  II  the sludge had S  prrcant
                                                                                                                                    stjliJi  tlw l"t«.'h Uyer over  an acre would still *eigh about IOM trtfis, b«( would tontain S tans of dry
                                                                                                                                    folids aad lufnisft S©0 poufkij  of lotal nitrq|f*i ana 500 peundi pownds of total phosphorus |>er acre
                                                                                                                                    Mut «pplic*t


                                                                                                                                    tatuayj. again,
                                                                                                            r»te,  repeated ^*r liter year, wnuU be r»ee4eij te prwiie the nttrogE
                                                                                                            |> of com on  Ultnois KHJ*^
                                                                                                                                                 ,    ludge with 1 p»rc»mi  wluls *nwl on  th* soil *url
                                                                                                                                                                                                              I  in Table  1. A  1  indi livi
                                                                                            a perwit
                                                                                           Me «iiht expect only half the  amxum ttitfoem to &e retati«d. If the sludtt is jnjieaed mio  the *oU,
                                                                                           •irr mtrofen will  be saved;  if  it ilrie» co^lettlr an the surface before plc*tng,t  Eess  -ill  be *a*ett   In
                                                                                           wUitiun 10 the wBtKiii* niirof«n, «buu( a fourth of thr ftg«nn, rttiivien t* •inrialiunJ r«th fnii «iid
                                                                                           thus becwr» available.
                                                                                                                                              t at *li»iff apf
                                                                                                                               Total  !W pounds of N avaiiafelc per acre

                                                                                           Under a high level  of aanagcamf,  2  imrhe* of this sludge would probably be necttadi tfic first  rear and  *Mti
                                                                                           pounds of mtrofen  pet acre would  b* available. In succeeding years, increasing anoums. of  nitrogen will
                                                                                           be available froK the .'inch application. becaiiM the organic nitrogen in the s Judge added  the  first war
                                                                                           will comintM to deecajpo** »frtr  ft» y«*rs of *uc£e«fivc and equal annual applicaiiofl*. ihe aacurtt of

                                                                                           added m th* sludlgc-  Tnus, 1  indi  of surf* sUdg* Mould providr*
                                                                                                                        HO i 0.5 •  bt pound* of aaaagmyB M available
                                                                                                                        1*0 » 1.0 • 1*0 pwawH of organic M atniilabla
                                                                                                                             Total IHi pound, of N available per acrv

                                                                                           CaM&fx(iantly, iftif (i*e v*»r» of  apfpUcation. otUy 1 inch ptr y«*r »«wld be MWted.

                                                                                           If sliaige of the composition  Iwlicatad >• Tafcle 1 I* applied at th» r»l* «f 6 dry to«* per  acre, «2
                                                                                           pound* of l^| Ci*e^*te| «qM*»»l«Rt to a**rlr I.tW pounds of ** pettait superp^vp^te  and M} pouMH
                                                                                           of ifO (pot*»hi ocr acn will b« addwd. Ifcts t* likely to be «or* ph*»|3h t«« af tH> -laical" sludwt par acr«  So It Mould
                                                                                                  Alt if mmaBl application r«t« art luoiMkl to [to** wif dcicrt ta provide rMtrt

-------
                   s  tu be Mil
IV imiMUM rate at fcbieH a
    l*Fiirw f\m\ jtn
  ?l, jn*i*i|xii.Hi|t
    * ifKlwJiWjt a wet  if

           (rouliJ t«atvr
                                 Mia* in i-i'S,  Ihc s
                                 vi iif slui^r u» MC!
                                 -o^lit in »iJ n*«wr.
MeSr, the i.lfe, long-trim «vi*l!


llon'Mir* for \lutfL- an ajiriculti
jeinc u«*l. TM* »n»tv«it
            of th* l
                                                                   tm-iH plant
                                                                    *  10 hr
we Jifffrrnt pree«0yr«.
mulll with lf«l
taama find «»
yictiant* a*d M
                                                    jeriod of ti»t,
                                                      JM/ fr« one
                                                                             «x>th,-r,
                                                                                             l.*.-i .
                                  this »**fl cdf«ri*
                           ,  ljhur»tui (•» wr *1*° «*** d*ff«-r«iil ataii^tHMl  tr««t»i.itts wl .iiht^si" J.tt
                       •TithHtt ic  MNITS ««d ilindard de-viitions. othei> (tmapirit.' MMIU and traikLirJ itc
                      ,  the •Miin w pereent v«Iiie will U usnj ** * m*tt,  tt«r arc not sUicti} vu*
                                                  ion.  r~»in,  fro. It to IS ««»o««l pc. KTt.  Sli«l|t
CM* «I«U»
      "
                                                                     t «f .!»(«•»««. Tkit ,.«!. I. «
                                                                     c —net.
                                                                                                                                  of th* surfmf soil  hca  hewn  raised by art Mount irla(*d to !*w <|u»niil> o( sli«lg« *ppli*ti  the p»*c**d!i»t
                                                                                                                                  ^*ar- IHe a«J? *?i!!«%• -p, li.Jti'Ji of S' IPEIS per KR in 197JU »r I9?S, ho«rer. th* . NM d|5««iB«r«i, the
                                                                                                                                  -rail pli «3rtJ|ip«J trui S.G to 4-9, foUowtr* iJw tfiptkilion of 16 ?S tnthrs of ilufe*' durinj tte fint tw>
                                                                                                                                  years, CansttftvnUy. Itmttane m* adbtod in fall of 1978 at r*te« calculitad to rat^e thr u>u pH to it
                                                                                                                                      s, the furrows wr* irrsj«tcil MitJt  liudfe  tn the **•* «iwi*r prenoalT dnerlfewt for cefu.  Ml
                                                                                                                                 plots received i broarfcasf  ^>ltv*tian of ?4fl pnund» of l?0 per *cre per ywr.

                                                                                                                                 In 19??, a fcwen ttepresiion of  loytwai}  irawtli MS noted in the plot* with the fu§h«.t rate of  *It*%e.
                                                                                                                                 The probloi MI «Df* levere on f»lot*  r«ceiyim «R adhittioul Z«0 pouds of P*OS per .civ  CofUHK^mtl/,
                                                                                                                                 only am *li«lf* ^pliciittm «•*  m4#  that yeet - »*>«|*oru« lomcitf *mpt&m Mre vtMklr «W the s*c*
                                                                                                                                 pl»onj« csnttNit of (iist«* indiv*ied th*t tM* wts the Mjor proklm  bic«ss soluble salt* "*r«  »l»o fp«*i
                                                                                                                                 tu be present, no doubt ccmtrtbuttnK  to  the profeUw

                                                                                                                                 Mhen the «*c«» »lu wr«  Iwched oul by r*tnf«ll, the pho*iitlC'rut ttuiiity probJM *»* «llevitl«4  Tie Ids
                                                                                                                                 on the higih *l«J^c plat i«covcre4 in  1971 uil slurfj* ^pltc*t*™a u*rr rciuMhl, bui tnly an ploit r«rei¥i»^
                                                                                                                                 »4iliti«wl |rfios|*orws («rtiliz«tian   Hi* pte^ihcnis tojicity tm^ianft «ppe»f*d only *&**! r»tt*  NMrJN hi§h»r
                                                                                                                                 than tho** nee^Ki to supply nitraf^n  or  pAojphems for tht cre|* ted b
                                                                                                                                          -iv« of the thirteen inches of sludfc kpftiiwl After twiinreit,
                                                                                                                                                                            wJdn>)  frs* j*M*9* SJu
                                                                                                                                                                             ••***ffli ONOCW MNUT
196.9 .
HJO .
1971 .
1»7Z .
\sn ,
1J74 .
       ,  .  .  ,  ,  29,S
       	22.1
       .  .  .  .  .  SS.T
       .....  22.1
 ,-..,,.,  II.»
 	  .  .  36,9
ftti *ver^p!  .  .  29.9
                                                                                                                                                                    Z7.I
                                                                                                                                                                    U  3
                                                                                                                                                                    H.I
                                                                                                                                                                    15.S
                                                                                                                                                                                    ».t
                                                                                                                                                                                    Jl.O
                                                                                                                                                                                    *2.3
                                                                                                                                                                                    JO.9
                                                                                                                                                                                    2S.7
                                                                                                                                                                                    4».7
                                                                                                                                                                                    11.4
                                                                                                                                                                                                 <7.6
                                                                                                                                                                                                 51.5
                                                                                                                                                                                                   i.l
                                                                                                                                                                                                 29.!
                                                                                                                                                                                                 31. S
                                                                                                                                                                                                 4S.S
                                                                                                                                                                                                 54 1
                                                                                                                                                                                                                     n.9
                                                                                                                                                                                                                     is.;
                                                                                                                                 miter i*s Applied «t tnc MM nte «iil tiflc ** the MUiiaa tludg» §p|ilu'*tion.
                                                                                                                                 "fiwe of the thittMM l*-hei of ila^e ifftiiag •ftet Inunnmt.

                                                                                                                          to C«H be MMR at T»itl** S ind 4,  rhs iluc^e «ffiJi«,«tiQRs *?er*ffti IS tani pet «cre per  *
                                                                                                                          thniifftt itn *i the »i|tfie:M f«* of ippHetti.*, tto pte*phor«* tiMKitj *>^to«» or ywld
                                                                                                                          found iAwn «lt*ig* »p|iiic»tio»* **r« o»»-fourth thi
                                                                                                                          fertiUter ms •n>U«d,

                                                                                                                                 i yt«14s an plots irrif*t*d  with *wll Mter IKK
                                                                                                                             Kit-plot field*, the imson is asiaiaMn. thti »* not topical ef the mpBM eip«Er«d In
                                                                                                                          pMian ie Illiaoi*, tut the rwtm for thsa eirMK {whtvior has not y»l M«i *a«d.

-------
 I.  J
  ,,J
 ,.  i
'.jr-i
          ,  i, •'•  i,. H'>.   I'litl* i' . IV  ;   . :  '  1  'i ! "^ I. i I .1... i t n it.
          V, !,. 1  Is 1.1 1-T4 j-il /"<1  K•,:.•!-. n, 1-.71   h. . u i . .;., jit. it  .
          -4  , :  ji.  .vii;*i'i. l\,r il j «.r  -': .   i     r. 4.  ^  .     i rJ/  ,  .1 J-. •
        MVKI'i'AL lOBG-ILW: BEKtflTS
       i
j."
                       ^,1- ..... I- nmtu- il.iiK  1 ...  .n n.,-,nit  it

         ikn .  ^o.l  types in 11- J i  '< •  M.A'u i ».  In •  nwi. j e> . 11
         12   to iM-iiwn )4»er IL t:*-   ji«J  Utt -»t  1.1 it...  fK-u.ci
                        diK'.lly i-  i ,'iJ  r i  tt.c ju..>i*it i. f ^liJm
        Or|>.iui: Mutt«r is Ix-r.pft.-i^l  in  J..-1-iiin pl^nt m>li H nfs  )>i  ih-  •,, 11  --.^>le\ ..',.! it: I.., 11 it -t MI,  t  .,r
        slob  rt-Ira-c  l»^ttn.J s.ittf  hoUmn thiijcuribluj. jlntLtutv,  JIK! tilth arc ,^i,.i,il]y (L>I J t <  i.-ult
    "^
*/    f
 M^
            tiit i
                                                                                                        _.11V
                                                                                                                Ifl.l
acre; cjr>*i4umt ly.  the pprcent:ige
awmal .i|ftlicati.««  of a very to*, i
If dtvoa^o   f.  1'*  Mmtur*- Jnd i
of height, 'i. j*.  tv-iKjfit* fru«) j|, 4>ii!t *
        •Mtter.  even though l'.c ptrccntifie of organac autter Jous

                I MOM.CK
ii_ BrftMl  .-.«Jd Ijjr  tn> fi;-ti.-lf.[ lo  i/iLTit ••<->  -*|.( r,. i.it.l-.  ITJ^i
thr C.IH.T  lu-iJ, orHJiiic ...tier proviJ.-s -nu-**, U-rn-Ilt  a- it
rtolc'injt  »nilit) is^uiy lines th.it  of  i;. i^.nnc ioiJi  pc:  ..: .1
        1J  IH.  <-vp*-vt-d. pulKuUih (MI sniK It*, in  r,i^:,i.
        CMMJ.  Odors fro* «'   'te can create proSlo** under certain circuwtances.  Anaerut>ically digested >|jJce
        Is usually  Jrscribed a  hac.ng an "earthy" odui  or one siailar to ttmt of crude oil.  ibtfrvcr, perions
        luring  adjacant to arvas iJ«« sluJg«  is  applied to land or is held  in lagoons  ire«H»Ntly cocvjUin of
        ob)fcttonafel* odon. If the s*^^ge has not been properly processed,  the  resulting nJois a>>>' t* verv
        •Micoebl*.

        SoMtiats odors  siailar to  mmi* are reported.  Khen  st'idge  is  held in Ugoons,  ihr ui^er  tav^is of
        liquid becow nthei high  in  anaonia and XMT is  lost  into thr •urophrrc.   The "lctropolit«n  Sarh salt con
        COMlVtiOJtft i* the tfa^er layer* of  the soil  I.MI ret*rlJ!it  ^r.inth  rht- sril «tn*.
        lure airiM kt aJvenely affe  led. reduunft water intaU- JA.I aerjtion. itoucvcr,  itl^lRt- gemr^lly ha> a low
        ratio off sodiiai ta ealcii* and WfTtesiui, indicatutf* a low adsorption of foJuai  Ihe -thlim that  is .id
        •orhcd by soil* toBds to be  leached out again in litatiJ ,ir«Ms where tUrc 1.1 *n  aiwml net -tut-Knt of
        taitet JoMt thraa^i UK soil profile.  Thus, there scr*w little reas«n  for concent about >oluhlc sjlt* in
        llltanU if rJv ftlulfe it applied at afronoaiic rates.

        nu« NtTAU.  Hany of the «.onren» atwnt pcwtihle. Jctrjamtal effects fraa loi.g lem an'li^^ttons of
        slulfje t>> the Mil have ctuteted ir»*ki the tr.H.e artsli  in sludge,  fhesc elearnt* remain homJ in the
        *«il. and .inf probU*s they create  arc diTficiilt to Correct. 'iK- elements of MO«I  cm>ccrn arc zim;, <-op-
        i*r. nidcl. and caJBiiui. hit r^uch  LOicvin e»t*nte t>-* frivupr. Ir;*!, noron. chrniMM. coKill. selenniB.
        .tnj HDlyhJeaiai. [he (car is  Out ic|*ait\l *i;ht  hiiild i^t co k i>nt rat inns of ih.-.r

        •e* thru e«t«B bv am or MI MM it could enter the fooJ rhnm at uno\-«iraMe levels.
                                                                                                                                                                     i t« to:i"w  .f.  trji.-fer  at  li*-.<
                                                                                                                                                                                                                                      Jrtna*f.t,*l  tun-  M-t^
                                                                                                                                                                                                    ls  of tu
                                                                                                                                                                                                wvJ.  «m^«(4urrit
                                                                                                                                                                                                                               > ^ere  to Jt-vt]j))  turn  4
                                                                                                                                                    »i 11 rj|>iJl> Ji-. r
                                                                                                                                                                                           Mg.f deco^use-
                                                                                                                                                                                           .  not toMowd.
                                                                                                                                                                                           .(K-n >.ludge  appl
                                                                                                                                                                                                                      i  to ilate, howet*
                                                                                                                                                                          Jit
                                                                                                                                                                        11 tuiti
                                                                                                                                                                                -rioni ^ot^fm that »«Ma)tr  sludge  Might  contain Jis«-a-,- prMiAinic or^iiisiu.
                                                                                                                                                                                jllfi pru'-lcito *i|cht rrsull  fru» il^c ul 1 1 1 :.tt io«i .  [Tin?, (inn-rxt^ of  11
                                                                                                                                                                                vt mtd mlh thii prot>l««- ^ iruar^  «rct4*illkrl> to 51111 nc j prrir>J ul  1 '. d*.
                                                                                                                                                                                er, jt K'd->t m j ionlitiori tiipdhlt ot «.jusi'i)t an intntuii. .i> dt'itrniiiN-J
                                                                                                                                                                                  h«& found in l^TI for  ii?v*ral kinos of znonitu pdrjMtf..
                                                                                                                                                    WTRATiS.   In t^M
                                                                                                                                                    to hjve about th<
                                                                                                                                                                                                    t  llHC
                                                                                                                                                                                                    , drair«K(.'  t.jler treat .tit-^k [>lot\ tus  >*-en lounJ
                                                                                                                                                                                                    looest sludgr  jpplujl iu«i plot-,  Mvt &ing ihuut
                                                                                                                                                           it appro i inuti'ir (.•quitjlent tu tha
                                                                                                                                                           i transformation tunitrate *i-t
                                                                                                                                                                 ttosphorus
                                                                                                                                                                                  to soili
                                                                                                                                                                                                    it  through Rhunt  ill Ian is tl*-.*we rr^;.

                                                                                                                                                                                              a constituent  of  slulgt appeals to he highly .
                                                                                                                                                                                                                                                     lit
                                                                                                                                                                                                                                              iiiUPU-  Tu  >.rops

                                                                                                                                                    it  sltKlge application rates are high. Also, the  levels  of phosphorus .. w« ent r? 1 1 on in Jrainag? watet MV
                                                                                                                                                    pc^>siMy irwreai* To the point that they pote a  futrophiCJt ion thrra! *^K-(I Jr^iru^c Hdtrr  is  returned  to
                                                                                                                                                    nunfliMifig iurf»<.c waters.  *4*in, the>« probl 1*3 arc  not  Opctted to rr^ull a» lung *•* *nrontmiL  rJtr^ uf
                                                                                                                                                    sludge application are net exceeded.

                                                                                                                                                    EPA REGULATIONS

                                                                                                                                                    Approval bf the Illinois ff'J is netessacy for any applii:^! ion jf ^««^g» ili4iigr ui> jjjritul lurjl liTkJ  i>n
                                                                                                                                                    erallv,  This approval i-. s*tured b»- the s«wage treatment  fatilitv fro* Mhiuh sli»l({* i> ol^taiwl   ^^roval
                                                                                                                                                    is  being given for jpplii_ai ions at agrOfKamic rate«  Producers who intend to use tlLklge mi  UnJ should
                                                                                                                                                    check  to se* that &ucK approval has been received

                                                                                                                                                    SUW1MV
                                                                                                                                                   phorus. and perhaps  trace elements.  An »
                                                                                                                                                                                                    uf the  sludge  should be obtained in onlr
                                                                                                                                                   nitrogen  and phosphorus content anJ that of ninor and tia>.e elnrnt^.  (teseirch at the On
                                                                                                                                                          and
                                                                                                                                                                         indic
                                                                                                                                                                                   that crop pla
                                                                                                                                                                                                                                              Kit few.  l
                                                                                                                                                                                                                                                n. The
                                                                                                                                                   crop production or enviromrntal proMeae are likely  to  result  fro* !«• rates of applica
                                                                                                                                                   content of  fresh,  liquid digested sludge Mill detemine  the application rate. If, howeve  ,
                                                                                                                                                   plied on  the sa*e  land ever a petuxJ of mmnf years, the  phosphorus  and/or the trace element content ,
                                                                                                                                                   the sludite  any  deterame the long tent appli ation  rtte.
                                                                                                                                                   Arm  lahnrat
                                                                                                                                                   P.O.  Box  b«
                                                                                                                                                   (^ton Fan  j
                                                                                                                                                   Joliet.  IL
                                                                                                                                                   (81S) 7.'7 U
                                                                                                                                                    P.O.  BQI  234-ll.S
                                                                                                                                                    Aochclle,  IL oio
                                                                                                                                                    [SIS) SA2  MJbO
                                                                                                                                                                                   LABuHATUfllLS TIUT NI1X PMIHIM >il LOI'J. ANA1 YSKS
                                                                                                                                                                                                          (sist  :s:  9iio

                                                                                                                                                                                                          Kosner -Itmson  Ulwratories
                                                                                                                                                                                                          3S*M N  Avondale Avenue
                                                                                                                                                                                                          (Tknago.  It  MX>1P
                                                                                                                                                                                                          (3121  S»8  §snn

-------
. ;i  iiifi  llii      If
              j    i    JS


   |s i, ji||f p!f jjjg if

   -'aE""* *5"*   "5"»"^* C"* 1 * «*
   !?:|l j>:p |:|§ |||2 I*

-------

-------
rfo
1

-------
                Bunmn WM> or -am wwtaiwn
                 •USE4V OF THE BUDGKT
                             t  10,  ItJ*
    Gary fchaaa*!,  teelaf Chltf
• .I. MMnMMtcl frotactlo.
teflo* f
IK loath tauten I trial
CUea«o, IllUoU    MM*
       Draft mircj
                      tfal  lapacc ItaCiMBt
                                           - S)ud«« Dlapoial  a
                                            . MIS f?*-0*-l$I
Baar   Ik, leW«i«l:

Pur*utn£ Co th* MACioaal fc«viron»ent*l  Policy Ace  (KEPA) and Che «*t.l-
bllaiMd ruiaa aad pracaduraa for ie«  lHpl«Mnr«tion *n4 In «i:ccra*t:c«
Vllk CMS Cifculir A->5 (rcvtud) and  chl  MtaliDiltTatlw polity of th<
Seacc, th« lltiaols Stat* Claarinshouac !•  trantaitting ehe tftt^ct)«« Ch« t«rg«l: of this atudj.

     2-  Land reclamtiaa 
-------
Tarry HotnbAcker
th*«* loBaW* «n4 their iaplitaiiun* should bt i.jti> Jiut us:,t-« v*rifl«4. end!, If these plant* do occur, th* tin.il LIS should  discuss
*ltern«tlv*i for prestrvatlon or Mitigation of thrsv xpK^ins.
                                                                                                                                                                        trei ts
                                                                                                                                          August 14. 1976
                                                                                                       Acttn, Chief
                                                                                                       Planning Branch
                                                                                                       United States, Environmental Protective Agency
                                                                                                       Reqfn V
                                                                                                       230 South Oearoorn St.
                                                                                                       Chicaqo, II.   60604

                                                                                                       Dear Mr. Scheozel :

                                                                                                            I Mould  lite to M»e the falloxlnq coawnts Included 4n the public
                                                                                                       htarlnq req*r4f the Metropolitan Sarlt»ry District of ClUiqo.
                                                                                                            As a pliyskUa «nd pilholoqist, I «i5i to Nke the
                                                                                                       nents.  Tiis  is • Urge iiM jnottlous project, one of the Units t in
                                                                                                       the world   The sludqe fs obtained by a digestion Method n« generally
                                                                                                       used tn «ary  larqt operations.  AH previous studies reoardfna, application
                                                                                                       of seutg* sludge to land, use sludqe eoulned by other wthoils.  I think
                                                                                                       you are probably mare of the various procedures.  The slixige being
                                                                                                       applied In Fulton County is ew*n nor« unique in that It H comprised of
                                                                                                       ipproxlmtcly 50? industrial mite with all of the Inherent tonic pro-
                                                                                                       ducts.  TnH, to ruve a rex, Includes all or the heavy tctals, possltly
                                                                                                       asbestos^ organic conpounds too numerous to Mtntion, PCB's and other
                                                                                                       known ai well as unknown carclnooens.  ft fs also been demonstrated and
                                                                                                       ucepted by your agency that various pathogenic biological oroanism
                                                                                                       could be present In sewage sludge In spite of the digestion process.

                                                                                                            While it has never been demnstrated that smaoe workers have an
                                                                                                       Increased Incidence of < lines: or disease,  1t is also true that ! have
                                                                                                       never teen a controlled study or nore iftportantly a prospective study
                                                                                                       •uch lets a control led prospective study on the effects of the eiposure
                                                                                                       of ItuBins to sludge.  The question of this effect on humans cannot be
                                                                                                       fully answered until sucn a study has been done.  Is such a study
                                                                                                       warranted?  To answer this, I would only point to the relationship of
                                                                                                       smoking and cancer, especially lunq cancer.  It MAS only after extensive
                                                                                                       Studies of huMh populations that the very direct and very significant
                                                                                                       link iias demonstrated.  The sane story and course of events has been re-
                                                                                                       peated Kith mawrous chexical agents be9in*lng vith the dUjo dyes,
                                                                                                       benitdln and many other organic chenl-.tls, too nunerous to mention.
                                                                                                       The saae 1s true with biological oraantsns, including bacteria and es-
                                                                                                       pecially viruses.  Since we presently ha*e d*ffic«ltv xith viral cultures,
                                                                                                       the true extent of this aspect has not been fu*iy investigated.

                                                                                                             At the present tine there are many many tools available to
                                                                                                       monitor populations in • controlled prospective study.   Since this is
                                                                                                       an experimental project by every criteria, these studies should be done.
                                                                                                       There ir* people who are directly eiposed to sludge on a dally basis.
                                                                                                       This Includes aerosols is well as direct sUn contact and other Indirect
                                                                                                       contact is Nell,   I would therefore propose that these workers plus

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    Sarjr Sditfitt!, United Stiles Environmental Protective »«enc», Piqe 2
matched controls be serially monitored far heavy metal bytldup,
tmmunoglobuHn lexis, antibody development  and certain Infectious
i«tntl Including viruses as as veil  as bacleria.  1 would also propose
tkat Mu>» be monitored for frequency and  typ« of illnesses, tncludinq
Uw fncldtnct of anc.tr. cardiovisculir disease and pulnonary disease.

     I would readily point cut tlut  these tests and procedures are
fully developed and readily available.  They should be performed and if
properly designed, these studies Mould not be prohibit!,* in terns of
cost.  It Mould provide answers to questions which will be asked re-
peatedly In the future.   Wiy not gtt the  answers now and avoid injury
to people In the future.

     Industrial Manufacturers are required to prove the safety of their
product.   I fee no reason why the Metropolitan Sanitary District mould
not also prow the safety of Weir product,  I see » reason why tewaqe
sludge operation and disposal project of  tHIs naqnitude Kith a potential
effect on 50.000 people 1 led.
                                                                                                  sen
 'age 1-10, Item 5, SoclB-Econoiilc and Land Use Conditions!  second
 entence reads - "According to present trends, denarii  for faraland  in
Fulton County has been decreasing,  	etc.*   This  Is  a questionable
statement.  Tne demand for faraland 1i not decreasing, however the
Incentives to go to other uses is likely  to be the  reason for the
change.  The next sentence 1s  very  questionable also.

Page 1-19. first paragraph indicates  runoff basins  art not  always
designed tc handle • 25 year stora  runoff.  TMs  should be  the ulntmur
for such Improvements.

-------
 Sawrge R. Alenander, Jr., 8/23/W
 >«oe 1-M-Z  Mltiaative MMKiris - Consideration should be given to avoid
 •orftfna fields when muddy.  This may b* affecting th* permeability of
 the 101 1 resulting tn more ponding

 Nat l-2». second paragraph - TMt refers to the use of wind barriers
 to reduce surface turbulence and wave action on the storage reservoirs.
 The Soil Conservation Service can provide technical guidance on species,
 spacing! and local tons of tMCh plant (1195.

 Etae 1-29-3, Monitoring and Research Program - He certainty concur in
 th* recapitulations for Ml upended progrw of nonitoHng and research.

 Nae 1-31 -  Suggest adding UM evaluation of the effectiveness  of  soil
 ind miter conservation practices bt included in the research and monitor-
 1*1

 fiat  U-Z2 states 'Cropping practices shall be such that soil  loss does
 not «»c»ed tolerable limits as defined by the Universal  Soil Loss
 Equation far that soil t*pe."  To date this standard is  not being fully
 Implemented.  The Soil Conservation Service through the  Fulton County
 Soli  and Mater Conservation District can provide  technical assistance in
 planning tie needed conservation practices to meet  this  requirement.

 Pay  lll-Z. paragraph g indicates the project site  has been contoured
 and terraced ---- etc.  According to the U. S.  Department of Agriculture,
 Soil Conservation Service definitions, the site is  not terraced.  Con-
 sideration should be given to applying the needed conservation practices
 according to the Soil Conservation Service technical  guide standards
 and specifications of the Sail Conservation Strvic* field office technical
 guide.

 faai  111-19 - Environmental Control  and Monitoring  Systems - The second
 «•*••*• refers t» terracing of fields.   Again we wish to refer to the
 ter» terracing.   To our knowledge terraces have not been  installed as
 one of the practices to help reduce  Hater runoff, erosion or control
of affluents.   The practices are also mentioned in  J-l,  second paragraph.
(rail
     li-!3. list paragraph.  MHrd sentence - Due to the leveling and
graph, t
a rat I on.
3        for >n* preparation, many  slopes are long.  If erosion is to be
       led the application of conservation practices such as contoyrtr.g,
terracing and other conservation practices should be considered to
hold soil losses within tolerable Itaits.

fay U-lj. first paragraph is  Incorrect.  Suggest it read "Are* 2 is
Int area in which no strip mining activities has been undertaken.
Approximately < to 8 feet  of loess. Mhlch is uchassmooth brume grals, orchard grass, fescue  and
reed canary grass where erosion is the significant problem.  These
should not, hoxewr, have been included in the Prairie Restoration
designated area.

Page vll-35-4, last paragraph - Nltigatlon of Adverse Effects •  The
use of wind barriers such as tall, dense hedgerows iround  the holding
basins is discussed.  The Soil Conservation  Service can provide
technical assistance through the Fulton County Soil and Mater Conserva-
tion District on adapted species, spacing, layout of plantings and
discuss the effects which could be expected.

fme VI1-42 t 43 - Surface Spreading - Very  little use If  my surface
spreading on vegetated land 1s being used.  This method could be an
excellent approach to rapid utilization of sludge nutiients.

Page VI1-45-S - Mitigation of Adverse Effects - This section  includes
•any good methods of reducing odors and erosion.   To be completely
successful we would reconeiend a complete conservation plan be developed
with the assistance of the Fulton County Soil and water Conservation

-------
George R. Al««ander. Jr., 3/23/76
District.  This plan could include soils infonnation, cropping patterns,
fitld arrangement* «oodf tod vegetative planttnos, erosion control
practices, seeding rites ml dates, recoeatiideo methods of sludge
application and other gut dine* to reclaim the land.  Consideration
should be glim to such things ai drainage. Irrigation, lengths of
Surface runs, rotating crops to provide adequate acreage for sludge
application throughout the growing season.   Consideration should be
given to developing mur budgets an fields to be Irrigated nith sludge.

Page ¥11-63. second paragraph, last sentence » This sentence indicates
retention basins for 18 fields do not Have capacity to contain a 25-
year itorn runoff.   AH retention basins should have a minimum storage
to contain a 25-year star» runoff.  The; should have adequate drawdown
facilities to maintain the needed retention capacity.

Paoe > 11-64-5 - Mtigation of Mvsrs* Effects - * number of the reservoirs
and streamswnttortd have substantial  areas contributing runoff that are
not under Metropolitan Sanitary District oMnership or control,

Pane VI1-67, first full paragraph, line jj states "low levels" - suggest
it read "lotur ie«is."

Paae l«-4-i. - There 1s no mention of tfte effects from numerous tillage
Operations and Many are done when the soil  moisture content is  Mgti.

Page l»-7, second full paragraph - The estimates of normal  yearly soil
loss figures arc wry questions!.   A loss of 1.5 tons per acre  seems
rather low.   Soil losses can fee estimated toy using the "Universal Soil
Loss Equation1* referred to in our comment for* Page H-22,   The  last
sentence refers to catch basins and sail conservation practices.  The
listing of the conservation practices being used would be helpful in
evaluating tin control,

Pane l«-35-b - Birds and Mfinmil! - Large flocks of migratory and local
geese and ducks spent «n/ 
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\
                       SOU CNMOffnCMT mPTEWfltS
                          Urn* ••*» On*, tun* mat. Cktati. WDM
                                                                                               Mr, G.  R.  Alexander,  Jr.
                                                                                                                                                        Mr 2, 1976
  > 372-4434
 Mr. Qeorge  R, Alexander,
 Oaglonal Administrator
 U.S. EM
 230 8.  DMftKxn Street
 Chicago, nilnoli   C0604
 Dsar )*. Alexander:
                                                       July  2,  1976
                                          aublect:
                                                    CIS foe Fulton County
                                                    Sludge Project
                                                                 material  ti of course very  difficult to pump  four pipeline was  about  I  mile
                                                                 long),  but  the extra co*l Is  more than offset by the  savings in transportation
                                                                 costi.   We were astounded at the 3.5% solids figure given on page V-38.

                                                                 Is the  3.5% figure  the swage of what has  been  hauled lo Fulton County tn
                                                                 your opinion ?
                                                                                                               Wery  truly youn,
                                                                                                                                             Wtliam I.  Bauer
                                                                                                                                             President
 thank you foe sanding to me i  copy of the subject IIS.  Being in the sludge
 business ourselves, we  wan intended In reading  It.  We have done research
 on  heavy ni*tat  upt»k« ourselves, for example, and It Is Interesting  to note the
 comparison with the results  repotted in ycu:  statement.

 Wa are also In  tfie mil  haulino business,  and  so were interested in your  rail
 natil  diaemn on peg* V-38,  Ifou m*y be  interested  to know that our 19?5
 experience with rail haul can be  «umm»rlied as follows;
     Quantity moved:
     Average  solids content:
     Cost of  nil freight:
     Cost of  tank car rental:
     Distance moved:
     COM par wet Ion:
     Cost par dry ton:
50 million gals. »  210,000 tons fwet)
13.9X fcaoed  on samples taken from toe of rail  car)
$420,000
$110.000
ISO miles
52.52
519.06
RfCHVID
       figures are vary orach different from those shown In your Stateinent.
asauoie that  you  merely copied  figures given to  you by others,  but we do
believe that  they ere misleading.
                                                                          We
                                                                                                        JUL
Psft*aps the current indictments regarding the sludge hauling by barge indicate
          pwrsorta are interested in showing rail  haul costs to be substantially
       than th«y really  are.   Moo, note that  we averaged  13.9% solids  in
the mil tout for all of 1975.  Some cars were as much aa  18V solids.   This  heavy
                                                                 Copy:   Mr. Wilbur Zlnn
                                                                 WHS/IP

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                                                         BWM
                                              LASL   H-8
                                              MS-490
                                              P, O, Box t08
                                              Los AlaHO*,  KB
                                                   87S44
                                              July 11,  l»?e
•r. Taldaa V.  »da»ku»
Deputy leglonal Administrator
     for B*|ion T
f. I. InolronawDtal  protection Atencjr
ISO 1011111 Dearborn
Cbtckco, Illinois    60604

DMr Hr. tdawktu:

     1 •• wrltiaf to you about tin Draft Environmental I«p»ct
tt»t«Mnt tor  8lBdg«Disposal and Land RecITiiTljon in Fulton"
County, Illinois.f nere are" aoete aTsvIoua error*',' wnoven  treat-
••BIB, fca4 ie,preci«iois* of language that need correcting  before
tlM final drift la issued,  1 will cite * few examples of  tiic
•o*t **riou* atiortcoiilncrf; there are m*&y wore.

     •I research  work It The Unlveraity of Texad at An-.tin  wnero
2 mi • prof«»»ori  !)•!• invalved airborne «ti43ionj from wn.strwster
       iit for  por» tk«a IS jmmra   I n«vn  the
        vftatewater bu«lue«* for Bbout 5 years, durin* v.,;ich iimc
       corresponded  at iencth with Aliteraan ward of i>c*a pia.me*
and Dr. lue-Rinj  ot  tiie Sanitary District,  Tnla corrpxtxindpni.*
•7 aall and phciie and in person baa extended to concerned citnens
Of the eity and to congfultinf with SoutHvest Research Irutitat?
on the Salt Creek Project (near O'Hare Airport).

     apparont  errors in tbv di*perBlon calctiittton^ and in  the
eoeelujiona draen fron the« include the following.

     ff. TlII-7 to 19—The 1% aero.solization a&jun||.<"iapeci»llf
     inportant bee nave  conclusion* were drawn from tbeae cwr»e»,
     The droplets ytidergo evaporation »*i they fill; therefore,
     they fill »ilh a cnaniciric  velocity   *lno, the flfur* Is
     not labeled properly;  me  ord^aate should h« Tiaw (a»c),
     the »bsclsui Initial Oiaaeier (nucroneiers), and tlie eur»«a
     should show vhtcli  arc  "asa half-li»ea «nd «kic» residence tia

     pp  V1II-5 apd 6--*  'jO-vm  panicle of unit denaity aettle*
     at 7.57 cm/sec or  n  5?.5-un particle iotlJe* at 1O c»/aec
     (s*ee appended ca Icola t iona) .
     Relative soKinmiei  of  various Rscea are given on
VII 16.  Sulfur dioxide  is  listed aa hignly voluble and a»a»onia
as intermediate i r.  solubility.   Aimnonia in about 4 tie*a a«
soluble as sulfur dioxide on a woigiit basis and 15 tia»a on a
volumetric basi.»*.

     Contradictions appear  in several places, including:

     p  jx~-TI» first  .,ri.t«-nce of tne Foreword contradict* itaelf.

     li  I-15~-Chr™i'atoBraphic analyses showed 711 probability
     that odor.-* came from the banin*.
     p  VII-23--The iinK<*rprlniing (chronatopriphic analf«e«) of
     odors wafi unsatl*facItry,
     p. VII-32--TIW wlrnl direction?* /or the complaints  indicate
     7J7 probability that the odor* are fron the bislns.

     p. VIII-3   'Evidence frow places other than..,of little
     predlciive value,.. "
     p  VIII  21-  "Uselul evidence may be  found, especially in
     foreign  journals.-   Should it not toe in the purview of this
     E1S to do  the  survey ralher than reeoninentling it?

     Oilier error-, itiat I <,•<• and «y re«3Ons for calling the»
errors  include  the  following:

     p  VII1-3--"   manv"^»lhogens survive..."  Thi« statement
     is singly  not  true rr|t:irdles« r-t the qualifying Introductory
     phrasy.   Pcrh»r'". fording s,ich ».< not many pathogens gee
     lhM>ugh;  thos<* ;nat h.ivi- been found  include...

     p. VIll-l--"   -him w,.rh wider  flue lu»t Ions. ••  Vou «u»t
     si.«-cify  rn>  x pcri-f-utane basis or the nK-aning say*  that  the
     fluctuation^ ari  eiraler than S.3i>tlOb organism,  which  I
     doubt

-------
p. ntl-S  <•!«) ••« ». Vltl-T  (top)— "Ho cr*lt  »linilic««ic«
1* Bttiekcd  to sis*..,"  Tk» *r(iNMiil  1* prtMvutwl tbat  in
r*«rtr*torV tract *nd *«*lio**4 »«T  «««•*  Inlectioo    I»en
If tkat 1« tb* c»»», th* gut  t< ecrttinlf  nor*  ho»Ul* to
th« •»croor»«Dl»m« tha« i*  tb* lung.   »u«b«r» «r«  important
to •tirtlng in inf»ction mod  tk*  nu»b«r» *ur«i«in( the ful
•r« r«duc»d.

p. ¥ttl-4-~TI)* srKUH*nt tliflt  depletion by  inpactit?n  id not
t Significant reduction foes  counter  to the  evidence   It is
tra* thftt tli« efficiency of iupcction  on a single  leaf i^
•Dt ««rj hi|tb and for the r«*«on* clt*d; ho»ev»r,  there are
•aof leaven i'=  — -'*•
                                                                                <- ~>   *(,..'*l.r"•„'.. ;'
                                                                                       *^ I *-' s.-. r'^.-, r
                                                                                        ,„  '•_,:  -/:•,,
                                                                                          f~"~ r ...:   •

-------
                      THK
*IKTM4»l*f»IJT.%:\ K.t.MT.lHY  IMNTNHT
10O tAST 1*11 ST. . CHICAOO. ILLINOIS «L«1I
                                         791 S«OO
                          September 20, 1976
  Mr .  Dougla* Eliorn
  U.S. Envlrommcal Protection
    Agmcy
  230 Horth Durborn Street
  Chicago. Illinois  60601

  Dear Mr. Ehorn:

       At tlw EIS  hearing for  Pulton County
  held In Chicago  on Auguat 17th,  Mra. Martha
  Strode itatcd  »he did not believe Spoon
  River College  was cooperating with MSB.

       I enclose the attached  Information
  for your files.

       Enjoyed seeing you In St.  Louli.

                          Sincerely,
                          Joanne H.  Alter
                          Coaalisloner
  JHAry
  Encl. 9/14/76 Dally Udger clip:
          "SRC students test sludge
             on crops"
SEC  stuchiiis   tsst

O I f f ff-j f-V/>  <-fc Tf»   <» T*^ n> (-•
olV£>O
                                                                           n KNNM GGbFREY
                                                                           « iw u J#r ten
                          rwr da *» • I.ITB. Tri-.Bdfr uU TM
                          0>'X* V £» (I fctX-* B .rfl :t«*U U UaJ)f|
                          • :) iw u-^.i.ffTTrt ta f^c p'jui;  HI-
 ASPAKT OFDir vr?P>!!at.»J •trleJhrf diprtdffit if •;*•/ »pptc*l|ji» (• U»e pr>*|.
      fo;nti, Srt--«i R;v«r CJ'.f* i*  On • h*M cot rh4 oo ft* *»o-t «iu, •
                          rm v •• c^f.^ractwl IM pn**** TMHff.
        _ . _-	 _._  vr * ihjJ •* the phrt V-M trutarf rttto
   ibr r H. :*.                Whicr; hit      	

   I tun. )>e!cd wit* M« midi l!w drctw* *f t,'*j ...   _	
       •rmnj# if^'f.jndart trtt* M ctiid.-*J U.. e«r*ct •nMHM hr crap
       l':ili»i *f!c-t» tfvf ^i«nt    («1'l ;^vr^ 7! - flrwJ t*>ifd vafi tirMerf
 p.i»- i  --4~f  dv.1 nf •!•> 'walk:1-' with ft'ir |--H»:> g,' •'•'•(• •. i' t*** l>»

lorV>;?fi >. '-* ->-»[ kn-.t^' r>Jnrr»k, **d

n» Mm M .*« ud IHIMIM fratn       "v?n e» »" I'ai M) wX Ul- ;^*4
 "Wc'r*  ret pfci.«crirt  •nylbl'1&." *?rrr.it*,' T«'!'-n»^T fn-1 "L'vtuihifKf utdUiK MBijd>inlffi:indMlS»).tldiui*v«
hMb«nirnn«nMrvic«>VM ta it* HMMB uu of «te plim ard a*
                        Students study  sludge
                         efr«m •>••« I
                          -IW tor ta M h •» mr.*
                        •M. -ta ndn wk. tap^B wta te
                        •>*J> tM Mil to UK M« en> w tar
                         _H>|      -  . .^  ^  -


                         IM CMMM tor mral ytm to i
                                                                                                                                 •* '* ttai "*»•» •  •*'.'
                                                                                                                                      «M.  OOwt >iiiUm tn
 •Ite •*« k e»n M> W •> Iml
•M'l Mfc to • ••* Mb. |MS» to •
                                                                                                    Ml M IM Mft. t«t l«< IW M taPJ     T» MMl |nka • »» Mj 1KC



                                                                                                    Trinbr uU Ita ™h tttal I»IT>»*    to MMM. k Ml u ton
                                                                                                    MM » U»I »i Mn M nmpfc •               ...
                                                                                                    ttcn M Iktr e« CMdwa ttar ««• Mi
                                                                                                                                -»«»r»r
                                                                                                     nwiu rmittiit ben   '              •
                                                                                                     Trimhr «••>! «wn ••» "» rndli m
                                                                                                                                    M *lm *hr]r grt *nl MI Ijwtr cwn

-------
                                                                no
         *f KfMFMJTAN SANITAMV MSTMi'T     ~
Hr. Gary V. Sch*tts*l

United 5tat*a  environmental
  Protect!on ftga-ney
230 South Dearborn
Chic-90, Illinois  60604

R* s  fc**eutiv«  suwaary of 7h* M«tropol it an  sun itary t>i »t ri ct
     of G£«*t*r Cbicaqo M*«p)ona« fco th* Emvi ron«*ntaJ  I«p«ct
     Stat*miit  tor the Fulton County Land Beela*«tion  Project
     (Prairi*  gjanl	__	
                                                                                        Mr.  Gary N. Seh«nE«]
                                                                                        USEPA
                                                                                        Chicago, Illinois feq&
                                                                                             However ,  the EIS contain*  error«,  fait* conclu*ion« and
                                                                                        ft««dless r*co«»eridmt ion* «rhi rh  Mill  l>e  »i«l*adlng and ut  th*  natioii** |»olicy for recycle and
                                                                                        1 and lr*8t*ent ,  Sumnsr i zed beloi*  are eight *a jor aieaa of
                                                                                        concern tcs the Di strict.
                                                                                         1.
                                                                                                           Hgnj^tor Li
                                                                                             Th* ££€ abates that  the existing District environ««ntal

                                                                                             • nvi roftM*i)t a I i#p«c t* .  The  CIS author* 90 further to
                                                                                             uuqges t addi t ion a 1  *on i tori n«  and re«*arch and that such
                                                                                             an expanded program  b«  revi ewpd t-y an i n dependent ageacy
                                                                                             of thia progr*« despite the  C»ct  th,«t ««**? opportunity
                                                                                             wmm g i ven the « uthora  to  i f* v*s t i 1* te the pto!|r**. .   The
                                                                                             eni*t ing prog raw is d i »c jased  in  Jetail in th* *t t ached
                                                                                             atate»ent and is desi^rtffi t o *on it or th* effect* on toi 1 ,
                                                                                             plant*, surface and groundwater,  a^r and indigenous
                                                                                             animals .
CDiEtri
SairirOn
prepare
Plan} p
rtlpantt
th» •» j
Xloc*iM*
• ntir*
K>i«txic
can b

     tfe
oC *a«i
b«rr*n
• ittd^*
acc*pt«
Th* Dis
*«ch in
         Metropolitan  Can itary ai«t r let of  Sweater  Chic ago
       ct) hat  pr*f*ac*d * d*taii*4 r*spam*  to  th*  Draft
        j*iital Ifcpact 8tat***«t (KISS which  youcr agency has
       d for th*  Pulton County Land  Rccl*«ation Pro j*t-t (Prair
       r*i*fitly toainif  conducted Joy th* Otsttict.   fhe detmile^
       * 1« *tt*ch«d.   This letter im deniqned  to »y«»a ri K*
       or r*0pon>«* th* District has conpi led in  th* detailed
       t. but flhould not pr*eliir>* an in-iS«p th review of th*
       (Soeu»*nt by your staff.  It i* thm jydq«»*nt of the
         tti*t th* BIS  mitmt b« coFnidarabiy  revised  before  it
       dt***»in«ted in its final for*,
       * USEPfc  »t*t»»»nt« In th* X1S rs^ataing  th* utilieation
       cip*i iludq*  (or f*Ttiiiting row crop* and  irwclafcttin?
       l*ad «r«  in «|*n«c*.l favor »bl*.  Kacycle  of  utinicipal
       in **co$ni**d *« a vL*bl« *i%4 ind«*4  •nwirofi»erst*l ly
       bl* wetliod of *lud«i« di»|»Oft*I {of mini ci pat I aq*nci«a .
       trict hat b**n on* of th* X*ad*r* Irt  this  flald *nd as
        sr«tifi*ore  »unieip«3 i fci«« wil
       tin^ thi* Method of *ludg* utlli**tion,
Me r* 5*ct  the  concept  that the pro i«ct requi res  ait  inde-
pendent agency for  review of all data .  fr«s*ntly,  th*
pfOj»»ct is monitored by the 311 inoi« Cnvironiiental
Protect ton *g*ncy  ItEPA),, Fulton Count? u*#lth Depart went
(fCflDi, United States  Ceoi epical Survey, and the University
of Illinois  *t n *ade toy the food *B*S
0 ca
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 nt. G*(y at, Schencel
 USEP*
 Chicago, Illinol. 606Q4
Augast 13,

Pag* Three
      the calculation*  y«ed  to  arrive at tNt atmospheric
      dilution at th* *ite were found by the District to be
      erroneous.  Bilution,  four  Mi.*s f row the District *lu
      holding basins was calculated  in the flS to be 2 - 4.
      fact, th* dilution at  four  sUlas was 3 - 75.
                                          a costpar is on that the District • lud
                                          County is inadequate ly stabilized.
                                                                                                                                    «hi pp««r.t» about probability
      • cure* were baaed on wind  directions eostpiled by th* FCMO
      at verified odor sites.  Mind  direction •»asure»«nts have
      * variance of 22,5 to 45°  fro* th* reported direction.  tf
      thi* fact were included, on* could *e*ily indicate * n**rby


      Th* District objects to tN*  conclusion that there ia an
      odor problem, as written in  the  EIS, and as** that thi«
      be eorracted or deleted fro* the Els.

III.   M*fe*le in the food Chain

      the EIS strongly suggests  that there i* a significant
      Health hazard due to wkta 1 accuetul at ioaa in the crops
      frown on eluda/e aaieRded soil.   However, little e*f>eri«en-
      t«l evidence ia pr*a anted  to a up pot t this suggest ion .

      fht U. of I., the Dittrtct and the USEPA hav* participated
      in a joint r* search venture  to etuSy ,  awong. vany things ,
      th* Metal uptake of crops  frown  on »Jud«f« a«*nd«d aoi 1 .
      The data f roe tfiie pro^raai conducted sine* 1967 , has been
      •ad« available to th* EIS  authors* the USEPft, and has been
      publiahed in th* technical literature.   This data has
      Shown, contrary to what 1« stated  in the EIS, that a»*t*i
      accnaiulatioris are not the  linitinf factor in sludge appli-
      catlon .   In fact ,  Metal 1*9* la in  crops hav« been found
      not to bt related to acctiaulat i ve  s !udc;e appl ^cation.

      The recently released usrPA  technical  bulletin on
      Municipal Sludq* utilization published on June i, 1976
      contain* no limitations on *ludf e  atetal ievele nor livit*
      •Indf* appl icat lona based on such  «et al levels .   Clear ly ,
      it ia 1 neons i a tent to indicate Metal level prob le*a it
      the Agency ha* not included  such  limitation* in Che above
      »*ntion*d bulletin.

             Quality
                                          Howevei ,  the coMpirison with fCHP  regulations  is  i neons is-

                                          not consistent with the PCHD regulations were  alud^i*
                                          alkalinity.  R**c«ntJ>., th* PCHD has aat«nd*d  its sludg*
                                          regulations and lowered ita alkalinity  criteria.   No
                                          further values are anti cipatwsl wh ich wou Id not b*  con si s -
                                          tent with tnes* new regulations,

                                          The use of the PCHD regulations for s ludg« quality  to
                                          condemn District sludae quality i* inrnnal stent with  Che
                                          fact that the rcHB has sever cited the  District for
                                          sludge quality violations,
                                          sludq« quality conclude* that *d
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Hr. Gary M. Sch*i***l
US I Pit
Chicago, Illinois  60604
ftuquat 13, 1976

Pmgm Hire
     ¥h« District  r*j*ets  th*  conclusion that th» field runoff
     basin* ar*  inadequate ly  aiiad and asks that thi • b* cor-
     rected in the sis.
     Th* BIS *tat*s  that  th*  •urf'ac* water on th« District'*
     Fulton County ait* has  levels of contaminant* above state
     standards and that th*a  is a result of discharge* frow
     *lu(5f « *«*nd*d  soi* s.

     It i* trut that a«rfae*  water quality at Fulton County for
     •on* constituents *xc*ada  State of Illinois standards,
     Hov*v*c, th*r*  i« no *wid*nc* fn th* US linking such
     w*t*r quality with District operations.  The surface water
     at Ful ton C©**«ty la  Influenced main ly by th* previous
     atrips)iftingi ojMtrationa.  *l*t»« thar* are discharges froai
     •evaqe tra«t*i*nt plants, sanitary landfilla, septic tanks,
     f**dlota and agricultural  nonpain t sources which influence
     surface water quality,

     fb* Stoat coeip*lliR9  *vid*nc* which «betw« no ditgr*d«t i an
     of surface watar quality at th* ait* it the quality of
     •19 Cr**k which flow* through the Diatrict property.  As
     noted la eh* HIS, wat*f  quality in Big cr*ek leaving the
     Dlstrict'a »tt* is consiatvntly of better quality than
     water entering  th* aite.  the obvlou* conclaeion i» that

     d*fra^ation aa  aaggaatad by th* EES.

     In addition, the 118 qo*a  on to assets th* water quality
     of ttiachar*;** frov DiaCrtct ccptive runoff b«*ln*.  They
     coeipare each water quality with what ia purported to be
     th* IIP* afcaadjarda for  thaaa basin a.  *f tar this evalua-
     tion, it is concludad In th* IIS that *»c*aaivt violations
     hav* occurred and  that  thia rcpraaenta th* aajor reason
     for surface water quality  d*fradation at th* site.

     •0w*«*rr th* tIS author* did not utilise th* proper
     standards which are  enforced by £h* l£?ft in pervUt condi-
     tion* for the Pulton County ait*.  Us* of th* propar
     standards would hav* revealed that on rar* occasions art
     the ZBPA standard* e»ce*de<5.

     Th* District reject* th* *tat*»*nt» in th* STS on surface
     »at*r quality and  aska  that they b*  aetendtedl  in the docu»«nt.
USF PA
Chi cage,
                                                                                                 Illinoii 60601

                                          The tls suggests  that  there  is  »  il^nlfjcant health hasard
                                          due to pathoqena  be ing  present  in aerosol • created by
                                          sludge iprayinq.  No do cu pen ted evidence  i a given to »up~


                                          Th« District has  co»pi led!  for  the record*, a literature
                                          survey which deals  with thit topic.   Thi*  i» contained in
                                          th* de tailed »t t acrhed  doe8i»*nt ,   The  survey concludes that
                                          tl.ere is no health  ha card  fro*  « 1 ydq« «pr«y inq .

                                          Th» District now  has a  contract with  the  USE PA whi ch is
                                          investigating  the atrosoliiation  of  fescteria and wiryses
                                          from si 'Jdqe spraying.   This  contract  is being conducted in
                                          The conclusions in  the  tIS  are  unjuati f ie4 and certainly
                                          premature until the  study  IK  cowp Le ted .  Me ask t hat the
                                          statesients  in  the EIS be  awended  and corrected in the
                                          document .
                                   y 1 1 1 . _ JklL JL j jig J. JH jg«_t t t
                                                              r d «  f r og JM ej a 1  1 r h a I
                                          The EIS presents  caicuJatlons  to  (*etee*iin« th* a»bient sir
                                          level* of certain Metal*  downwind of  a  «l«df# sprinkler.
                                          The EIS cDnclucl*» fro»  these  calculations that there is

                                          air me t« 1 lev* 1 s .

                                          Kowtver^ th« calculations in  the  EIS  are erroneous and are
                                          toc» high by a facto* of at  least  100.   fh* EIS authors

                                          own ca 1 eolations .  Therefore ,  the concluaiona about
                                          anbient air **tal levels  are  erroneous  «nd should be
                                          deleted fro* tHe  EIS .

                                          In closing, I would a^ain a«k  that your eqcncy earnestly

                                          before issuing th* final  draft  o* th* EIS.  Th* District
                                          also strongly urge* the USEFA  to  rewrite th* EIS in ii*u
                                          of serely attaching the public  an£ written cosi»*nt» to th*

                                          Draft EIS requires a co*>p3*te  rewrite to siaJte it factually

                                          inf or*at ton about tha Ful ton coun ty sit* ,

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Hi,  C«ry  K.  Sch«n««l
USfFA
Chlocjo,  Illinolt  «0«04
Au?uafc  13,  1976

Page  Seven
f *ill ««k« « Dlitrict  co«««nt«
                                     v»rp  truly  yours.
                                                   7.
                                      Rat r T.  Ly««»    _/
                                      Gimeral  Super I n t*nd*n t
     TEDtQTIj BJB j•C•

      Board of  €&••!••ton*r«
      Mr*«  £.oui«* Komi
      Central sap»rint«nd*nt
      Mr.  ftivlcuc
      Mr,  N*i)
      Dr.  Lu*~Hiiig
      Mr.  Levin
      NX. Nortiaer
                                                                                                                                                           Canton,
 Af**r r*a-ivM* t^<* 'traft -f

to flake a f«i« t* wnrrv* *( T)  ,^

'~it'w ft '.3 h»"*» a »^r*-y f

:>  ^t t.'-« «->Hor fr j^ t* P ' id
                                                                           A •»  T-T1-'  *t  ra"a t^ *• -n

                                                                            — -  It d.-^sn't ST«11

                                                                           ng  """ns «nd r'^n It
                                             (IS o- put  I-7I It
                                            to tMsl? Arc WP -11 In**a plt»s for O.icatta Mj^pt*1.' "hy rust we ~;»Y* to -^it f^r

                                            an «pi,fc"-r1e h^f^re sinv-th'if, 1? '1-»f»?  *v »^n 1*. nay ** t^o lsf<».

                                            (3) "he  -.P.«. 3*-ts s^andmrds fdf tw?  "..'.^. But Ir^y  (H.-v./«j violatw*

                                            tN*s« (n,T-?r,T-?''}. Oh p.II-7 it ata',«a If elud.«t is  ap-l^#d in lar -c

                                            aiaunts :t '•.-ui retard se*"d *^>rmirat''in mid plmnt. f^r.swt.h wid »*1'»i«r9*ly

                                            affect soil structure. IP* sa* this harden on a n«lrt south of £t. :*'i!?»i ri«ta t-> nroire this. Ajatn ««at  «w "*a't until neap** ^1* b«for* socts-

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                                                                                                                                                     ft]
(i) Mm Mis nine**-*'1' rr°"r<|W 1* * f*re« —  *e don't. need *<>d ajl'wfll* 1r> tMR

part of tha eoantry, *>**  iM t»-w* trl»d  t»t of this tiraft It  t-w difficult for th* ordinary l«j"»n *» «>.>r«t»r/«. Murh

 Of H il l*lUBt«nt. "•'« •>•»< h^jn told th«t IN- p«o|>l» 1l»inp m>ar l!i>t 'ul.lin,:

hi«in« «r» BHMne but  illtt^rat* firtiwri. This d^iea  IKH nak« gjod pwfclle

r»l«t1on« d«(« it?

 f*) p. IX-tX3 Rtftt^i *  h.i'wrt to h»w«n« iwj ^ulnt *HtH ewiwi-^fj m or fish ar

  »'.W1W» fron l«nd «pnad with >lod-«, i»t •niu'ii d»t» to tell— •» iust ««-'t.

  and ae* hw  lan;* poopl* dl« fc»fm-« unyt.1 in? Is dar» tj eor»«*fl *t,l T^ »re

 el* of f 1'tonCo'jntj.

  M*S*Dt *alc«» th»1r projwet aowxl £tx*l an fap«r Iwt  in actual practice it atlnfcs!

 ft may provida Joha for  a fav b«it 'idtm  ^mt^ had  joba for thair p0or>1« before

d.S.D. and T'n mr« thnra vill ha vork far all "ho nuit to «^-k «ft«* •(.S.D. )i
    *iral lauta I
    Canton, nilno'.i 61570
          United States Department of the Interior

                     OFFrCE OF THE SECRETARY
                      W*5HINr.T'IN, DC  3OS40
 PEF ER-76/613
                                                    1 :< 1976
 Dear Mr. Alexander:

 Thank you  for the letter  of  June 25, 19?e,  requesting our
 views and  comments on the  draft  environmental  statement  for
 Sludge Disposal  and Land  Reclamation, Fulton County, Illinois.
 In reviewing  the document, «e  have noticed  several ar«as of
 discussion which we feel  merit: re-examination.

 We recognize  that the area beinj, used for sludge disposal  is
 strip-mined land which has been  reshaped  for project purposes
 and that the  likelihood of historic or arcneilogical resources
 being present  within the project area is quite  remote,  never-
 theless, an inadequate discussion on page IV-C-l indicates  that
 numerous such  resources are  to be found within  Fulton County,
 Evidence of cortact with the State Historic Preservation
 Officer (Mr.  Anthony T.  Uean,  Director,  Department of Conser-
 vation, 60? State Office Building, Springfield,  Illinois
 67706)  and a  diiclaimer to the effect that no cultural re-
 sources would  be affected by the proposed project, if such is
 the case, should be include'! in  the final environmental  state-
 i^pnt.

 The draft statement does not describe sufficiently existing
 fish  and wildlife resources and  project  effects  on these re-
 sources.   The  statement  should be  revised to describe habitat
 typea and acreages  of  fish and wildlife  habitat  that will be
 destroyed by the  project.   Although a substantial  portion of
 the proiect has  been completed,  we  understand valuable wetland
 habitat  may be destrr.v->d by additional sludge deposition
 Wetland  destruction is  contrary  to  EPA policy,  and we would
 be  opposed  to any corttii.uat ion of  this activity.

Three scans of coal, Fultcn County's  most  valuable mineral  re-
source, are present in  the project  area of 15,000  acres
Apparently  at  least one  coalbecl, the  No.  5,  which  is  the thickest

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and closest to  the  surface  of  these  three seams,  ha« te^n
entirely removed  by either  surface or ursdersrounJ mining.
However, th« draft  stale:,i«nt does not adequately  discuss
this, particularly  with  regard to lands wsst of Fiatt -ind
lands west of Canton.  Project lands should be located by
section, t0wiship»  and range;  not enough detail Is shown on
m#ps provided wi^h  the statement.  In addition, the current
Status of coalb&il No. *4  and No.  S should li*» el^arlv stated.

Table I¥~9 (page  IV-?85  incorrectly  labels a column of -jati
extracts! from  Durfor and Becker (19St) as "U.S.  average."
Apparently the  data represent  a range of values found in. \m~
treated **atfir froa  ground-watar sources in the supplies of th*:
100 largest cities.  The numbers for Al, Cr, Cu,  Hi and 3n in
that column should  b« divided  by 1,000 to fit the units given-
Errors in the citation (page IV-62)  should he corrected ac
followi; Durfor,  C. N. art4  Becker, Edith, 1961*, Public Water
Supplies of the 100 Largest Cities in the United  States, 1^62,
U.S. Geological Survey,  Water  Supply Paper 131?.

The jnonltoring  stations  for surface-water quality shown on
Figure VXI-13 (page VII-1*?) are not  adequately identified in
relation to either  the stream  net or the sludge application
sites,  "'"his mak«a  it v«ry  difficult to evaluate  either the
data givwn ot th« discussion in the  section on potential
surface-water contamination {page vjl-ng . S8>,

The draft statement provides valuable information in its eval-
uation of the potential  for impacts  on ground water at this
stag*.  HotiNSver,  w« believe that in  addition the  final statement
should include  data on horizontal and specific yield or storage
co«Ffici*nt(s)  of the aiquif«r  that mast have been obtained in
the field testing,  lateral  velocity  magnitudes for the ground
water involved, and typicsl hydraulic gradientCs) or* water-
level contour*.   Velocity of flow concepts se«m very pertinent
to consideration  of the  data.   It is not clear whether any ar
all of the project  is located  directly upon strip-mined areast
although souse of  the text suggests this.  It would be helpful
in isKpact evaluation tc.  know how such of the project lies on a
section sach aa that of  Figure TV-6  and how much  lies on shale
or coal »|»ails  with no section similar to that of the figure.
   also r«co
                  that
«c* «i»o x-«c:o«BM!iKi X:R«^ « map tie  included in the statement that
d«pict* *11 of the r^ereation areas,  ani?crge F . Alexander, Jr.
?e?,i';5na I Adfi inistr^t^r, Fef?:"^
Environment -3 i Protect irstt Ap^n
2T '•nuth r»*r^crr: "tr^et
Chicago , 111 In-; if.  tC'jv1-

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                                    IiBI fl)
                                    ST. &<•
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          -1
Vi*w ef
                  n»
                                                                                                       if-

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                                                                                                                                      1 . :. *'. t)
.: :' '-i!o:/ ' >.n i.i'" :.•.•••..'.
•,!••! i ..-.i.:v; THAT •/• '. ;.'
Vi» CLM!">W ODOHS *.*il !,
:n"f F:;':I- -ii'AT :;IHC'. TMI
                 "HIT ru:i
TO T;;I-. !'H
            (110 SIOMTUKtS)
•|." i:j :;;. ,A''':f,'
 AT,'. WAr:.
                                                                                                        CITIZEN'S ST*T»IEIIT
                                                                                                 USEPJ> DRArrBNvriionNnifM, IMPACT STOD?
KET     FULtON COOBTlf PMIKrE PUkH MOJECT
        Or THE HETK0IKU.ITMI SANITARY DISmiCT OT GKEHttR CHICAGO
D»TEt   AUGUST 16,  H7t
                                                                                        My n»w if Leon zedrtc|>  «1<1  I  r««lfl« *t
                                                                                                              M**  K»  Tuk  Hills, rulton County,
                                                                                  Itlinoii,  *r»d hav« lived there  for  j
                                                                                        I «H epployed by Pulton County •• ttie'Director of
                                                                                  the Pulton County Conservation  and  Cmp ar«i» coik*t»tlng of
                                                                                  •pproxinatcly   f/^f^      icre« of itrlp-*iiwd land which
                                                                                  nai been purch**ed by the Metropolitan Sanitary Diitrict of
                                                                                  Greater Chicago and turned over to  Pulton County for a public
                                                                                  recreational area.  1 have been th* resident superintendent
                                                                                  and !?anaoer of the Bite ftinee it was opened to the public in
                                                                                    J y  //	• aft<* have been  on the lite virtually every day
                                                                                  during the turner camping aeaion.
                                                                                        The recreational area 1*  ideal for canpinq and for tiahing.
                                                                                  It  hat a large nunber of pondi  and  lake*,  formed by the de-
                                                                                  preailon* in the • trip-Mined land.   Tfteae bodie* of water are
                                                                                  stocked with fish and th* entire area it open to the public for

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fishing and transient  capping,  for * lee of 5  t	 p«r
day.  Sine* the project  started,  there hive been approximately
              people use  the f«.-illtie*.   Th« topography li
rolling, wooded and ideal  for  canplng.
      ffre entire area  is adjacent  to fielda upon which the
MED applies sludge, formerly by  •  spray Irrigation system.
now by incorporation.  No  part of  the caiap qrounds and recrea-
tional area la nore then 300-490 feet fro* auch an application
field, and nany parts  of the aite  are aa close a« ISA feet to
application flalda, «Mch  are  in plain view from *o*t parta
of the recreational area.
      I teatitled aa to the alleged  presence of offensive sludge
odor* emanating froo the application fielda and from the holding
baalna utilized by MSB in  ita  sludge fertilisation project.
Thi» teatlKony waa given before  a  hearing officer of the iMnoii
Foliation Control Board in Deeealier  of  1575 in Pulton County,
and a copy of aqr aworn teatinony ia  attached to thie atatement.
I vaa eubpoenaad aa a  witneea  to teatlfy at the hearing by
PSD.
      Aa of thi» date, Jkoguat  K,  1»76,  I on lay that I htve
never been peraonally  bothered by  any odor fro* the alodqe, and
I have never had anyone ualng  the  recreational aite complain to
me about any auch odors.   The uae of  the area by campere
and fiahera has increased steadily, since it vac opened,
a* ivy attached testimony IfidiratAft.
      I believe that the eonplainta of  a few fai»iliee who
live in th« proximate are of the f^D Prairie Plan site  and
have led the public opposition to the  project, are unfair
and qrossly exaggerated.  Host of the  people vho arc the
chronic cmv>lainers are alao plaintiffs in a lawsuit seekinq
SI.000.000 damages fran the district.
      As for my own observations, I can say that this auaSRer
of 1976 has been the busiest season yet for the recreations!
area which I manage.  We now have a maxiwtusi number of season-
lonq canper*, who rent sices at the recreational area for
the whole summer, and live there day in and day out.  Tttere
*re  ,P ff     such aites available, and every one of the* is
rented, at an annual fee of 8 /.J.C1	 per year.  That Is
our high-water Mark for uaeaqe.  tto complaints, as 1 say, fron
any of the permanent campers have ever been made to ate  con-
cerning odors from the adjoining MS0 application fields.
      In addition to the permanent canper*. this emmer has
been the «>o«t active sunier for transient users of the  recrea-
tional aite, and to this date we have had, t>y actual count.

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              visitor* and cmp«r« who  have uMd  th«  facility.
I hav« iwv*r h«ard a complaint  trow  any of  them concerninq
odor* or any fora cf pollution.  Tti. fl.h »r» plentiful  in
our lakaa, vildllfe ia •vcryvtwra, the people of Pulton
County UM the facility to Ita Mxlmu* capacity and I personally
believe it ha» been a qreat boon to  our county and to our
cltiiena.
                                    Leon Eedrv
                                           •  . '* •'
                                           idricl

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fj
                                                                                            CITMEH'S   STATEMENT
                                                                               TOR  USEPA DHATT  EHVIRONHENTAL IMPACT STUDY
                                                                             FULTON COUNTY  PRAIRIE  PLAN  PROJECT
                                                                             OF THF METROPOLITAN  SANITARY  DISTRICT OP GREATER CHICAGO
                                                                             AUGUST 16,  1976
                                                                         My nam« la
                                                                                                      ^ '  Swan
live with my husband and children  In  a  farm house about
300 or 400 yards  from  the  hone of  Mr. and  Mrs.  Lyle Bouqhan.
We rented the hou
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Sanitary District of Greater Chicago,  and aaked whether
or not any aaafcar of «r  fawily  or ayaalf h»«  been bothered
by any •lode* odor* during  tba  y*ar l*?f.  I  have atatad
that ve hav* never experienced  any bothereone aludq* odors,
•van though u* hav* no air-conditioning  in our heuea and
ha** alept with oar vlndon opan  to tha  air during all  of
th*> .  they ranva in  aoa treat  / «/    to  if-
      I an repawtinf thaaa  verbal atataewnt*  in the for* of
ttiie written atataawnt, for Inclmion  In tha US IP A  Environmental
Iiapaet Study, at the requeat  of NED.
                     CtTIIEM'S  STKTEHEBT
            ro» USEPA amrr FNvinoNxrvTM,  MMCT stuoi
          rULTOH COOHTT PM1IIB PLAN
          Or THE HETHOTOLrrMI SIWITMI* OIS1WICT OT C1««T11« C««»eO
          AUGUST It, H76
      Ny naai* la Junita Creaatte, and I own and operate
the village Cafe la St. David, Illinois.  Ny reataurant
la in the village of St. David, juat north of Route 100,
vhich run* through the property ovned by the Metropolitan
Sanitary Dlatrict In Fulton County and uied for their aludge
fertilisation project.  My reataurant 1* vithin a Mile of
tha operation'* office of MSD, wtiich la In a (ormr fan
houee on the aoutli aide of Route 100.  Many of the USD
employee* and many vialtora to the Prairie *lan office eon*
to m/ reitayrant for lunch, aa well aa many towna people and
neighbor* in the immediate coaaxynlty.
      I have been operating the reataurant alne* before MSD
began ita project and purchaaed it* property, and the pretence
of NSD in the neighborhood h«« certainly increaaed ay bualnaaa

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and increased the patronage at my restaurant.  I recently
expanded my facility, by addinq a room to my cafe which
••att an addition*!   . '.	 people, giving me a total
seating capacity of approximately    '   	 people.
      I spend every day at my place of business, and I an
on a friendly baail w*th all of my customers.  I visit with
them about their jobs, and I hear all of their complaints
and all of their daily experiences.
      I can honestly say that I have never been bothered by
any odor fro* the USD operation, and it has certainly not
affected my food buelness adversely.  Hy customers do not
complain about odors and they have healthy appetites.  Many
of the employees who work in the application fields cone to
my restaurant for lunch, and they certainly have no visible
ill-effects from their wort in the sludge application fields.
I believe that the, protestors against USD, who constitute  only
a few fa»ilies and a small number of critics, probably about
20, do not represent the majority of the homeowners or cltisens
in my community) and I believe that the  few critics of the
USD project have grossly exaggerated their claims, and have
enjoyed the publicity which they have generated.  Most of  the
people whom I come into contact with on a daily basis
simply pay no attention to the USD project, and go about
their business routinely and without any complaints about
USD.
      I have been asked to make this statement on behalf
of USD, for the record in connection with an USEPH
Environmental Impact Study.
                                 Junita Crosetto

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                     CITIIEH'S  3THTE«IIT
           fO» USEPA DKAFT FHVIKOHMEWTAI,  IMPACT STUDY
                COOHTI FMIRIE PLAN PROJECT
         OF THE MTUOPOLITllN SAHITARY DISTRICT OT  CREATED CHICAGO
DAK:    AUGUST 1C, 19Jt
      Ny name la Lyle Bouotian,  and  I  reeide on the border
of the Metropolitan Sanitary  District'!  Prairie Plan project
in Pulton County,  f live in  a  farwhouee on a townahip road,
west abouf one-4MT »ile-*aa» the holding lageona, and about
one-foarW mile eouth of the  Shlelda  Chapel Church,  t
have reeided at thia location with  wy wile for  3_~~     yeare,
We own our home and veenjoy the relative secluilon and open-
epace of the rural arete in which we live.
      I believe that 1 a» the closeat reaident to  the HSD
holding baaina, and I » In the direct line of the prevailina
weaterly wind* fro» thoce bailna.  Among lay neighbor*, within
a dietenee of a «ile or t»o couth and north of me, are ao»w
of the amt conaiatent and chronic  complalnera about the USD
operation.  5o»e of «r neiihbori including Mr. Ton Downa and
        of the Vaughn family, have  aaked me to join the Citltene
for Better Health and Knvlroment, which ha* becon* the
central or^enizaticin oppoelnq the HSU operation.  1 h»v«
declined to join the organisation, believing that their
claim ar* areatly exaqqerated and that their co«plaint«
are not well founded.
      I an enployed »« a euparintendent for a wlninq
covpany, which operate* a at«ip-a4ne near  .'/,,* 1 * '^j   •  in
Fulton County, and 1 have been employed by the coepany
operating that Bine for    <»'./. .'   yaara.  Hy wife ^"a achool
                                                                                       teacher in the
                                                                                                                                 »chool in Canton,
                                                                                       IllinoiB,  in rulton County*' - 
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aobeiiailon  u tart of  th* r*oerd  in an  DSBM  IwriroMMtal

        8tody o*  th* ^•iri*  Vlan  project.
                                                                                                                         *"  q-i.!«T, if: (r-IUII^V

                                                                                                                        HV: "achel Vhnit't. n-' '
   ''anat>inr the em-ifi—ent in rut ton Poupty  is a tomlex and ch»llen\erfKi open t'ne
*ptv, ve frit tKit • c ').-».!  an environnent  reltf (vrl1, frer of pollution.
•» •*• mm ralat*v»l» tm.   Tha> oaHat ia nil iaHI«««l wallt.

   The ''. 1. n.
 the w>rld has t
 fooled hv »'. s.
                                                                                                                      j5 a wrle* nrolect.  It fs 11 "fe"*r1rei»t".
                                                                                                                      i1* fr-e of nroiect, thi^ extpns ve Ncen tried.   Itan't
                                                                                                                                    about ."-j .   at also heavy Indus-
                                                                                                    :ri3l v/aste^.   It i«  i<™**rrt*t at this tiRe to <'*' i»c. analyce* and atte-?t
                                                                                                    to  ^escriSe r«itenti-il T^|««.B of this *ort.  t? - M  require not only
                                                                                                    expert resources h-!»  *-"-i, the neonle of Fulton Tomtv.  fhillenRinK the
                                                                                                    "^nr^lers emotionsjlv  i< («*)t the acceptable forr- of -i^nroach.   Scientific
                                                                                                    -et'-o.ls  rust he jnstr^»nte<|.  It is *ost IrwirHfit t'wt ».e seek out quali-
                                                                                                    r'teU and trosruorth*-  r^srnirces.  Ke cannot tn»c  . c-  '*. to  loofc after us.
                                                                                                    T-eir primry iwal is to pet rid of a lot of *1n!-e.   T^eir credibility, or
                                                                                                    l3:V thereof, has heen siihstantiated.  Thay BnnflHriLtfl-inal  '• •flit' ful.ly
                                                                                                    di^es^ted s^udca, bjiit .then theyproceedad {a,J||cwwKi]aMBvlapaDMAy«aUt9itelf.

                                                                                                         In sewaf-e dispm«l mcworjanluB play an iTwrtant part In treifwrt
                                                                                                   of scwa<^.  A larse fta-fcer of bacteria are present i* ^r-*af^f scsre are
                                                                                                   intMtinal in ortiiip  • I.e. f.Coli.  Saw are frwi <«ll, lir, and In fore
                                                                                                   Cases t industrial vwtes.  The rain objective of T*V "*tJtod of ne%.a«^ treat-
                                                                                                   nmt  is to remw or decofxtie the organic naterial to a final product.  T*rat
                                                                                                   i*. to a chemically jtahle nradet i*ich is not subject to furtlwr deoorpo-
                                                                                                   sltton.  'J^H • ureent v*sit to the SaniMrv ^istrtcu protect, considerable
                                                                                                   huMiIinf was noted in holdinc *'isin nui*er tv-o, which prvcludes Hut a chart-
                                                                                                   cat process w»» «till talims place.  A report fron Lvle A, tajr, Illineis
                                                                                                   Mrect Si*-liriit S.1;. it.K.o.f. noted on "arch W, l^'l tf* follnwifif tlii*r»
                                                                                                   •bout Holding haiin '?.  The basin was hein* 'illi-i vith sludav.  . * strant
                                                                                                   sempe-liris.  The sanple  col-
                                                                                                   lected is worth* of nentinn.  Analysis H » fellows;

                                                                                                                 OoliforVllO .'Slliliters - SC.IM
                                                                                                                 Feeal CblifOftVlM «a    -  S,W>0
                                                                                                                 Fecal strep/I"" ml       -  S,Jin
                                                                                                                 Volatile 
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     "':e exclusion op * r. ^ay is thai the sarf>le$ collected and nhysictl
cyr'i*  "* cMervc-J 3t I1'.? holcJinp basin ind'cnted the sludge *3S not veil


     '•''"t follwinf: concwtrntions ,iml nercentn.ses are extracted fror hT"C
'!an .•< »." Practice *'o. II, i^ntion of l.'aatei-ater Treatrent Plants and
repr?--"t coTcmtratiwi? f:-i' "i*r?'07 R? einecteTTrS^^ell dir.estea sludre
•trr •••.•-«!

••-Iat4!«  ^i
* '"olatile Solid*
•Iff Raiin *1


       M,»«
                                                                 Slirfw »asin «2

                                                                        »ln rr/1
                                                                           -S.J1
                ;--•* this *s an er~f r" c~?al nroject *e ire t-in''r~nted with nar- ni-
          V*,* " •"" "f'irs sml rany ir*t**!'.e*a'*le «'«stions.  "Tni* i* •* prefect that s--*t
          v* :--.l: s Ith to the finest '!,vr<-e.  * prelect of t':i* sort involves poll'j-
          t»nt*.  Titev are classified *•* "hi-slcal, chemical or hiolofricvl-  ^*ur rest
          i^Ttiit  amceins are the Meloi-ical and chemical -wllutants,

               >* o» first dtsct«< Ho!--leal nollutants.   l-.-ro are living or?»ni5-J
          feiri in st**g».  'Wess tK« »••.»»• is fully dtt-eite.1 t!-ese orf-anisn eontirue
          to t-rivt,   "ilnoiwlla ii » e«-pl« of * hardy tacfrls that can pollute
          m'f' •"^ i* a larc* or
          an electron ract"»coe».

2.i-Sl          "Th» hum Intestine i* now known to fcarhour on occasion viruses alrost
          •s divers* as their hacteiial in>abltantf.'>"  It is necessary  to further
          Jefend the emrlionrent of Fulton rounty »»l the private rlsht of the citizens
          to a '•! rl-. ''. s, ".  is hrimsln.; Aji,-n alone Kith the h*-an
                                                                                                                      '*ich can "
                                                                                                     r^li-'.s^*' in t! f? e!ivimr"^e"t \n tl'O forw of v.iooitr.   'Vdrocarhans are as
                                                                                                     •itc.i vith carcinogenic (cancerl dise.ises in fin.  The heizene rint is i
                                                                                                                                      »• "i laf^tlv rc^rr if t  .r :  relei-i?
                                                                                                                                     g.''-c^stve anp'rt-^ t'--^e can prove l i*-''i;.sl

                                                                                                          The Mior Interest in nitrogen osidei as  lir co^taminarits is related to
                                                                                                      reir participation in at?o^pVeric  photochemical  reactions i.e.  pro>j;tion of
                                                                                                                                             ainants denenii on  several factors.
                                                                                                     a:cr.e.   The forr^ition ef secoadar>'
                                                                                                          "The reaction rates, route*,  and intetre^iate steps  involt'ed in  eenerat-
                                                                                                     ir~* ~!*t pollutants are influence"!  hy  wanv factors  sfich  as concentrations of
                                                                                                     fetcf.^nts, e^t^nt of nhotoactivif ifm, p^teorolopic U  ^orces,  local  to — ranHv,
                                                                                                     tf ~~en tyres ,  ;r>J relative arwnts nf woisture.  ftr important cof»efi'**;e  is
                                                                                                     t~* fay— Tti-^i  if s-ilfatcs, fro"\ sulphur dioxide  .'~ ' nitric oxide.  ' ost  trouble
                                                                                                     ss^e to control  incltid* ozone,  f or^jildehyde ,  oftiic  and
                                                                                           P.ll l»rj      "he pollnriofl is  also a  threat  to uil.fliff.   n-.loripar*d hi-Jrr;-----.* -.•»<:«
                                                                                           y1"^      into w:iter where thw  are Hre«t*ti hy microor^'wiis-s  t'ien  eaten hy  ":.. •  ,-ir.J
                                                                                                     of.or amrai5.   These  are later citen Hy hirds  and haterfowl.   At e^c*  ?!;•*  in
                                                                                                     the f^^d chain,  the concentration of the hydrw^r!'1^m3 is greater. "- '  r   :lt ol
                                                                                                     s-jch concentration i«  that ,if*»ctrtf  hirds pr»l<,_.- T-TS  kith shell.-  =:   •"t."j^'<
                                                                                                     in c-ilcitF* that  they ar* crushed ir  i nciih.it i <:•?.'')  let  us  now  focus   ™  tVre-
                                                                                                     very heavy netals: mercury, lead, and c»A*t*!.
                                                                                                              ) Kan* nm*r twen nentionad nor discutsad by M.  S.  D.   Mr.*   ~*-.ry  ire
                                                                                                     notorious  and very hizardom.  ""-ere  is  nuch  to  be said  ahout these. TV*  dis-
                                                                                                     cussion nust  he Halted,  r«uvv«r.  First  we  Kill  look at  "eroiir.   It  is seen
                                                                                                     as  a special  threat to oan ^'ecsuse tnorjrxnc rerciw^" can  he  converted  to rethyl
                                                                                                     nercury an orrrwic coryyyd fat 'MS .1  lone  '^ioloqjcal  ntif-ltfe f*1 days in  nd
                                                                                                     comarod to the inarsamic fcrra of •wrctiry,  '-ihich are usually excreted fro" the!
                                                                                                     hody In a  few itays.  "ettfl aerany's had reputstlos is fortified by the fact
                                                                                                     that it easily passes through  hisloptcal  r*rhmnes including the harrier that
                                                                                                     separate*  the hrnin fro»  the rest of the  body.  The coraoMid  li particularly
                                                                                                     destructiv* to nirve cells sm! earlv -syi^ito^s irclude readache and  fatigue. Thi
                                                                                                     is  follff.-ed K-» senfitirttr In^s In toes ml  finrers, vivaul  diiorders, poor
                                                                                                     wscular coorttmticn, «^eec)-> arJ "-earin; difficulties,  rental  retardation and
                                                                                                     •leath.13)

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                                       ef >lera«ry Is  m  i cuaiiu>eiit In tk* electrodes
                       hi'.i-nurity hydnuiJe anJ chlorine -.is free brine «ilutio« to
                       • ot netrole-r, rl*w. miwr.  .ir,i drtercmt industries. There
                                    '
     •-.r-4
     ""•-e rreifest si»«l!
t-!» -retire M«
~r*,'-. e-.» we-'	

"rtr;!^|j!|^^j ?£fa* v'"r*  "  ic "**<• WH u w* reason it'i.'inc'reastn;


     The eumnt cmicem o/er rwtv-l nercury pollution can re trsced to WSJ
    • rv. mi t-*  •in.irata  Pi'Mse". Tn 1-VW, the disease hrol-e cut in Xiltati
  -v anJ even tables sea-*.! to h* affected by the disease.            «'S»"

       ftyl "ereury  also ermt up In feeden vhen conservationists ahsnvad
«.a .-^".frf*.!!?" rony seed eatin* birds, includi«f nhesants and partrid*
:M anont their mrcdaton.  There is also * case in Al*K*ordo, »'e» 'eiico wher-
wenu r**kcrs of a Tartly «tc th» reat of a tw tli.it had eifn -j!'1'-! *«•>*
.--.t rnntain--! sethyl  reroirc.'1)  'he coqaaqkier^— vtn «ad.  r»>-{>r c^i 'e-ics
•:cirr»l In Tr.in,  Pakistan  anri •• —   "  •"                    ""
                ki        ..           it the UniraraltK of :>ntm
               that nnwrciil  shipntnts of fish fron Laic* St. Clair ('«»r
 »treit) emt*lmtl mtom rtose to the lewis fewd In the fi*  inwi-.rf in «•
 -rtra u and Ntlgiti eoUodes.  nih,r OHMi*ts reported jtotlarly hiffc le»*l§
 x-out 7r,T»} In ft Ji fro. Mnv  other lake* «nd riven alone the U.S./Cmadtan
                                                   fn« tte wter, of 3J of th
.^u-,        **  f* reiyl* of *• "ctl°" of
.*thfla«an can continue for teitntlons enc» the
 r.»s
 VBSF
P.MS
P.SM
YBSF
n.J6T
VKT
li ii n   ^—iiHSrf1 ™*rlttion et «*» '•rcuric ion r«- the hnan body has not vet beer
i ,H;n   STSS??! l* i* ""* WaaaMiiafcle to expect that such a reaction cwaJ occ-r.
P.ll«    Th. nrtvlxum of wrcury in Urti-t iwrem m Ji*ceveTrt in iKtjrti ••.• R.  L.
          »"  ill  •IZi'18*'1**^ °>lt *^* ** ''* "ort "•" *"• " ^f* iraortnt in.-luencs nr
          tnt Bialorlc uivwuies of t*» R!c-s!3uj  substance tiian evir reco»ni-ed.  This
          su&asts that the aut flan could sera- as « source of nethylated rercuty in isan
          A l»e«nt rariew by T, C. Stadtmi, Science 1971, notes the presence of enz?ne
          lystara) aR>ropriite tar the nethylatior, of •ercnric ion in the liven  of naanali
          vntT than nan. rht huaan body Itself adjtit have the c.tpaclty to rethylite
          ••roiric ion.«»  The tresr-ent far nethyl nercur/ poisonini it not t«ll  defined

          '* .  *f V* J0"* ** !*w*»r he"7 •«««.  1-ead. Irihistry wastes contain high leve:
          of lead. It is re-.ronsible for the increased presence in the auensphere.
     Ike potentiij  for tfidw^read nethyl rercurr raitanlB»tiori Is enhanced bv
-«n» kinds of industrial pollution, farbon dioxide, organic vutet. nitr'tes'
and p^o^Trutes provide food for One oitwtism that nernit trans for-atlor, of
isorjanie ancwy runoff fro* indotrin into cetM nereury.H)

                                                             in H«-s o* va
                                                        he» be-j«.l*5

            thresheldi for HBroiry are mtjsie because it is not 'a^vr nx> — jeh
       Mraiiy in the Mood is renutrad hefore polsonin» ocam, '-etaoloiicai
           occur  at 0.4-J.B iMrti wr nil lion of rereury. IJJ
                                                                                                    !?ii pai«-5itn'- i1;  0*12  of th<* fO't unnleJsnnt ailnents afflictirtf
                                                                                                HJ  5--7to-* ire c;ir— notice  an-l often nisdi.ifnosed as lesser nrcftlens, such :
                                                                                                ! <*i '*c ?-, •* irr'-ea, ^r iiist  plain Irrit.i^iHt**. ^$ the lead reaches its, as
                                                                                                *'#t , •"^orl-  'lefinc^I to^ic level in th* '•*,"', t5^* synjitors  cf miisoninp Hecore
                                                                                                'ore c irartercstic .me! Ic.vl  to v:ild Jeliriir, cona, convulsions. MirJness,
                                                                                                'ft*I retarjatiw, hrain Air
                                                                                                ".T/* nroAjc«Hl Hmirj dara^c, ^irt*i  defects, daa»^ to rerTvluctive orians. "  sr~
                                                                                                ' •" irraJLtics anJ Mny ot'wr «Hysiolo|;ical disturbance*.  In ran, iptelafion f>f
                                                                                                ri^iui dust is kno^n to have caused lune (linage resenblinK eaphysera. In Japa
                                                                                                I?"1 case* of severe desenersti^"e N»ne diseo^G occurred. This  vat due directly
                                                                                                ea*uir.)J)

                                                                                                    Toiticolotists are concerned abnut cadritpi as a hazard to nan's nealth. Dei
                                                                                                •v.»rp  is to little irrefiitahl* evidence aho^t t-*« Ion(t ranee  effects of I*** tl
                                                                                                Kviouali; exposure to catkuup, health officals have been slov to set up staolai
                                                                                                :s\»l§ for it in food, air anJ w«er. » joint FnSWfi condssion has suceested
                                                                                                "77-,  ecen thouoh scieritist, Bohert  Mlsson of the S>*dish "atural  Scierie
                                                                                                .Vseareh Ooaisel, in»ists that aninal itudies awl the Japanese cadrtir ^oisonir
                                                                                                Incidents i"*ke that level nueh too hifh.  The U.S. has established  the -wirun
                                                                                                per-issible lei*! apmnt of cadriun  in drin! inc vater as n.il on",  "ejs .remts
                                                                                                of t5ie netal's pres€fice in riv«rs  and reservoirs throughout the cojr.tr. mdicat
                                                                                                that S3 out of 720 water sarnies tested nere hicher in cadniuai than t-e rrescri
                                                                                     ».S?S          These other aetallic haiards that have triBfered  investigations jr» -iclel
                                                                                     YB'SF      lire. a»d arsenic.  Michel has been pjxwen ahle to product cancer. 1'e presence
                                                                                               of any of the previously nentiened netals kill  certainly V detrirental to t e
                                                                                               health of any individual,*2)

                                                                                     p.:?1; :7i      Let us  on atather coroonent of slo^pe - Asbestos.  It is considered
                                                                                     Yf,<:t      occupational disease of the lunys.  Asbestos is * hydrated raenesiu-j-silicsM.
                                                                                               has a very hi^» affinity for xater in both liquid and  vapour fom.  ' It can
                                                                                               certainly b» carried W-rom* air.              '

                                                                                     '•4? 49*       Respiratory diiaajad can occur after breathing air polluted with ashesMs.
                                                                                               It appears in finely divided state as minute particles ranging In tilt lit* of I,
                                                                                               and S mcrora- (unit of nasurevent) in dlareter.  It If thought that even smllei
                                                                                               si»d particles are potentially dangerous. An Increase in cancer has bean found
                                                                                               in persons xha have been in contact or breathed these  particles. »>)

                                                                                     11-1*6         It involvas the pleura and pericardium (the coverings of the lungs and ham
                                                                                               and causes heart failure. Invention is itjiortiBrt. b«cai*e there art no success!
                                                                                               cure once the fibroses has actually developed-  Cases have bean clteJ in Quebec,
                                                                                               Canada.1^)

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P 91"          ~>c*Bt studies hwe sho^n that 1/4 to 1/2 of Hie liajj* of ir^-m *wric.-
x.r..v •  er-M!n detectaMe ast-estos bodies. The ff* KM not set pjidelire*  for asHr
1-26-1?"* rhe "««s;iihwett's I*narti«nt of Pi*>Hc Health established Its c-."  --.ission
          itr, '•!•*.  It is  on" of the first states in the nation to take such action.
          reswlrticn no* bans the application by sprayim o* asbestos fiber*  or  of ra:
          containing asbestos fibers. The nenartnant it authorized to ban tht apnllca-
          these -aterials by any r-ethorf it believes nay cause or contribute to pollut:
          «*;e-.t air. 1?)

               Vxrther topic of interest 1* organic ferdaniite..  The M. S. D.  brour'rt '
          allerrv specialists to .ipeak at tfwir reeling. They titled at "re.it lencth -
          f-« i-ercwMue •Tfanic food, O» talked about chickens being Hashed  in  a detc
          •-"-.ich '•is nothing i*.it M tMW W *i "it1* "r-a-ic -.'--4-nin-.

\.f.J."         '•* Vex Rinland .lournal of 'Wicine has featureJ articles citiri  •?«,•>•.
Vol.ZiS   IS 3 f*»»l. I* see a let of »d*ertisliK lately of 'T»rsaBi<: Rood" ».t «e!i purro
•-1I-71   -es-.i nwn wlt'«ut nUed pesticides or chemical contaniniits. Me ir.sw t%i*
          'ei-Je» mna dierteal soil additions haw had torlMde .Hstrtbution and  tuat v
          l>staneH ree»in in ths soil for nany years at least. At this point in ti-f
          Can suestlen xheflier sueN pure murtnf soil exists. *e «iey find ttsat people .
          **-lrlp a tot wart t«ney for an Inferior food because he haw no standards  fo
          teV- iara»iieall» nromi". "Onenlcally Crowi" food looks Hie Hie blsjest  co
          fraud -It perpetrated on the fcerican nuMlc. * definition for organic is  ta
          or relating to, or derived fro» living ornanls«i (b) of, relating to,  or Ciir
          Ir,- ;aroon coeMMe*.  Therefore, all feod is orrwic and indeed onartically
          •TTv^.ll}  To further ftintaniate the discrepancies of organic cardmi-.; t.i
          look at this atatament.
                                                                                    ' o
                                                                                    V.I
JI.5.4.M.
voi.zw
6-M971
              •The ornanic
         dc*> not I	lii
         shSt(Tnot W mf Kpoi not
                                 lia*ri<»
               and veeetaMes in the iVtf'eJ Star
    	as a fertiliter. Slud",e treated
    ibles or aaythinii that will be eater, rsv..   '
  coldes is present in ta^tet. The aacari.- i: -•
n«*er of taf ray pass out  tl-.mutfi t'-s »«s!
                  called ascaris
         K99>$,W/9O* HiW§llflW( S §•—r,~ —  - - --  ,-,-    .  .             _
         •ffhant... «*en Ala efnuent ii used tovater salad plants thnt are e»»:
         uncooked bf "an, tt» f«r»l»in|[ e)Ri wy «et on to *«se plants and then tr'
         person «N> eats it. Therefore, afeartosls is *ow Hiely  to be » wre.-al e-
         mtal pwbler», cawed b» failure of sewaje treatment and the sii-sequent vf.
         efful«it fer irrtiation."')"
rmim
        MMii.  It was  h
                      a failure
                       cnndittem pnraiM
                                                                 land of v»»t quantie.-.
                   hae  **'*f'l«'l' **** dry M^tf P*r T**r "*• * ^'5r»l  faiUrre,
                  *• In «Jnr o*er countrTes in unlch equally inapproprtata
                  IBM  prevailed and -here sufficient rfiiTWrtrilVinable.   :n
                                                     1> too fine to prewnt    •
                                                     ;oofi«g.™J  Certatalf^,*
                                                     Cfitgi are not"co«iljeiye t|
                                                         th
                                                     irtflhout
unpno .wnlliier eonlalnln? s
ieeajn.li that haa bean *me in
  i never be
                            containw IIWOK i> !»•>»»• to the salt. There  is so littl
                            been done" in tfli area, ftiithergore. the people  of Fulton **
                            awl I'tould vtex »ith skentlsiB any sludge that enters we o
                                                                                                 r*rso-»l       '-ot*i«r urea cr concern and nprhifis an area vhere no one has the answer
                                                                                                 m:-.-**  f.e 5ira>-uw of_t> slnd«e  itself,  "imite n«rtiel« fren the vm itif tlud;*
                                                                                                            •• '. 'Tied *•«• fc - tnJ in t'-e fona of rift -ml ran a*»re to Asst i.irtlcles
                                                                                                             «t ;:ncen- iv.ireelves '.'it' :w.-.l«. i.Si )i\<. ir ttxh close nrortci-it^ to tre
                                                                                                           - -r- r— of ji-.i.!«c.   It i§  sn infrinrcntnt on tht ferson.il rt'-'tts of the^e -•
                                                                                                            f t.-.rsv p»rt>a-« on then i« a violitlnn, hut to «nrav ilud-? IP t*"elr r«ce I-
                                                                                                                  an agricultural  mleivor. t.'nt *l«r«- cfrw:t* can von errect*
                                                                                                 •'•• • rtpc ITS are highly concratrateil and cortarirau-'.  raw toxic t'ie»e »re .V
                                                                                                 — t'-e -f-»t!eal st»te at  t'if tine of ipfaytnV.""

                                                                                                      ff-fr very irrcrtant ar»«s of concern are the Cw» and '-ildlife ^«sen-e
                                                                                                 tV* ri$hinf Lakes, These areai were created lonf before ::.S.l), -.as Hrat-ht ir
                                                                                                 t'-« coimty. I  ir» totally uninnmxed that a sl«d»e di»-x«jl .nr?a r-i-wil ! ---
                                                                                                 cr«»r;.! in »uch rloK! frosici-ity to such » rr*ri\t,  II "os$  it.V>-* -,j»i: ; r
                                                                                                  •-' "jdjerent vu nnt used. If the crons -l  ai=*  r»e«ll h« affecttd.  If ehere i« runoff, then t»e laic
                                                                                                 .ir* \ery capeMe of receivin- the tlralnii;*.  Tha»e can  easily t-ecorr« polluEed.
                                                                                                  .tsrfo-il  al» rii:rate art there are other areas where hunting is nllc •(L.«ter contanr
                                                                                                 _ :s  is possihte  roue so in that the soil and  drainage system have been disti
                                                                                                   i cannot possibly  he j*tt tofether in the ssine f«hion as nature did nillior
                                                                                                 •tars  aj-o.  AnJ to mn concentrated sludge on it i» another thin. It has oniv o
                                                                                                  •.   to fto  and  tiiat is down,

                                                                                                      I  Mould hone that nil the "m-iously pentiened nsterial helps tc '-rirr in
                                                                                                 fxus  a broader persnective of the situation that  confronts us.  71-* fictx  3-i
                                                                                                 '••-•otes  Presented are  researched,  l^rannal thoughts  are included,

                                                                                                     "^e last person thoiirt^  iiivironnentil  plarmine »«it be sn lr*e-r«:  -art
                                                                                                 the conitnity.  It wust be ranajed and directed to be  successful.   '.  ,;.
                                                                                                 ?-*rition$ have a de)rr*!int effect on the corr«»i!ty.   It  is irpr-tart  i-  :jrre
                                                                                                 f-e problen before tlie critical need to face the dae-age arises.
                                                                                    coin

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        .,
           V:S.  2   p. 1010  i
  3.    L-l. A. Say. Illinoii Direct Su'i-llilt.
           S.S. tUFC. :?ar. 30. 197J
           Kxcenits freri report to Division of Water Pollution Control.
           .>slth Department  Fulton Couity.
  4.    Si.-* M '3; Mr. Ray1* ate of Minu.1 of  the KPCF - ftwraticn of
           ' istevater Treatnent PUnts.                 	

  S.    ":..- :1:-«JU Rriumica. 1«TO
           '.ol. 1«.   P.  141
  6.    V.cy:lrriedia Britannic*. 197n
           Vol. 2J,   P.  49
  1.    Licrclapedi* Britannic*. 1970
           Vol. 21.   P.  SI
  ».    >.r.-cl-?«dU Britannic*. 1970
           Vol. It.   PP. 1JJ. 1M. US
  9.   Vurbcok of Scimc* and Fuf^re,  1973

 10.   YfoTbook of Science and Future.  1973
           PP. 362. 345. 364
 11.   S*K England Journal of 'Micine, July 1, 1971
           Vol. 28S   PP. 49-50
 12.   Y*arbcolc of Science and Future.  1975
           H>. 365-S73
 13.   I*.- EnilandJournal of Medicine, Nov. 11, 1971
          Vol.  2IS   P. 1141
 14.   Incyclepedia Iritamica, 1970
          Vol.  9.     PP. j:a. 229
 IS.   Fr.i^clonedU Iritamica. 1970
          Vol.  7     PP. 48, 49
 1«.   Encyclopedia Britamica. 1970
          Vol.  II,    P. 1S6
 17.   N*M Hnfland Journal of  'Wicine, April 26,  1973
          Vol.  2lf. No. 17  P. 910
 II.   Xew Enjland Jwnul of  ^:«^ici^.c,  *•;. 12.  1971
          Vol.  2JS
 19.   NCH Enfland Journal of Medicine, June 3, 1971
          VoL  2S4
 20.   Taartook of Science and Future.  1972
          P.  373. 374
 21.   met WTBUALS:
        a)N*H Enflird .Journal of Medicine, net.  21, 1971. (Vt. 2».  1971 Vol. 21$
        b)\ew Enfland Journal of Medicine IIS April 13, 1972 Vol. 286
        c}Xeu England Journal of Medicine '9  'larch  1, 1973, Apr.  19. 1973 Vol 2SI
        dJSclence, Vol. 181,  Methylftercurr Polsonirj in Iraq pp.  230-40
                          STATEMENT

                             BY


                      JOANNE H.  ALTER

                       COMMISSIONER


                             OF

THE  METROPOLITAN  SANITARY DISTRICT OF GREATER CHICAGO

                             ON


         DRAFT ENVIRONMENTAL IMPACT STATEMENT

              FOR THE  PRAIRIE PLAN  PROJECT


                 FULTON COUNTY,  ILLINOIS
                      Presented  at

                PUBLIC HEARING  HELD BY

 THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                 Monday, July 26,  1976

                      1:00  P.M. and
                      7:00  P.M. CST

               Hallace  Park  Field  House
                   Canton, Illinois
Report by  - Rachel Sc'midt

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KSDGC Statement on Draft BIS for Prairie Plan
          Thm Metropolitan Sanitary District of Greater  Chicago
is pleased to have this opportunity to make • statement  on its
Prairie Plan Project in Fulton County and the recently itsued
draft Environmental Impact Statement (CIS).  These remarks are
intended to supplement our More detailed written response which
im now being prepared.  Th* United States Environmental  Protection
Agency ie to be commended for moving; forward and completing the
draft statement on thie comprehensive and complex project.
          The Prairie Plan i« a fundamental redirection  fro*
waste and depletion to recycle and reue*.  The project demonstrates
on a major seal* that through careful planning, monitoring,
engineering, and operation, municipal wastes can be beneficially
utilised to reclaim »trlp»mined land and fertilize place land.
          The successful implementation of the Prairie Plan has
been mad* possible through the cooperation of the local, state and
federal governments and various agencies which have been involved
in this prog-am-  He would like to take this opportunity to
recognise the following organisations and thank them for their
important contributions and continuing support and effort:
     The Fulton County Board
     The Fulton County Planning Commission
     The Fulton County Health Department
     U. S. Environmental Protection Agency
     Illinois Environmental Protection Agency
     U, S, Department of Agriculture and Soil Conservation Service
     Stat* of Illinois, Department of Conservation
     State of Illinois, Department of Transportation
     State of Illinois, Department of Business and Economic
        Development
     U. S. Geologic Survey
     University of Illinois
     Spoon River College
     Cities of:  Canton
                 Cuba
                 St. David
                 Bryant
     Scientists and Researchers
                                                                                   HSPCC Statement on Draft EiS for Prairie Plan
                                                                                                                                           Page 2
          The Metropolitan Sanitary District has, from the
beginning of this project, invited governmental, organizational
and citizen input in the program and its specific site developments.
The Steering Committee, for-med at the Inception of the project,
has continued to provide valuable input from citizens and Iroe all
levels of government.
          In its «0-ye«r history, the District has always strived
to provide maximum service and, at the same time, protect the
environment.  In 1967, the Board of the Hetropolitan Sanitary
District, after reviewing a large number of wastewater treatment
and disposal or recycle alternatives, adopted the policy of
recycling »«stewat»r treatment by-producti on land.  This commitment
was the impetus to establish the Prairie Plan now operating in
Fulton County, Illinois.
          A great deal of research work on the utilization of
wastewater solids as a fertilizer and soil condition* srecertejl »l|e
actual implementation of the Prairie Plan in 1971.  i'hu*  the project
should not fce considered as an eXj'«"i*^ineiit v on tne contrary, it is
a large scale {implementation of the long and widely practiced
utilization of wastewater solids in sn agricultural setting.
          From its inception, the Prairie Plan has been funded solely
by the^ District,  The cost of this vast project has been great,
however, and financial aenlatance from the Federal government would
be most welcome.  Sine* the Prairie Plan has nationwide significance
with respect to two »ajoriproblei»s--di8posal of municipal wastes
and reclamation of strip-mined land—Federal funding would be quite
appropriate.
          A recently adopted Federal law, Public Law 92-500,
expressly encourages the recycling of municipal wastewater solids,
and has established programs for providing Federal funds to assist
in the attainment of that goal.  The draft Environmental Impact
Statement which is being addressed here today has been prepared to
assist the USEPA  in evaluating th- District's grant application.

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NSDGC Statement on Draft CIS for Pr»iri* Plan
                                                        Page 3
          The CIS for the Prairie Plan 1* really quite unique in
that-the project has already been in operatic.- for several years.
Thus, the project's impact on the environment la not merely
speculative; there is a wealth of monitoring data, operational
data and supportive research available.  For this reason, we 'eel
that Mm* Of the statement* made in the EIS regarding the impart
of the project on surface water, the health effects of the project
and the matters of odors and noise are incorrert.  A detailed
discussion of the items which are felt to be in error will be
included in our written presentation.
          In addition, the Draft CIS fails to delineate the
comprehensive objective* of the Prairie Plan, which are;

     1.  KMCIE wastewatar treatment by-products through
         rebuilding nutrient depleted moil,
     t.  COMSnm natural resources by alternate soil enrichment
         through a liquid organic fertiliser and the conversion
         of urban waste product to a resource.
     I.  COMSOtVG energy by the reduction of fossil fuel energy
         in the weetewater treatment process.
     ».  IWKOTE environmental quality in the Metropolitan
         Chicago Area and in rural Fulton County.
     S.  pMreCT the environment through a safe, intensively
         monitored and regulated recycle program.
     I.  EXPAND Fulton County economic base through increased
         employment opportunities, ancillary facilities, real
         estate taxes and personal property taxes.
     1.  PROVIDE a broad spectrum of multiple-use benefit* and
         complementary land uses including agriculture, conservation,
         recreation, wildlife management, natural science education,
         urban and industrial developments.
     t.  DEMOMSTMTE a full-scsle viable working model for the
         •ation in the utilisation of advanced wastewater
         treatment technology, background research, data and
         experience through a recycle and reuse philosophy.
                                                                                    MSDGC Statement on Draft EIS for Prairie Plan
                                                                                                                                            Page
                                                                                              The Prairie Plan is one alternative that does not  use
                                                                                    extravagant amounts of energy and demand increasing amount*  of
                                                                                    valuable urban land.  It has amply demonstrated that land ruined
                                                                                    to extract energy resources can again be made productive, and
                                                                                    continually replenished without having to resort to costly and
                                                                                    scarce petrochemical fertilizers.
                                                                                              Immediate energy savings include major reduction in fuel
                                                                                    used during the treatment process, and long term energy savings by
                                                                                    reducing further depletion of petrol  chemical resources used in
                                                                                    rnamiircial fertilizer.   Energy savings will release millions of
                                                                                    barrels of oil yearly for alternate uses as well as increase energy
                                                                                    self-sufficiency for this Ration,
                                                                                              The Metropolitan Sanitary District ii  proud cf the Prairie
                                                                                    Flan in Fulton Count/t  we feel that the environmental monitoring
                                                                                    and careful operation of the program JBj^iniure^th( protection of
                                                                                    the environment.   A full range of professional and technical skills
                                                                                    including planning, engineering,  research, management and operations
                                                                                    has gone into the project.   Thme efforts have been recognized
                                                                                    nationally by the American Society of Civil Engineers (ASCC)«**>*.
                                                                                    Outstanding Civil Engineering Achievement Award  of 1971;  by  the
                                                                                    National Society of Professional  Engineers (NSPE)?*One of the Ten
                                                                                    Outstanding Engineering Achievements  in the United States, 197?;
                                                                                    and the Izaak Walton league.
                                                                                              In operating  the Fulton County Project,  no detrimental
                                                                                    health effects have been evidenced or substantiated nor have water
                                                                                    quality problems arisen.   The programs, technology and experience
                                                                                    relating to this Prairie Plan Project in Fulton  County will  lead
                                                                                    the way for other sanitary districts  throughout  the Nation,  and
                                                                                    provide valuable methodology for  an alternative  to utilize a once
                                                                                    discarded resource material.
                                                                                              The Metropolitan  Sanitary District  believes  that the
                                                                                    USEFA should adopt a national policy  of recycle  as. demonstrated  in
                                                                                    the Fulton County Project.   In adopting this  policy and  providing

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MSDGC Statement on Draft EtS for Prairie Plan
                                                        Page 5
                                      SECOND REVISION 8/17/76
                                                       B5.W
the necessary and essential funds, th* USEPA would be implementing
their stated preference for land application as a Beans of wastevater
solids disposal.  Such funding by the USEPA would support the
findings of the Ad Hoc Panel on Sludge Disposal/Utilization which
concluded that with good engineering practice, proper experimental
design and a better understanding of the •can* to protect human
health and ecosystem, sludge utilisation options can be made
environmentally safe and acceptable.  The District feels that the
Prairie Plan represents an answer.
                     STATEMENT

                        BY

                 JOANNE H.  ALTER
                   COMMISSIONER
                        OF
THE METROPOLITAN SANITARY DISTRICT OF GREATER  CHICAGO
                        ON
          DRAFT ENVIRONMENTAL IMPACT STATEMENT
              FOR THE PRAIRIE PLAN PROJECT
                 FULTON COUNTY. ILLINOIS
                                                                                                               Presented at
                                                                                                          PUBLIC HEARING HELD BY
                                                                                              THE UNITED  STATES ENVIRONMENTAL PROTECTION AGENCY
                                                                                                          Tuesday, August  1.7, 1976
                                                                                                                 7:00 P.M.
                                                                                                            Dlrksen Federal Center
                                                                                                              230 South  Dearborn
                                                                                                              Chicago. Illinois

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     The USD.  after  Initiating Its  Sol Ids-on-Land  Program with
 the  Board of Commissioners  decision in  1967,  has accomplished
 In the Prairie Plan  the  first  large-scale  reclamation  program
 baaed on the recycle of  wastewater  treatment  by-products.
 The  policy established by the  Board and the nearly 10  years  of
 subsequent reaearch  . development and Implementation have
 demonstrated that recycle la not only the  safeat,  but  an
 economical and conservative Methodology for managing sewage
 •ludge.  The Prairie  Plan la an Integral part of the MSDCC
 facility plan.  Though the EIS has  concentrated on the Fulton
 County Prairie  Plan;  It  It seriously reals* In not mentioning
 the  7 Billion  people  served In Chicago  by  the Prilrle  Plan and
 the  Integral part of  the MSD facilities In the metropolitan
 area.  The Prairie Plan, operating  In Fulton  County, has  bene-
 fited millions  of urban retldenta with  cleaner air. cleaner
Mater, a productive re-use of processed solids, no new land
or capital coata for  storage, and a much reduced energy cost
and  consumption for treatment operations.
    The USEPA'a EIS on the Prairie  Plan  la unique  in several
wayt.  The Impact statement ha* been written  after the project
has been In operation for five years and ten  years  of  research
ha* been completed.  The studies that Indicated the cost
effectiveness, energy saving, and environmental safety are now
history rather  than projection* of  alternative course*.  When
the program waa In the research, planning  and design stages,
there waa little literature on which to base development.
                             -1-
 There were no governmental guidelines or standards   The USD
 In initiating this program, established as the highest priority
 that the program would be environmentally safe   Built-in
 monitoring. Information feedback, checks and fall-safe options
 were integrated in the development to prevent damage due to
 unforeseeable errors,  accidents or extreme weather occurrence*.
 The system was designed to be operational under all condition*
 and to be a permanent  facility.  The MSD with partial federal
 funding initiated,  with the University of Illinois, studies
 and research on liquid fertilizer application,  plant response,
 toll  development,  and  environmental  protection  and quality.
 After several  years of that still on-going program,  the  MSD
 established a  number of "micro recycle demonstration sites" In
 the Chicago and Cook County area  and several  beyond the
 Metropolitan region   These provided valuable work data  and
 methodology that wan Incorporated into the  about-to-be initiated
 Fulton County  Project.  The MSD.  In  its  own behalf,  searched
 literature  and available documented  sources,  initiated research,
 and established with Its Interdisciplinary  professional ataff
 and consultants, the program,  the planning  and  the operations
methodology  that became the Prairie  Plan in Fulton County.
    The Prairie Plan has been  successful.  This success is
demonstrated by the encouraging documentation of soil develop-
ment and plant response* In Fulton County.  The Prairie Plan
ha* not degraded the environment;  it has acutally Improved
                                                                                                                 -2-

-------
water quality leaving the »ite, Implemented conservation practices
and is reclaiming apoil lands into farm  fields able to support
agricultural crops.  The program continues to be monitored by
the MSD a* well ai county, atate and Independent organizations.
The USD ii nost appreciative of the cooperative and competent
contributions from many federal and itate agencies; among thea,
the It. S. Department of Agriculture, the Soil Conservation
Service, the Cooperative Agricultural Extension Service, and
the University of Illinois,
    Though there ham been, on rasa occasions, sone human and
operational errors, as well as some Major act* of vandalism,
the plan's fall-cafe systems have operated as intended.  At
each occurrence, and for each alte, repair or modification was
Immediate and no permanent damage was done to the site or to
the larger environment.
    A msjor point of benefit in the Tears of research and
development prior to and continuing through the project Im-
plementation haa been the modification and rperatlonal changes
indicated by the research and Implemented in full scale oper-
ation on the site
    At the inception of planning for the Fulton County Project,
the MSD, In conjunction with the Fulton County Board, requested
cooperation fro* federal, state and local agencies and
governments, established the Pulton County Steering Committee.
                             -3-
The Conraittee provides a forun for information interchange
between citizens, governtnent agencies, educational institutions
and the MSD   It provides valuable Input and public response
which has modified and in some cases redirected specific
aspects of the recycle-reclanation program.  An example of
this mutual benefit ban been the 400-acre Fulton County con-
servation area leased to the County for a dollar a ye^r to
provide recreation and conservation lands available to local
people and citizens of the State.  The establishment of this
Steering Committee h«» demonstrated Many tines over the value
of Intergovernraent and Interagency cooperation, wirh citizen
input.  The idea of establishing this '.road base coordinating
conmittee predates and, in fact, encouraged federal program
requirements.
    The Metropolitan Sanitary District Is, and has always
been, concerned not only with the safe operations of the
project, but also with the beneficial results that land
recycle of solids could have on local and national resource
recovery programs.
    Though the project has not been without criticism, even
the most Intransigent critic recognizes the benefits of soH.ds
on land and of recycling this resource.  A major concern
presented has been; even though the project operates safely.
are there possible dangers of long-term or even perpiHual us*
of the site?  The MSD and the University of Illinois research
Is 6 years ahead of actual operations on the site   Any possi-
ble potential damage to the land, plant materials, water or

-------
 the environment will be  forecast  years earlier  through  Choc
 continuing studies.  There would  be  time  mi  the  professional
 expertise to Modify, change or  redirect the program  long before
 * point of critical damage could  occur,   The  HSD  has •pent
 millions of dollars of It* own  resources  as  well as cooperated
 In federal funding for long-tern  and comprehensive research
 and monitoring.  It believes  that the project not  only has end
 doei demonstrate safe and productive re-use,  but  that primary
 research toward a national policy for resource  recovery  In
 this field has been planned,  demonstrated and documented.
The MSB is confident that a significant amount  of its on-going
raoril torlng can be redirected  without endangering  the validity of
 the data base.  The MSB  propose*  to  redirect  a  portion of its
 research activities toward specific  areaa of  development unique
 to this lite, such as the Big Bluesten Prairie.   The MSD
 accepts the responsibility of having pioneered  and demonstrated
 the validity of the economic  and  environmental  benefit*  in
 the Prairie Flan.  It will continue  to make the research, the
 information and the methodology available to  the  federal and
state governments in the development of other recycle
policies end programs.   The HSD will cooperate  in larger and
•ore nationally applicable research  end operations studies.  It
 la willing to provide the professional expertise,  the land and
equipment resources; but would  require funding  for these wide
rent* programs and long-term  activities.  Though  the vast
msjority of work accomplished In  this recycling program h«s
                              .5-
  been entirely funded by  the  USD.  it  1.  no*  .eeking and  urgently
  requesting reimbursement funding  and long-term research ind
  operation, costs  for th* nationally  significant work  initiated
  in  Fulton  County,
      The 0.  S. Environmental  Protection  Agency i» to be  commended
  for  moving forward and completing the EIS for thi. conpreheniin
  and  complex project   The HSD expected,  and is appreciative,
  that  the document affirms the recycle program and concur. In
  recommending that a national policy of resource recovery and
 recycle be established and implemented.   The MSB is  taking thli
 opportunity to request amendment and modification of  the draft
 statement.   In the preparation of  the Draft  EIS  for  the
 Pratrie Han,  some areas  of  benefit  and  value have been  over-
 looked; some base  and research information misinterpreted,  and
 some errrrs inadvertently committed.   The  USD has submitted
 recommended changes,  deletions and modifications  to be Incor-
 porated In  the final  environmental impact  statement,
     However,  the E1S  contains err.ors,  false  conclusions  «nd
 needless recommendations,  which will be misleading and  damaging
 not  only to this project  but  the nation's policy for recycle
 ami  land treatment.  Summarized below are eight major  areas
 of concern  to  the District which are contained in the EIS.

 L	Environmental Monitoring
    The EIS states r.hat rhc existing District environmental
monitoring and research program* are  Inadequate  to ascess

-------
environmental Impacts,  The EIS author! go  lurther  to  suggest
additional monitoring and research and that such  an expanded
prograa be reviewed by in Independent agency  (unnamed)
    the District; haa the noat extensive Monitoring  program,
ever attempted for a sludge application site.  The  EIS  doe*
not recognize nor discuss natty Important aspect*  of thii  pro
gram despite the fact that every opportunity va»  given  the
author! to Investigate the program   The exliting prograa It
discussed In detail In the attached statement and li designed
to monitor the effects on toll, plants, surface and ground-
••Mr, air and Indigenous inlmals.
    We reject the concept that the project requires an  Inde-
pendent agency for review of all data,,  Freiently,  fhe  project
la monitored by the Illinois Environmental Protection Agency
(UP*), Pulton County Health Department {FCHD) , United  States
Geological Survey, end the University of Illlnola (V. of  I.).
PeerIdle reviews of the environmental monitoring  data have
been isade by the Food and Drug Administration and thr> United
States Department of Agriculture.  Also, the District and
the University of Illinois have been active In disseminating
such information In the technical literature.
    He believe that the existing environmental monitoring
prograa can determine any potential ham to the environment.
II.  Alleged Odors
    The CIS statea that there la insufficient dilution  of
alleged odors at the Pulton County site.  This i* concluded
                             -7-
by neans of calculations raade regarding atmospheric dilution
of alleged odor emissions it tht site.  In addition, odor
complaints phoned in to the FCHO are u«ed to state that the
probability of «n odor complaint b*lnr, tied to the District
project la greater than 7QV
    The calculations used to arrive at the atmospheric dilution.
at the site were found by the District to be erroenoua.  Dilu-
tion  four miles from the District sludge holding batir.i wsj
calculated In the EIS to be a 2-4 fold reduction   In fact, the.
dilution at 4 Biles from the holding basins Is a 7 - 75 fold reduction.
    Analysis of complaints to the FCHD neglected to Include
the fact that only about 21 of the complaint! are confirmed by
the FCHD,  The statements about probable sources were baaed on
wind directions compiled by the FCHD at verified odor sites.
Unfortunately, wind direction measurements have a variance of
22 5 to 45° from the reported direction   If this  fact were
Included, one could easily Indicate a nearby agricultural feed
lot.
    The District objects to the entire section on  alleged,
odors as written In the EIS and asks that this be rewritten
IB the final statement,
III.  ttetals in ._the_ jFooJ_ jJjiJUi
    The EIS suggests that there Is a health,
hazard du^to metal accumulations In  the crops grown on sludge
amended soil.  However,  little experimental evidence Is pre-
sented to support  this  suggestion.

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    The U. of I..  the District and the USEPA have participated
In a joint research venture to study, among many things, the
metal uptake of crops grown on sludge amended soil.  The data
from this program conducted since 1967. has been made available
to the EIS authors, the USF.PA, and has been published In the
technical literature.  This data has shown, contrary to what
Is stated In the EIS, that metal accumulations are not the>
limiting factor In sludge application.  In fact, metal levels
in crops have been found not to be related to accumulative
sludge application.
    The recently released USEPA technical bulletin on Municipal
Sludge Utilization published on June 3, 1976, contains no
limitations on sludge metal levels nor does It Unit applica-
tions based on such metal levels.
IV.  Sludge Quality
    The EIS compares certain sludge quality parameters with
then existing FCHD regulations.  It Is concluded from such a
comparison that the District sludge shipped to Fulton County  Is
Inadequately stabilized.
    However.-the comparison with FCHD regulations  Is inconsis-
tent with District sludge quality data.  The only  values not
consistent with the FCHD regulations were  sludge alkalinity.
Recently, the FCHD has amended its sludge regulations and.

                             -9-
 1owered its  alkalinity  criteria.   No  further values  are
 anticipated  which  would not  be  consistent with  these new
 regulations.
    The use  of  the FCHD regulations for  sludge  quality to
 condemn District sludge quality ts Inconsistent with the fact
 that  the FCHD has  never cited the  District for  sludge quality
 violations.
    The EIS  after  reviewing  the FCHD  regulations and District
 sludge  quality  concludes  that additional lagoon!ng at the Hest-
 Southwest Treatment Workc is needed prior to shipment to Fulton
 County.  In  fact,  the District  has been  lagooning sludge prior
 to shipment  to  Fulton County.   However, due to  the northern
 Illinois climate,  it is not possible  to provide lagoon sludge
 to Fulton County during  the winter season.
    We object to the abov? recommendation in the EIS  as not based
 upon valid data and ask that it  not be included in the final
 sta tement.
 V.  Field Runoff Basin Capacity
    The EIS states  that the District  field runoff basins are
 undersized and cannot rotain the 100-yeai storm.  In addition.
 siltation is stated as sufficient to even /iirther reduce this
 capacity.
    The calculations used to determine capacity assumed that
 the soil had no absorption capacity during  storm events   This
 is an unrealistic assuraptiqp.  According to accepted  engineering
principles, the field runoff basins were designed  to  accept
                            -10-

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 th*  100-year storm.   Additional capacity wa* provided for
 possible  siltatlon.   This capacity exceeds recently published
 requirement* for agricultural fsedlots.
     Ml of the above calculation* and field runoff basin
 capacities were submitted to the IEPA and permits Her* issued
 by thli agency without any question on thl* phase of the
 project.
     Th* Wittier doe* not agree with the conclusion chat th* field
runoff basin* ara Inadequately  si*ed and asks that thl* be
corrected In th* final *t«te»ent.

 VI.   8urf«c«W«t*r Quality
     the IIS state* that th* »urf«c« water on th* District's
 Fulton County »lte haa level* of contaminant* above *t*te
 standards and that thli is a r**ult of discharge* from sludg*
 •tanded toll*.
     It 1* true that surface v«t«r quality at Fulton County
 for  toa*  eonatituant* exceade St*te of Illinoi* standard*.
 •owever,  there 1« no evidence In th* EIS linking luch w*t*t
 quality with District operations,.  The surface water at Fultot
 County i* Inflnancad mainly by the previous strlpmlning opera-
 tion* at  the lite.   Also, there are discharges fro* sewage
 treatment plant*, sanitary landfill*, ceptlc tanks, feedlots
 and agricultural non-point source* which Influence surface
 water quality.
                             -11-
    Th* nose compelling evidence rfiich shoits no degradation
of surface water quality at thf site 1* the quality of Big
Creek vhlch flows through the District property.  As noted in
the EIS, water quality In Big Creek leaving the District's
alte is consistently of better quality than water entering the
site.  The obvious conclusion is that District operations dp
not contribute to surface water degradation el suggested in
the EIS.
    In addition, the EIS goe* on to assess the water quality
of discharges fron District runoff basins.  They COB-
pere such water quality with what is purported to be the 1EPA
standards for these basins.  After this evaluation, it Is
concluded in the EIS that excessive violations haw* occurred
and that this represent* the major resson for surface water
quality degradation at the site
    However, we believe the BIS author* did not utilise the
proper standards which are enforced by the IEPA in permit
conditions for the Fulton County site.  Use of the proper
standards would have revealed that on rare occasions are the
UFA standards exceeded.                                     —
    The District does not accept the statements In the FTS m>
surface water quality and asks that ther be rewritten in the
final statement,
VII.  Alleged Pathogens from Sludge Spraying
    The_EIS^suggests that there is * significant health hazard
due to pathogens being present in aerosols created by sludge^
                            -12-

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                         evidence  If given  Co  support  thli
•prlying.
suggestion.
    The District has coawjiled  for  the records,  a  literature
survey which deals with ttiti topic,  this  is contained  in  the
detailed document subaitted.   The  survey concludes  that there
1* nn health hazard from sludge (praying.
    C!i« District now has « contract with the USEPA  which is
Investigating the aerosolliatloo of bacteria and  virus** fron
sludge (praying.  This contract is being conducted  In coopera-
tion vlth Illinois Institute of Technology Research Institute.
    The conclusions in the CIS are unjustified  and  certainly
jii ••slni i  until the study is completed.  He ask that the
statements in the BIS be  amended  and corrected in  the  final
document.

fill.  Alleged Health Hasards  froei Hetal Inhalation
    The EIS presents calculations to determine  the  sublent sir
levels of certain metals downwind of • sludge sprayer.  The
EIS concludes fro* these calculations that there  is a signifi*
cant health hesard frae these  calculated ambient  sir metal
levels
    •owe»s--, Che calculations  in the EIS are erroenous  anjl
are too high by • factor of at least 100.  The IIS  author*
llBpl* forgot to include a factor which was pert  of their own
calculations.  Therefore, the  conclusion* about ambient air metal
leT*ls are erroenous and should be corrected in the  final EIS.
                            -13-
    In closing. I would again ask that your agency earnestly
consider this tummry and the attached detailed document before
issuing the final Environmental Impact Statement.  The District
also strongly urges fce USEPA to rewrite the CIS in lieu of
merely attaching the public and written coamentc to the first
draft of the EIS and making this package the final Environmental
Impact Statement,  This EIS requires a complete rewrite to make
it factually correct and commensurate with existing data and
scientific information about the Fulton County site
    I will make available to the USEPA all of the District
staff who have participated in the writing of the District

    The Metropolitan Sanitary District would like to thank
the USEPA for issuing the EIS and to express its appreciation.
He join with the USEPA and Mr.  Russell Train, its sdnlnistrs.
tor, in supporting a national policy of environmental safety,
resource recovery and energy conservation.
                                                                                                                -14-

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                                                                                    lit
          Bagueof
             mmmn an im mtrr maaummreu. IMPACT aaammrit

        siumx DISPOSAL au LUK mcuswjoK » mjKH warn, ILLUIOIS

                                 August 17, 19T«
                       **•*. fcilj asdta, natural lt**oun*a Chairaaai
UK La*gu* of Ifcsian Voter* of Cook County li pleased to off«r tit* following co»-
•anta on tlM Bnft brrironaenUl Input 3tataa»nt for Sludge Di.poeal  and Land
ItoeUiBUea m Pulton County.   UK development of anilfonaaiitally sound l«nd re-
«J*a»ti<»i ism* BMII eipreeaed la our continuing support of federal and  state (trip
•rile* legislation.  M»intemx» of air and water quality *t*naarils i» fount in our
long-standing support of both regulatory «JK| enforcement nsaaurea inherent in the
Clean Mr Act (r.L, 9l-*0*) M(| th* Padcral water pollution Control Act aa»n*»nt*
at 1972 (f.t. 92-500),  we an MM concerned with tit* Issue* of nut* disposal,
r**our** recovery and *n*rgy c n**rv*tion.

IB NB**a*>*r 19TJ, Ihf League of Wai in Voters cuaamted favorably and with specific
raweareh mi. lasjsmli limn on th* drift atavlranBantal A*****Mi>t of the  Ml ton County
lt*claisationf or Prairia Flan,   for th* record of thi* haarirw,  we have not changed
our pultloo ind vould Ilk* to reatate a portion of It aa follomi
    *...Wt Mao th» Dittriet'a projact aa a rmaarah *xp*rlia«it and dnaonatratloR
    project ullieli ha* U laMiiduua iaplicationa for tlw nation aa a vtiol* and have
    Included «n ootialatit: deacrlption of the rralrl. Plan in our national publi-
    cation, aniroimaiital update OB Solid lfc»t« Manaa-eaant.  Sept«**r  1973, League
    of mum Voter* Mucatl n fund, fubUotlon Ko.*^>. . .with ap»cjfie referenee
    t« imiajt altadf* in taatiaonjr before tfte Hoiiac Public Norka Comitt^e on pro-
    Doaed aaiiirrtaiintii to the Federal Mater rollution Control  Act in Dccofeer 1971,
    th. Lea«-u< of tkawn Vstara of th* United State* Mid,  'The  Uacue
    •ttpport* projecta dmn^ad to deacnatmt* Uw affMitiirmaaa of v.:nf iraag*
    aludf* to r*elai> alned land and prevent aeld miim drainac*.   Lvagura  in coaat-
    al area* and arouni the Oreat lake* ha*c lent town aerioualT concerned about
    duapinc aludte Into ocean* and lake* and have *ou«ht a non-pol luting ex>ana of
    dlrpoaal.  H* hope that utiliilnc aludge to ooiftat another  type of  wwironnent-
    al  l»»t . retumiiwi othenrte* uaeleee land to pro• for  neat
  4rjrin« operation* thia year and fa«e  a major increaee  in that eoat for vm   ttM
  u*e of nature! gaa for this purpo» u highly questionable.  &ch  of  theie'iirobleav
  i*  a aerioua .n»»ron«ental  threat  but coliectneiy they  are  a a»jor challenge to th*
  United States ftiwronnental Protection Agency.

  nearly four yeara after paaaace of T.I.  92-500,  the Section  20i(d) reouiraaenta for
  "recycling  of potential  «euag« pollutants  thrnugh the  praductiori of agriculture
  ailiriculture, or  aquaculture pr ducts"  and'the ultiamte  diapoaal of aluog* In a nan-
  ner that will not reaul*  in emriromwntal  hazards' reejain etaentlally unaddreoied.
  The Agency's June 3 Technical  Bulletin  on Mumcii)|j  Sludne Manaiement places respon-
  sibility for determining  the heavy  metals  levels  of sludge used in agriculture on
  the Pood and Drug Administration and  th* Department  of Agriculture.  >fc are without
  definitive  directions  fnja  the U.S. EPA uhich is  the agency reepoosible for enforc-
  ing r.i. 92-500.

 «ie  Uegue  position mipports uttllution of aludge  for reclaaaition of atrip erined
  tanda.  In  apite  of th* negatiw <|ue«tiona raised  in th* Ijapact Staitaawm(. it
  clearly afateai -Seia«ge iludge ia particularly well adapted for ua* on atrip
 nined  lands where  the topsoi*. has not been replaced" {page 11-55 and project*
 eno uraglng remits for reclamation.  Since there ate approxiaait«ly 1CO.OOO
 acre, of unrectaiawd pre-l»w land in Illinoia, the potential  for sludge utilisa-
 tion la great but mat wait for a policy decision by the 9.E. EM,   We would
 •<*•?,->*** to point out that strip nlning is incremsJng in Illinois  with specV>
 reqMiraawnta under the Illinois Surface fcoed land Conservation Act for the return
 of-row-erop lands to their original use.  No action can be taken to utilize sludge
 on any of thia  land without n policy decision from U.S. EPA.   we are alao  aware
 "l^the use of aunicipal aludfe on agricultural land by a large  number of .other"*
 •"ft**, treataient oyotenw in the state.  (See report of the Illinois Advi|pry
 &>emttee_9n Sludge and Maatewater Utiltaation on Agriculture Land, February
 1335»J  Itie District's Pulton County Project utslitea sludge  on both etrip mined
 and place land,  offering a unique laboratory for monitoring a total land utiliza-
 tion prograa in one location,

 fh* Fulton County Project has tieen funded by residents of the Metrict and we
 strongly urge close cooperation between the Wstrict and the  U.S. fiHfironiaental
 Protection Agency so that thia Jargeit project of its kind can be scientifically
 evaluated with  a  broad, national distribution of research results,   tne project's
 implications for  the entire nation are too broad to place the financial burden
 on a local  jurisdiction.

 The League,.agrees, with, the .District, the wtata and.federal agencies that tni*
 pro^e^t requir*s..car*fUl eumtaTing to d*t*i«in* both positiv* and  nacatim*
^naeTiaerices.  -we agree that only properly  digested^ludgei should be shipped  to
 Hilton County so  that  health natards froai this source are ellannated,  ftie beat
 engineering  a^^ewfut'-rins ismtt.b*  u**d to  protect groun<| and surface  ifaters
 from contamination. The w»^*r,*iualltjf^standards  o£ the Pollution Control  Board
 must be awt  at all times.   Heavy nwttla and toxic  substances  in the aludge, soil
 and  crop nuat be  acicntifIc.illy evaluated,   we recognize  that the potential build

-------
  up of heavy SMttals, particularly
  the land.
u», could liMit  future agricultural use of
  Tie Uagaw supports those provision* of P.L. 92-500 «r.leh require efflu.pt ll.ita-
  tlona,  or prw-trsatasant. for Induatrlee dlscharrina- to auniclpal systflna and asks
  U.S.  B>A to oppose any tffort to Makan theee provisions in p*ndin« aawndnents
  to  the  IIH, since thajr will help reduce the load of heavy petals and tone sub-
  stance* In uleipal sludce.  He reconlae that a  lane share of these substances
  COM* fro* doawatlc seieure aa Mil and would euccaet an educational proa-ran to
  fuide coneua»n  In the selection of how product* MMcn do not contain these
  eontaatlnanta.  M aupport your rarnaaiimlatlona to eJnt.l.e direct health hazards
  and believe the  District's future action* irtll incorporate .11  of theai.   We believe
  the iatroved evaluation of Indirect health hazards  requires your cooperation In
  research and fundlnc.   The Mbllocraphgr is replete  irtth District research reports
  u  Mil  aa vniTeraity  of Illinole research reports.
- In  teoeral.  M support the rrairie Plan and urge leas  rhetoric  and enre  research
  to  establish a national  policjr  on aluda* utilitatlon since the  quantity  can only
  Increase and haa  rno«n benefictel reeourcee uhlch »e vould like to see effectively
  and safely utillied.
                                                                                 7  J    -y
 '•a Pate V in the Hat of Federal Slate I local acencl-s t Indlvldusls Hotlfed of
                                                                                     I IBM ff2
 tl.is action, ai> Organisation aede up of a very large crouj of cltliena sno are
 probably the «ost Interested concerned I affected by this project sere oaltted.
 They are the FuLTCB COIHTT CITIZFVS FOP nCTTfJI nT»lTH * -CT1BO: HUTT e»o are the
 reoldents,  nxpayr ra tt voters of Fulton Codnty.
           On Page 1-1, I call your attention to an apporsat i-irtahe-thsre are    ~\
 512.WO sens In Fuller. Co. ad there Tore *b,COO aci is of strlppedlard eould
 not be GO* but •*.
           I question the sentence "Tne Sanitary District does not anticipate any
 future sj i^ i f cai.t  land purchases upon fulfilling the developoent plane for the
 pr> cert lai.d holdlm."."  '''he Dec. 1975-ABi:i CORPS OF TGIr'tlM— OPBAII »»TI3I
 D.JJL E 3TUDI	TLt. C::ICAGOUUD U DTJIOW PIJul Include the Fulton County project
 as one of the four  sources of disposal  leeded tc Inplc ont the underflow (or tunnel Plan)
 for which hSD is also ssklnc the Federal  overnaent to finance "1th s pries tag
 of rillloiis of ooll»r«.  leferencc to additional land neida In Fulton County is eede
 several tines.  I quote you ore of the« ft*pesdlxes-page 1-22 line 60), "-it ie
 propoeedto expand the Pulton County Prograa.  Presently, over 15,700 seres sre
 owned by IISDOC."  "If the Fultor County elte is to be expanded to s»et the total
 systea disposal need for the year 2OOO, soae 2J,«00 seres eould be required for
 direct application.  Based on the preeent ratio of laasl uss, l.s., productive
 versus gross scrsage, tale level of application would require s total coa itient
 of oa,«OO scree."
           In the evaluation of the Prairie Plan, the past, proeeat, ear! future of
 MSDOC aaat be considered.  This project directly affects sany lives of the
 cltliensi a:Ki rfldecte of title coui ty, enoee property, buslneeeee, hoeMe, llvea,
 end wxlstsncs In Pulton County eould depend on the eoralualona reached >y this IIS.
 Of uteost Isportance to us are the pending aaagere of aa experiment of this alia.
           The report statss—the eurfaee eater ea aad near Ine RSCOC Prlarle Plan
has been cuntalnsted by runoff froa the eludge flelde.  "Strip sluing haa left
 etteeply sloping spoil aound enlch aay increase the espselty of store runoff to
 carry suspended solids Into receiving eeteri.  funoff over etripalned areas and
 eludge application fields la Host likely responsible for poor etrsasi quality.
 The estsblished aonltorlng progresi la Incapable of revealing this respective sourese).
 The insdsqusts design and sanagseent of rany runoff retention baelna is indicated
 to be one of the sajor causer of surface water cortaeil nation.
           The retention baslu were aeant to be conetructed to hold runoff froa
 a 100 year etora.  Nuaerous fcaslns eould not hold lOO-ysar etors run-off esd that
 eoM could not even hold s 25-year atorn runoff.  "Runoff basins that are deflellent
 In capacity are partieulary ineffective  In reaovlng euepended aaltaa, result Ing
 In elltatloa and excess dissolved oxygen depletion In the receiving waterways  aad
 reeervedjre were eubetandard eater has beea docuneatsel.

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          •Swrfaca water  1s an. axtramely is^ortant resource in Fulton Count/  because
frovadvatar eo-ieentratlone of  dissolved alnerala  ake th« grourdwater an unaultaHe
•ewe* for public water supply. OOl-TA/I.-lTION RFSULTl? 0 fro* Siud&s Use not yet
aaan fownd In groundwater, WT WITH rOmOU AP LI CATION THE POTEhTIAL IS THHtE.
          Sine* nany of the Heavy satal co; taalnat* are found In both atrip sine
•poll and saw*fa elude*,  ground water rasourcaa will be increasingly vulnerable
ta pottultlon by run off and leaching aa eludga loading rates are Inerruaed.   Th*
dangers of eater yallwtion itself should be eauae enoueh to dsnand that this
•ssjtct si«a bffj *Taatly **ducad.   But tbcra la aora.
          Tfce CIS agreas  with  tha cltlBana of thla area that there la an ODOR
problem.  It la diacrlbad aavaral tloes with tha sord "Earthy"  An ^ntire chaptar
should ba Inclwded in  tha final atata ant on Ule problem.  Input and Inttrvivva
froa- tha local raaldanta  ahould b* taeludad.  I'a aura you will f«t descriptions
•ad vorda that dcacrlba the problac auch aora accurately, and • better understanding
of tha auffarln*; eayaad by tha odor problaai.
          Tha EH draft aaya *Th* odor iapact ar*a 14 contained -Ithln a circle
with a radlaa of four  to  five  allea,  Incljdiic the coMiunitltea of St. David.
D^yaat, Cuba and tha outaklrta of aouthvaat Canton .Dunfarnllne, Flatt and •«» Ka Tuk
•Ilia, ahould ba Included In thla.  ^ha report adnita tha odor problaa could b«
hasardooa to hiwaaa  and  aageaat  «haaicala ba aaed to euppr^s* *vaporatlon or
•aak aialodoraata ba ua*d,  atheach taeae hav* baan triad and have not prored to ba
affactive  or feaalbla  in any  way, ta eltlcana feal adding norc ehenicala to tht
problaej could poaalbly  add to  th* danger•,  and we faal the only raaaonabla eolation
to taa problaa la raduea  and allaata  tha aourea.
          Heat of tha odor la  attributed to tha lagoora, where USD etorea • Billion
cable yard* af wet aludga.   Aaroaolluitian froa aludga apraylng la a aajor aouce
of odor and also affar  tha greatest potentloal for direct transfer of hazardous
ceatponanta to huaaaa or anlnala.   "Inhalation of aludg* aaroaola poaalbly
contalainf pathoganw or toxio  ambitancea praaanta an opportunity for protwacted
and repetitive evpoaurf.   "Aaaaaalng  tha rlaka aaaelated with the Inhalation
of alrborna partlclea la  aztraawly difficult, becaaae tha abaanea of data concerning
the nature aa4 eoncantration of pathogen* in tha aludge, tha virulence of these
•ataofana aftar downwind  transport and the nvabar of inkalad orcanlaaia required
Mr hwmaa and aalaal Infection."   treataent plants also contain a aida range of
•ataoeeas ln«l«alng sceia  virama that  arw not totattly deatroyad by treatment and
holdlAg IM atorage basins according to tha report.
          Tb» IsailUTi area h*a  already had one unaxplalnad death, which doctors
•ay slant a«va bssn eaaaed  by  inhaltlon of soaw unknown vims.  Mus% there be aora
bafora ww are protected froa this axparlaant.
           Perhaps  a  Chapter  should  be added to t)i)« project or the Ecoiomle 1 pact
 the Fulton County  project  haa  had or Individual aiid businesses both large and ar.all
 ttirouci-  tht rcBuurci>H  L*"'rated  by  nuneroua cor tracts,  hleUbacka alleeed bribes
 and private co  tributioia.   I-cludfd in  thla ahould be  eoplea of the recent
 Indlctnenta handed down  by th* V S  attorneys office.   Perhaps In this,  the rsal
 reason (otticr tnan the disposal  of  alud^«)  will  be  found  and why th«a project la
 beint allowed to coi.intue  In spite  ±: the  fjajlurs of  the  Pro»l«e of tha Prairie Plan.
                               ^^,  -sUS^. ^
           Since str'puine lar^^iiow  li^storieally  supported pasture type  cattle operation
 in the past, without tl.e Hazard* s -d  Dangera of  Sludte,«nd sine* t.ila project
ea.not be  used indll* tly and safely for the row-crop reclamation that  was
pro ised.  Sines Fulton Co.  certainly dote  rot  need aore  large  scale recreational
type projects we cannot afford.  *,  d  taking  1  to eor.sirferatlon  all the  Buffering,
both physical ai.d Menftal anf finn e i al an| experioieut tbia alee Ic ca
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           To b* a ml* »or« jxeraonn), why do «jr parent* mtio «» in thai* *)ghtl*
 tat k«r* lint and worked on th«lr fam owr 55 year* have to fe.l th*
 al*eo fortlts *f feet* at thl* ***• * dl*po«al project.  tt hurts in d*«ply to
gr«*t the*. la tk* »*rnlEH and haw than toll *• they couldn't «l«»p th* night
 before baeaii*. ih« _a»«ojil« froai tat iluUfc. »«« «o strong it. burn. d thai* ML«*.
 «•«_ taro.ta.
           H • B ha*  taken ad*ant«£* of gar Coanty Off lc«H,  traailad ov.r our
 nl« «nd regulation*,  m now trying th* MM khlng with the st.t. r. p. A.
 •mi «11 the wtll* th*y  ara aaUnf th* Fader .1 Oov.rnpwnt to  p«  Ih. bill on thli
                                                                                                                                                                                      Ittt 1211
                                                                                                      Cgnent*  for I I S ktarinf  —  chleBgo *ug. 17, 1B76, Helba »lpp.r   fcr      ICotil'd)
                                                                                                                           COUISTf CITIZEKS FOR BtTTfS REALM »
          M H • n e«t» tH«M
tkat o«r tax ioll.r* «r» k*inf
boU ykjalcallf aa4
tk* vala. of our prop«rtj.
                                       Qrant»  it  »111  b.  • dani *haaw  to  tbtak
                                     to atipport a proj.ct  .tieh »(t»«»*t»i  IM
                                     o«r  rlrtt to tnjoj our  hn... «n«  d.cr.a««
           *t th« Julj ;«, tOTe  CIS H«wll>( •*!« 1> Ontoa,  Illlnol.  a  itioetiMlo*
va» held about « fvtltioil aipicd IB FoltOB Bounty Bbont aluaff*  project*.  f« weala
like to «ut»tt the rollo.lng InrorMttOB about th* PET 11 Ion  FOB BrmUKDOH.
           In Marea of 1974 a petition ••• fil«4 «ltfc tB*  ^oontj Cl*rk In  th. Countr
«f  Fultm a p.tltlon >hlek r».a« aa fello...	(3t^,..A.t)	
*hlm patltlon *aa «igB«4 bj 7oll reeiatarod vot«ra whicb  ia  ovar f ooo-fovjrtll
tb* r*8iat«rd vot*r« ma required bjr la* for » public policy  ouaatloii.   fhla
r*f*r*ndo> *aa placed oa ta* ballot for th* Heir. ?i *l*etiiaa<   la aaffaat 6f 19?(
tB*r* be(*a a svrie* of legal action* afalnct thla petition, befinnlnf  vltk ta*
Ccwpl^lot for Daclartor* Jud£ea*nt bj tha MetropolttaD Sinltar? Diatrlct of
Oreatar Mlleacs.  1i« caa* 10 «o.74-!'»-1» til** In tk* County of rmtaa a*k*« tkla
b*  brought befor* tb* court 1 mowd froa th* ballot.. Ill  l«al aetloM* th. patltlon
*ja on fll* in th* FultoB Count; Courthou**.  ^b« legal actloB* an4*d vitb USA
achieving their foal.  f%* R«fer«iHlim *a» rraovvd fro* the ballot th* nigfet befor*
to* election.
                                 j»*
           f» call ?=ur attentioB^t° th* "edneodai, Aug.  11,  1970 edition of tha
Canton Ball? ittgmr,  the »tlltor«l page «t»i tb« Mlltoral wrltt.o  ty th*  f*t*r*
fteit*ral Kanafler Mr.  Thonaa Wood.  In it he euaavrlxva the f  I 3  and expree*** nla
concern* for (He citizens of Fulton Count; and hopea tba  Federal Oov«r]kB«nt will
fore*  the necessa??  change* in the project to reduc* potential  h*K*rda,
                           *Ct« ^*-V
           I %»«teHr.  Vooda4*?H£N PFKHAPS  the HSD could devote a little aor* tl«a
to  doing what It oald it would do when It cue into Fulton Count/ and f*ll far
abort  of;   levallng  and  reclaiatng strip ained land by Bfpl?c*tSoB of aladfe.*"«nouote,
•B  aak that Ihla editoral be aad* part «f th* flaal E I s State»*nt.
         /fh* MS Draft  KtaUi " The -'.ailtarJ Dl.trlct do*i  not anticlpat* aoj
im        *
futur*  aignlClcant land  purehMMB upon fulfilling tbe developsant plan* for ta*
freaent  lan« hoUint«.«   ' I, qfteBtlon thlt •t«tr««nt.   Tk* d*c.  1979-A1MT COS PS or
E»aiKEERS"UgBAll 'JATER DA.-UOE STOUT —gtt CBICAOOLAKP UUCBirUlt M^g  Include tb*
PultoB  County praject aa oe* of tbe four aourcea of diapoaal needed to iapl*n*at
tba  uodtrflov Cor ttmn*l Plan) for wmich HS& ia alao aaking  tha Fedaral Gov*rn>*Bt
to  Ilnacn.  wltb a price  tag of Billion* of Dollar*.   Inference to additional aaa*
need*  IB Fulton County ia •*!* *av*ral tlB*a.   I quot* you on* of tkeai {*pf*a4ix*v
I»t* E-Z2 11«* 6O), '-It 1* propo«*d te axpaad t»* fultoa Co«Bt» frofrai.  Pr*a*ntlj
ow#r 1S,70D acrea are owned  by KSDOC,*  NIf th« Pulton Couwty alt* 1* to b*
•tpaaded to ***t tha  total »y«t*a di*po«al r»*d ;or th*  ?*ar 2000, aoa* 22,«OO aer**
*omM b* rwouired. for direct application.   Eased on th*  pre**nt r*tta of land IM*
I.e., productive v*r«uB  gro«« acreage,  thi* level  of appllcatloa would reoyira a
total goaaiitaaBt at «BttOO ael»a."          _^—

-------
          la tk* evaluation af  tk* Freirle Flaa,  tke  paat,  preaeat,  aad future of
HUHIC Beat a* considered.  Tkla project directly  affacta many live,  of tha cltlaaaa
Bad resident* of tkla cowaty, akoa* property,  bu*lnesses, hoe* a,  llvaa, aad
exlataace la Faltoa County could depend on tke concluelona reached by tkl* IIS.
af Dtaoat Importance to aa ara  the pending danger!  of aa experlaent  of thla site.
          Tka report stste*—ta* our face  aatar oa and near the HSDOC Prairie Plaa
haa been eoatsalnatsd fcy runoff froa  tk*  aladg* field*.   "Strip alnlng kaa left
dteeply aloplBg apell aoaada which aay laeraada the capacity of atora runoff to
carry saapended aollda Into receiving watera.   wuneff over atrlpalned areaa and
•ladga applleatloa flelda la Boat likely  naponalbl*  for poor atraaa quality.
Ta* •atakllaked aonltorlng prosraa la Incapable of  revealing thla reapectlv* aourcea.
Tka lasaweuat* dealga and aanagaaat of aany  runoff  retention basins  la Indicated
ta W aae of tke aajor causes of aurfac*  eater contsalnstlon.
          Tk* retention baalna  were aeaat to be conatructed to hold  runoff froa
a ICO year atora.  luaeroua baalna could  not kold 100-year atora  run-off and that
BOB* could aot even kold a 23-year atora  runoff,  la  recent aa July  2t, 1«7e, 'he
Cai.tea Dally Ledger reported a  braak  la a elltatloD baaln OB Field «7.  Th* break
had kaea caused by heavy rain.  It had; been  iaveatlgajted by Fulton County Health
Dapt. aad tka 111. Environmental Protection  ageae;.
•Surface aatar la an eltreaely  laportant  rescares In  Fulton County because
growadwater eonceatratlona of dlaaelv*d alnarala  Bake th* groundwatar an unsuitable
aourc* for pablle water supply. SnrtU.nVTKI* HtSOXTWO  froa Sludge has not yet
keaa foaad la groandwatar, m  nit PvaTKfl  APFlICATIOIl  THI POTEvTI.L IS THERE.
Sine* aaay of tka Hoary aetal contaalnatlona are  found In botk strip alas apoll
aad seasga eludf, growad water reaowrcaa will be Increaalngly vulnerable to
palutlsarby ran off aad le.cht.g aa aludga loading  ratae ara Increaaed.  The dejigere
of water pollitlou Itself aaould a* eno.gh to  daaaad  tkat tkla project else be
greatly rodaced.   Eat tkare la Bora.
          Tka fit atrea* wltk tk* cltla
prohlea.  It 1* dlecrlbed several tlaea wltk tka  word "lartky" Aa Entire chapter
ahouad ka Included la tk* final atateaent oa tklw prwklaa.   Input and Intarvlewe
froa tka Iwaal r**ld*nt* akould bo Included.  I'M aura you will gat  description*
aad word* tkat daaerlba th* problaa Buck  aor*  aecnratsly, and a beater und.rctanding
af tk* suffering caused by tke  odor problea.
          Tka IIS eaye "The odor lapact area la contained within  a circle with s
radlue af fear ta five wiles, me lad lag the  coaamnltlta of St. David, Bryant, Cuba,
aad outaklrta af aoathweet Canton.  Daaferallne,  Flatl and Wee Ha Tuk Illla, should
b* laeleded la thla.  Tke report adalto th.  odor  arable* eoald bo kaxardoua tc
»„,», aa* a-tr*at cksalcals^b* ueed  to wippreaa  evaporation or aaak aalodroanta
k* aaad. altkoagk tkeeTkav. been triad and  kava  aot  provad to ba affective /or
feaalkl* la aay way.  *a (ItlMaa  feel addlag  Bare  ekealcala to th.  problea could
.  ^ftt.... •••-•^(it.V.'.'V-V. V-'-«'"- *V'  ^'V
    >7^.V..«/^ UJ ''  **•** V-^--' ' f         rr>t'l -^
tlaaad of tkl* ara* tkat  th«r« 1* an ODOR       ' •  j
m*m with tha anrd "EarthT"  An ^ntlr* chactar ' - . ,..'ZV .
                                                                  poeslbly  add  to  the  c-n
-------
                                                                                 tttK
                                   OaCMIO CRY COUCOC
                                                       aO£-I_,H2GrH3
                                                           *IC*»tt, ILIIMOIC OOfta*


                                                           IT *«u»t 1976    mfmM ,.,„
T
         U.  S. Bwlroraawital Pro tuition Afemsy
         Melon V
         ?}0 South Dwrtorrf Street
         Chicago. Illinois 6060*
         DMT Sirs,
Dfal you tarn orange J*lc« for breakfast?
Old i«i «x)0)f it* Jlworf
CMnm «r» your orange Juioe CM* froai FlnrMB oranges,
Bit flavor of the Juice was fro» the Mnml content ]n the  s**l.   these
•Inertia h»lp»d wake th* trapses that pen full growth  and perfornance to
th* onng* tree, and the flavor to Its fruit.
This mineral content of the nil Is brought to you  thru the  courtesy of
th» JfctropiAitan Sanitary DlatrSct of trtAter  Chicago.
Did jou have a steak lately?
•a* It earn MT
Old you Mm •wins an your to«st this nornlng?
Mra tht frineh fries you had with your hwagUTBtr fried in com oil?
Th* Nttropolitan Sanitary District of (tenter Chicago has probably touched
the nutritional lift of *t least half of tht U. S.  population.

Surprised Chat a unitary district Is directly related  Co your lutrltloiml
hs«lth, tt» nutritional ftaaltn of ths nation?

Back In Hit pre-lndustrlal days of our ration, it Has natural for agrteul-
tun to pit back on the land *»t It took fna the  lanl.  Afttr ill, this
Is tt» MQF it norttt In naturs from tat Beginning of tint,   IMS it tht way
        iBlntsJntd thetr soil fartlllty and could produce better crops each


      tht fanBr still, sells his products to tht people «ho new live in
       oonMntratod cities.   Thru tht tnmntlwness of Industry, «dth the
aid of aclvitlflc KmiledBt and a lot of cooperation with nature, •antclnd
MM bean able to dereUve a xeter seperatlon process that is faster, safer,
Ml BDre efflclsnt than ertr knotei to this world before.   Mineral Health
Is rtooti'td and can no* be returned to the soil from vhere It originated.
Tht cycle Is eeaylete.     _
MliMrals Art iHwsi" lost or destroyed*
They only ohmet ferns as tney pass thru the cycle  of nature.
These are the facts of nature  I help my collees students to urexrstand.
Everything MJST go soraei^ierc.
nothing Is disposable.
flat out where the object flta In the natural cpele, and you will know where
to secure Its supply are! wren it goes Mhen you IT* finlsntd with It.

1'w* taken |ty students to t «  Sanitary District's operation In Stlckney
for the last 5 years and to Rilton County for the last 1 jears.   They n-ti-'m
with greater kntwlelge of the  wisdom ami understanding of the pps«t for-
tlfjit and Invantlveness of man.   they understand where the work of the
Sanitary District Tits In the  total picture of n%tur».   Ttiey r»ave hop*,
great hope, that there will be snmethlj* of value left In the environment
for their cheldnen to see, to  eat from, to run thru, to fish from, to visit
again and again.

To ask what the tofuct of "sludge" Is on strlp-wlned rocky land airfaces,
%3k like asking the question of what liqaet cow mnur* will have on own—
marl water-gullied lard.
However, both of these studies have been approached.
Both studies continue to M Investigated.

Aa long as we have a contlmiing incraaae In th* hunen world population, theae
studies, snrl others that show  us a better way to cooperate with nature, as
well as to Increase our food yields and nutritional content, fust Be
pursued for our own sate u «*11 as for the generations that are to follow.
Any other apFroach would be to deny hope or continuity for the future
^mentions.

A staple exarrple:
How would I explain to »y students that an Important project , In operation
for 6 years, which lnclide-1 the application of Uojuld ore»nlc fertilizer
directly to leveled-and-graded strip-mined spoil produced a fertile site
for plant 0x>*tn and nl0> nutritional yields, wu aiseantLnued tote»y»e:
there was a distinctive odor to the lltjjid ortpnlc fert!ll;-*r?
Gr1, there nd^it be souw soil mineral run-off Into a local stream In the ease
of a heavy cloud burst?
Or, the effects of a second application of liquid or^nlc fertilizer are
not oertain?
Op, that there be any oUter question to be asked, but the project wms not
allowed to pursue the question or to seek the answer.

the Sanitary District Is an isportant link the the biggest business of this
nation, the agrlsultural business.  How It handles wter and what It recovers
Is one of Industry's greatest  •efiievwajnts to nan's inventiveness.   To cjll
id product anythlr^ other thin the important organic fertilizer It Is,  Is
to misread Its contents anJ all the effort put into Us reclamation.
"Sludge" Js an ouant>led and Inaccurate word .  It only attempts to describe
its appearance.
It does In no way convey to me Its contents or its value.

-------
£1 reading ewr tM* E.I.S. Draft, i*y I offer an editor!*! «ugBMtlon
Mtti fl*M •«» BHninc to tM way I ntw this MM.
tetMtl of "31ud»» diapo**! and Land ftetaBtlan In Matin County, niliRj«",
I uouU mtff*t that It  batter a*t* th* Kind  to the lumtUame of this drift
If It Ml* to fMd! "Liquid Cx-ffnlc MrtUlMT *n>lle«tlcn on Future and
Dead «B*o&ti*tt Lard in Mton. County , Illlnoli."
        V tm Bora otaarntlon* 1 irtah to sail  to your attention at thla
tiaa —  on* 1* • restriction, on* la an oalulni.

9m »l*jp*t reatrlotlon I can *** In thla entire draft It that the only
location to U oonaldarad that darlm the bamflta of thl* project 1*
Milton County, nilnol*.
* irojeot of thl* nvnltud* ml lieportanoa nil! awely hm aura than a
nutritional lapact felt ttmout th* ^rlcultureJ wnrli.
M to ttn oalulcn, tMn 1* another «*iol» nr» dlaiAlcn of thl* project
th»t tm» MIT bMn troparly 
IB th» otrr»et i»«iirtlgM »ir«lv mt~W thf ftoMt «iftll««M.nt of «rlcul- j
Ihls proj«
        J»ct emittflw* thl iMRlflBtlan of UB but to help solw thl
        th»t em aehim thl* B«l	for the benefit of all of us,
Mi for HI of our children,
Ml ft* all of our children's eMMran.
•nd for all of our children•» chlldpwi'i children	
                                                                                                                                                                    I 111
                                                                                                             DEPABTMENT  or CONSCRV«TION
                                                                                          TO:       Terry Hornbttcker         /


                                                                                          fHOM:     Anthony T,  D*an     , .A^'^


                                                                                          DATE:     Au.iu-n 5, 19/6


                                                                                          SU&JCCT:  KCVIBT OF THE BWtfT  K.I.S. F&fc SLUDGE DISPOSAL ASD UJND
                                                                                                    RFCLAMATTON «1f THI METROPOtTTAM SAMITAIty OlSfRICt OF
                                                                                                    GREATER CMICACO tH FDLTOS COt'WTY (DKIS f?
The draft EIS did a good Job of  outlining ihe cnvironHMBtal £**ue* of the
Hccroprlltan Sanitary District of Greater Chicago's land r*cl***tios «n^
• ludu* pros"** is Fulton County.  «o%iever, th* Tollowing enwlrcrw.wst»l
i*r^up« need More attention or a  detailed investigation as to Eh«lr iaiwct
oa the fish and vildltfe r«sn«rre*i of the region:


     1-  4pdet*ited atudy !•, needed to identify the source* of  heavy
         •etals *nd thelt fate in the vnrlous food chairs,   Flah
         flesh nhould also 1>e analyzed for various conta*inant«.  Bit
         Creek should b« th* target of thli study.
                                                                                               2,
                                                                                                   Ur>d  recUaation, Cdratnat*. leveling and  sludje applicAtlon)
                                                                                                   •hotfld bV evjtluatcd ant to ita at feet on the  giant Canaja
                                                                                                   too«» populati>m of tlU ProjWt 'Jgy.  Hat^  acre, ot Mri^      \
                                                                                                   tjt>e  n^hitat have been lo«e Ipr the land reclamaclon art,lvltlr»  I
                                                                                                   of MSDCC,  Habitat dflvefsity lost  through rrelsMticm artlvlciesl
                                                                                                   wa» not adequately Covered In th^  draft EIS  atatet*»enL.         J
                                                                                               3.  Effects of
                                                                                                                    afB||fmg.loa on wild bird- and
                                                                                                  specie* needs •ore investigation yinre  it  Is seated in tit*
                                                                                                  draft EIS that available research data  Indicates a potent t«l
                                                                                                  hazard exists.


                                                                                         &• of Aufuit, 19?>, the IGSDCC mmvA. 15,528 acvei of strip (tine landli 1«
                                                                                         central Fulton County.  These lands currently contain • Magnitude and di-
                                                                                         »tral*:y pf surface water resource* con»lstirt|t of lakes, ponds, maraheM and
                                                                                         »trea»s.  The faMt LTfi ''Vt^ not call  attention to the loss of valuable
                                                                                                                                   ''
                                                                                               resourcea__tltroua!.i the
                                                                                                                                                      T"

-------
Terry  liornbackri                       -  2  -


these  losses and  their Implicit Ions  should  be fully .;isru<;s,>it in ihj fin.il


We also note the  dr.ift KIS indicates  Mure  ar:.  rbrf? Fnd.ingereJ plant species
which  probably  oxi'it in the project ar,..i.   Ue U-,1  this 1 nforirit ion sho.ild
be verified,  and, IT thpsp plants do occur,  the  final  F.IS  should .llscuss
alternatives  for  preservation or mltlf.nt iun  i>f  these specic-s.



ATD:meh
                                                                           ITW 123
                               Hirl.,.t-l H  H"c.-1,(n((.  fjir*>ftu
iimyiJiFT'nc ULU> ? •! rnrt--E il
 (2?00 ClHjnl',11  RIH.I. %.niyiel'.l  III"  MS  W/()(, /,

     217/782-33*2

                               September 28, 1976
     Mr. Kent Fuller, Acting Chief
     Planning Branch
     U.S. Environmental Protection Agency
     230 South Dearborn Street
     Chicago, Illinois   60604

     Dear Mr. Fuller:

          Attached are this Agency's detailed  coMKnti on  the  draft  Envlronmentnl
     Impact Statement on the KSDCC Fulton  County  project.

          Our criticism* and suggestions regarding  the water quality analyses
     are quite detailed.  It is not our Intent  to criticize  for  the  sake  of
     criticizing.  We hope to help In  producing a final  document which  will
     analyze as  fully as possible the  impacts  this  Important,  controversial
     project which has be«n In operation for  five years.   Inat the project
     has been in operation so lonf^_2lkAL_££lJLjU£jffl^fl!i&*   Ihe need  in  thil
     ELS ii broader  than the usual cage of merely analyzing  potential Impacts
     of and possible alternatives to a proposed Federal  action,   ftftis EIS is
     also an opportunity to analyze Is^acts which have already happened and,
     where those Impacts are not easily defined,  propose better  methods to
     measure the Impscts.

          In the written comments, we  offer this  Agency's  aaslstsnce to the
     USEPA'S consultant In refining the analyses  of surface  and  ground  water
     impacts.  To arrange sueh assistance, contact  Daniel  J, Goodwin, Manager
     of the Planning and Standards Section, Division of  Water  Pollution Control,
     (phone 762-3362).

                                         Cordially,
      DJC/DtC/mkp
                                         H. P. Mauty
                                         Men*(er of Environmental Programs)
                                                                 Al fNUICCIKW M.I
                                                              • CCEIVt n

                                                              ^T   ] 1976

                                                        rLAMMftG UKANtH

-------
                  Illinois iiw'rofPWnlal  Protection Agency
                      Comtntf on MSOGC  fultoo County
             •raft Environmental Iwpact  Statement, June 197*
                            Context of tfca IIS
There It virtually no dlicutflon of  the proposed USEPA action.
TN* Foreword, p.  Ix, mentions  thai NSPCC it "a grant applicant
for tMs *lt»d9* application/  land  radwMtlon program."  Ho further
Information  li flvtn about  the extent  of possible USIPA funding
for the project.  This  lack of Information se*** to preclude satis-
faction of th* requirement! of the USCM's own |15 regulations of
April 14, 137$.   lT**fe  reflation! (federal BegUtcr, Vol. *Q,
No, ?2, Section b.|04)  require, among  other things, theie two
Items:

      I.  MekBreand and description  of the proposed action.
         <*.»*<*)).

     2.  Alternatives  to the  proposed  action (6.30 Mb}).

UNIte th* draft CIS dee*  contain some  detail* about the background
and description of the  project and about alternatives to the project.
Information  about the project  !» aot the tame a* Information about
the propo*«d federal action In eelallon to Iht project.

ffcl* paucity of Information about  USEM Involvement in the project
resyltt in a document without  a context, or perspective.  We hope
the final EIS will rectify  this deficiency.
                      Surface  Water  Quality
the analysis of the  impact  of  the  project on stream* Is superficial.
The analyst* cites some  of  the voluminous NSP data contained in MSB's
monthly "Fulton County Environmental  Protection Syslear* reports.
Th« CIS attempts  to  summariie  the  MOtt  relevant data in the reports
for the last four years.  SOME of  these data and some of the conclusions
ttated are useful, feyt two  important  Items of available inforssation
were Ignored.  witHoMt including these  lte**s, the analysis coyld a for  the  two n-stJor point  spu* c«i
                                                                                                     (Canton and Cuba Sew.iq^  Treatment  Plants),  and fii.illy.  |wr> USES
                                                                                                     s. I ream qagin^ st.it*o^*> nn 819 treefe,  A winre  (horough anat^itis fNan
                                                                                                     thnit cmitjinr"1  i"  t*-«* i|r»>fi fIS  is  possiole.   Aid Considering tr«>
a r oun«
Stich ;
advise
i thp
• and
war hi i
lys i s s
a^^ist
n t c i f
i.. J.1
-. lr
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                       Operation of detention Inlm
The operation o' retention basin* should be nor* thoroughly enplalned.
This would contribute to the surface Mater quality analysis discussed
The retention basins collect runoff fro» application field* and dls-
charee the collected water through gales during per I oil usually between
* few hours to i to ) days.  Sonet lues, however, the gates ire left
Oftntlt for long*'' periods.  For «««pl«, the MO -onchly reperl for
Hart*, 1)74. show that of the Ik basins opened during the iwnth,
three Mara left open** JO, l> days each and & others mere left opened
between l| end It day*.

One •)•( Mon«»r «hy these f*t*i were left opened >o long.  It can
hardly be because the hydraulic capacity of any fate Is sa United
m to n*ed 30 days to eesjty Its basin.  It oust be presuwd thet the
reeson M« th*t It >ns Merely Incanovnlent for the optretors to close
Ik* !•'*» seen**.  In (his cese, letvIng the jetn opined for 3D d*ys
epperently resulted In runoff fro* the 1.5" of rtlnfell reported in the
••ether tnfor>«tlo« for ttm 17th wd 28th of the mntti ruruilna rlej»t
              ites ulth no retention.
It Is *l!B noteble IhM no pueplnf »>ek of retention bet In niter to
eppllcatlon fields Is reported or even nentloned In the Monthly reports.
Condition HI of the Berth ?, IJ?», operetlne. pen.lt (reproduced In
Appendix A of the (It) required records to be kept of punplng beck.
The  lock of puep-beck d*t> In the reports supports the conclusion *treedy
retched by ItM free) Its context »ith the project ""•*
IOP6C Is IKM ope rat I n» at Fulton County otthout an  Iff* peralt.  Ike
Ncrdi 7. 157* penult has expired end  ItM has not yet  Issued * ne»
permit.  The UP* has declined to  Isiut a MM permit becws* of the
•if***!)! ^%fi.TfMf^ generated by  the project.  Upon  the  resolution
of current  IItleatIon, a MM per.lt •III be considered,  *» that tl«.
a MM evaluation of pemlt tondHloni -III be Hde.  ' issulnf a pemlt
with any  less  strlnoent  peralt  conditions Mill, of  course, depend on
proof that such operation *lll  not pollute  the streets domstraa* of
 the  project.   Thus,  a thoronoh  enaeilnatlon of  current  operation and
current surface Mater liapact  Is  essential  to the  UFA. The UP* offers
 In  eld to the f IS  extractor In a ra-evelintlon of operating practices.
Providing  the deems t rat I on of non-pollution of stream, as discussed
     i,  li  -»ee,  future penal ts could b* revised as  follEMSi

         Rwoff  collection basins Mould haw no affluent standards  If
         tributary  fields received sludge -only at «aro»nailc rates.
                                      Individually calculated tor
These rates Mill have to be
emh crop but Mill probably be
                                                             lv^ dry tens
                                                                                                                                                       used Ert the
                                                                                                             March, l*7«. paralt.
                                                                                           There are two errors In the EIS regarding runoff  collection basins tm
                                                                                           want to rectify here:

                                                                                                I.  The IE** used a runoff coefficient  of  .77  IA setting up design
                                                                                                    criteria for  batln capacity,  not the  lOOt  used  In the EIS.
                                                                                                    Thus, the basin Inadequacies  ihovn  In  Table vn-ll arc not
                                                                                                    correct by ICFA criteria.
                                                                                                                               ih.  ii..t-
                                                                                                                                                         In
                                                                                                              basin CJMC|>IT«  h.« been reduced br ovtrlona
                                                                                                              jnd/or by siltation.
                                                                                                    The cownent (page VI1-5!)  about  Inappropriattness  of
                                                                                                    "averaging effluent  quality  as  required by  State standards"
                                                                                                    Is not correct.   While 2%-hour composite saneles are  re-
                                                                                                    quired of sewage treatment nlant*.  linala nrafa  saegles  are
                                                                                                    »*».»nf^fc.^ fnr ih»** lffge retention basins, whose concen-
                                                                                                    trations of (00, S$  and fecal colifor* would not fluctuate
                                                                                                    •uch.  Thus, thi MSB reported values are single grab  samples
                                                                                                    and considered representative.   A JOI>| nf 71 ma/\  it  a  fross
                                                                                                    "iT'fl1"*1 °f 'frf "'f|fni  «t««s.rds l»ms«d bv  the March
                                                                                                    permit.
                                firounowater

The Fulton County Sludge project Is  very inportant  not only  to  the
local r«ld«nts, tot (o ewryone Involved «•!«« sludge aispOfal.   *
thorough, conscientious analysis of  the impact of  the project on
groundwater is needed.

The draft (IS dors not  satisfy that  need.   The ICPA identifies  the
following deficiencies  In groundwater data  and analysis:

                                                    way  groundwater
                                                             rface
ndicatai in a crude
is neeifed t
                                                                                                I.  The map. Figure IV-9,
                                                                                                    flov directions.  *a
                                                                                                    mta.  Figure IV-) does not alldM conclusions about  eventual
                                                                                                    •Tgrat Ion of pollutants Into groundwater sinks.

                                                                                                1.  It is especially Interesting that soec arrows of groundwater
                                                                                                    flow In figure  !»-«,, especially In Ihi southeastern part  of the
                                                                                                    project, e«it the project area, but Un i   i
                                                                                                    *tiatn r^'rh fimll llewili «rrir-*-""

-------
                                  - 5 -
     }.  Peg« VI-70 recommends the use of  tracers  to help  identify
         sources of contaminant!.  This Agency's experience with
         tracer studies Indicate) such studies ere  generally un-
         reliable because their success depends on  properties of
         aquifers not determined in most subsurface Investigations.

     «.  On the cru lal matter of groundwater flows and gradients.
         pet* VII-70 refers to the "absence of complete grounduater
         flow data . . .".  We can only say that if the data is not
         complete, It should h« "ada co»c.late.  The same page also
         States "Groundwiter quality monitoring and analysis should
         be continued to detect possible contaminants from  the
         project."  We suggest that a Mere  continuation of what has
         >een done wl11 not relieve present uncertainties.

     '..  Table VI I-II (page VII-65) summarizes groundwater effects
         by presenting ranges of values for each con-.tiluent for
         all wells.  It would be more meaningful to indicate trends
         for Individual wells.

     t.  The statement that "variations in  their concentrations are
         Influenced primarily by the geochemical characteristics of
         abandoned strip mines. . ." (page VII-68)  is a tenuous
         conclusion If based on Table VII-I3-


The draft CIS suggests en Independent agency be brought tn  to to study
existing data and formulate an improved research and monitoring program
(pages 1-29 to 31).  The IEPA feels that such a study of the existing
froundwater data with the purpose of recommending improvements in the
monitoring program is needed,  whether or not an Independent agency  Is
necessary can be determined by an initial study by  the EIS consultant
(If Such	          	
             rwith the assistance of groundwater specialists of this
                               Kir Pollution

The odor potential of the project Is dependent upon several variables,
Including sludge quality, quantity and operating methods.  Because
of curret.t unresolved litigation, it Is difficult  to see what changes
there will be in those parameters.
The outcome is *t this date unpredictable.  We hope the 1*9*1 compllca-
lions will be resolved within the next few months for the sake of all
parties, including local residents, IEPA and HSOGC.  It is especially
important to HSDGC Co have the legal uncertainties of their Fulton
County project eliminated so they can proceed with sludge processing/
disposal planning on a more firm basis.

Considering the situation described above, the IEPA «i11 withhold
recommendations regarding the odor problem until  the need for addi-
tional ItPA action is butter defined.
2.
                           HI see I laneous

Page 1-13. bottom, states that increased fprtillty of (he former
strip-mined  la**d will "possibly make row-crop production economically
feasible."  The pr««n.t« of large rocfts In |he plow layer, however,
nay make it difficult for the average farmer to prepare and
cult!vate these f!elds.   MSO has been using spec!•!, expensi we,
equipment to overcome this problem.

MSP has stopped (as of approximately March, 1976) barging super-
natant back to the «W plant.  MSD has just (as of August, 1976)
begun apnlvino tup*rn*t*«i- i» I*»H Ky -^ •-^affl-fig It thrnuoh
gated pipes.  TT.* us *hn..iA x;tf.^< »hi«. m+th^A  fOr which MSD
has hopes of eventually using for sludge as well as supernatant.
                                 reduce    odor omnmr»t irn from
    IhU ^Ihod. if	
    
-------
                                                                                                     OTILIZATIOK OF SEMOE  SWOSK OH LtND
                                                                                                                                                           ! Ill
                                                                                    Aral  Part**
                                                                                                                                      November IB, 1W*
                                  «rv
Th* following *r« laeroveaenlt  tn the It** »i«he» to »t*  In the
final Fulton County IIS:

    I.  fxptiia MM context of  th* IIS. M dUcusod aba**.

    I.  wo * "or. thorough *n«lyili of the mrftce w*tir  nullity
       l***ct of the erojaet,  tnlitg I)  IE»A •'fluent »n* itrev»
       1*1*1 In* 4*1* M «*!! « USB 4*1*. and 1)  utlnf  tb« (inn
       of retention caclit slidtaff* *t * variable, ** tfiteustcrf
       *arll«r,  | EM I> »!llln| to p«rl I clp»t« In oolnf |hi<
3.  Ev*tu*t* tH«
   ItM
                          of Ih* 9roun4M*t*f «enltorfng prograo.
                          c*n **tlit  In Ihli ccll*ncm»"
     Our eeuBtry IB faced with m probl** of  what to do with all th*
•••t*  ••tcriala we h>v* ere*tw>.   OB* of  th* profclw* t* what to
da  with  nil of tbt •tw.'uj* *act*« our l*rg» citici JLT« crMting ««ch
yiron»ental Protection If me* hive
curtallwi or clonly regulated i*ch or tb* p**t awtbod* of di*-
poelng of B*waj;* waatee.   Agenclea throughout the D nit ad St=te* are
looking  to  toil* a* a amjor way of diapaaal  of aewage *4adge.
Mllvaukee aad Chicago Nave been selling activated ««*ag« sludge
•lace  tbt *arly fortl«».    Sludge can bo a uaefol aourc« of nltroien
and pfaoaphat*.
     A county la e*ntral  nilnol* learred  supposedly of the value of
•ladg* and  tk* problma Chicago *a* having with dlapoaal.  Chicago
ha* aor* *lodfe than they have outlets for lispoaal,    No*t larre
citie* tiroughont the D.S. seen to have thr  fume pro bleu, l»rr<-
quintitlas  of gludge and  no real good M*OB  of disposal.   Since
ralton County in central  Illinois has forty  thousand  acree of uisuaabbl*
land due ttt atrip adnir.g  of CD ml; It seeamd  to county official* as
a good place for Chicago  to dispoae of their sludre.    County offi-
cials  hoped  that Chicago  would level land  which coal  Mining coapanle*
were allowed to leave in  a state 0f die^Btsr,    H*anln§ the laQ't
tbnt na> stripped w«* MMe of the b«at far*  l«nj  in ta* United
States,  six  and **ven percent organic Batter content  in th* soil •-»
quite  coBMOn*    After strip •lnln*:i the land  pas allowed to ren^ln
In In  go hilt* aad irulleys with the top eoll  covered  with hundred?
of feet  of  rock and clay.    Sine* 19?t Chicago has  iieenBrirglng their
alBdr'* by truck and tsarifre to Pult0n County,    Is  f*ct (  Tts* Greater

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•tUllatisn *>f Sm«* «!»««* on Land . Page 2
fmloaf-i "stropolltaei Sanitary District Prairi* nan, a* it ia
csllso:, U *md*r tk* watchfml ey* of large cltlss throughout th*
••it**! States.   Sine* tb* B.S. already contains ts» Billion Mr**
•f similarly rmim.** land. **wag* sludgs appear* at first glance a
C*»d ••f to r»*tor* •e*rr*d land.2
     •aforttm.mtslf, r**4d*B.ts of Fulton County *«r* not Informed of
tk* pommlhls •»* proven buarria of sludge.   Soil *ei*ntists through-
Mt ti* ffmlt*d Ststss anil B*rop* van of th. problems of sludge as
* source of Mtrlsnts to plant.,   Sludgs can be s useful Mure* or
mltiwej** aa   Official* working for
MMromilitaB Aanitarr District claim th« moil n*a an absorption
Mmaeitr for trme* dsmaits and that traea *l*m*nt* art naavailabla
U mlaat* at • kifk •! 1«T«1.   tti* gsnsralltatlon 1* simply not
•Mml*t*l* trm*.   Jft far *»a«nl* bacom** more available with
SmcrMdag "• I*'*!-5     It mkould also e*  pointed out tkat soils
aanrlag apnr*elaol* asvjaata ot orgaalc matter, tne awailaeilltf of
•mmmar ia mor* cleaslr a*s*ciat*<) with organic content of  tk* moil
titP mitk ml.^   fclla are kavra to ha»e a*  abaorftion capacity  for
a**t trae* •!**>**taj kow*<*r, th* *xaet nature of  this effect.
•atmaelall? ia cb*lat*d *r*t*m, ia not completely unrterstood.?
•••tck*  <1«*«> ham nmhliak*« data from plot  experlaanta  indicating
*mmanc*m*at of tke 1*T*1* of aTallable copper,  Chromlna,  nicKel,
I*** as«9 «lae ia moils raamlting  from sludge spplleatloos.   Th*
l*r*l* fommd  la  the aalerity of *ludg** are  ao  high  that  their tit* a*
f*rtUis*r Ma* inewitably lead to  eoatamlnatloo of  soil  with  trae*
Basis'a    tiyaisstlj. oae* tb* rateetire  capacity of this soil  for
trace  elaartas from aladga haa  b**«  reached,  •nkanctd solubility  in
tk*  Mil ocomr*.8    B*a*arch  for  long term effectn of slulg* eon-
taimiag  %fg*i  l*r*l* of trae*  elements is very limited  In  the Doited
Mat**.   Beamon h*ia« th* soil ka* onl» r*«*Btly teen considered
rns-s. major  sit*  for  th*  dleposal  of sludge.
fitllizatloe Of Savage
                                Land — Fag* 5
     Research in Europe *her* **«ag» aludg* application ha* b**n in
praetlc* for many y*nr* has a any results of loaf term effects of
•**age aludg*.   J. B. Pstteroon of tMgland studied th* effects of
s**ag* sludge application for thirty years on market garden soils la
Somerset and concluded that there Is no doubt that the application
of seeage eludg* containing truce elew.er.ts can eortrlbute to sell
contamination.   Evidence of the cont-imlnotion of the soil with
respect to copper, lead in-! zinc appears to be vi rtuslly permanent,
for tke levels of these elements *sre not substantially reduced
on leaching columns of two he-wily contaminated sludre treated soils
with a volume of distilled  water equivalent to 40 a rainfall.9
     Host of the research done in th* United States has beta done
under controlled greenhouse condition* where researchers have trle.i
to obtain loud-term effecte by increasing the speed of reactlo: s
that naturally occur over m period of years.   Research result*
printed in tke '9V5 Journal of Environmental Quality by Bradford,
Page, Land and Olmetead all soil scientists from th* University of
California indicate toxlcity problem* mvalvad with sewage sludge
trae* element contamination.   The data discussed ehoeed that th*
extracts from the source* of sludge used in th* greenhouse experi-
ment all contained at least one and sore often several elements
available at toxic concentrations to bean, barley and to*ato plants.'
     Research dose by Pennsylvania State University Indicates that
••wage (lodge should not be u**d a* s fertilizer until an effective
monitoring *y*t*m keeps track of heavy settle added to soils and
takes up by plants.   Dr. Dale B. Baker and associates showed plots
sf earn and grain sorgknm fertilised with sewage sludge as part of
a rec*st P*nn State field day (fall of I97O.    "he fsrtilizsr value
ef sewage dude* was demonstrated.   stodg* samples sere analysed
•very two weeke sine* April 1 for elements and potentially toxic
heavy metals.   Tk* results show th* need for accurate systems of
monitoring eewage sludge as s fertilizer.  Composition of aludg*
varies greatly slth time and i* generally higher in copper, zinc,
SBd cadmium than is desirable, Dr. Baker stated..   1%e research is
•dpported in part by fair fund* from th* Pennsylvania Department of
a&ricslture.   Trace* of some a**ry metal*, ar« needed In eoll for
healthy eras growth, IV. Bhtksr explained.  Rice pounds per acre per

-------
Utilization of Snag* Sludge on Land - Pig* 
-------
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-------
•»n»>11«*»1«i f«r p*tefttSA «lr
                                                      and odor*.
      If thli mtjMt 1* «41**»* to «on«tlmn» vitk «r
f*4*r*l todlnc,  It thaald to Mr* «lo»«ly aMitoni.   Thl»  •bould

to *••* *r a*NMi** *«Mr MMB tto •»«ro*«llt«

•T fevttor CblM«*( •"* UM I>«e*l  »»«ltb Otpa-twnt.
li
                    «B *ar Hr«  Adt*hua:

                                                                                                  l»f»rov«n«itt of environmental qmalitv through the use of **\«,ltt**ri«§
                                                                                               am and analjreifH h«» be«« »y profestioRcl coufttn ft»  the past tventy
                                                                                             yean.  I M fre»*ntly professor of civil engineering and coordinator  for
                                                                                             e*r?trotmental  health engineering at **orthw«*ttcn llBin*c»ity in E*»n*ton,
                                                                                             !i]fiioi>< THe Draft tnvirotmental Impact Sfate*«nE for Sludge Oi8jj£*s«!'*nd
                                                                                             I4HMI RtcIa»'St:ion in Fulton Count?t Illinot', CAM to •? mct*neton c*c««tly.
                                                                                             Th« prairie  Flan, th« subject af elM 9r*ft RTS, wu }ti4s«4 to b« one «f t^«
                                                                                             outstanding  civil «Ti{lii««ting «vbiev«Mtnea *ev*r«l yenri «§o Inr * pjiMiaajtt:
                                                                                             njitiontl  or««nlM&ion, tka n*trican S^ciatj! ol Civil EntlM*rt.   Th* rr«lri«
                                                                                             Flan potentially r«|>r«»snt« « *i§nif [cane advance la mat* traaCntiit.   UMb
                                                                                             rjtiit,oxatldn  of •ar|lnal land, for «£ttcultur*l ««* rt"ui*«r v«fu« from VJIUIQ vctt* *JT» i««Kirt*nt b«n*f|t*ft  Sine* th« ^roj«M the Draft
                                                                                             EIS h€§ at touted to iiy|i^tHL*-j"Ti- t^t'tBti^^ •^t*J14^t:*nSA* ^*
                                                                                             ^*r«lcv*  atyls nic4 In the Draft EIS do«» not cngwvler cufif|4*nc* in th* IIS,

                                                                                                  H0r« *«rlcnt«ly, the Drift EIS  tttftmicaj .ggicajt,*^

                                                                                                           ntt ] vlaft to present for year easetd«r*tion d**l* «lttt po*


                                                                                                  I.   ft  «fr . 11 -» The dgJinltio* of ItLudgi lUnriti flMliiaa* 1""*
                                                                                                      V^PI^^M^MBMHH  corrp~  The ci'prV'ssionprcsented l« not even
                                                                                                                    di»*n»lnnally correct.

-------
                                    -J.                                                                                             -}-


           t,  p. ?II * 23 *- The diecoMlon of th* odor c*»plalnt dac*
                              It •ItUadlns and it not a«b«ta»U*t« of detcriblns th«
                              •hewn probably rcfora a Kind direction aector                        eitittinp,  situation,  tut Is (rent rally rari-lc...  in ir, »«««._„» of nountl.l
                              «« Minor 2Z.5" ,w -is".  If thlf variance  i«                         iapicrt.                                                 ^»«-«IK 01 pottnti.l
                              *hownr ona could m«k« a |cri,r_l..
                              odor co«pl«irvtt.                                                    4ttt*~-*fr<**  Che  »«!»»  ilirit*T inT thlt latortal nii_iur,
                              Btti«*> *v*c tn*a period* iMnr* ixrf tr«** -emaatiBaaV  A
                              recent eaaa of wind born* dlaparaion of lead  duet from
                              t let iterate pile* of a tBeltcr and the consequent
                              •ailllv* lead po I toning of children In tha vicinity via
                              th* aeil la caut* for concert*.



     In **aa«erjrt  I would Ilk* to urge * wen nor* careful ami nation of the
 potential odor probln and tt» .11l»«tion; and of th* coaf«qu*rcei of long tejaj

-------
      t  §.  ItM
                                                              UKWtlT MMMCH M»TltUTt
                                                     |M
». JMHI N*it*n
n*ll« Multh AtelnUtntor
r»lto« Comty ltr«ltfc
U0 iMtk Mill Stn*t
C«nt-i.  IllliwU U510

Bur Mr. HtMm:
                 eh* «inrigumMnt»l tepae* fttaCMwnt for tfi* HSR Otie*§o
•lndt« 4Uf«*l *f*ntt*n  In  Pulton Ctufity «nd h*i teit««nt».
«lf«cton>
                              -f
iU«. «>Mi
                                            nf
                                 vltfc confln»«tli
                                                         coi.»tllu«nt. .. th.
                                                                      with
                             tti«  t«»fc ft cli»r»el«rtilni th« odor «i on*
illttll U tT»lc«l of . ..jMtt  .».rc..  rfilcti c«« >• tX MO
       i y «•»!!.  loJ  >ctitL« U«.tillc'«tliw ot
                It «Tljli.  1» Hil'i »!«».  ttiti froe«ro»»ei po.ltH
                l UtVtb« «xltt«nc« vt ajor *at it* «ourc..
                                                                                                                                                                        IT Rf MMCH iHSmill
                                                                                                     Mr. J»»e» H««««
                                                                                                     r»i« 2
                                                                                                     Auguit S, !»'»
                                                                                                                                tn Ha »»«r«ui»n». «itfi«y*^ 'i« "f till infill
                                                                                                                      JL lij|t^ niMfcer of CC
                                                                                                                                                              f*
                                                                                                                                                       MSD
                                                                                                                                                                      .
                                                                                                                                                                  ilgnl f y* «
                                                                                                     i»""'errbt ^gr the efitirg mgi"ln que atito;* for them mr» athmt #ex*Fcrf ..of
                                                                                                     oiof . ' Que'voiij M VEER* r_ J o ..... ^ Ja i t i_f i .W||if . ^t^
                                                                                                     quoted probability of 0  'I R«*ms cu E>* eansvrvatlv*.
                                                                                                     Mr. S*rp*"" !• on vacation *o  I do not have his reaction.  Ke «•? «l«h to
                                                                                                     ••pllfy this »t»temcrtt, partic'ilarly with  f-;»rd to iource identification.

                                                                                                     Very truly yuur».
                                                                                                     A. ». »:Klroy, ll^Jid
                                                                                                     Treatment *f»4 Control FriKe*fi6;« Section
                       -°*t

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647-1134
                                                                 ta*Mt
                                                    M »Mni HUB trmiT
 AOfust 11,  1976
 Mr,  S«or§e I.  Mcxandsr,  Jr.
 ••atonal Administrator
 o.i.i.»..v.
 230  South tVitbom Street
 Chicago.  Illinois  6060*

 Dear Mr.  Alexander;

 fti*  lavironwontal Health  Stuff of this ftocarewent lias reviewed the
 USEPA Environmental  fevact .statement f-'i- sludge Disposal a-id Land
 Rsclsn)*tton in Fulton County,  Illinois.  Th« st«t«8enc eaoruuiccs
 oany of  the concerns of chs Pulton County H-olin Uepsrt.«*nt in 1971.
 (refer to t-'ird of Hiilth *nd  Sewage) Sludge Hearings)   Subsequent I•»
      *xp*r'.s kav* described Fu'ton County ts cue lenefnccor and th?
                                              •
victim   ^tf falfnfln fiffiwT M*-t*->fc tt*r•-**—» -•- ~^-y ca&£*£m&**bu
t^>T Ji*r*t*5J_o~_ *°?*_?^ F^* ^^L?'  . ^*  (*?p*^J^y iti  19/5)  tlwx
r*jjy^M^BLflBnB3s^^      iroffrfyifJ^^^S^^ ^"' «**R~sptrt ijzspJ
4s.,yjJA2BSi^ss4s..*^^^^flfl'*fc  rerhap* .*,hcrlng of tfifomttiu*n msyp?
                    review •«•* lnt«rar«l;f^jn of thr date tl tb« r««l
Our r«vl«w t« prlnurily concerned with ftm d«t» and ilocui»«nt«  ih»c ha
been picaulnittd by the. Health Department subiequent co  tha  loplenrti-
catlon of thin project,

         D«f«r*ln
                       the «Sor fron «ludgt •» »n "earthy ancll"
          j           u«iJfi Hi »IU t>^»!T'<.7aftn)T.ir.,~yy-nty"
          trained  odor  inveittgiitor o£ the Hi-«lth Dco»rtn«nt .
          Certainly it  muld be nore rrnlittic to deicrlbt the
                 ess  deicrlhed trttMn tin report si it rt Is tee to
                    ^BMttaK^H^gCTTffliryr^py^PBTCTir^CBnffty neaj;
                   _: & HtsiiiHilinitcroi not accurate..
                                                                                     Mr.  Alex«n
                                                                                              '"tsI
                                                                                                                                 ce th« sttechcd mi
                                                                                                              •is
                                                                                               	                       It is imperative to confider
                                                                                              very carefully th* 1975 Health Department Report and
                                                                                              the 1975 MRI Report before concluding the spproceh was
                                                                                              unaatIsfactory.

                                                                                              In defining tha  problem in 197) It becant apparent that
                                                                                              control on the quality of sludge was neseaaary. ££i|
                                                                                              for Slm'gjS QualitT Mere sqba^gueBt^y •d.PBt*'! by ffy* J
                                                                                              The Heal tk. jj4aM3c£sWtt£..jtaa&lga^aaJkly the %lu^£e. nrriv:
                                                                                              at_Ui»' U,»»»i»ol Bn»lis.  *itf^fffl""'''f J '
                                                                                              results)
                                                                                                              .               	
                                                                                                             e&«£aiMC)K*  (enclosed are aynopsie ot these
Attached to this letter are item coanents to the EIS Report and a
letter  received tram HRl on August 10,  IJ7S.  The Health Department
has  considerable experience in developing a REAL approach Co the
identification and quantification of sewage Kludge quality rnd odor
nuisance.   It  is imperative tha; the Fulton County Health Oeparwcnt
be a cooperating part* for the collection and publicizing of all
existing and future information regarding the Fulton County Project

Sincerely",     ;       " 7--

 ;             •''('•
//•t-    ..'  l  f.     '  ^ •-!--"«
Janes Musters
Public  Hfalch  Adr.iriitrator

Enclosures:   197* Fin«l Report by HRI
              197} Final Report by iiHI
              1974 Health Dept.  Annual Slu« Report
              197S Health Dfit   Arvnut. 1 Sludge Rewoct
             Odor (VrrlainJ (-'orms *or i')7i
              I'.'T) i'ti'ilic rti.i.-'T. <*n :"|i--'- •
              197J Board of Hsaltn Minutes
             Synop^i* of F.vcr-t» *ug,  1972-March 1973
             Fulton County Boat:d Ordinance
             Fulton County Board of Health Rules and Regulations

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Mr. Alwandar
tog*. 3
       11. 197«
                              ery Sheet
                                                                                   It, 3, » Hater
  elaaoraa coot:  l»7*-7S-76 fCHO Air Samples and Complaints
                  1974-75-7* FCHD Monthly Reports
                  1974-75-76 Sludge Quality Sailed at Liverpool
                  bT FCHD and analysed via contract with FCHD
                  1973-74-73-76 Holding Basin Staples and
                  Amlys 1« by FOB
                                                                                            b* lncff«celvt in rtmovlniiu*p«nd«d   *tl **•
                                                                                                                 -* *—gH
                                                                                            rates will be based upon heavy awtals.


                                                                                   li, 3,  c Odan and Noise
                                              part states sol
                                                                                   1-)  A sludu analyiit prograsi ts datlgnad to in»or« sdvquata traae-
                                                                                        •ent of the iiudge btfort shipiMfK to Cha holding baiina.

                                                                                        1)  Th« Fulron County H««lth Oipartawnc hac saanlad tall; tit*
                                                                                            sludge arriving at the Liverpool Decfca for laboratory
                                                                                            analysis Co amira only good qualitT aludaa is abJjcaA
                                                                                            to Fulton County.
                                                                                        c.e.  pp.  1-26 "A procedure ahowld be inpleaanted to laavri
                                                                                        that  only good quality sludge la aklppad to Fuleon County".
                                                                                  1-15
                                                                                  1-1?
                                                                                                                                  _
                                                                                                                                  ^a£^^A _
                                                                                                       smance,  arc uiscoboliterju3§ailent« baled an
                                                                                        fundingt froei iLnllar sludge experiment! elsavhere.
                                                                                  1-15   More recent and valid Information it attached tor yovr rerle*

                                                                                  I- la   Paragraph 2--iaatlc_tant «ftiuent» cootributa to lool_Millati
                                                                                                      Paragraph IT---HniBjattBUa_l(lALlUaBe»Jl{-£U>>aay1
                                                                                                     .fux_i«tentien basin tfflunntj"

                                                                                          	r-raragraph III chat codiiias enrlclsacnt Bay be the aott
                                                                                        Uniting single  factor In sludge loading rates.

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    Summary  Sheet-Fage  2
  •1-22,  This  section docs not take into consideration the Fulton Count
          Health  Depaitnertt stapling and tefL result^ for ses.-pc sludge
          reflects  only USD dma 8s il relates to tht Wealth Department
          Standards.   Attaclied is A copy of o*ir
  11-37  the JUfeUt
UBsVasft the Fulton County  Beard of Health,
         Ordinance  and  Regulations.

  VII-7  Refer*  to  i*B«*MrMksastt*atl talks •bcue applicable standards

         Standards  for  alkalinity have been unintended (attached)
   1-25, 1, Sludge Quality  Paragraph II--

         1}  Referi to operating permIr
             • )  «*m_«-—* >fc- »—^*?
             b)  li pataUi  sn..l>id;
         2)  Refer*  to violated alkalinity" •tandaro's

             b)  mm tuLtimlnmt May mm*  tm  •Hililli
             c)  Ommm*»*m Uf lUl.itim.
   1-26  Paragraph  II--enclo»»d ordinance  anil  teat reiultt of eludge are
         *ub*itteubteq
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                               APPENDIX C

                          Response to Comments

JS£PA has responded to tne man/ comments that were received from the public
on our Draft Environmental Impact Statement.   The "Itan"  nuoer preceding
tne comment refers to the Comments •mien are  found in Appendix B.   Many of
of the comments nave oeen extremely neipful and nave teen incorporated in
tne production of tnis Final Environmental Impact Statement.

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RESPONSE TO ITEM il

                      Illinois Wildlife Federation

1.  Trie riill Count/ ibid/ data is contained  in  tae baocground data presented
    to the USEPA o/ MSDGC.  Also, Uw main University o£ Illinois partici-
    pants were active in cringing tneir experience and Knowledge co  tne pro-
    ject.  The project was not on strip-mined soils; tnerefore, the  use of
    tneir data was only put into toe national data oase for  nutrients a,k3
    fate of metal cations in tne environment.

2.  Acknowledge.  Reraemoer, nowever, tne Pulton Count/ 3oacd also wanted to
    oontrol tne land, out individuals sold tneir  land very quiotly to doJGC
    and left Fulton Count/.

3.  Acknowledge

4.  Tie COOK Count/ Forest Preserve System coulJ  not logically oe used
    oecause access can not oe controlled and there are insufficient  areas
    of open land for spreading.

5.  No Caokaent

6.  This statement is mostly untrue.  Tnere  are sons management proalems tnat
    riSOQC must learn to control, out overall tne  data clearly indicates tnat
    streams exiting tne MSDGC property are of ni-jner quality tnan the water
    upstream of the project.

7.  This statement nay be too siiqply stated.  If  tne project actually builds
    soils while producing row crops, tne soil would oecorae a natural aiologi-
    cal filter, holding pollutants in certain zones until tney are naturally
    degraded.  There are no data to indicate the  discrete Lnpacts of sludge
    versus the contaminants from past strip  mining.  Tne impacts are des-
    crioed in some detail within tne Final £IS.

8.  Utilization of tne project site could cause increased exposure to heavy
    metals aid sludge conta>Binants.  However, tne risk to human iiealth would
    oe relatively small.

9.  Tne concerns expressed would oe the normal  concerns for  any sludge dis-
    posal project.  Tne Draft £ZM indicated  tnat  surface and jroundwater con-
    tamination were not major proolems in the rtaOGC project.  The air pollu-
    tion issue has been largely resolved due to mxlified application tecn-
    nkpes.  Control of the crops grown on sludge amended soil should signif-
    icantly reduce any nazard to nuoan health.  Our introductory comments to
    this Final SIS have tried to portray the relative risks  anJ oenef its of
    the project,  rtnile no one could accurately state wno is receivinj tne
    nost oenef it or tne nost risk, the project  certainly is  oenef iting tne
    majority of tne people involved either tnrcugh worK opportunities, tax
    base, reclainad land, disposal opportunity, nutrient recycle, and overall
    energy.  A recent suggestion that could  oe  made to the MSGGC is  to use
    the corn grown on site for gasohol production, thereoy even furtner re-
    ducing toe riaxs to numan health or agricultural animals.
                                   0-1

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 10.   Runoff  basins  (generally do work.   Tnere is a management proolem associ-
      ated witn operations of tne Daains.   Valves mist oe correctly operated
      to obtain the  desired benefits.   Some operations have recently taKen
      piaoe to rectify tne sedimentation proolems t«at nave filled in tne
      oasin.   To dater no records of pump baoc onco tne fields have oeen pro-
      duced to analyze tnis proposed aspect of tne project.  Again, the water
      quality of 819 CreeK is Better after exiting tne project site tnan wnen
      it first enters tne site.   Tnere is a self-purification process talcing
      place.   Tnere  are no impoundments along the stream that could oe eutro-
      phied.

 11.   This statement has no foundation.

 12.   This statement has no real foundation.   Studies from tne University of
      Illinois nave  been inconclusive as to cause and effect relationship
      using forage grown on sludge amended soils.

 13.   We are  currently unaware of any data on this topic.

 14.   Since tne Pulton County aoard amended the alicalinity and pH standards
      for  sludge in  November 1975, there have oeen no violations of sludge
      quality.   Please refer to  text on tnis item.

 Due  to  the imprecise language of the Draft EIS sane of your conclusions could
 be reached.   However, the misconceptions of the Pulton County experience
 must be overcome.   The project  began in 1971, so there now is plenty of data
 to indicate  that no major harmful effects have occurred.  The lacx of any
 substantiated health-related proolems in either fish, human or wildlife
 resources is a significant piece of information.   Tne MS3QC nas used a steer-
 ing  committee throughout tne project to obtain input and define goals.  To
 date itajor positive achievements have oeen reacned with no significant
 environmental impact.   When viewing this project you must realize the goals
 that both Fulton County and the M30GC wete trying to achieve.  Botn parties
 wanted  to return land back to its former productivity.  Their goals are cer-
 tainly  being attained.

 RESPONSE  ID  ITEM 12

                            VOLUMc I - Tnorne

 Your comments on Agronomy Pact  Sheet SM-29 have been utilized in tne Final
 EIS.  There  were certain production errors.   Me also gave credit to tne
 University of Illinois for the  materials contained within tne fact sheet.

The  error en percentage of strip-mined land in Fulton Count/ has been cor-
 rected!  too say 6 percent.

The  issue of  production of sludge in dry tons by MSDGC has been confusing.
The  current  figure  we are using is 1250 dry tons per day for this Final
EIS.
                                    C-2

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RESPONSE TO ITEM  *3

                              Dale Vaughn

Toe Environmental Protection Agency has  not awarded any Federal funds to
tne M3DGC project to date.   There have oeen some expenditures for nealtn-
related intact studies.

A letter was written to Mr.  Dale Vaughn  snortly after we received his
contents asking if he could  provide furtner information to docunent the
death of cows in  his pasture.  No response was received.

Tnere certainly are mixed reactions to the project by persons living along
tne perimeter.  Sane people  have never oojected,  some people have contin-
ually oojected to odors.  There is no positive way to respond to the odor
complaints.

RESPONSE TO ITEM  14

           Bureau of tne Budget and Department of Conservation
                           State of Illinois

rfhile there nas not oeen much research on fate of neavy metals in the
Fulton County environment, no prooleras have oeen identified.   Tnis Agency
would support tne suggestion to do furtner research to determine impacts
on fisn and wildlife on tne  project site.   Sane caution is necessary oe-
cause it would be difficult  to sort out  tne impacts of ambient metal pro-
oleras due to strip mining versus sludge  application.

The MSDGC has agreed to Keeping certain  pot hole areas on the property to
support water fowl.  Also the major surface water resources are being left
intact.  It is not necessarily the intent of this study to analyze tne
loss of marsh land through recontouring  practices.  The joint goal of
Fulton County and MSDGC was  to return these lands to agricultural produc-
tivity.  This meant loss of  some raarsn land while developing a land use
plan to conserve  the rest of the land.   There are no figures availaole to
indicate how mucn diversity  was lost since 1971.   Therefore it is dif-
ficult to provide a definitive answer to these types of questions.   If tne
project area is expanded, the opportunity bo nave these questions addressed
is certainly possible.

RESPONSE TO ITEM  15

                           Marvin Schmidt,  HD.

Tnis Agency has put together several publications on the relative risxs
and potential health hazard* of sludge application projects on humans.
Pertinent information has oeen incorporated into tne Final £15.

Nnile your suggestion that a controlled  study oe performed on humans to
obtain answers is very good, sludge disposal activities must continue.
Tnere are no easy answers in disposal activities.   We must evaluate the
present alternatives and ma/ce wise choices.   Tnere is no reason at present
                                   03

-------
to discontinue the project since no adverse  inpacts have been defined.  More
research and wont in tne area may result  in  a cnange of attitude.  Tne Wil-
louvjhby Farm in Australia has oeen applying  sludge to  land for 150 years
without significant impacts.

KESPONSe 'ID ITEM #6

                                  U3CA

Tne comments of your Agency nave oeen incorporated into tne Final £13 text.
Tney have been extremely helpful.  Please note  tnat the text has oeen ex-
tremely modified and tnerefore pages noted in your text are not tne saiie  in
tne final £13.

RESPONSE TO ITEM 17

                       Soil Enricnment Materials

The figures used in tne Draft EZS were fran  national averages available at
the time of BIS preparation,  four new data  is  extremely helpful in updating
tne existing data,  vfe are nappy to include  this  data  in the text.  It is
hard to obtain good, suitable data because of varying  rail conditions and
secrecy surrounding contracts.

Tne 3.5 percent figure was provided by tne MSO  as their average for earlier
snipping.  They are installing new dewatering facilities and should oe aole
to ship higher solids in the future.

RESPONSE TO ITEM |8

                            Ledbetter Letter

Tne wtiole section on aerosolization of sludge particles and dispersion cal-
culations has been redone.  There were many  errors.  The latest text has
dealt wita those errors, but nas been reduced suostantially because spray
application is not the current node of sludge application.  This nas oaen
replaced oy direct incorporation of sludge.

Your main comments are addressed point by point as follows:

Content:  pp VII-33 and 34...
          p 1-16 and p VII-35...

The figures in VII-33 and 34 are concentration  isopletns normalized to unity
and are incorrectly labeled.  Also the text  on  VII-32  indicates that tne
normalization factor for Fig. VII-14 is 4.75 ppm  and for Fig. VII-15 is 0.50
ppm.  Since both figures should represent the same source'atrervjtn g, tne
normalization factor should be identical  for both figures.

At a guide glance Ledbetter's calculations seam correct.  However the error
in figure titles suggests a confusion in  the moaning of dilution ration and
therefore tne Ledbetter number OKI/ not be wnat  tne EIS is attainting to
illustrate in the figures.
                                   0-4

-------
Since definitions,  input  numbers,  and sample calculations are lacking in tne
£13, resolution  of  the raised questions must cone from tne EIS's autnors.

Comments  pp. VII 1-7  to 15 — Tiie 1  percent aerosolization. . . .

This comment  refers to an error in tne calculation of the source emission
rate.  On page VIII-8 it  states that "1 percent of tne total  sludge sprayed
becomes airoorne" and tne mass is  used as tne emission rate for tne disper-
sion analysis.   On  page VI 11-10 the source emission rate (Q)  is numerically
calculated.   The calculation however is oased on 100 percent  of tne sprayed
sludge Becoming  the emission rate  for tne dispersion anal/sis.

Tne 1 percent assumption  was not utilized in tne numeric calculation result-
ing in an emission  rate Q oeirvj a  factor  of 100 too large. Tne resulting
ground level  concentrations will likewise oe a factor of 100  too large.

fnis office makes no  comment on the validity of tne 1 percent assuny>tion nor
tne interpretation  of tne nealto nazards, if any, of tne nunericai ground
level concentrations  predicted.

RESPONSE  TO ITEM 49

mo Comments

RESPONSE  TO ITEM |10

                                     Comments:
Due  to  the nature and  extent of tne comments from tne Metropolitan Sanitary
District, major  changes  in format and information have been instituted in
tne  Final EIS.   The  oasis of tne Final £13 is now the 1975 plan witn updated
figures on land  utilization and incorporation methodologies.  Because of tne
extreme cnanges  in text  and content, we are not providing detailed answers
to tne  MSD comments.   It is hoped tnat sufficient information transfer has
occurred to correct  errors contained witnin the Draft EIS.

RESPONSE TO ITEM 111

                             Lydia Dams letter

The  draft EIS did note tnat malodorants in sludge nave an eartny smell.  It
is nard to characterize  the smell exactly, so that term was cnosen.  Tnere
apparently is a  petroleum-lute smell also.  Host malodorants are contained
within  the perimeter of  the project area new due to modified application
tecnniques.  Setter  incorporation of sludje into soil would reduce dispersion
of malodorants even  further.   The goals of the USD at the project site should
oe closely examined.

The  influent into the  MSD system does contain a wide range of pathogens.
Many of tne pathogens  are either inactivated or Killed py the treatment pro-
cess.   Others remain in  activated states.   Most of the pathogens found in
sludge  shipped to Pulton County are ocomonly found in all Human heings.  The
rate and degree  of exposure to pathogens would dictate tne risK of being inr


                                    C-5

-------
fected and sucsequently being ill.  The greatest risk occurs to tne farm
operators at the site.  However, there is no evidence that the farm operators
ace any sicker than other local people who live in the Canton area.  Ajain
methods of treat/rent, storage and application over toe past few /ears nave
decreased the risk tnat a resident along the farm perimeter would oe adversely
exposed to pathogens.

The MSD has experienced a wide variety of proolems in tne early stages of
sludge application.  In the strip-mined areas, soils were destroyed, parent
soil materials and shale were mixed with top soil and subsoils.  These mixed
soils did not aosoro moisture well, tnereoy creating ponds or dump soils.
Wet soils can cause seeds to rot, not germinate.  The rtSD has learned this
lesson and now uses fields on an alternating basis to obtain two goals:
nutrients recycle through row cropping and utilizing/disposal of sludge
solids.  Place land, never strip-mined, was a prime target for early applica-
tion oecause no major preparation of soil was needed.  However, the greatest
ajnjunt of land owned and fanned is strip-mined land.  Tne land partially  re-
clamed oy otners prior to MSD experiences the same needs as unreclaimed
land - a lack of sufficient soil structure and nutrients to support row crops.
It makes good sense to upgrade the previously recontoured areas to provide
cow crops and tnerefore wider tax uase in Fulton County.

Tne MSD is monitoring groundwater around the site.  The results are made
available to both tne State of Illinois and Pulton County.  Two aquifers  are
found on the site} a shallow aquifer wnicn has been contaminated oy tne
strip-mining activities and a deep aquifer wnicn is used for drinking water
supplies.  There is no evidence that the *@D project has adversely affected
either of these aquifers.  There is evidence to snow tnat on-lot systems  at
rfe-rta-Tuk Hills has adversely affected the surface waters in tne small ponds.

Me have no comment on the Big Sluestem project.

The final EIS has been streamlined and hopefully is more readaole.  Me
are unaware that anyone has called tne local farmers illiterate.

It would be an overstatement to assume tnat local Fulton County people
may incur a hign risk from tne consumption of fisn and wildlife found
on the project site.  Host people do not have access to hunting on the
property.  Tne fisning at the local recreational area should oe
approached with extreme care.  The site is apparently pleasant enough
to attract visitors, even though surrounded by sludge application
fields, from man/ local towns.  Pishing is an opportunity at the site
and while there is no evidence that fisn are tainted from sludge con-
stituents, every fish should be tested prior to consumption.  Nate that
this is not a requirement of this Agency.

HESPONSE TO ITEM 112

                          Department of Interior

Regarding the State Historic Preservation 6£ticer contact, an initial contact
nad been made with the office.  Tne project is found in a rural setting that
naJ been almost totally impacted oy strip-mining activities. • Tne reclamation


                                 C-f

-------
of  this land will not further adversely  inpact cultural resources.   It
provide additional  recreational  and work opportunities within tne area.

Tne draft EIS did state tnac tne land  within tae project area fell into tnree
categories? unreclaimed strip-mined land,  partial reclaimed stripmined  land
and existing farm lands.   Bach of these  categories has potential for wildlife
naoitat.  In the case of unreclaimed land, tnere were many potnoles wnich
provided water fowl cover.   Many of these have been left intact due to  input
at  steering committee meetings,   on tne  United Electric property, tnere exists
a scruo forest tnat provides anyle ocver for deer.   MUCH of tnis cover  is
oeing preserved.  Tne rtSD provided land  for fisning and otner recreation and
this is fully explained in tne text.   Host oox end cut laK.es on tne site are
oeing preserved.  In  snort,  no major f isn and wildlife naoitat is oeing lost
due to tnis project.   Tne row crops will provide food for wildlife and  proper
contouring and soil conservation procedures should ennance tne fisn nabitat
in  tne major streams  traversing  tne area.

The MSD project, altnougn on strip-«ained lands, currently is unrelated  to tne
remaining coal oeds.   This statement can not deal with future, unanticipated
unrelated activities.

Tne corrections in  numerical values throughout the CIS nave been modified.

rfe  regret tne initial errors.

The major portion of  the project area  is strip-mined land.  Tne taoles  within
the text clearly indicate tne undisturoed place lands from stripped land.
There is not a lot  of good data  on ground water movement witnin the strip-
mined soils.  It is even difficult to  differentiate oetween tne unpacts of
the coal shale and  the sludge oonstituents at the site.  This Agency suggests
that tne USD design a oetter ground water testing program to reliably indi-
cate impacts to ground water and provide furtner data.

Tne Draft and Final EIS ootii contain a nap snowing recreational sites in
relation to the project.   Tne impacts  are explained in tne text.

RESPONSE TO ITEM |13

                               Peter Ferro Sr.

There Is no application for Federal funds at this time for tne MSDGC project.

Insofar as this Agency can determine,  standard nealtn and environmental pro-
cedures have oeen adhered to witnin Fulton County.   See Chapter V for full
description.

Me  are in receipt of  several petitions from people and they are published as
part of this Final  EIS.   Funding of aspects of the project are at this  point
uncertain and should  not proceed until litigation is final.

This Agency feels that tne MSOQC has made  significant progress in leveling
land and utilizing  solids for fertilizer value, while building soils by con-
tributing organic natter to toe  disturoed  soils.
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Tne MSDQC has no plans at this point to abandon the farming practices in
Pulton County.  Various Federal and local agencies, plus toe University of
Illinois, are watcning this project closely.  To date no significant environ-
mental problems have oeen surfaced, except tne air issue.
RESPONSE 20 ITEM 114
                          Clarence Oswald Letter
Ho Comment
RESPONSE ID ITEM J1S
                                Petitions
No Comments
RESPONSE m ITEM 416
                           Citizens* Statements
(to Comments
RESPONSE TO ITEM 117
                             ttachel Schmidt
for answers concerning sludge quality see tne appropriate section of tne EIS.
HSOGC  has met all applicable standards set by tne Pulton County Healtn Depart-
ment.
Thank  you for your good research  into heavy metals and other compounds.  Me
viewed the material and changed sane details in our rewrites.
Spraying of sludge has been stooped oy tne united efforts of the citizens.
This is very positive and snojld  help in the long run oy decreasing any risks
associated with the practice and  also decrease visual blight.
Tne wildlife in the area could oe adversely i%>actad of tne project.  Tnere
could, on the other hand, ae beneficial iapacts.  No study design has been
put together to measure the overall impact on non-game animals:
There  is evidence that animals are abundant on tne land.  They seen to be in
almost all area* of the project site.  From personal sitings and from col-
lected data, it Mould appear tnat there are relatively no external impacts on
populations of animals.  If disease and aonormal oehavior is occurring in tne
populations, a study should be undertaken.  The loss of some haoitat has been
noted.  However, much of tne most important nabitat has been and will oe
preserved by the project.
If people examine the record carefully tne MSOOC has completed many major
task*  that wen negotiated oy the Fulton County aoard.  Tney added to tne tax
roles, they created employment, both full time and
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RESPONSE 10 ITEM 118

                         Joanne Alter Statement

Acknowledged

RESPONSE TO ITEM 119

                      League of rfonan Voters' letter

Acknowledged

RESPONSE TO ITEM 120

                              Melba Ripper
                    Citizens For a tetter Environment

The rtSDGC would nave  to continuail/ expand their  land application naldings  if
tney were to apply all sludge to land from all of their plants.   Current oper-
ations do include several land application areas  outside of  Fulton County.
Some sludge has oeen  shipped to Florida for application.  Taere nas  oeen some
discussion aoout expansion of land application at other sites on  both strip-
mined land and other  land.  In the recent past, rtSOSC <*orKed in cooperation
with the U.S. Forest Service in southern Illinois to reclaim land where acid
mine drainage was a f coolenu  The exact extent of project needs nay  oe  on-
Known.  However, the  important issue is to create and operate projects  in
productive harmony and limit the amount of risk incurred.

Since the time of the draft IIS, MSDGC has made extensive changes to the
existing environmental carriers and holding structures,  ite  agree that  a. oet-
ter monitoring system should be developed and constantly cnecked  to  obtain
desired results.

The capacities of retention basins have oeen redocunented and in  many cases
resolved.  Operational recommendations have oeen  suggested to remedy the
project.

Since spraying operations were terminated from the project and more  sopnisti-
cated application methods employed, odor complaints nave decreased.  Certain-
ly the new operations and ponding created some odors.  It is difficult  to
determine tne exact impacts of nornal fam odors  sucn as nanure spreading,
hog fanning and tnen  the land application practices.  An attaint  was made.
This agency recognizes tnat odors exist, cut we are unaole to say they  are  a
nuisance.

Tne information dealing with aerosol izat ion was incorrect in the  draft  £13.
It has oeen corrected.
RESPOKSE TO ITEM

                           Herbert J. Schooner

The Fulton County site water cycle assumes  tnat precipitation is  equal  to
evaporation.  The addition of water  (and sludge)  is  a type of irrigation

                                 0-9

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 system  that  snould ultimately help crop production.   Some crop results no*
 show that  strip-mined land is producing nearly tne same crop yields as place
 land.

 P"SPQNS£ TO  ITEM #22

                       Illinois Department of Conservation

 Me acknowledge  that more studies could ce done on the rtSQGC project, However
 tnis is already tne most monitored project of its kind in tnis nation.

 Sources of heavy metals and otoer contaminants in tne localized environment
 include and  are not limited to tne following sources: tne MSOGC project site
 itself  because  of past stripraining activities; sludge that was transported to
 tne  site oy  MSDGC; atmospheric fall out from industrial and residential
 sources; etc.   A very sophisticated study design to determine exact quantities
 of contamination from all sources has not been undertaken.  It sould oe noted
 nowever, that water quality in cii-j Creek does improve as it flows through tne
 project site.   Tiiere is seme data available on fisn flesn analyses, rf3D3C
 snouid  try to upgrade this aspect of tnair monitoring.

 Contained  in the 1975 land use plan for the site were several aspects of land
 management and  tradeoffs that would be undertaken to protect resident water-
 fowl.   It  was decided by M303C in conjunction with tne steering committee to
 protect pothole areas and certain marsn areas to provide adequate naoitat.
 Not  all areas were preserved.   Lakes and retention basins exult into the pro-
 ject augment tne existing haoitat and provide some mitigation for tne losses.
 MSDGC does provide a staoilized situation wnich snould ensure use oy water-
 fowl for many years in the future.   It must oe kept in mind that tne project
 did  meet many of the County's objectives to return the site oacK to row crop
 production and  provide an increased tax case.   Secondly, tne row crop pro-
 duction may  become a source of food for waterfowl and otner wildlife.

 This Agency  is  not aware of any new data on the potential hazard of direct
 ingestion  of sludge on manuals or birds at this point.  The University of
 Illinois did sore preliminary studies on pheasant populations and their in-
 gestion of crops grown on sludge-amended soils.   Tnis is referred to in the
 EIS  text.

 The  EIS text does address the loss of water resources based upon the 1975
 land use plan.   All effects were made to protect toe best water resource;
 however not all  resources could oe protected.   The i*30GC actions did provide
 several new  areas such as tne supernatant basins wnich provide haoitat for
 waterfowl.  A setter discussion is now provided.

At tnis point several race plant species were identified.   Tne areas were and
 are currently protected oy MSDGC from farming and construction activities.
 Tne rtSOGC  is also developing new areas for rare and  important prairie species
 under the Big Blue Stem program,   further information is availaola from the
 HSD3C.
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 RESPONSE 1O ITEM 123

              Illinois Environmental Protection Agency (IEPA)

 Tnere is no proposed EPA action at tills tine.   Tnis is addresseJ in tne for-
 ward of  the final EIS.

 The  items suggested by the IEPA were used as part of a sucstantial rewrite
 on the surface water quality.   Tnis is also true coneerniry tne operation of
 retention basins.   Me are grateful to IEPA for suai in-deptn oamnants.

 The  ground water section oamnents are hard to accommodate in certain respects.
 Since the land has recently been disturbed, in geological terms, patterns of
 ground water f low are emerging and contamination of ground water could be
 from a variety of factors which include the MSDGC project.  No attempt was
 made by USEPA to do a detailed analysis of ground water, therefore the general
 trends presented by MSDGC were used to the extent possiole.  If the IEPA is
 requiring this study,  they snould inform the MSDGC of that fact.

 Maps were changed when a better data basis was available.  The other IEPA
 comments are valid.   A detailed study snould oe recommended oy I£PA and nego-
 tiated with the MSDGC as part of their continuing operational permit.

 Comments on air pollution are acknowledged.

 The  main oody of tne £15 was rewritten and does incorporate, where possible,
 IEPA oQanents.   A preliminary final was provided to IEPA for review and can-
 raent and hopefully will satisfy all State requirements.

 RESPONSE TO ITEM |24

                                Paul Parisn

 It is inaccurate to state tnat Fulton County did not understand the project
 or the consequences of sludge  disposal.   Mr.  Charles Sandoerg of the County
 had  presented an overall position paper whicn discussed favoraole and  un-
 favorable aspects of the project.

 As far as toxicity is  considered,  two points must be made.  If tne constit-
 uents applied to the land are  toxic to plants, tne plants die and then some
 caution  should be taken in using the land.   If one considers toxicity  of
 constituents to nuraans,  it must be pointed out that tne MSDGC is not growing
 crops for numan consumption.   There are tests  being conducted on animals
 either on the site or  being fed with crops grown on tne site.  To date no
 negative conclusions have been reached.

The  discussion In the  final EIS does address and verify tne items you  dis-
 cussed in your very  interesting presentation of fate of  heavy metals and
 their impacts en organisms.  It oust oe noted  that tne HSCGC project is the
most heavily monitored project in  the United States.   The results of the
project  are national discussion items and to date no substantial adverse
 inlets  of  sludge  application  other tnan odors at the project perimeter have
 oeen  found.

                                 Oil

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Tnere have been many beneficial aspects of land application at Fulton County
and nation-wide.  And tnese  oenefits appear  to outweign toe potential risks
of sludge application.

RESPONSE ID ITEM |2S

                               liaro Luthy

Major strides nave oeen made since tne early years  of  reclamation activities
at the Fulton County site.   Tne MSDOC naturally took advantage of tne exist-
ing nonatrip-mined land to oegin implementation of  tneir project.   It takes a
great deal of tine to recontour tne strip-mined land and apply sufficient
nutrients to grow crops.  It is premature to judge  tne final  outcome of  tne
project.  New fields have been created since late 1975 and  early  1976 tnat
were oeing readied for crop  production. Tne  final £13  states  tnat many fields
can not produce rot* crops annually.  But you are  correct in stating tnat ini-
tial com crops were grown on undisturoed lands.

Tne draft and final EZS both addressed tne application of sludge  on nonstrip-
mined land.  Tnere are different rates of application  for place land.  Tne
rates are based upon fertilizer needs and not  reclamation rates.  To the oest
of our knowledge much strip-mined land nas oeen recontoured and is  oeing used
for application of sludge and  crop production.  This is evident from existing
aerial photographs.

There was a tremendous initial investment in equipment at tne site.  But since
the equipment is related to  tne transportation and  distribution of  sludge
solids they can not oe separate fran otner reclamation costs  sucn as recon-
touring, wages and environmental monitoring  equipment.

RESPONSE TO ITEM 126

                          George Spyres Letter

Me recognize tnat there were previous attempts to reclaim tne project lands.
dowever, tnese early projects  did not build  soils or bring  tne lanJ bacx: to
its former productive level.   Tne M30GC is now growing row  crops, providing
construction and fanning joos, and paying county  taxes.  Tnis is  a  positive
move for tne Fulton County area.  Tne draft  £IS was clear in  pointing out tne
increased taxes that tne rtSDGC paid on the land.  They are  not wnat undis-
turoed land values ace but do  indicate a positive trend.

Tnere has not oeen a stud/ directed at health  impacts  in Pulton County.  How-
ever, the oest indication is tne lade of evidence tnat people living near tne
site or working on the site  have not reported  any abnormalities or  sustained
health impacts.

Crops are not grown for human  consumption at tne  site, therefore  tne risKs to
human health are consideraoly  reduced.

Radioactive subsstances are  strictly controlled and tnere is  no conceivaole
way Car tne suostances to reach the waste streams in Chicago  and  therefore
the sludge at the treatment  plant.


                                 0-12

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There were many areas  within the site that  needed modification and repair due
to changing methods of sludge and supernatant application.   Tnis is a con-
tinuing maintenance practice which deserves better documentation,   it is true
that runoff from  the site could  contaminate water.  Good maintenance proce-
dures are aimed at minimi zing tne occurrences and impacts of accidents.   It
oust be noted  that not ail probable  contamination should ue attributed to
this action.   The land was destroyed c>/ strip-mining  operations which contain-
inated many of. the existing  wells and surface waters  in the areas.  Also,
residential developments  in  the  area are a  major  source of  excessive nutri-
ents and sedimentation in the area.   The soils are generally not acceptable
for the construction of septic systems and  maintenance of such systems should
DC questioned.

As soils are worked they  are more capable of aosorbing the  nutrients put on
tne ground.  Also many fields Iwe seen reoontoured to remove depressions
which created  ponds.   However, the MSDGC should further anal/ze their opera-
tions so that  they maximize  loadings without creating ponding situations.
This is described expecially in  relation to rainfall  events.

The riSDQC had  investigated many  systems prior to  developing tne Prairie Plan.
In their opinion  this  project created a great opportunity to bring land bade
to a level approximating  its former  use while allowing a major metropolitan
area to utilize its waste by-products.   The costs of  energy are increasing
oontnly and incineration  of  sludge does not appear to be a  wise use of oil.

RESPONSE TO ITEM  127

                              Or. Quon Ph.D
                          Northwestern University

There was substantial  error  in the presentation of aerosol  transmission at
the Pulton County Site.   These errors have  osen corrected and toe associated
graphics were  either corrected or deleted from the final SIS.

The issues of  storage  tins,  odor complaints and wind  rose configuration have
been resolved.  Mew data  inputs  were used to give correct information.

The 3>A does recognize that  toxic effects are different depending upon the
person and the node of material  entering the body.  People  nay become in-
fected with pathogens  and not become physically ill.   The moan body is also
capable of warding off deleterious materials depending upon where tney enter
tne body.

Tne Stability  Class and missing  0.01 factor in calculations have been cor-
rected.

One very positive thought should oe  considered when reviewing toe success or
failure of tne Pulton  County project.  The  HSO3C  has  token  land tnat was
essentially unusable and  put it  bade to productive use.  If crops are moni-
tored and precautions  taken,  the relative risks of the project snculd reaain
in the acceptable range.   He do  acknowledge tnat  heavy Metals and ocganics
will continue  to  accueulate  in the soils receiving sludge,  this is part of
risk and good Management  should  ensure that the risk  is snail, not nonexist-
ent.

                                  C-13

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                             ,4id«iest Research

As in toe response to tne Fulton County rlealtn Jepart.runt, nun/ o£ tne state-
>aents in tne draft oIS were unclear or .aisrepresentations of  fact.  Tne majjr
topics of air qualit/, aerosol ization and odors nave oeen couyletel/ re-
written.

?iid«#est Research  Institute was correct to point out tne  technical errors.
Please refer to the appropriate sections o£ tne final  £13 for revised Jis-
cussions.

«*e essentiali/  ajree tnat tna prooaoiiit/ o£ sone odor arisinj in tie project
area *ras generated a/ tne project.  Tne t4aO5C aas ta-ten  steps to reduce
sources o£ odor on site.   Since tnat tine odor jcxiylainta have oean reduced.

       2 TJ IK14  #29
                                 Comnents
                      Fulton Cou.it/ tlealtn Departinent

"f.e final SIS will address .nan/ aspects and correct data calculations
out t.ie entice  dooi,ient.   me «ura specific co»ii«nt3  raised are addresaaJ in
1.  It is  reall/ difficult to characterize t»»e odors  irom aludjj due to tie
    nature of  tne constituents and ttie ps/cnolojicai  Liyrassionj.  In ;to3t
    cases  tne  ter.n sewaje sludje odor nas no-* been  applied.

2.  Inis matter of docuaentation nas oeen corrected after visits to tne lealtn
    Deparbnent offices.

3.  Tiie odor identification iiet>iodolc<]/ .ias oeen  rewritten.

4.  Corrections on tne f injer printinj .tetiiodoloj/  na*/e oeen inade in tm final
5.  Tnis cannent is actuu^ledged and a corrected  stateo&nt appears in tae
    final document.

Tne itans on  tne su.anary sneet served as a basis  for a caiplete rewrite of
data as it pertains to tiie Falcon Count/ rlealtn Jepdrt:aent.

.•Ian/ of tiie sections in tne draft SIS were cnanjed  drasticali/.  Please refer
to tiie Taole  of  Contents for tne topics.  There were .run/ .nisleadinj state-
iients in the  draft that were clarified.
                                  C-14

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