910/9-81-087
United States	Region 10
Environmental Protection	1200 6th Avenue
Agency	Seattle WA 98101
Water	August 1981	EPA-10-WA-Spokane-WWTW-81
Environmental Impact Final
Statement
Spokane County
Comprehensive Wastewater
Management Plan

-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
s r4>	REGION X
4%
r,	1200 SIXTH AVENUE
5	SEATTLE, WASHINGTON 98101
0
*T
^~mTm~/	August 14, 1981
%	c<
¦*L PROlfe&
REPLY TO
ATTN OF-. M/S 443
TO: All Interested Agencies, Public Groups and Citizens
Enclosed for your review and comment is the Final Environmental Impact State-
ment (EIS) for the Comprehensive Wastewater Management Plan for Spokane
County, Washington.
This EIS was prepared in compliance with the National Environmental Policy
Act and implementing Agency regulations (40 CFR Part 6, November 6, 1979).
Availability of the EIS will be announced in the Federal Register on
August 14, 1981, beginning a 30-day comment period which will close on
September 14, 1981. This agency will take no administrative action on this
project until the close of the comment period.
We will appreciate your review of this document any comments you may have.
Please send all comments to Kathryn M. Davidson, M/S 443 at the above
address.

-------
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROJECT NO. C 530-918-01
COMPREHENSIVE WASTEWATER MANAGEMENT PLAN
SPOKANE COUNTY, WASHINGTON
U. S. Environmental Protection Agency
Region 10
Seattle, Washington 98101
With Technical Assistance From
Jones and Stokes Associates, Inc.
2321 P Street
Sacramento, California 95816
L. E. Coate
Deputy Regional Administrator
Prepared by
Responsible Official
Date
July 13, 1981

-------
PREFACE
On February 20, 1981 the U. S. Environmental Protection
Agency (EPA) released for public review and comment a Draft
Environmental Impact Statement (EIS) which evaluated the
environmental impacts of the Comprehensive Wastewater Manage-
ment Plan (CWMP) prepared by Spokane County, Washington.
The decision to prepare an EIS on the county's proposed pro-
ject was based on the EPA Step 1 construction grant appli-
cation from the county to plan, design and construct waste-
water treatment facilities. The Draft EIS was prepared con-
currently with the draft CWMP in order to reduce unnecessary
delay. EPA has prepared this Final EIS to respond to comments
received on the Draft EIS and to evaluate recently received
information relating to the water quality of the Spokane
River. The following discussion summarizes the activities
completed to date and the issues identified during the EIS
process.
The Draft EIS evaluated seven alternatives, the "no-
action " alternative and six "build" alternatives. Common
to all "build" alternatives was the sewering of identified
areas of the county on a schedule phased to meet the demands
of urban growth. The primary goal of the sewering is to
eliminate on-site and community waste disposal facilities
over the Spokane Vallev-Rathdrum Prairie Aquifer, a desig-
nated "sole-source" drinking water aquifer, and thereby reduce
the potential for contaminating this aquifer. The primary
differences in the alternatives were the location and methods
of treatment and disposal of the effluent, and the cost
associated with the various alternatives.
The preferred alternative identified by Spokane County
in the CWMP is Alternative A, which would collect wastewater
from all sewered areas of the county and transport it to
the City of Spokane wastewater treatment plant for treat-
ment . All effluent would be discharged directly to the
Spokane River.
After the Draft EIS was released, the State of Washington
Department of Ecology (DOE) released the preliminary results
of Phase I of their waste load allocation study for the Spokane
River. The results of this studv heightened concerns about
future water quality in Long Lake, located below the City
of Spokane wastewater treatment plant. The study indicated
that increased discharges of effluent to the Spokane River
might aggravate current (algae growth) conditions in Long
Lake. As a result of this information, several modifications
i

-------
to the county's preferred alternative (identified as Suboptions
A-1 through A-5) were investigated by the county, DOE and
EPA. A suboption could be implemented to provide a higher
level of phosphorus removal or to provide seasonal land dis-
posal should it be necessary to reduce phosphorus loadings
to Long Lake at a future date. Suboption A-3 would also
provide chlorine and ammonia removal, two toxicants of parti-
cular concern in the river. This information was summarized
and presented at the EIS public hearing held on May 14, 1981
in Spokane. The county's preferred alternative, identified
at the May 14 public hearing, is Alternative A. EPA concurs
with the county's selection of Alternative A as the most
cost-effective alternative and recommends, with certain condi-
tions, that construction grant funds be awarded for those
portions of the project which are on the state priority list
and are eligible for state and federal funding. However,
consideration should also be given to Suboption A-3 following
DOE's review of the effects of seasonal phosphorus removal
and following review of monitoring data on chlorine and
ammonia levels.
There are, however, issues which need to be resolved
to complete development of the 20-year project. One is the
uncertainty of the impacts on the Spokane River and Long
Lake of increasing the total effluent load beyond 44 million
gallons per day (MGD). Because of this, and existing condi-
tions, EPA is recommending the following condition be placed
on any Section 201 construction grant approved by EPA for
this project. The grant condition requires that the state
and county continue to monitor the Spokane River and Long
Lake to quantitatively determine the impacts of the project
and to allow them to ascertain which of the suboptions or
combinations of suboptions will best protect the water quality
and thus the beneficial uses of the river and lake.
1. Spokane County agrees to:
A.	Continue ongoing water quality monitoring of
the Spokane River in order to complete ana
later verify the waste load allocation for
toxics, oxygen demanding substances„ and
nutrients that may alter the eutrophic state
of Long Lake; and
B.	in conjunction with the Washington Department
of Ecology, conduct bioas say s to establish
maximum concentrations of chlorine and un-
ionized ammonia allowable when considering
the fishery resources in the Spokane River
near the City of Spokane's discharge.
This action is necessary to provide for the attain-
ment and preservation of Spokane River water quality
that will be consistent with beneficial uses.
i i

-------
Secondly, in order to comply with the National Historic
Preservation Act, the following condition is recommended
to be placed on any future grant relating to this project.
2. Spokane County must complete an archeolog ical/
historic records search and field survey of all
selected wastewater facilities sites, including
interceptor routes, pump station locations and
equalization ba sin sites. The research and surveys
should be conducted by a qualified professional
archeologist, The findings of the survey must
be submitted to the Washington State Historic
Preservation Office and the Advisory Council on
Historic Pre servation for their review and deter-
mination of effect.
EPA recommends that an agency or agencies be appointed
to oversee implementation of the water quality control strategies
identified in the Spokane County water quality management
plan. All necessary measures should be enacted to protect
the aquifer from nonpoint sources of pollution due to addi-
tional dense urban development over the Spokane Va1ley Aquifer.
EPA construction grant regulations allow EPA to provide
up to 75 percent of the cost of eligible portions of sewage
treatment projects. At the present time, only the North
Spokane interceptor is on the State of Washington priority
list for potential federal grant funds. The remainder of
the project must be paid for by state and local funds. If
the county decides at a future date to request federal funds
for other parts of the project, a determination for further
environmental analysis would need to be made by EPA for com-
pliance with the National Environmental Policy Act. Future
federal funding, however, is uncertain.
The Final EIS contains certain sections of the Draft
EIS which have been rewritten to reflect information and
comments received after release of the Draft EIS. These
sections include:
1.	Impacts on Surface Water Quality
2.	Consistency With the County's Generalized Land Use
Plan
3.	Project Economics
4.	Relationship of the CWMP and the County 208 Plan
Also included are chapters describing the county's pro-
posed action, EPA's recommended action and responses to comments
received on the Draft EIS. Upon publication of the Final
EIS, there will be a 30-day public comment period. On or
after September 15, 1931, the EPA Regional Administrator will
issue a Record of Decision making known his final determina-
tion on the award of a Section 201 construction grant.

-------
TABLE OF CONTENTS
Page
PREFACE	i
EXECUTIVE SUMMARY	1
Project Background and Objectives	1
Project Alternatives	4
Impacts of the County's Preferred Alternative	8
EPA Recommended Action	9
Remaining EIS Process	10
CHAPTER 1 - SPOKANE COUNTY'S PROPOSED ACTION	11
Introduction	11
Recommended Comprehensive Wastewater
Management Plan	11
Phasing	13
Project Suboptions	14
CHAPTER 2 - EXPANDED DISCUSSION OF DRAFT EIS ISSUES	19
Introduction	19
Spokane River Water Quality	19
Project Economics	58
Relationship of the CWMP to the 20 8 Water
Quality Management Plan	6 4
Consistency Between the CWMP and the County
"Generalized Comprehensive Plan"	67
CHAPTER 3 - EPA RECOMMENDED ACTION	6 9
Recommended Project	69
Conditions of Approval	6 9
Significant Adverse Impacts Likely to Occur
in Spite of Mitigation	71
CHAPTER 4 - LETTERS OF COMMENT ON THE DRAFT EIS AND
EPA RESPONSES	7 3
Introduction	7 3
CHAPTER 5 - ORAL TESTIMONY ON THE DRAFT EIS AND
EPA RESPONSES	20 9
Introduction	20 9
BIBLIOGRAPHY	253
ACRONYMS AND ABBREVIATIONS	25 9

-------
Page
INDIVIDUALS AND AGENCIES COMMENTING ON THE
DRAFT EIS	26 3
LIST OF REPORT PREPARERS	265
APPENDIX A - FINANCING PLAN COMPARISONS AND
RECOMMENDATION FROM THE CWMP	26 7
APPENDIX B - MATERIAL APPENDED TO LETTERS OF
COMMENTS ON THE DRAFT EIS	27 3
EIS DISTRIBUTION LIST	309

-------
LIST OF TABLES
Number	Page
2-1	Monthly Mean and Range of Selected Water	21
Quality Parameters for the Spokane River
at Post Falls, Idaho, and Riverside State
Park, Washington
2-2	Washington Water Quality Standards for	22
Class A Waters, Lake Class Waters, and
EPA Water Quality Criteria
2-3	Monthly Mean of Selected Water Quality	24
Parameters for the Spokane River at
Stations from the Idaho/Washington State
Line, to Gonzaga University, Spokane, from
11/79 to 06/80
2-4	Projected Effluent Volumes and Effluent	30
Pollutant Concentrations for Each
Alternative
2-5	Projected and Permissible Total Phosphorus	32
Loadings to the Spokane River
2-6	Projected Loading of Selected Water Quality 34
Parameters Due to Each Alternative
2-7	Calculated Increases and Resultant Spokane	35
River Concentrations of Selected Water
Quality Parameters at the Point of Effluent
Discharge Due to Each Proposed Alternative
at Low Summer Flow - 1992
2-8	Calculated Increases and Resultant Spokane	36
River Concentrations of Selected Water
Quality Parameters at the Point of Effluent
Discharge Due to Each Proposed Alternative
at Low Summer Flow - 20 0 2
2-9	Resultant Zinc Concentrations at 30-Day	37
l-in-10-Year Low Plows Due to Each
Proposed Alternative
2-10	Calculated Increases and Resultant Spokane	38
River Concentrations of Selected Water
Quality Parameters at the Point of Effluent
Discharge Due to Each Proposed Alternative
at Q7-X0 Fl°w ~ 1992

-------
Number
Page
2-11	Calculated Increases and Resultant Spokane
River Concentrations of Selected Water
Quality Parameters at the Point of Effluent
Discharge Due to Each Proposed Alternative,
at Q7-10 Flow - 2002
2-12	Calculated Increases and Resultant Spokane
River Concentrations of Selected Water
Quality Parameters at the Point of Effluent
Discharge Due to Each Proposed Alternative
at Dilution Zone - 1992
2-13	Calculated Increases and Resultant Spokane
River Concentrations of Selected Water
Quality Parameters at the Point of Effluent
Discharge Due to Each Proposed Alternative
at Dilution Zone - 2002
2-14	Resultant Copper Concentrations at 30-Day
l-in-10-Year Low Flows Due to Each
Proposed Alternative
2-15	Resultant Lead Concentrations at 30-Dav
l-in-10-Year Low Flows Due to Each
Alternative
2-16	Resultant Chlorine Concentrations
at 30-Day l-in-10-Year Low Flows Due
to Each Proposed Alternative
2-17	Resultant Un-ionized Ammonia Concentrations
at 30-Day l-in-10-Year Low Flows Due to
Each Proposed Alternative
2-18	Resultant Un-ionized Ammonia Concentrations
at 30-Day 1-in-10-Year Low Flows Due to
Each Proposed Alternative
2-19	Resultant Cadmium Concentrations at 30-Day
1-in-lQ-Year Low Flows Due to Each
Proposed Alternative
2-20	Summary of Costs for Original CWMP
Alternatives
2-21	Capital, Operation & Maintenance, and User
Costs for Supplemental CWMP Disposal
Alternatives
2-22	Estimated Costs to System Users
39
40
41
42
44
45
46
47
51
60
61
63

-------
LIST OF FIGURES
Number	Page
1	Regional Setting	2
2	Comprehensive Wastewater Management Plan	3
Study Area

-------
Executive Summar

-------
EXECUTIVE SUMMARY
Project Background and Objectives
The City of Spokane and its urban periphery are located
astride the Spokane River just a few miles west of the Idaho-
Washington state line (Figure 1). The urban area has a popula-
tion of approximately 290,000 people and has shown a rapid
increase in the last 10 years. This large population over-
lies a glaciofluvial outwash plain of coarse sands and gravels
which transports a large underground flow of water draining
from the Spokane River basin.
The cities of northern Idaho and the City of Spokane '
have relied on this aquifer as their primary source of drinking
water for many years. Most of the wastewater generated within
the city limits of Couer d'Alene and Spokane have been col-
lected, treated, and discharged to the Spokane River. Resi-
dents of outlying areas have relied upon on-site disposal
systems or small community disposal systems that discharge
wastes through ponds and drainfields over the aquifer.
As the population of the area has grown the waste dis-
charges have raised public health concerns both for the river
and the aquifer. Under provisions of Section 208 of the
Clean Water Act, Spokane County investigated the water quality
conditions of the Spokane Valley aquifer and the factors
that affect its water quality conditions. The study findings
(Esvelt 1978) indicate that the rapid urbanization and pro-
liferation of on-site waste disposal systems over the aquifer
are causing the quality of the groundwater to deteriorate.
The 208 report has been conditionally approved by EPA, pending
identification of an implementing agency. The Spokane County
Board of County Commissioners has accepted the 208 plan,
but has not adopted its findings or recommendations as policy.
In order to seek a remedy for the sanitary waste dis-
posal problems over the aquifer, Spokane County embarked
on a wastewater facilities planning effort in 1979 for the
urbanizing areas around Spokane (Figure 2), and sought grant
aid from EPA under Section 201 of the Clean Water Act. The
county's Comprehensive Wastewater Management Plan (CWMP)
was developed simultaneously with a Washington Department
of Ecology (DOE)-funded investigation into the sources of
and potential control measures for nutrient loads affecting
the water quality of Long Lake, an impoundment on the Spokane
River below Spokane.
The CWMP has been prepared for the county by Economic
and Engineering Services, Inc. of Olympia, Washington. The
document is designed to meet the wastewater planning require-
ments of a Step 1 facilities plan under Section 201 of the
1

-------
WASHINGTON
	
*"• "" r . ••, •; ' \%ms-i££»a2	«.— U_\ 	




BASE FROM USGS I 250,000
SPOKANE QUAD

FIGURE 1. REGIONAL SETTING

-------
GENERAL sjcWER SERVICE AREA
BOUNDARY ,
FIGURE 2.
COMPREHENSIVE
WASTEWATER MANAGEMENT
PLAN STUDY AREA
f
>uV5.
WASTEWATER
i —¦ MANAGEMENT
^	AREA
PRIORITY
v

-------
Clean Water Act, the state's General Sewer Plan {GSP) require-
ments under WAC 173-240, and the state's Sewerage General
Plan (GSP) requirements under RCW 36.94. The plan has assessed
the future wastewater management needs of the Spokane area,
identified specific facilities needed to meet wastewater
service demands, and described a management program to imple-
ment a coordinated city-county wastewater system.
EPA has prepared a Draft Environmental Impact Statement
(EIS) to describe the possible environmental consequences
of implementing the CWMP, as required by the National Environ-
mental Policy Act (NEPA). That document was issued to the
public in February 1981. The EIS is also being used to meet
the environmental analysis requirements of Washington's State
Environmental Policy Act (SEPA). This Final EIS has been
prepared to respond to written and oral comments submitted
on the Draft EIS.
Project Alternatives
Alternatives Considered in the CWMP
The CWMP investigated seven project alternatives, six
that would provide wastewater facilities for the urbanizing
unincorporated areas around the City of Spokane, and the
"no-action" alternative. The six action alternatives were
designated A through F and provided various means of trans-
porting, treating, and disposing of wastewater from North
Spokane, Spokane Valley, Moran Prairie, West Plains, Liberty
Lake, and Newman Lake.
Alternative A, which has been selected by the county
as its preferred action pending completion of the EIS, in-
cludes collection and transport of all county wastewater
to the City of Spokane's central wastewater treatment plant
via the city's interceptor system. Wastewater storage and
equalization basins would be used to regulate county flows
into the city interceptor system in order to avoid increasing
combined sewer overflows (CSOs) which occur during wet weather.
The city's combined sanitary and stormwater runoff interceptor
system is overtaxed during rain or snowmelt periods; this
causes discharges of untreated wastes to the Spokane River.
Alternative A has a projected cost of $81.6 million.
Alternative B was similar to A, but waste flows collected
from the Spokane Valley, Moran Prairie, Liberty Lake, and
Newman Lake areas would be treated at a new treatment plant
at Felts Field, on the eastern edge of Spokane. The treated
wastewater would be discharged to the Spokane River upstream
from the city. The principal drawbacks of this alternative
are that it would cost $27 million more than A and would
discharge wastes to the river upstream from the city, in
an area that recharges the city's underground water supply.
4

-------
Alternative C was also similar to A, but wastewater
from the North Spokane area would be treated separately and
disposed of to the land northwest of Spokane. The land dis-
posal method contemplated was rapid infiltration. The pro-
posed infiltration area was along Rutter Parkway, within
the boundaries of the sole source aquifer designation made
by EPA. Therefore, EPA found that rapid infiltration dis-
posal was not acceptable. The county has indicated that
other methods of land disposal in that area (irrigation,
overland flow) are not economical; they also indicate that
there are no rapid infiltration sites in that area that are
off the aquifer. Alternative C would cost about $6 million
more than A.
Alternative D proposed separate treatment for both North
Spokane and Spokane Valley as described in Alternatives B
and C. The only county flows feeding into the existing city
system would come from West Plains. This alternative has
been rejected by the county because of the drawbacks listed
for both Alternatives B and C. In addition, Alternative D
would cost about $36 million more than A.
Alternative E proposed to transport wastewater flows
from Spokane Valley, Moran Prairie, Liberty Lake, and Newman
Lake to the North Spokane area to combine with a North Spokane
land disposal facility. It would be located in the Rutter
Parkway area and would use rapid infiltration as the dis-
posal mode. As with Alternative C, this disposal mode is
not acceptable to EPA over the sole source Spokane Valley
Aquifer. This and the project1s high cost {$33 million in
excess of A) led to the alternative's rejection.
Alternative F would transport both city and county waste
flows, after treatment, to a rapid infiltration disposal
area adjacent to the Spokane River in Stevens County. No
waste discharges to the Spokane River would occur. This
would have a very positive influence on Spokane River water
quality, but would cost $'41 million more than Alternative A
and was considered too expensive.
The no-action option, which would provide no new waste-
water facilities for present or future residents of the study
area, was rejected because it would do nothing to alleviate
the public health threat created by on-site waste disposal
practices over the Spokane Valley Aquifer.
Alternative Preferred by Spokane County
As mentioned earlier, Spokane County has tentatively
identified Alternative A as its preferred wastewater facili-
ties plan. This was the recommendation of the facilities
plan engineers. Final county approval will not occur until
the environmental impact review process is complete and the
CWMP has been accepted as complete by DOE.
5

-------
Alternative A involves construction of trunk interceptors
serving Spokane Valley, Moran Prairie, North Spokane, and
eventually West Plains- Waste flows from Liberty Lake and
Newman Lake would eventually feed into the valley interceptor.
Raw wastewater storage basins would be constructed adjacent
to the valley interceptor near Carnahan and 8th Avenue and
near the North Spokane interceptor at the Ledgerwood Lagoons.
These basins would be used for both flow equalization and
storage during wet weather. The valley interceptor would
connect into the city's existing interceptor system near
Havana and 8th Avenue. The North Spokane interceptor would
connect to the city system near Rowan and Ash Streets.
The facilities were planned in two stages, with the
emphasis being to serve a priority sewer service area (PSSA)
outlined in the CWMP. In the first phase (1982-1992), the
valley interceptor would consist of four major branches,
serving Moran Prairie, Pasadena Park, Opportunity, and the
central portion of Spokane Valley along the Chicago-Milwaukee
Railroad line as far east as Sullivan Road. The North Spokane
interceptor system would also be constructed. This would
increase the waste flows to the Spokane treatment plant from
its present 32 million gallons per day (MGD), to approxi-
mately 4 4 MGD. Wastewater treatment at the plant would
remain as at present, unless DOE allows phosphorus removal
to become seasonal rather than year-round. Approximately
90,000 county residents would be served by Phase I.
During the second phase (1992-2002), the valley inter-
ceptors would be extended to Liberty Lake, Trentwood and the
urbanized area generally east of Locust Road between the
river and Sprague Avenue. The Liberty Lake treatment plant
would be abandoned and its flows would be fed into the valley
interceptor. West Plains would be sewered directly to the
Spokane sewage treatment plant (STP) in Phase II. Total
flows through the Spokane plant would reach 62 MGD by 2002
and a county population of 176,050 would be served.
The facilities plan recommendation is to finance the
local share of the project construction costs by issuing
general obligation bonds. The entire county would be assessed
at an estimated rate of 52 cents per $1,000 of assessed valua-
tion to repay the bonds. This would repay the local share
of the Phase I construction costs, estimated to be $26,486,600.
This assumes that federal and state grants totaling $20,000,000
would be available to pay the rest of the $46,486,600 total
construction cost. Payment for treatment capacity in the
Spokane STP and the Spokane interceptor system ($4,001,000)
would be funded through monthly user fees, estimated to be
about $8.56 per month (Economic and Engineering Services,
Inc. 1980a). Local collection systems would be financed
by formation of utility local improvement districts (ULIDs)
and assessing residents for capital and operation and
6

-------
maintenance costs. Collection system costs will vary con-
siderably, depending upon terrain and development density,
with total costs estimated in the range of $3,200 to $6,600
per dwelling (Economic and Engineering Services, Inc. 1980a).
While the financing scheme has not yet been finalized,
it appears that $20,000,000 in federal and state grants may
not be available for the county's recommended Phase I. The
state draft priority list for EPA construction grant funds
lists the North Spokane interceptor for $1.23 million in
fiscal year 1985 or 1986. Therefore, the county may decide
to embark on a scaled-down version of Phase I. Councilmanic
bonds may be used for initial funding. The scope and content
of a smaller Phase I has not been determined to date.
Project Suboptions
After the Draft CWMP and Draft EIS had been published,
DOE issued its Phase I waste load allocation study. This
study analyzed the status of phosphorus loads in the Spokane
River and their effects on Long Lake. A model of the rela-
tionship between phosphorus loads entering Long Lake and
the chlorophyll a levels in the lake was developed and used
to generate several waste load allocation scenarios. Initial
interpretations of the report were that added phosphorus
loads to the river would exceed levels necessary to maintain
Long Lake chlorophyll a levels at 10 yg/1, a level described
as indicative of eutrophic conditions (Washington DOE 1981).
Because the engineers' recommended Alternative A would
increase river phosphorus levels, DOE requested that several
suboptions to A be investigated; these could be initiated
to relieve water quality problems in the river and lake:
Suboption A-l. Modify Alternative A by limiting phos-
phorus removal to either a 5- or 7-month period. This would
reduce operation and maintenance costs rather than improve
water quality.
Suboption A-2. Store wastewater flows in excess of cur-
rent levels during the 7-month warm weather period. Stored
effluent would be used to irrigate crops in the West Plains
area or to generate power during the 5 winter months. There
would be no increase in the level of phosphorus discharged
from the Spokane STP during the principal algal growing season.
Suboption A-3. Increase phosphorus removal efficiency
by adding effluent filtration. This would keep phosphorus
discharges down as flows into the plant increased. The addi-
tion of ammonia removal and dechlorination were also con-
sidered in this suboption, in order to avoid exceeding EPA
recommended concentrations of chlorine and ammonia in the
river.
7

-------
Suboption A-4. Improvement of water quality conditions
in Long Lake through mechanical or chemical treatment of
the lake waters, or changing the depth of the lake's outlet.
Suboption A-5. Use of various water quality management
techniques, exclusive of wastewater treatment plants, to
limit the inflow of pollutants to the Spokane River. This
might include a ban on phosphorus soaps, improved street
cleaning, improved CSO and urban runoff control, and transport
of all wastewaters downstream of Long Lake.
While none of these suboptions has been recommended
to date, they could be initiated at a later date if it appears
the preferred alternative would cause unacceptable water
quality impacts in the Spokane River or Long Lake.
Impacts of the County's Preferred Alternative
If Alternative A is implemented as planned, a number
of significant impacts are likely to occur. These impacts
are summarized below:
o the Liberty Lake waste discharge upstream from the
City of Spokane will eventually be eliminated
o interim and on-site waste disposal systems serving
approximately 87,000 existing residents over the
Spokane Valley Aquifer will eventually be eliminated
o will provide wastewater service to approximately
89,000 new area residents by 2002
o will add approximately 12,100 new urban acres to the
Spokane area by 20 0 2
o anticipates servicing a population well in excess
of the EPA-state approved total for Spokane County
o projected phosphorus loads discharged to the Spokane
River from all sources will exceed the DOE recom-
mended total loading (507 pounds per day) to Long
Lake before 1992
o algal production in the Spokane River and Long Lake
below the City of Spokane waste discharge will
increase as the level of nutrients in the river
increases
o chlorine levels in the effluent plume and in the
Spokane River below the waste discharge will exceed
EPA 24-hour criteria for protection of freshwater
biota under low river flow conditions in summer months;
the anticipated concentrations could have a major
impact on the entire fish productivity of waters
below the outfall
o un-ionized ammonia and heavy metal concentrations
in the effluent plume of the Spokane waste dis-
charge will exceed EPA 24-hour criteria for pro-
tection of freshwater biota under low river flows
in summer months; these concentrations are likely
to be detrimental to those early life stages of
fish that are relatively immobile (eggs, fry) and,
therefore, unable to move away from the plume
8

-------
o odor and aesthetic impacts could affect residential
land uses surrounding the proposed Spokane Valley
wastewater equalization basin
o county residents hooking into the new wastewater
system will face additional costs; this will
include a collection system hookup fee of
$300-$ 1,300, a OLID assessment to pay for the col-
lection system averaging $366 per year (will vary
considerably with dwelling density), and a monthly
user fee estimated to be $8.56
o as growth occurs, urban runoff over the Spokane
Valley Aquifer will increase
o chemical and energy use for wastewater treatment
will increase significantly due to increased volumes
of influent
o carbon monoxide levels will increase along major
North Spokane and Spokane Valley transportation
corridors
EPA has identified Alternative F as the environmentally
preferable option, but its costs are too high when cost-
effective suboptions to the county's preferred alternative
are available that would protect both surface and groundwater.
EPA Recommended Action
EPA concurs that Alternative A is the most cost-effective
wastewater facilities alternative for Spokane County. While
it has not been identified as the most environmentally pre-
ferable alternative, we do not feel that the benefits asso-
ciated with Alternative F justify the added costs. With
the initiation of the monitoring and response plan programs,
Alternative A provides an opportunity for an environmentally
acceptable solution at significant cost savings.
EPA is proposing to place two conditions on this decision.
The two conditions are as follows:
o The State of Washington and the City and County of
Spokane should continue general water quality
monitoring in the Spokane River and Long Lake in
order to determine when (or if) any of the Alterna-
tive A suboptions should be implemented. In addi-
tion, ammonia and chlorine concentrations upstream
and downstream from the waste discharge, and in the
effluent plume, should be regularly monitored to
more fully assess impacts on the Spokane River
fishery. This is consistent with DOE's recent deter-
mination that dechlorination and ammonia control
must be implemented by June 1983 unless monitoring
data indicate it is not necessary. In the event
that water quality problems are identified, the City
and County of Spokane should take all necessary steps
to eliminate these problems.
9

-------
o Spokane County must complete an archeological records
search and field survey of all proposed facilities
sites in order to comply with the National Historic
Preservation Act.
In addition to these grant conditions, EPA is strongly
recommending the following:
o If the phasing of the project is determined to be
other than that recommended in the CWMP, the water
quality impacts should be carefullv evaluated.
o Spokane city and county agencies should proceed with
implementation of the nonpcint source water pollu-
tion control strategies identified in the county
208 plan.
A variety of other impact mitigation measures identi-
fied in the Draft EIS and reiterated at the end of Chapter 3
in this Final EIS should also be pursued in order to minimize
the potential impacts of Spokane County's preferred wastewater
facilities plan.
Remaining EIS Process
The Spokane County CWMP Draft EIS was issued for public
review in February 1981. A public hearing was held on the
document in Spokane on May 14, 1981. All comments received
on the Draft EIS prior to May 29, 1981 have been responded
to in this Final EIS. Comments on the Final EIS received
prior to the close of the comment period will be considered
by EPA before taking action on further grant awards to Spokane
County. On or after September 15, 1981, the EPA Region 10
Regional Administrator will issue a Record of Decision making
known his final determination on the grant award.
10

-------
	Chapter
Spokane County'
Recommended Actio

-------
Chapter 1
SPOKANE COUNTY'S PROPOSED ACTION
Introduction
The Spokane County CWMP analyzed seven basic options,
including "no action", to provide wastewater service to the
unincorporated but urbanizing portions of Spokane County
surrounding the City of Spokane. From this list of seven,
the engineering consultants to the county eventually recom-
mended Alternative A. This plan and recommendation are de-
tailed in the Draft Spokane County 201 Comprehensive Wastewater
Management Plan {CWMP) published in December 1980 (Economic
and Engineering Services, Inc. 1980a). The CWMP and its
recommendation were accepted and endorsed with certain pro-
visions by the Board of County Commissioners in December
1980. This chapter briefly describes the county's preferred
option and a series of suboptions that could be incorporated
into the plan in the future if water quality conditions in
the Spokane River and Long Lake downstream from the city
treatment plant so dictate.
Recommended Comprehensive Wastewater
Management Plan
The following description of the recommended CWMP has
been extracted and slightly modified from Economic and Engi-
neering Services, Inc. (1980b).
The recommended plan for the CWMP is Alternative A.
Wastewater flows from areas outside of Spokane would be con-
veyed to the existing city treatment plant through the city's
trunk and interceptor system. Secondary treatment, plus
phosphorus removal, would be provided at the treatment plant
and discharge would be to the Spokane River. Interception
of wastewater flows from the surrounding North Spokane, Spokane
Valley, Moran Prairie, and West Plains areas would be accom-
plished in two phases. Phase I would occur in the years
1982-1992 and Phase II in 1992-2002. These dates are approxi-
mations only.
Wet weather storage and equalizing basins would be con-
structed to accommodate flows from North Spokane and Spokane
Valley/Moran Prairie. Wet weather storage of flows would
be necessary during the initial phases of the city's combined
sewer overflow (CSO) abatement program, because during severe
storms all available treatment and conveyance capacity in
the system is needed to handle flows from the city. In addition
11

-------
to providing wet weather storage for flows from areas outside
the city, during the separation program's implementation
period, the basins would a11ow the dampening of daily varia-
tions in dry weather flows from these areas. This flow
equalization would have the effect of allowing a reduction
in the size of facilities designed to handle peak flow rates
and would increase the effective capacity of the city's
existing treatment and conveyance facilities. A significant
long-term effect of equalization would be to prolong the
life of the existing plant site.
North Spokane
Flows from North Spokane would be concentrated at a
point near Hawthorne Road and pumped out of the North Spokane
drainage area into the City of Spokane system. Initially,
the point at which North Spokane wastewater would enter the
city system would be approximately at Rowan and Milton Roads.
The existing Lidgerwood treatment lagoon would be converted
to the storage and equalizing lagoon for the North Spokane
area.
Wastewater service to the Indian Trails area is being
currently undertaken by the City of Spokane as an extension
of their system. Indian Trails area flows will be conveyed to
the city's Assembly Street trunk system by a gravity interceptor
currently planned by the city. Complete service to the Indian
Trails area will require the construction of pump stations
and force mains so that areas south and west of the city
interceptor can be served. It is assumed that sewer service
to this area will continue to be the city's responsibility.
Spokane Valley
Flows from Spokane Valley would be concentrated at the
east city limits north of Sprague Avenue and would enter
the city interceptor system through a large trunk sewer at
Harston and Havana. Spokane Valley would be served by a
gravity system with pumping being used only in isolated lower
areas. The backbone of the valley system would be a corridor
interceptor line which would generally parallel Sprague Avenue
east from the city limits to the Dishman Mica Road at which
point the interceptor would follow the abandoned Milwaukee
Railroad right-of-way to Liberty Lake.
Storage and equalization for Spokane Valley and Moran
Prairie would be provided at joint basin facilities. Phase I
basin facilities and pump station would pump wastewater into
the city system. Phase II improvements would inc;lude an
additional 45-million-gallon storage capacity to accommodate
the addition of customers from the valley as well as the
connection of Liberty Lake and Newman Lake.
12

-------
Phase II interceptors would extend to pick up flows
from Liberty Lake and Newman Lake. Additional interceptors
would also be constructed to the east, north and south
during this phase.
Moran Prairie
Service in the Moran Prairie area would be provided
by constructing a gravity interceptor which would begin at
the point of concentration south of the city and connect
to the main corridor interceptor serving Spokane Valley at
a point just east of the city limits.
Liberty and Newman Lakes
Liberty Lake would be initially served on an interim
basis by a treatment plant using secondary treatment with
discharge into the Spokane River. Treatment for phosphorus
removal would not be required until daily flows to the plant
exceeded 800,000 gallons. As part of the second phase facility
construction, the corridor interceptor would be extended
to Liberty Lake in lieu of expanding the 1 MGD plant. At
that time, capacity in the interceptor would be available
for all flows from the Liberty Lake and Newman Lake area.
Once interceptor capacity is available, the Newman Lake
facilities plan could be implemented.
West Plains
Service to the presently sparsely populated West Plains
area would be deferred to the second phase when the projected
population density would make viable the construction of
interceptor lines which would serve the Spokane Airport and
Airway Heights areas. The flows would be conveyed directly
to the Spokane treatment plant.
Phasing
Although the above paragraphs describe the plan as pre-
ferred by the county, this should be tempered by the realities
of funding. It is possible that the construction of inter-
ceptors and equalization basins would be accomplished in
phases as money became available. The project engineers
had not developed nor included in the CWMP a phasing scheme
beyond that described above. If finances dictate develop-
ment in smaller segments, the Spokane Board of County Com-
missioners will determine which elements of the project are
13

-------
constructed first. Judgments on which parts of the Priority
Sewer Service Area (PSSA) are to be sewered first will be
influenced by which areas show the keenest interest in forming
ULIDs for the collection systems. The implications of various
phasing schemes should be closely analyzed by the county
and DOE in terms of their impact on aquifer water quality.
Changes in the phasing of the CWMP may have significant
effects on water quality.
After reviewing the CWMP and the CWMP Draft Environ-
mental Impact Statement (EIS) (U. S. Environmental Protection
Agency [EPA] 1981), the Washington Department of Ecology
(DOE) took, several actions that could affect phasing of the
proposed project. In a letter of comment on the CWMP, DOE
stated that it "cannot support the requirement that the Liberty
Lake Sewer District hook up to a county interceptor unless
one of the following conditions is fulfilled:
a.	The sewage treatment plant (STP) does not meet
its National Pollutant Discharge Elimination System
(NPDES) permit effluent limits.
b.	The STP effluent is proven to have an adverse effect
on the Spokane River fisheries.
c.	The STP effluent causes unacceptable deterioration
of the Spokane-Rathdrum Aquifer" {Washington DOE
1981a).
It is therefore possible that the phasing in of Liberty Lake
flows might not occur as described in the county's preferred
project.
The DOE also requested that the project engineers develop
a series of suboptions to Alternative A that could respond
to possible water quality changes in the Spokane River created
by the project in its first phase. These suboptions were
subsequently described by Economic and Engineering Services,
Inc., (1980), in a supplemental report. Spokane County and
the City of Spokane could choose to implement one of these
suboptions in the future in order to meet changes in the
city treatment plant's NPDES requirements.
Project Suboptions
The following suboptions were developed by Economic
and Engineering Services, Inc., after publication of the
Draft EIS; therefore, they were not discussed in the Draft
EIS. The general nature of the suboptions and their potential
impacts were described at the EIS public hearing held in
Spokane on May 14, 1981. A summary report (Economic and
Engineering Services, Inc. 1980) describing the suboptions
was also made available to persons attending the public
hearing. Each of the options and its potential impacts is
reviewed below.	_ ,

-------
Suboption A-l
Suboption A-l would include the same interceptors and
equalization basins as Alternative A. Wastewater treatment
would also remain the same with one exception: treatment
for phosphorus removal would be discontinued in the cooler
winter months. Economic and Engineering Services, Inc.,
analyzed both a 5-month and 7-month cessation of phosphorus
treatment (October to March or October to May). During the
summer months phosphorus removal would be continued at an
efficiency rate capable of meeting DOE requirements.
Most of the impacts of Suboption A-l would be similar
to those of Alternative A. The significant differences would
occur in water quality and costs of treatment. The water
quality impacts are described in Chapter 2. If phosphorus
removal is halted for 5 months, annual operation and main-
tenance costs at the Spokane treatment plant would be reduced
$565,000 per year in 2002. With a 7-month cessation, the
annual cost savings in 200 2 was estimated to be $792,000.
No increase in capital costs would occur from Suboption A-l.
User fees for county residents would be $.27 and $.38 lower
per month by 200 2 for the 5- and 7-month halt in phosphorus
removal, respectively (Economic and Engineering Services,
Inc. 1980).
The change in phosphorus treatment would also create
a savings in chemicals and indirectly in energy consumption.
Alum or ferric chloride and polymer are added to the waste-
water to remove phosphorus. The amount of this material
consumed annually would be significantly reduced. The energy
involved in mining, manufacturing and transporting the
chemicals would be saved.
Suboption A-2
Suboption A-2 involves seasonal storage of treated waste-
water. Again, interceptors and equalization basins would
be used to serve the county areas just as in Alternative A.
During the 7-month warm weather period, however, all treated
effluent above current levels would be pumped across the
Spokane River to the south and stored in a reservoir con-
structed in Old Trails Canyon. This would maintain discharge
to the Spokane River at present levels during the peak re-
creational and algal growth seasons. The stored secondary
treated effluent would subsequently be distributed for crop
irrigation in the West Plains area or returned to the river
through an electrical generator during the five cold months.
The major impacts of this suboption are listed:
15

-------
o Would inundate an unspecified number of acres of
open space in Old Trails Canyon west of Spokane.
o Would provide an agricultural water source in an
area currently lacking in water supplies (irrigation
option).
o Would generate between 1,000 and 2,000 Kwh of elec-
tricity from return flows to the river (power genera-
tion option).
o Would use an unspecified amount of electricity to
pump effluent up to the storage area (more than
generated by return flows).
o Capital expenditures of $12,919,000 if storage and
power generation implemented.
o Capital cost of $40,210,000 if storage and crop
irrigation implemented.
o Increase in annual operation and maintenance costs
of between $281,900 and $320,400.
o Increase in monthly user fees of $.28 (power genera-
tion) or $.52 (irrigation reuse) for the average
service area resident.
The water quality impacts of Suboption A-2 are described
in Chapter 2.
Suboption A-3
Suboption A-3 would involve modifications of treatment
processes at the Spokane treatment plant to meet water quality
criteria for the Spokane River and Long Lake. Three separate
treatment modifications were investigated by Economic and
Engineering Services, Inc. (1980). Effluent filtration
was considered as a means to improve phosphorus removal effi-
ciency beyond the current 85-90 percent removal level. Re-
moval efficiencies of 9 2.1 percent in 1992 and 94.4 percent
in 2002 were investigated. This would reduce effluent phos-
phorus concentrations to 0.51 and 0.36 mg/1, respectively.
In the event that residual chlorine and ammonia con-
centrations in the treatment plant's discharge reached toxic
levels, Suboption A-3 would add dechlorination and ammonia
removal capabilities. Residual chlorine would be reduced
from about 1 mg/1 to nondetectable levels using sulfonator
equipment. During summer, ammonia would be reduced to 2.5 mg/1
in the effluent through breakpoint chlorination.
16

-------
The principal impacts of Suboption A-3 are in the areas
of cost and water quality. The water quality impacts are
discussed in Chapter 2. In terms of cost, the effluent filtra-
tion would require $10,900,000 in capital expenditures ini-
tially. An additional $2,920,000 would have to be spent
annually (by 2002) to operate and maintain the added -treat-
ment. This equates to a $1.57 increase in monthly user fees.
The dechlorination equipment would cost $360,000 initially,
with a $50,000 per year operation and maintenance cost in
the year 2002. The monthly user fee increase would be $.03.
Finally, ammonia removal by breakpoint chlorination would
have a capital cost of $1,000,000, an annual operation and
maintenance cost of $177,000, and a monthly user fee increase
of $.10 (Economic and Engineering Services, Inc. 1980).
Suboption A-4
Suboption A-4 has not been developed in great depth
by the project engineers. Its general concept is to solve
water quality problems in Long Lake by managing the lake
rather than changing wastewater treatment practices. Three
possibilities were briefly considered, including chemical
treatment of the lake, mechanical aeration of the lake, and
alteration of the lake's outlet. Chemical treatment could
involve periodic dosing with copper sulfate to control the
growth of algae. The idea behind changing the lake's outlet
structure is to improve circulation of waters that become
anoxic in the deeper parts of the lake. Little work has
been done beyond listing these lake management proposals.
The impacts of these management options cannot be listed
without more specific project definition. Economic and
Engineering Services, Inc., (1980) estimated that chemical
treatment of the lake would cost $135,000 a year in operation
and maintenance. This equated to a $.06 per month increase
in user fees. They also estimated that modification of the
lake outlet would have a capital cost of $1,680,000, an annual
operation and maintenance cost of $2,000, and a monthly user
cost increase of $.02.
Suboption A-5
Suboption A-5 has also been presented in only general
terms by the project engineers. It is a collection of
various water quality management techniques that could aid
in controlling pollutant levels in the Spokane River. The
range of possibilities described in Economic and Engineering
Services, Inc., (1980) includes a phosphate detergent ban,
improved street sweeping, improved urban runoff control,
connection of northern Idaho wastewater systems to the Spokane
system, and transport of all Spokane area effluent to a dis-
charge point below Long Lake.
17

-------
Rough cost estimates were prepared for a number of these
management techniques, but details of location or operational
procedures were not developed. The use of a phosphate soap
ban to reduce influent phosphorus loading was rejected by
the project engineers after determining that local residents
would suffer a net financial loss due to increased use of
bleach and water softeners and decreased clothing life
(Economic and Engineering Services, Inc. 1980). Piping
effluent to a point below Long Lake had an estimated capita 1
cost of $95 million, an extremely expensive undertaking.
Interception and transport of the Coeur d'Alene and Post
Falls, Idaho wastewaters was estimated to cost $14 million.
The concepts of increasing data collection and water
quality monitoring were also presented under Suboption A-5.
The idea would be to monitor the Spokane River and Long Lake
systems as Alternative A is being implemented. The additional
information could subsequently be used to determine whether
any of Suboptions A-l through A-4 should be implemented to
reduce the impacts of the continuing wastewater discharge
from the Spokane treatment plant. Continued monitoring of
the Spokane River and Long Lake is included as a condition
of EPA's recommended approval.
18

-------
	Chapter 2
Expanded Discussion on
Draft EIS Issues

-------
Chapter 2
EXPANDED DISCUSSION OF DRAFT EIS ISSUES
Introduction
Public comment on the Draft EIS focused on several key
issues. The economic and surface water quality impacts of
the proposed alternatives were two of the major concerns.
The relationship of the CWMP to other water quality manage-
ment planning and land use planning efforts was also the
source of many questions. The following sections of this
chapter update and expand those sections of the Draft EIS
receiving considerable comment.
Spokane River Water Quality
Introduction
EPA1 s CWMP Draft EIS presented a detailed water quality
impact analysis of seven project alternatives. The analysis
was based on projected wastewater flow and quality data pro-
vided by the facilities plan engineers, and on river flow
and quality data available from the U. S. Geological Survey
Storet system. Waste discharges at Liberty Lake, Felts Field
and the existing Spokane treatment plant were described.
Pollutant loading and concentration increases were predicted
for each alternative at mean river flows.
Since publication of the Draft EIS, the Washington DOE
has released the results of Phase I of its Spokane River
waste load allocation study (Washington DOE 1981). The
report was prepared for DOE by the URS Company of Seattle,
Washington. The report includes a detailed description of
existing water quality conditions, a description of the major
pollutant sources, and a listing of criteria for protection
of the river's beneficial uses. A model was developed for
use in making waste load allocations. It initially consists
of a simple steady-state river mass-balance model plus a
linear regression between phosphorus and mean seasonal
chlorophyll a in Long Lake. The report indicates that under
modeled conditions, future phosphorus loading will result
in Long Lake chlorophyll a concentrations greater than 10 yg/1.
The report states that 10 v.g/1 is indicative of eutrophic
conditions in the lake. Several allocation scenarios are
presented which would reduce phosphorus loading to acceptable
levels.
19

-------
Because the waste load allocation study presented new
water quality data and there were a significant number of
public comments on the water quality section of the Draft
EIS, an expanded water quality analysis is included in the
Final EIS. This expanded analysis uses revised effluent
quality data provided by DOE, and analyzes impacts at extreme
low flow conditions in the river below the Spokane treatment
plant. This presents a more conservative analysis of impacts.
It also presents a phosphorus allocation analysis based
on recent DOE revisions to the waste load allocation study.
Because DOE has not established a specific daily phosphorus
loading limit for the Spokane plant, it has not been possible
to indicate at what point the Alternative A discharge might
place an unacceptable phosphorus load on Long Lake.
The revised water quality analysis has focused on the
county's preferred Alternative A, the "no-action" alterna-
tive and a number of suboptions to Alternative A developed
since publication of the Draft EIS (see Chapter 1 for a
description of the suboptions). The other alternatives have
been dropped from consideration by the county.
Existing Surface Water Quality
There is considerable public and agency concern over
water quality in the Spokane River and Long Lake, especially
with regard to concentrations of algae, phosphorus, un-ionized
ammonia, and chlorine. Current data indicate (Table 2-1)
that Spokane River water quality between Post Falls, Idaho
and Long Lake is generally satisfactory for the support of
beneficial uses of the river, although several parameters
exceed recently revised EPA criteria for toxic pollutants
(Federal Register, November 28, 1980) and the State of
Washington water quality standards (Table 2-2).
Standards and Criteria
Washington has designated the Spokane River from its
mouth to the Idaho border as Class A. In this classification,
quantitative standards are listed for dissolved oxygen (DO)
fecal coliforms, turbidity, and pH. Toxic or deleterious
material concentrations are required to be less than those
of public health significance or that cause acute or chronic
toxic conditions to the aquatic biota or which may adversely
affect any beneficial water use. Toxic or deleterious concen-
trations are determined in consideration of water quality
criteria published by EPA and/or other relevant information.
20

-------
Table 2-1. Monthly Mean and Range of Selected Water Quality Parameters for the Spokane River at
Post Falls, Idaho, and Riverside State Park, Washington
(concentration in mg/1)
Post Falls
(River Mile 102}
Riverside State Park
(River Mile 67)
01/73-05/79
01/74-12/77
01,'7°.- 09/79
Parameter
Total Phosphorus (P)
Orthophosphorus (P)
Total Nitrogen (N)
Total Ammonia (N)
Un-ionized Ammonia (N)1
Nitrate and Nitrite
(NO3-N, NO2-N)
Cadmium (dissolved)2
Copper (dissolved)2
Lead (dissolved)2
Zinc (dissolved)2
Mercury (total)
Hardness (total)
FecaL Coliforms (#/100 ml)
Dissolved 02/'A Saturation
Biochemical Oxygen
Dom.uiilrj1
Suspeiulud Solids''
Dj I veil S-j I ids-1 80c
Mean
0.019
0.010
0. 249
0.011
0.00003
0.026
0.009
0.039
0.082
0. 196
0 .00009
8.7
11. 1./104
1.1
6 . 8
40
Range
0.0 -0.090
0.0 -0.040
0.030-2.300
0.0 -0.050
0.0 -0.00026
0.0 -0.11,0
0.0 -0.030
0.0 -0.330
0.004-0.250
0.090-0.675
0.0 -0.4
19-31
0.0 -200
7.7 -13.9/
91-125
0.2-1.9
0.0-56
28 -54
Mean
0. 113
0.055
0.873
0. 263
0.00394
0 . 345
0.009
0.012
0.100
0.168
0.00007
2,989
10.9/-
2.9
Range
0.020-0.949
0.010-0.147
0. 220-2. 360
0.050-0.600
0.0013-0.036
0.010-0.920
0.0 -0.020
0.0 -0.030
0.006-0.200
0.045-0.475
0.0 -0.0005
22-92
3-42,000
8.1-14 . 2/-
0.6-8.3
Mean
0.035
0.015
0. 832
0.098
0.00162
0.456
0.001
0.004
0.093
0.00013
59
105
11. l/'.'9
14 . 7
68.7
Range
0.010-0.088
0.0 -0.039
0.270-1,850
0.0 -0.360
0.0 -0.01194
0.030-1.200
0.0
0 . 0
-0.003
-0.010
0.009-0.210
0.0 -0.0008
24-170
1-1,500
7.2-15.1/79-118
0.0-80
40 -90
' C.i leu 1.11 1 'il ! coin L0U1I ..million i .1 coiicen L r.i t j 011, pll, and tempo ra t u re using conversion table in Wil1i.rujli.Jin (l'J7fi).
'I'.i r.iiiietr r recorded as "total" for Riverside; State Park (01/74-12/77).
!BOD at Riverside State Park for 1972-1973.
" il:;i 11 -i i*.!. •! I Uoli.l:; al.	L-'.ill:; for 1 0 / 7G-0'I / 7 H .
SOURCE: li. S. Geo Log ica 1 Survey 1974-11379 .

-------
Table 2-2. Washington Water Quality Standards for Class A Waters,
Lake Class Waters, and EPA Water Quality Criteria
Parameter


Standard or
Criterion



River
Lake


Maximum Value
24-Hour Average
Maximum Value 24-
¦Hour Average
Un-ionized Ammonia (N)
17
yg/11
NA1*
20 yg/1
NA
Chlorine (residual)
3-5
yg/i9
NA
3-5 yg/1
NA
Cadmium (recoverable)
1.5
yg/i2'8
.012 yg/18
1.5 yg/1
.012 yg/1
Copper (recoverable)
12
yg/12'8
5.6 yg/1
12 yg/1
5.6 yg/1
Lead (recoverable)
74
yg/12'8
•75 yg/18
74 yg/1
.75 yg/1
Zinc (recoverable)
180
yg/12'8
47 yg/1
180 yg/1
47 yg/1
Dissolved Oxygen
8.0
yg/i3
NA
no change from
NA




natural conditions

Fecal Coliforms
100
mg/l3'5
NA
50/100 ml6
NA
Turbidity
5
NTU3'7
NA
5 NTU over
NA



background

PH
6.5-
-8. 5 3
NA
no change from
NA
natural conditions
1EPA quality criteria for water (U. S. EPA 1976).
2Section 307(a) (i) toxic pollutant criteria (Federal Register, November 28 , 1980) .
3Washington water quality standards (Class A and Lake Class).
l,NA = not applicable
5Not more than 10 percent of samples can exceed 200/100 ml.
6Not mere than 10 percent of samples can exceed 100/100 ml.
7For background levels less than 50 NTU or 10 percent of background levels greater than
50 NTU.
8Hardness 50 mg/1 CaCC^.
9American Fisheries Society 1979.

-------
EPA. recently published criteria for the section 307 (a) (i)
toxic pollutants. These replace the criteria for those same
pollutants found in the EPA "red book". These newer criteria
designate both a maximum value which generally corresponds
to an acute toxicity concentration and a 24-hour value which
generally corresponds to a chronic toxicity concentration.
Specific Water Quality Parameters
Phosphorus. Extensive studies have been conducted on
phosphorus levels in the Spokane River. Total phosphorus
values for November 197 9 to June 1980 upstream from the Spokane
STP were relatively low and uniform (Table 2-3). Total and
orthophosphate levels at Riverside State Park below the Spokane
STP have decreased significantly since phosphorus removal
began at the AWT facility in late 1977 (Table 2-1). Soltero
et al. (1980) determined that effluent discharges increased
orthophosphate concentrations in the river during 1979 less
than 3-fold. However, prior to AWT, orthophosphate concentra-
tions in the river usually increased 13-fold following the
introduction of the sewage effluent (Soltero et al. 1980).
The major source of phosphorus in Long Lake prior to
AWT in August 197 8 was the Spokane STP; however, with phos-
phorus removal, upstream sources now contribute a higher
percentage of nutrients to the lake. Phosphorus appeared
to be the growth-limiting nutrient in the euphotic zone (zone
of light penetration) of Long Lake in 1978, as determined
by algal growth assay tests (Soltero et al. 1979). Previous
studies (Soltero et al. 1976; 1978) have shown nitrogen to
be the primary nutrient 1imiting phytoplankton growth. The
transition to phosphorus as the primary growth-limiting
nutrient is attributed to reductions in phosphorus loading
from the Spokane STP (Soltero et al. 1979).
Yake (1979) found an inverse relationship between phos-
phate concentrations and flows in the lower Spokane River.
Funk et al. (19 7 3; 1975) observed two annua], peaks in nutrient
concentrations, one during high flow and one during low flow.
High phosphate concentrations during low flows (August-October)
are especially critical because they occur during the prime
algal growth period.
Chlorophyll a. There has been an overall decline in
chlorophyll a concentrations since 1978, which has been dir-
ectly related to decreased phosphate loading (Soltero et al.
1979; 1980). A decreased phytoplankton biovolume was evident
for most of the 1978 and 1979 growing season as a result
of decreased phosphorus loading. On an annual basis, however,
phytoplankton standing crop increased due to a single bloom
of Microcystis aeruginosa in August and September (Soltero
et al. 1979; 1980).
23

-------
Table 2-3. Monthly Mean of Selected Water Quality Parameters for the Spokane River at Stations from the
Idaho/Washington State Line, to Gonzaga University, Spokane, from 11/79 to 06/80 (concentrations in mg/1)1
Spokane River Stations
Harvard	Barker	Sullivan	Greene
Parameter	State Line2	Bridge	Br i.dge	Bridge	Uprj.ver	S treot
(96.5 RM) 3	(92.7 RM)	(90.4 RM)	(87.8 RM)	(80.2 RM)	(78.0 RM)
Tot ^1 phosphorus (P)	0.016	0.021	0.021	0.021	0.023	0.021
Total soluble and
soluble reactive
phosphorus (P)	0.014	0.012	0.010	0.011	0.012	0.010
Total nitrogen (N) "	0. 186	0.164	0.193	0. 219	0.385	0.395
Biochemical oxygen
demands	1.0	1.2	0.7	1.0	1.4	1.3
Zinc (dissolved)	0.112	0.110	0.106	0.110	0.105	0.097
'Funk (19R0), unpub1ished data.
'Data at stale line station for 11/79-03/80.
'station location in river miles (RM).
''Data for Lotal nitrogen for 11/79 — 04/80.
Gonzaga
University
(76.0 RM)
0.018
0.010
0'. 372
1.0
0.0 96

-------
Since the initiation of AWT with phosphorus removal,
Long Lake has conformed to predicted recoveries made by
Gasperino and Soltero (1977), and Thomas and Soltero (1977).
Blue-green algal blooms in Long Lake persist, but their
association with eutrophic conditions is uncertain in view
of the improvements in lake water quality (Soltero et al.
1979). Decreases in reservoir phosphorus and orthophosphorus
concentrations, chlorophyll a concentrations, and primary
productivity, indicate that Long Lake is changing from a
eutrophic condition to a mesotrophic condition (Soltero
et al. 1979).
Nitrogen. Total nitrogen values for November 1979 to
April 1980 between Post Falls and the Spokane treatment plant
were generally low and gradually increased from upstream
to downstream stations. Soltero et al. (1980) determined
that in 1979 the Spokane treatment plant effluent produced
a 160 percent increase in total inorganic nitrogen in the
river. The mean daily inorganic nitrogen loads to Long Lake
19 7 8 (June through November) were not significantly different
from loads before AWT at the Spokane treatment plant (Soltero
et al. 19 7 9) . However, organic nitrogen, which comprises
the majority of total nitrogen loading, declined after AWT
due to the activated sludge process and associated solids
removal at the new plant. Although there was an increase
in inorganic nitrogen load in the river due to the Spokane
plant, the Spokane River upstream from Hangman Creek appears
to be the major source of total nitrogen to Long Lake (Soltero
et al. 1979) .
Heavy Metals. The Kellogg mining district, located
along the South Fork of the Coeur d'Alene River in northern
Idaho, contains major mineral deposits and is the primary
source of heavy metals in the Spokane River. Mining and
milling activities have discharged quantities of metals,
(primarily zinc, but also lead, copper, and others) to the
drainage system since ore production began in 1885. In addi-
tion to metals contributed by mine drainage water and tailings
leachate, metals are discharged by a large lead smelter
located near Kellogg, Idaho, and an electrolyte zinc plant
which reduces ore and ore concentrates to refined metals
ready for market (Yake 1979).
In the early 1970s, state and federal regulatory agencies
initiated programs to reduce heavy metal input to the Coeur
d'Alene and Spokane River drainage basin. Nonetheless, signi-
ficant quantities of heavy metals continue to leach into
the Coeur d'Alene and subsequently the Spokane River. Ex-
tensive research has been conducted on the sources and effects
of heavy metals in the drainage systems, and has been pub-
lished in works by Ellis (1970), Mink et al. (1971), Savage
and Rabe (1973), Funk et al. (1973;1975), Maxfield et al.
(1974), Sheppard and Funk (1975, and Yake (1977).
25

-------
The toxic effects of these elements on fish and other
aquatic organisms depend on a variety of environmental factors,
including dissolved oxygen concentration, pH, temperature,
water hardness, and the animal species itself (U. S. EPA 1976).
An increase in water temperature along with the concomi-
tant reduction in dissolved oxygen solubility increases heavy
metal toxicity, especially to the more susceptible trout
and salmon species (American Fisheries Society 1979). In-
creased temperatures accelerate metabolic processes and the
rate of gill irrigation. Consequently, fish are usually
killed more rapidly at moderately elevated temperatures than
at lower temperatures. Reduced dissolved oxygen concen-
trations require increased irrigation of respiratory surfaces.
This brings to these surfaces a larger quantity of any toxin
present in the water. Consequently, the summer period
characterized by low flows and increased temperatures repre-
sent the time of year with the greatest potential for adverse
effects on the Spokane River fishery.
Water hardness is also another factor which affects
the toxicity of heavy metals on fish. Hardness is the measure
of the concentration of polyvalent metallic ions dissolved
in the water, principally calcium and magnesium (U. S, EPA
1976). The calcium and magnesium ions complex with the heavy
metals producing a compound less toxic to fish. With some
metals such as cadmium, a truly antagonistic reaction occurs
in "hard" waters which inhibits uptake of metals by fish
(Davies 19 7 6). Thus, heavy metal toxicity is generally more
severe in "softer" waters. Ion concentrations in the Spokane
River vary from 0-50 mg/1 CaCO., ; values in this range are
indicative of "soft" waters (U. S. EPA 1976).
Zinc. Mean zinc concentrations are 0.196 mg/1 at Post
Falls, Idaho and 0.093 mg/1 at Riverside State Park, Washington
(Table 2-1). Concentrations at Post Falls exceed both the
maximum and 24-hour average criteria values established by
EPA whereas only the 24-hour average value is exceeded at
Riverside. The 96-hour median lethal concentration (LC^)
for rainbow trout is reported to be 0.43 mg/1 (26 m/1 CaCO,)
(Sinley et al. 1974). Acutely toxic concentrations for the
more tolerant sunfish species exceed 15.0 mg/1 (Cairns et al.
1971).
Funk et al. (1975) state that zinc levels in muscle
tissues of fish in the Spokane River may be 2-3 times that
of the same species of fish from unpolluted streams high
in the Coeur d'Alene drainage. Tissue and water quality
data indicate that either resident fish have acclimated to
high zinc concentrations or measurements of zinc include
forms nontoxic to fish.
26

-------
Cadmium. Mean concentrations at Post Falls and Riverside
are <0.009 mg/1 and 0.001 mg/1, respectively (Table 2-1).
Recommended criteria are .000012 mg/1 for the 24-hour average
value and .0015 mg/1 for the maximum value. Only the 24-
hour average value is exceeded at Riverside whereas both
values are exceeded at Post Falls. From a practical'per-
spective, measurement of cadmium as well as other heavy metals
is imprecise at such low concentrations and should be viewed
only as an estimate of existing conditions when compared
with EPA criteria.
Copper. Mean concentrations of copper in the Spokane
River are 0.039 mg/1 at Post Falls and 0.004 mg/1 at Riverside
(Table 2-1). Once again, heavy metal concentrations are
lower at the downstream station. The EPA 24-hour average
value of 0.0056 mg/1 and the maximum value of .012 mg/1 are
only exceeded at the Post Falls sampling station. McKim
and Benoit (1971) reported that the 96 LC,-q value is 0.1 mg/1
for brook trout (45 mg/1 CaCO^) and 0.77 mg/1 for bluegill
(46 mg/1 CaCO^). Thus, acute toxicity values even for the
most sensitive salmonid species are not exceeded.
Lead. Mean lead concentrations are 0.082 mg/1 at Post
Falls and >0.100 mg/1 at Riverside (Table 2-1). The 24-
hour average concentration of .00075 mg/1 and the maximum
concentration of .074 mg/1 are exceeded both at Post Falls
and Riverside State Park.
Toxic Substances.
Chlorine (Residual). Chlorine is highly soluble and
reacts readily with many inorganic substances and all plant
and animal tissues. The denaturing effect of chlorine on
animal and plant tissue forms the basis for its use as an
effective water or wastewater disinfectant. The recommended
criteria for protection of freshwater organisms are .003-
.005 mg/1 (U. S. EPA 1976; Thurston et al. 1979). Chlorine
toxicity is most likely to occur in the zone of mixing near
the outfall.
Credible data for chlorine concentrations in the Spokane
River do not exist, hence comparison with safety criteria
is not possible. The primary sources of chlorine in the
study area are existing treatment plants at Coeur d'Alene,
Idaho and Spokane, Washington. The Coeur d'Alene facility
discharges approximately 9 pounds of chlorine per day which,
under mean flow conditions, results in a 0.001 mg/1 river
concentration at the outfall site. The Spokane treatment
plant discharges approximately 316 pounds per day, which
under low flow summer conditions, results in 0.034 mg/1 in
the receiving water. Under Q7 ig flow conditions the resul-
tant river concentration would be .096 mg/1. Thus, safety
27

-------
criteria are exceeded downstream from the Spokane plant under
low flow conditions. These resultant concentrations may be
conservative as they on iy take into account chlorine inputs
from the two treatment facilities.
Un-ionized Ammonia. The un-ionized form of ammonia
(NH-.) is generally recognized as the molecule toxic to fish
(Willingham 1976). It exists in equilibrium with ionized
ammonia (NH^). Because of this relationship, the concen-
tration of un-ionized ammonia is affected by pH, temperature,
hardness, and the total ammonia concentration (U. S. EPA
1976). Suggested criteria are 0.017 mg/1 for salmonids and
0.082 mg/1 for other freshwater species (American Fisheries
Society 1979). Existing Spokane River concentrations are
considerably below these values at both Post Falls and River-
side State Park (Table 2-1). However, during the summer
months when river temperature exceeds 15°C and pH is high,
criterion violations may be occurring.
Factors Affecting Dissolved Oxygen Concentrations. Dis-
solved oxygen concentrations at Post Falls range from 7.7-
13.9 mg/1 with a mean of 11.1 mg/1 and percent saturation
varies from 91-125 percent with a mean value of 104 percent.
Dissolved oxygen concentrations and percent saturation at
Riverside range from 7.2-15.1 mg/1 (mean of 11.1 mg/1) and
79-118 percent (mean of 99 percent), respectively (Table 2-1).
The minimum dissolved oxygen concentration necessary to main-
tain productive fish populations is 5.0 mg/1 (American Fisheries
Society 1979). Recommended minimum criteria in the inter-
stitial water of the gravel for salmonid spawning beds is
also 5.0 mg/1 (U. S. EPA 1976). Recorded concentrations
in the Spokane River do not fall below this value downstream
of Post Falls Dam. Washington Class A water quality stan-
dards, however, require that dissolved oxygen concentrations
exceed 8.0 mg/1.
Dissolved oxygen concentrations in Long Lake, however,
violate suggested EPA criteria and state standards during
certain times of the year. An annual cycle of dissolved
oxygen fluctuations was presented by Soltero et al. (1979).
Dissolved oxygen concentrations exceeded 7.0 mg/1 throughout
the water column dur ing May and June. With the deve.l opment
of thermal stratification in July, dissolved oxygen in the
hypolimnion (the lower layer of water in a thermally strati-
fied lake) began to dec]ine. Hypolimnetic stagnation reached
a maximum in mid-August with dissolved oxygen less than 1.0 mg/1.
The greatest dissolved oxygen differential between surface
and bottom waters was 11.2 mg/1 in August, With the loss
of thermal stratification in September, surface and bottom
waters began to mix. By mid-October, dissolved oxygen con-
centrations again exceeded 7.0 mg/1 throughout the reservoir.
28

-------
Biological oxygen demand (BOD) and ammonia discharged
from the treatment plant are primary factors which contribute
to the deoxygenation of receiving waters. The relative effects
of BOD and ammonia on the river downstream of the Spokane
STP have not been measured or projected by mathematical
modeling. BOD represents the measure of the quantity of
dissolved oxygen necessary for the decomposition of organic
matter by micro-organisms such as bacteria. In oxygenated
natural water systems, ammonia is rapidly oxidized to nitrite
(NO2) and then into nitrate (NO^). The rate at which ammonia
is oxidized to nitrite and nitrate is highly dependent on
environmental conditions. Unlike carbonaceous BOD, which
is generally oxidized by a spectrum of heterotrophic (nonself-
nourishing) bacteria in the water column, ammonia is oxidized
by a few specialized genera of bacteria. These nitrifiers
are typically found attached to substrate. Therefore, the
nitrification rate is a function of river bottom area, water
volume ratios, as well as substrate types (Yake 1976).
Impacts of the Proposed Alternatives on Existing Surface
Water Quality
The following water quality impacts for those project
alternatives still being considered (no-action, A, A-l, A-2
and A-3) are based on projected effluent concentrations,
effluent volumes, and river dilution at the proposed outfall
site (Table 2-4). River discharge data at Post Falls and
Riverside State Park were obtained from USGS records. River
loading and concentration increases were calculated for three
different flow regimes: 1) median flow of the critical month,
2) Q7_10 flow lowest 7-day average flow recorded over a 10-
year period, and 3) 15 percent of the	flow which is
used to represent the initial dilution zone of the Spokane
STP. The dilution zone value may be more indicative of the
most severe possible river conditions as it does not assume
complete mixing of wastewater in the river at the point of
effluent discharge.
Resultant river concentrations due to each alternative
were calculated by considering the effects of the increase
in effluent load over the present load rather than the effects
of the entire proposed load. For example, under the no-
action alternative the proposed effluent volume by 1992 would
be 34 MGD. Rather than considering the effect of the entire
34 MGD, only the difference between proposed and existing
(34-31.5 =2.5 MGD) effluent volumes was considered. The
increase in river concentration due to the additional effluent
volume (2.5 MGD) was then added to existing river concen-
trations (Table 2-2). This method was chosen as existing
river concentrations monitored at Riverside State Park already
take into account the result of the current effluent load
being discharged by the Spokane treatment facility.
29

-------
Table
2-4. Projected Effluent Volumes
and Effluent
Pollutant
Concentrations for
Each Alternative




1992




2002


Parameter
(nw/1.)
NA
A
Alternative
A-l
A-2
A-3
NA
A
Alternative
A-l
A-2
A-3
Effluent Volume
(April-October)
(MGD)
34
44
44
44
44
36
62
62
44
62
Effluent Volume
(November-March)
(MGD)
34
44
44
44
44
36
62
62
66s
62
Total Phosphorus
(April-October)
(nig/1)
, 94 3
. 94
. 94
. 94
.51
. 94
. 94
. 94
. 94
. 36
Total Phosphorus
(November-March)
(mg/X)
.94 3
. 94
5.0
5.0
5.0
. 94
. 94
5.0
5.0
5.0
Total Nitrogen
(nig/1)
19. 2 3
19.2
19.2
19.2
19.2
19.2
19.2
19.2
19.2
19. 2
Total Ammonia
(mq/1)
.1-5.5°
14 5
14
14
14 7
.1-5.5
14
14
14
14 7
Un-ionized Ammonia
(mq/1!
.21'*
. 54
.54
.54
.54
21
.54
. 54
.54
. 54
Chlorine (ma/1)
. 8-1.2 J
.8-1.2
.8-1.2
.8-1.2
8-1.2'
.8-1.2
.8-1.2
.8-1.2
.8-1.2
. 8-1.2 '
Fecal ColiEorms
50-200/
100 ml1
50-200/
100 ml
50-200/
100 ml
50-200/
100 ml
50-200/
100 ml
50-200/
100 ml
50-200/
100 ml
50-200/
100 ml
50-200/
100 ml
50-200,
100 ml
BOD (mg/1)
213
21
21
21
21
21
21
21
21
21
Cadmium (mg/1)
<.011, 3
•: .01
< .01
< .01
< .01
< .01
< .01
< .01
< .01
<.01
Cooper (nirj / I )
.03'
.03
.03
.03
.03
.03
.03
.03
. 0 3
.03
Lord (mg/1)
< .OS1
< .05
<.05
< .05
< . 05
< .05
<•05
< .05
< .05
< . 05
Zi.ic (ir.'j / 1 )
.11 1
.11
.11
.11
. 11
. 11
. 11
. 11
.11
.11
'Bernhardt pers. comm. DOE/EPA intensive monitoring program, March 31, June 10, 1], 1980; and February 11, 1981.
'fine sample only.
* U;i i.M.-'t on l>nknne t.rontm,;iit pl/mt monitoring data (suraiar months) (Wash, DOE pers. comm.).
fjuunfc nonct'ii L ra t i oua of chlorine jiul nn-ionized amnion in will bo reduced if river concentrations exceed critical vj 1 uea.
" tv-rm. 'yer pert.;. comm.

-------
A different procedure was followed for calculating un-
ionized ammonia and chlorine river concentration increases.
Since background data for chlorine concentrations do not
exist, resultant concentrations were calculated by con-
sidering the total effluent volume rather than just the in-
crease over present volume. The effects of un-ionized ammonia
were assessed using two methods. Resultant river concentrations
were calculated by; 1) considering only the effects of the
increase in effluent load over present loads, and 2) by con-
sidering the effects of the total effluent load. This v/as
necessary as the value used for the projected effluent concen-
tration of un-ionized ammonia is significantly different than
the value used for the current effluent concentration (Table 2-4).
No-Action Alternative. This alternative would allow
the existing Spokane treatment plant effluent discharge to
increase from 31.5 MGD to 3 4 MGD in 1992 and to 36 MGD in
2002.
Phosphorus Increases. Phosphorus concentrations high
enough to produce algae of nuisance abundances are difficult
to determine and vary from one geographical area to another.
A given phosphorus level may produce noxious plant growth
in a lake, whereas that same level may produce no visible
effects in the river which flows into that lake (U. S. EPA
1976). Total nutrient loading to a water body is more
indicative of potential long-term effects than concentration
increases (Vollenweider 1968). Hence, any attempt to establish
single-value critical concentrations in the water for phos-
phorus is inadequate (Thurston et al. 1979).
Based on the formula of Vollenweider (1968) and modified
by Dillon (1975) and Soltero, Washington DOE (1981) calculated
the phosphorus loading to Long Lake required to produce a
designated concentration of chlorophyll a during the algal
growing season (Table 2-5).
The Washington DOE report further states that a chloro-
phyll a value greater than 10 yg/1 is indicative of eutrophic
waters. Using this criterion, the no-action alternative
exceeds permissible loading to Long Lake by 11 pounds per
day by 1992 (Table 2-5). Based on recently revised data,
DOE is considering a maximum permissible load to Long Lake
of 507 pounds per day (Washington DOE 1981a). If a phos-
phorus allocation scheme is implemented which only requires
waste treatment facilities to reduce loading, the Spokane
STP could only discharge 259 pounds per day, 8 pounds per
day less than projected under this alternative (Table 2-5).
31

-------
Table 2-5. Projected and Permissible Total Phosphorus
Loadings (lbs/day) to the Spokane River1*'5
Alternative
Projected Load
Spokane S'l'l'1' -
Projected Load
lake
STP1' 2~
Projected Load
Idaho STP" 2
Projected Load
All Other1'2
Total Load
to Long Lake
Total Permissible
Load to Long Lake2
Percent
Reduction
Required3
Total Permissible
Load at Spokane
WWTP3
1992









A
346
30
53
168
597
507
21%

273
A~1
346
30
53
168
597
507
21%

273
A-2
346
30
53
168
597
507
21%

273
A-3
187
30
53
168
438
507
0%

NA'
NA
267
30
53
168
518
507
3%

259
2002









A
487
0
70
168
725
507
39%

297
A-l
487
0
70
168
725
507
39%

297
A-2
346
0
70
158
584
50 7
19%

• 280
A-3
186
0
70
168
424
507
0%

NA
NA
283
0
70
168
521
507
44

272
f-OOTNCH'ES:
'Washiii.jton DJE WiisUs load allocation ytudy.
"Washington DOE pers. contn.
JJf only yrp's are required to reduce phosphorus loading.
'"Retention coefficient of phosphorus in Long Lake = .25, chlorophyll a concentration of 10 tig/1.
'•siin.ik.nic, l.ilurly Kike and Idaho St'P's at 85 iJercent ruiioval.
"NA =-not applicable.

-------
Total Nitrogen¦ Nitrogen loading would increase from
approximately 5,0 52 pounds per day to 5,4 54 pounds per day
(8 percent) by 1992 and to 5,775 pounds per day (14 percent)
by 200 2 (Table 2-6). Nitrogen increases are unlikely to
produce any significant effects on Long Lake water quality
as long as phosphorus remains the primary limiting nutrient.
The only potential adverse effects would be increased algal
growth immediately downstream from the outfall site.
Zinc. Under low summer flow conditions zinc concen-
trations in the river would increase from .0 930 mg/1 to
.0932 mg/1 by 1992 and to .0934 mg/1 by 2002 (Tables 2-7
and 2-8). Although these increases would be relatively
small (<1 percent), river concentrations already exceed EPA
24-hour average criteria, which generally represent chronic
toxicity to fish. At 30-day l-in-10 year low flows the
24-hour average criterion would be exceeded during every
month of the year (Table 2-9). The maximum EPA criteria
of .18 mg/1 would not be exceeded under Q7.1Q flow conditions
or in the dilution zone (Tables 2-10 through 2-13). Any
additional zinc input, however, regardless of how small,
would exceed chronic toxicity conditions and have an adverse
impact on fish productivity.
Copper. Copper concentrations in the river would in-
crease from .0040 mg/1 to .0041 mg/1 by 2002 under low summer
flow conditions (Table 2-8). This resultant concentration
would not exceed the 24-hour EPA average criteria of .00 56
mg/1. At 30-day l-in-10 year low flows the 24-hour average
criterion would not be exceeded during any month of the year
(Table 2-14). In the dilution zone this value would be exceeded
by 19 9 2 (.0115 mg/1); however, the maximum EPA criteria of
.0012 mg/1 would not be reached. Consequently, fish pro-
ductivity should not be significantly impaired by increased
copper inputs; however, the possibility of increased fry
and egg mortality, in the initial dilution zone, immediately
downstream from the outfall site is conceivab]e.
Cadmium. Under low summer flow conditions cadmium con-
centrations would reach .001 mg/1 by 2002 (Table 2-8). The
24-hour EPA criteria of .000012 mg/1 would be exceeded, whereas
the ,0015 mg/1 maximum vaxue would only be exceeded in the
dilution zone (Table 2-13). Fish productivity would only
be significantly reduced in the area immediately downstream
from the outfall site. The size of the area affected would
of course depend on a variety of physical river parameters
below the point of effluent discharge.
33

-------
Table 2-6. Projected Loading (lbs/day) of Selected Water Quality
Parameters Due to Each Alternative1
1992	2002
Alternative	Alternative
Parameter	A	A-l	A-2	A-3	NA	A	A-l	A-2	A-3	NA
Total
Nitrogen (N) 7,058 7,058 7,058	7,058 5,454 9,945 9,945 7,058 9,945 5,775
Total
Ammonia (N)	2,022 2,022 2,022	2,022 1,562 2,849 2,849 2,022 2,849 1,654
B0D5	7,720 7,720 7,720	7,720 5,965 10,878 10,878 7,720 10,878 6,316
Projected summer effluent concentration and volume (April-October).

-------
Table 2-7. Calculated Increases" and Resultant Spokane River Concentrations1 of Selected Water
Quality Parameters at the Point of Effluent Discharge Due to Each
Proposed Alternative at Low Summer Flow2 - 19923 (my/.I)
	Alternatives	
A	A-l	A-2	A-3	NA
Paronietcr	Increase Resultant3 Incrjaoe Resultant Increase Resultant Increase Resultant Increase Resultant
Ui lution ratio
1/92

1/92

1/92

]/ 92

1/549

Total phosphorus (P)
0.010
0.045
0.010
0.045
0.010
0.045
U.010
0.045
0.002
0.037
Total nitrogen (N)
0.209
1.041
0.209
1.041
0.209
1.041
0.209
1.041
0.035
0.867
Total siinonia (N)
0.152
0.250
0.152
0.250
0.152
0.250
0.152
0.250
0.010
0.108
Un-ionized aimionia (N)
0.006
0.008
0.006
0.008
0.006
0.008
0.006
0.008
0.0004
0.002
Chlorine1 (CL)
0.046
0.046
0.046
0.046
0.046
0.046
0.046
0.046
0.036
0.036
C. ubuiir.i
<0.0001
0.0011
<0.0001
0.0011
<0.0001
0.0011
<0.0001
0.0011
0.0000°
0.0010
Copper
0.0003
0.0043
0.0003
0.0043
0.0003
0.0043
0.0003
0.0043
<0.0001
0.0041
Lead1'
<0.0005
0.1005
<0.0005
0.1005
<0.0005
0.1005
<0.0005
0.1005
<0.0001
0.1001
Zinc
0.0012
0.0942
0.0012
0.0942
0.0012
0.0942
0.0012
0.0942
0.0002
• 0.0932
BJU,.7
0.228
3.128
0.228
3.128
0.228
3.128
0.228
3.128
0.038
2.938
'Using river water quality at Riverside State Park averaged over January 1978 to September 1979 (USGS).
oF the most critical summer month (August) 1,700 cfs.
'resultant concentrations were calculated by taking into account only the effect of the increase in effluent volune over present conditions,
''lining I In: simiuji: eFFluent discharge.
'-CaloukiUxI increase due to total effluent discharge (using 1.2 mg/1) .
'"Using data at Riverside State Park averaged over January 1974 to December 1977 (USGS).
'Uoing data ut Riverside State Park averaged over 1972 to 1973 (USGS).

-------
Table 2-8. Calculated Increases'* and Resultant Spokane River Concentrations1 of Selected Water
Quality Parameters at the Point of Effluent Discharge Due to Each
Proposed Alternative at Low Summer Plow*" - 20023 (mg/1)
Alternatives
Parameter

A
A-l

A~2

A-3


NA
Increase
Resultant5
Increase
Resultant
Increase
Resultant
Increase
Resultant
Increase
Resultant
Di'uLiou ratio
1/38

1/38

1/92

1/38

1/275

Total phosphorus (P)
0.025
0.060
0.025
0.060
0.010
0.045
0,025
0.060
0.003
0.033
i'oLi! nitrogen (N)
0.505
1.337
0.505
1.337
0.208
1.040
0. 505
1.337
0.070
0.902
'total .".TOnid (N)
0.368
0.466
0.368
0.466
0.152
0.250
0.368
0.466
0.020
0.118
Un-ionized aitmonia (N)
0.014
0.016
0.014
0.016
0.006
0.008
0.014
0.016
0.0004
0.002
Chlorine5 (CL)
0.064
0.064
0.064
0.064
0.046
0.046
0.064
0.064
0.038
0.038
Cadmium
- .0003
0.0013
< .0003
.0013
<0.0001
.0011
<.0003
0.0013
0.0000
0.0010
Copper
0.0008
0.0048
0.0008
.0048
0.0003
.0043
0.0008
0.0048
0.0001
0.0041
lead1"
<0.0013
0.1013
0.0013
0.1013
<0.0005
.1005
0.0013
0.1013
<0.0002
0.1002
Zinc
0.0029
.0959
0.0029
0.0959
0.0012
.0942
0.0029
0.0959
0.0004
¦ 0.0934
dod5v
0.553
3.453
0.553
3.453
0.2284
3.128
0.553
3.453
0.076
2.976
'"Using river water quality at Riverside State Park averaged over January 1978 to September 1979 (USGS) .
'Moan of Uiu most. critical sumier month (Auyust) 1,700 cfs.
'fcsultant concentrations were calculated by taking into account only the effect of the increase in effluent volurte over present conditions.
'Usiny Ok; maimer effluent discharge,
^Calculated increase due to total effluent discharge {using 1.2 mg/1).
6Using data at Riverside State Park averaged over January 1974 to December 1977 (USGS).
'Uuing d.'.it.a at Hiversidc Stale Park avurayud over 1972 to 1973 (USGS) ,

-------
Table 2-9. Resultant Zinc Concentrations at 30-Day l-in-10 Year
Low Flows Due to Each Proposed A1 ternative3'
Month
30-Day1
l-in-10 Year
Low Flow
Cri terion 2
24-Hour
Average
Cri terion
Maximum


Zinc
Resultant Concentration
(mg/1)
Alternative




1992




2002


A
A-l
A-2
A-3
NA
A
A-l
A- 2
A-3
NA
January
2, 820
. 047
. 180
.0937
.0937
.0937
.0937
.0931
0939
.0939
.0950
.0939
.0932
February
3,971
.047
.180
.0935
.0935
.0935
.0935
.0931
0938
.0938
.0945
.0938
.0931
March
4 , 571
.047
.180
.0935
.0935
. 0935
.0935
.0931
0937
.0937
.0943
.0937
.0931
Apr i 1
5,661
.047
.180
.0934
.0934
.0934
. 0934
.0931
0935
.0935
.0934
.0935
.0931
May
6,870
.047
.180
.0933
.0933
.0933
.0933
.0931
0934
.0934
.0933
.0934
.0931
June
3, 360
.047
.180
.0936
.0936
. 0,936
.0936
.0931
0939
.0939
.0936
.0939
.0932
July
1, 308
.047
.180
.0946
.0946
.0946
.0946
.0933
0953
.0953
.0946
.0953
. 0935
Augus t
742
.047
. 180
.0957
.0957
.0957
.0957
.0935
0969
.0969
.0957
.0969
.0939
September
716
.047
.180
.0958
.0958
.0958
.0958
.0935
0971
.0971
.0958
.0971
.0939
Oc tobe r
1, 266
.047
.180
.0946
.0946
.0946
.0946
.0933
0954
.0954
.0946
.0954
. 0935
November
2, 058
.047
.180
.0940
.0940
.0940
. 0940
.0932
0945
.0945
.0958
. 094 5
. 0933
December
2,360
.047
.180
.0939
.0939
.0939
.0939
.0931
0943
.0943
.0954
.0943
.0933
'USGS data at Riverside State Park (cfs).
' lYxk ra I Hon i ^ to r , November 28, 1980.
3Using river water quality at Riverside State Park averaged over January 1 978 to September 1979 (USGS).
'' !<¦ :iiu 1 tan t concuritrat ions wore calculated by taking into account only the effect of the increase in effluent volume over present
corid itions.

-------
Table 2-10.
Calculated Increases'* and Resultant Spokane River Concentrations1 of Selected Water
Quality Parameters at the Point of Effluent Discharge Due to Each
Proposed Alternative at U7_10 Flow2 - 19923 (mg/1)
Alternatives
A	A-l	A-2	A-3	"	NA
tviraruter	Increase Resultant3 Increase Resultant Increase Resultant Increase Pesultant Increase Resultant
Dilution ratio
1/31

1/31

1/31

1/31

1/182

Total phosphorus (P)
0.030
0.065
0.030
0.065
0.030
0.065
0.030
0.065
0.005
0.040
Total nitrogen (N)
0.619
1.451
0.619
1.451
0.619
1.451
0.619
1.451
0.106
0.938
Total annonia (N)
0.452
0.550
0.452
0.550
0.452
0.550
0.452
0.550
0.030
0.128
Un-ionized 5v
0.6774
3.577
0.6774
3.577
0.6774
3.577
0.6774
0.6774
0.1154
3.0154
1Using river water quality at Riverside State Park averaged over January 1978 to September 1979 (USGS).
'7-ilay, ]0-yu.ir low flow - 560 cfs.
tdtit c'.K'^nLiatLons were calculated by taking into account only the effect of the increase in effluent volume over present conditions.
''Udiiiu Uio sunu'or effluent discharge.
^'Calculated increase due to total effluent discharge (using 1.2 mg/1).
6Using data at Riverside State Park averaged over January 1974 to December 1977 (USGS).
'Usjny data at Riverside State Park averaged over 1972 to 1973 (USGS).

-------
Table 2-11, Calculated Increases'* and Resultant Spokane River Concentrations1 of Selected Water
Quality Parameters at the Point of Effluent Discharge Due to Each
Proposed Alternative at Q 7 ^ g Flow2 - 20023 (mg/1)
Alternatives
Parameter


h

A-
-1
h-
-2

h-
-3

HA

Increase
Resultant3
Increase
Resultant
Increase
Resultant
Increase
Resultant
Increase
Resultant
Dilution r.ilJo

1/13


1/13

1/13


1/13

1/91


Total phosphorus (P)
u.
,072
0.107
0.
072
0.107
0.030
0.
065
0.072
0.107
0.010
0.
045
Total nitrogen (N)
1.
.477
2.309
1.
All
2.309
0.619
1.
451
1.477
2.309
0.211
3.
943
Total aniionia (N)
1,
.077
1.175
1.
.077
1.175
0.452
0.
550
1.077
1.175
0.060
0.
158
On-ionized armonia (N)
0,
.041
0.043
0.
.041
0.043
0.0174
0.
019
0.041
0.043
0.001
0.
003
Chlorine5 (CL)
0,
.176
0.176
0.
,176
0.176
0.130
0.
130
0.176
0.176
0.109
0.
109
Cadmium
<0,
.0008
0.0018
<0.
.0008
0.0018
<0.0003
0.
0013
<0.0008
0.0018
<0.0001
0.
,0011
Copper
0.
.0023
0.0063
0.
.0023
0.0063
0.0019
0.
0049
0.0023
0.0063
0.0003
0.
,0043
Lead6
<0
.0039
0.1039
<0.
.0039
0.1039
<0.0016
0.
1016
0.0039
0.1039
<0.0005
0.
,1005
Zinc
0
.0088
0.1018
0,
.0088
0.1018
0.0035
0.
0965
0.0088
0.1018
0.0121
0.
1051
MY
1,
.615
4.515
1,
.615
4.515
0.6774
3.
577
1.615
4.515
0.231
3.
,131
'Using river water quality at Riverside State Park averaged over January 1978 to September 1979 (USGS).
"7-day, 10-year low flow.
'Resultant concentrations were calculated by taking into account only the effect of the increase in effluent volume over present conditions.
"Using the sunner effluent discharge.
^Calculated increase due to total effluent discharge (using 1.2 mg/1).
"Using data at Riverside State Park averaged over January 1974 to December 1977 (USGS).
'Using data at Riverside State Park averaged over 1972 to 1973 (USGS).

-------
Table 2-12.
Calculated Increases'1 and Resultant Spokane River Concentrations1 of Selected Water
Quality Parameters at the Point of Effluent Discharge Due to Each
Proposed Alternative at Dilution Zone2 - 1992 ! (mg/1)
	Alternatives		
A	A-l	A-2	A-3	NA
Parameters	Resultant	Resultant	Resultant	Resultant	Resultant
Dilution ratio
1/2.2
1/2.2
1/2.2
1/2.2
1/2.6
Total phosphorus (P)
0.427
0. 427
0.427
0.427
0. 362
Total nitrogen (N)
8 . 727
8. 727
8.727
8.727
7.385
Total ammonia (N)
6. 364
6.364
6 . 364
6. 364
2.115
Un-ionized ammonia (N)
0.245
0.245
0. 245
0.245
0.081
Chlorines (CL)
0. 545
0. 545
0.545
0. 545
0.461
Cadmi um
<0.0045
<0.0045
<0. 0045
<0.0045
<0.0039
Copper
0.0136
0.0136
0.0136
0.0136
0.0115
Lead"
<0.0227
<0.0027
<0.0027
<0.0027
<0.0192
Zinc
0. 0500
0.0500
0.0500
0.0500
6.0192
BOD , 7
5
9. 545
9. 545
9. 545
9. 545
8. 077
'Using river water quality at Riverside State Park averaged over January 1978 to September 1979 (USGS,
*'Cj leu ] a tod using 15 percent ol Q7_lf) flow - 84 cfs.
JResultant concentrations were calculated by taking into account the effect of the entire effluent volume, disregarding existing
i" i vor coricciiLi'utioiis.
''Using the summer effluent discharge.
'I'd I <;u i u led increase due to total effluent discharge (using 1.2 mg/1).
Using data at Riverside State Park averaqed over January 1974 to December 1977 (USGS).
U:;hu] ilii.d at I! i v<_-r.s i do Statu Park averaged over 1972 to 1973 (USGS) .

-------
Table 2-13, Calculated Increases'* and Resultant Spokane River Concentrations1 of Selected Water
Quality Parameters at the Point of Effluent Discharge Due to Each
Proposed Alternative at Dilution Zone" - 2GQ23 (mg/1)
	Alternatives	
A	A-l	A-2	A-3	NA
Parameter	Resultant	Resultant	Resultant	Resultant	Resultant
Dilution ratio

1/1.9

1/1.9

1/2.2
1/1.9
1/2. :
Total phosphorus (P)

0.495

0.495

0.427
0.495
u. 37b
Total nitrogen (N!

10.105

10.105

8. 727
10. 105
7. 680
Total ammonia (N)

7.368

7. 368

6. 364
7. 368
2. 200
Un-ionized ammonia (N)

0. 284

0. 284

0. 245
0. 284
0.084
Chlorine5 (CL)

0.631

0.631

. 545
0.631
0. 480
Cadmium

<0.0053

<0.0053

<0.0045
<0,0053
<0 . 0040
Copper

0.0158

0.0158

0.0136
0.0158
0.0120
i.ead6

<0.0263

<0.0263

<0 . 0227
<0.0263
<0.0200
Zinc

0.0579

0.0579

0.0227
0.0579
.0200
BOD 7

11.052

11.052

9. 545
11.052
8. 400
!Using river water quality at Riverside State
¦ Park averaged over
January 1978 to Seotember
1973 (USGS).

Calculated using 15 percent of
Q-j flow -
84 cfs.





'Resultant concentrations
were
calculated by
taking into account
the effect
of the entire
effluent volume, disregarding
existing
river coiicei.trat ions ,








"Using the summer effluent discharge.






'Calculated increase due
to total effluent discharge (
using 1,2
mg/1).



""Using data at Riverside
Sta te
Park averaged
over January 1974 to December
1977 (USGS).


'Using dat.a -it Riverside
State
Park averaged
over 1972
to 1973 (USGS).

-------
Table 2-14. Resultant Copper Concentrations at 30-Day 1-in-XQ Year
Low Flows Due to Each Proposed Alternative3'''
	Copper	
30-Day1	Criterion2		Resultant Concentration (mg/l) Alternative
l-in-10 Year 24-Hour	Criterion	1992	"	2002
Month	Low Flow	Average	Maximum	A	A-l	A-2	A-3	NA	A	A-l	A-2	A-3	NA
January
2, 820
.0056
.012
.0042
.0042
.0042
.0042
.0040
.0045
.0045
.0046
.0045
. 0041
February
3,971
.0056
.012
.0041
.0041
.0041
.0041
.0040
,0043
.0043
.0044
.0043
.0041
March
4, 571
.0056
.012
.0041
.0041
.0041
.0041
.0040
.0043
.0043
. 0044
.0043
.0040
April
5,661
.00 56
.012
.0041
.0041
.0041
.0041
.0040
.0042
.0042
.0041
.0042
. 0040
May
6, 870
.0056
.012
.0041
.0041
.0041
.0041
. 0040
.0042
.0042
.0041
.0042
.0040
June
3, 360
. 0056
.012
.0042
. 0042
.0042
.0042
.0040
.0044
.0044
.0042
.0044
.0041
July
1,308
. 00 56
.012
.0044
.0044
.0044
.0044
.0041
.0050
.0050
.0044
,0050
.0041
August
742
. 00 56
.012
. 0047
.0047
.0047
.0047
. 0041
.0058
.0058
. 0047
. 00 5 8
.0043
September
716
.00 56
.012
.0048
.0048
.0048
. 0048
.0041
.0059
.0059
.0048
.0059
.0043
October
1,266
.0056
.012
.0044
.0044
.0044
. 0044
.0041
.0050
.0050
.0044
, 0050
.0041
November
2,058
. 0056
.012
.0043
.0043
.0043
.0043
.0041
.0047
. 0047
.0048
.0047
.0041
December
2, 360
.0056
.012
.0042
.0042
.0042
.0043
. 0040
.0046
.0046
.0047
.0046
. 0041
USGS data at Riverside State Park (cfs).
' Fedui'aj. Register, November 28, 1980
'lltixiiij river water quality at Riverside State Park averaged over January 1978 to September 1979 (USGS).
''Resultant concentrations were calculated by taking into account only the effect of the increase in effluent volume over present
cond itions.

-------
Lead. Both the 24-hour (.00075 mg/1) and maximum EPA
criteria (.074 mg/X) are currently being exceeded at Riverside
State Park. Consequently, any additional lead input would
adversely affect existing fish populations. Under low flow
summer conditions, concentrations would exceed .1000 mg/1
by 2002 (Table 2-8) and under Q7_->0 flow conditions exceed
.1005 mg/1 (Table 2-11). At 30-day l-in-10 year low flows
the 24-hour average and maximum criteria would be exceeded
during every month of the year (Table 2-15).
Chlorine (Residual)¦ Under low summer flow conditions
chlorine concentrations would be .036 mg/1 by 1992 and ,038
mg/1 by 2002 (Tables 2-7 and 2-8). The EPA criteria of .00 3-
.005 mg/1 would be exceeded by a significant amount. Con-
centrations would be .103 mg/1 by 2002 at Qtiq flows (Table 2-11)
and .480 mg/1 in the dilution zone (Table 2-13J. The EPA
criterion would be violated during each month of the year
at 30-day l-in-10 year low flows (Table 2-16).
Un-ionized Ammonia. Un-ionized ammonia concentrations
would not exceed the .017 mg/1 criteria under low summer
flow or Q__1q flow conditions (Tables 2-8 and 2-11). Only
in the dilution zone where concentrations could exceed .084
mg/1 does the potential for significant impairment of fish
productivity exist (Table 2-13) .
If background un-ionized ammonia concentrations are
assumed to be 0.0 mg/1, the 34 MGD 1992 and 36 MGD 2002
effluent discharges would not produce river concentrations
that exceed EPA criteria during any month of the year. Only
during August and September would concentrations approach
the 0.02 mg/1 criterion (Table 2-17).
If only the increase in effluent volume over present
conditions is assessed, resultant concentrations at the point
of effluent discharge would be well below the safety criterion
(Table 2-18).
Dissolved Oxygen Deereases. BOD loading would increase
from the current level of approximately 5,526 pounds per
day to 5,96 5 pounds per day by 199 2 and 6,316 pounds per
day by 2002 (Table 2-6). Concentrations would increase from
2.900 mg/1 to 2.938 mg/I by 1992 and 2.976 by 2002 under
low flow summer conditions (Tables 2-7 and 2-8).
Total ammonia loading from the Spokane plant would be
1,562 pounds per day by 1992 and 1,654 pounds per day by
2002. The resultant river concentration increases would
be .108 mg/1 and .118 mg/1, respectively.
43

-------
Table 2-15. Resultant Lead Concentrations at 30-Day l-in-10 Year
Low Flows Due to Each Proposed Alternative3'1*
Lead
30-Day1	Criterion2		Resultant Concentration (mq/1) Alternative
Month
l-in-10 Year
Low Plow
24-Hour
Average
Criterion
Maximum


1992




2002


A
A—1
A-2
A-3
NA
h
A-l
A-2
A-3
NA
January
2, 820
. 00075
.074
. 1003
. 1003
. 1003
.1003
. 1001
1.004
.1004
. 1009
. 1004
.1001
February
3,971
.00075
.074
. 1002
. 1002
. 1002
. 1002
. 1000
. 1003
. 1003
. 1007
. 1003
. 1001
March
4, 571
. 00075
.074
. 1002
. 1002
, 1002
. 1002
.1000
.1003
. 1003
. 1006
.1003
.1001
April
5,661
. 00075
. 074
. 1002
.1002
.1002
. 1002
. 1000
. 1003
. 1003
. 1002
. 1003
. 1001
May
6,870
.00075
.074
.1001
. 1001
. 1001
. 1001
. 1000
. 1003
. 1003
. 1001
. 1003
. 1001
J une
3, 360
.00075
. 074
. 1003
. 1003
. 1003
. 1003
.1001
. 1004
. 1004
. 1003
. 1004
.1004
July
1,308
.00075
.074
.1007
. 1007
. 1007
. 1007
. 1001
.1010
.1010
.1007
. 1010
.1002
Auyust
7'I 2
.00075
.074
.1012
.1012
.1012
. 1012
. 1002
.1018
.1018
. 1012
. 1018
. 1004
September
716
.00075
.074
. 1013
. 1013
. 1013
. 1013
. 1002
. 1019
. 1019
.1013
.1019
, 1004
October
1, 266
.00075
.074
. 1007
.1007
. 1007
. 1007
. 1001
.1011
. 1011
.1007
. 1011
.1002
November
2,058
.00075
.074
. 1005
.1005
. 1005
. 1005
. 1001
. 1007
. 1007
.1013
. 1007
.1001
December
2, 360
. 00075
.074
. 1004
. 1004
. 1004
. 1004
. 1001
.1006
.1006
.1011
. 1006
. 1001
'USOS data at Riverside State Park |c£s).
'Federal Register, November 20, 1980.
3Us tag data at Riverside State Park averaged over January 1974 to December 1977 (USGS) .
''Resultant concentrations ware calculated by taking into account only the effect of the increase in effluent volume over present
conditions.

-------
Table 2-16. Resultant Chlorine Concentrations at 30-Day l-in-10 Year
Low Flows Due to Each Proposed Alternative3
	Chlorine	
3 0 - Day1		Resultant Concentration (mg/1) Alternative

l-in-10 Year



1992




2002


Month
Low Flow
Criterion 2
A
A-l
A-2
A-3
NA
A
A-l
A-2
A-3
NA
January
2,820
.003-.005
.0233
.0283
.0283
.0283
.0220
.0395
.0395
.0420
.0395
.0233
February
3,971
. 003-. 005
.0203
.0203
.0203
.0203
.0157
.0284
.0284
.0301
.0284
.0166
March
4, 571
.003-.005
.0176
.0176
.0176
.0176
.0137
.0247
.0247
.0262
.0247
.0145
Ap r i i
5,661
.003-.005
.0143
,0143
.0143
.0143
,0111
,0200
,0200
.0143
.0200
.0117
May
6,870
,003-.005
.0118
.0118
,0118
.0118
.0091
.0166
.0166
.0118
.0166
.0097
June
3,360
.003-.005
.0239
.0239
.0239
.0239
.0185
.0337
,0337
.0239
.0337
.0196
July
1,308
.003-.005
.0595
.0595
.0595
.0595
.0465
.0821
.0821
.0595
. 0821
.0491
Auyust
742
.003-.005
. 1010
. 1010
. 1010
.1010
.0796
.1376
.1376
. 1010
.1376
.0839
September
716
.003-.005
. 1044
. 1044
. 1044
. 1044
.0823
.1420
.1420
. 1044
.1420
.0868
October
1 ,266
.003-.005
.0613
.0613
.0613
.0613
.04800
.0847
.0847
.0613
.0847
.0507
November
2,058
.003-,005
.0385
.0385
.0385
.0385
.0300
,0535
. 0535
.0568
.0535
,0317
December
2, 360
.003-.005
.0337
.0337
.0337
,0337
.0262
.0470
.0470
.0499
.0470
.0277
1USGS Data at Riverside State Park (cfs).
•'Qaality criteria for water (EPA 1976).
''tcuulI ant concentrations were calculated by taking into account the effect of the entire effluent volume, as no credible data
exist on river concentrations.

-------
Table 2-17. Resultant Un-ionized Ammonia Concentrations at 30-Day l-in-10 Year
Low Flows Due to Each Proposed JU tornative'
Un-ionized Ammonia
30-Day1



Resultant Concentration
(mq/lj h'
ternative



1 - in
-10 Year



1992




2002


Month Low
F1 ow
Criterion
A
A-l
A-2
A-3
NA
A
A-l
A-2
A-3
NA
J anua rv
2 , 820
.017
.0127
.0127
.0127
.0127
.0039
.0178
.0178
.0189
.0178
.0041
February
3,971
.017
.0091
.0091
. 0091
.0091
. 0027
.0128
.0128
.0135
.0128
.0029
March
4, 571
.017
. 0079
.0079
.0079
.0079
. 0024
.0111
.0111
.0118
.0111
.0025
Apr i 1
5,661
.017
.0064
.0064
.0064
.0064
.0019
.0090
.0090
. 0064
.0090
.0020
Ma y
6,870
.017
.0053
.0053
.0053
.0053
.0016
.0075
.0075
.0053
.0075
.0017
J Ulle
3, 360
.017
.0176
.0176
.0176
.0176
.0032
.0152
.0152
.0176
.0152
. 0U 34
,Iul y
1 , 308
.017
.0268
.0268
.0268
.0268
. 0081
.0369
.0369
.0268
.0369
.0086
Auijusit
74 2
. Ul 7
.0455
.04 55
. 04 55
.0455
.0139
.0619
.0619
.0455
. 0619
.0147
September
716
.017
.0470
. 0470
.0470
.0470
.0144
.0639
.0639
.0470
.0639
.0152
October
1, 266
. 017
.0276
.0276
.0276
. 0 276
.0084
.0381
.0381
.0276
. 0 381
.0089
November
2,058
.017
.0173
.0173
.0173
,0173
.0053
.0241
.0241
. 0256
.0241
.0055
December
2,360
.017
.0152
.0152
.0152
.0152
. 0046
.0212
.0212
.0225
.0212
.0048
'USGS data at Riverside State l-
•'Federa 1 Register, November 28,
'Resultant concentrations were
river concentrations.
ark {.•!.:-) .
1980 .
calculated by
taking
into account the
effect of
the entire
effluent
volume, d
isregarding e>:i
sting

-------
Table 2-18. Resultant Un-Ionized Ammonia Concentrations at 30-Day
l-in-10 Year Low Flows Due to Each Proposed Alternative3
Un-ioni^ed Ammonia
30-Day1		Resultant Concentration	(mq/1) Alternative
l-in-10 Year



1992




2002


Month Low Flow
Criterion 2
A
A-l
A-2
A-3
NA
A
A-l
A-2
A-3
NA
January 2,8 20
.017
. 0053
. 0053
. 0053
.0053
.0019
.0105
.0105
.0116
.0105
.0021
February 3,971
.017
.0042
. 0042
.0042
.0042
.0018
.0080
.0080
. 0088
.0080
.0020
March 4,571
.017
. 0039
.0039
.0039
.0039
.0018
.0071
.0071
. 0078
. 0071
.0019
April 5,661
.017
.0034
. 0034
. 0034
.0034
.0017
. 0061
. 0061
.0034
.0061
.0019
May 6,8 70
.017
.0031
.0031
. 0031
.0031
. 0017
.0053
. 0053
.0031
.0053
.0018
June 3,360
.017
.0047
.0047
.0047
.0047
.0018
. 0091
.0091
.0047
.0091
.0020
July 1,308
.017
.0095
.0095
. 0095
.0095
.0022
.0204
.0204
.0095
.0204
. 0027
Aucjudt 74 2
.017
.0154
.0154
.0154
.0154
. 0027
.0339
. 0339
.0154
.0339
.0036
September 716
.017
.0158
.0158
.0158
.0158
.0027
.0350
.0350
.0158
.0350
.0036
October 1,266
.017
.0098
. 0098
.0098
. 0098
.0022
.0210
.0210
.0098
.0210
.0023
November 2,0 58
.017
.0066
.0066
.0066
.0066
.0020
.0137
.0137
.0152
.0137
.0023
December 2,36 0
.017
. 0060
. 0060
.0060
.0060
.0019
.0122
.0122
.0136
.0122
.0022
:u"SGS data at Riverside State Park (cfs) .
"Quality criteria for water (EPA 1976).
¦'Resultant concentrations were calculated by
cond itions.
taking
into account only
the effect
of the
increase
in effluent
volume
over present

-------
Fish embryonic and larval stages are especially vulner-
able to decreased DO concentrations because their abil ity
to extract oxygen from the water is not fully developed,
and they cannot move away from adverse conditions (U. S.
EPA 1976). This is especially true of the salmonids which
bury their fertilized eggs in gravel. The flow through gravel
is often slow, especially if siltation has occurred. If
it is slow enough, the developing fish and other benthic
organisms can easily deplete the oxygen supply enough to
cause damage, especially if the concentration in the water
is relatively low before it enters the gravel (Cooper 1965).
Embryonic and larval forms restricted to the flowing
portions of the river should not be subjected to significantly
decreased DO concentrations. However, DO concentrations
in slow-flowing or impounded areas, such as upstream from
Nine Mile Dam, may be reduced below existing levels due to
increased BOD,- and ammonia loads. Adult fish, repelled by
low oxygen concentrations, particularly at high temperatures,
can simply avoid these areas (Jones 1952). Embryonic and
larval stages, in contrast, cannot usually move away.
The magnitude of the DO decreases is difficult to assess
as sufficient data on physical river parameters are lacking.
A modeled stream segment can only be indicative of actual
conditions if sufficient data exist on re-aeration rates,
temperature, BOD, nitrogenous and benthic oxygen demand,
de-oxygenation rates, and algal respiration and photosynthesis
to calibrate the model. DOE proposed the use of two different
models to predict the effects of additional waste loads to
the Spokane River and Long Lake (Washington DOE 1981). A
preliminary run with the simpler of the two models was con-
ducted to assess the effects of future BOD loading. The
results show little marked difference in resulting DO concen-
trations from a previous run used to determine existing con-
ditions without additional BOD loading. The report indicates,
however, that new synoptic surveys are necessary to provide
a technically valid basis for waste load allocation as data
are insufficient to accurately establish de-oxygenation co-
efficients necessary to calibrate the models (Washington
DOE 1981).
The effects of upstream increases in	and total
ammonia on Long Lake is another area of extreme uncertainty.
Cunningham and Pine (1969) and Soltero (pers. comm.) suggest
that the BOD carried by the river is essentially exerted
before entering Long Lake. The anaerobic condition of the
lake is the result primarily of plankton decomposition within
the lake itself. Cunningham and Pine (1969) found a high
positive corre1 ation between the quantity of volatile sedi-
ments and the DO concentrations in the overlying water.
48

-------
The warmwater fish species (bluegill, sursfish, crappie,
bass and perch) inhabiting the lake are capable of surviving
in waters with DO concentrations of less than 3.0 mg/1 (Moyle
1976) . They feed in a variety of locations within a lake,
including shallow water, on the bottom, in midwater aquatic
vegetation and on the surface. All species generally spawn
in shallow waters 1-3 meters deep. The northern squawfish
is an exception, as it usually spawns in groups at depths
of approximately 12 meters (Patten and Rodman 1969). There-
fore , even if upstream BOD_ and ammonia loads contribute
to the de-oxygenation of tne deeper waters at Long Lake,
resident fish species productivity probably would not be
impaired.
Alternative A. This alternative would increase the
Spokane treatment plant effluent volume from 31.5 MGD to
44 MGD by 1992 and to 62 MGD by 2002. Eighty-five percent
of influent phosphorus would be removed during both summer
and winter prior to discharge.
Phosphorus Increases. Total phosphorus loading at the
Spokane STP would increase to 346 pounds per day by 1992
and 487 pounds per day by 2002 (Table 2-5). Based on re-
cently revised data, the maximum permissible loading to Long
Lake from all sources would be 507 pounds per day (Washington
DOE 1981a) . Assuming that all treatment plants on the Spokane
River are achieving 85 percent removal of influent phosphorus
and all other sources contribute 168 pounds per day, the
total phosphorus load to Long Lake would be 597 pounds per
day by 1992. This value is 90 pounds per day higher than
DOE 1s suggested maximum loading.
If a phosphorus allocation scheme is implemented which
only requires waste treatment facilities to reduce loading,
the Spokane STP could only discharge 273 pounds per day,
73 pounds per day less than projected under this alternative.
All waste treatment facilities would have to achieve 88 percent
removal of influent phosphorus to reduce loading to per-
missible levels. This result would only be necessary if
other phosphorus discharges are allowed to continue at current
levels. If, for example, industrial dischargers transport
effluent to the waste treatment facilities rather than dis-
charge directly to the river, maximum permissible loading
could be increased at the treatment facilities.
By 2002 phosphorus loading to Long Lake would increase
to 725 pounds per day (Table 2-5). This value is 218 pounds
per day greater than the suggested maximum level (Table 2-5).
Based on the allocation scheme presented previously, Spokane
would have to reduce to 297 pounds per day, provided loading
from other sources remains constant. The STP1s would thus
have to achieve 91 percent remova1 of influent phosphorus
to reduce loading to permissible levels.
49

-------
Nitrogen Increases. Total nitrogen loading would in-
crease to 7,058 pounds per day by 1992 and 9,945 pounds per
day by 2002. These increases should not have any significant
adverse effects on Long Lake water quality as long as phos-
phorus remains the limiting nutrient. Algal production
immediately downstream from the outfall site could be enhanced.
Zinc. Zinc concentrations would increase from .0930
mg/1 to .0942 mg/1 by 1992 and to .0959 mg/1 by 2002 under
low summer flow conditions (Tables 2-7 and 2-8). Existing
river concentrations already exceed EPA 24-hour average
criteria of .047 mg/1 thus any increase regardless of how
insignificant would have an adverse impact on fish pro-
ductivity. At 3 0-day l-in-10 year low flows the 24-hour average
criterion would be exceeded during every month of the year
(Table 2-9). The maximum EPA criteria of .180 mg/1 would
not be exceeded under any flow conditions. However, mortality
due to zinc and heavy metals in general is more severe in
the embryonic and fry stages (U. S. EPA 1976). The 96 LC^q
value for fry of cutthroat trout has been reported to be
as low as 0.09 mg/1 (Rabe and Sappington 1970) and 0.10 mg/1
for chinook salmon (Chapman n.d.). Thus, even through EPA
maximum criteria would not be exceeded, acute toxicity con-
centrations for the more susceptible sa]manic fish species
may be reached.
Copper. Under low summer flow conditions copper con-
centrations would increase to .0043 mg/1 by 1992 and to
.0048 mg/1 by 2002. Neither value exceeds the 24-hour average
criteria of .0056 mg/1. At 30-day l-in-10 year low flows
the 24-hour average criterion would not be exceeded during
any month by 1992, but would be exceeded during August and
September by 2002 (Table 2-14).
Under Q-j_tq flow condi tions the 24 -hour average value
would be exceeded (Table 2-11) while in the dilution zone
both the 24-hour and maximum criteria would be exceeded
(Table 2-13). Thus, effluent discharged during extreme low
flow conditions could have a significant impact on fish pro-
ductivity. The embryonic and larval stages of fish inhabiting
areas immediately downstream from the outfall site would
be the most seriously affected, as their movement is restricted.
Cadmium. Cadmium concentrations would increase from
.0010 mg/1 to .0011 mg/1 by 1992 and to .0013 mg/1 by 2002
under low summer flow conditions (Tables 2-7 and 2-8). At
30-day l-in-10 year low flows the maximum criterion would
not be exceeded by 1992 or 2002 during any month of the year
(Table 2-19). Background river concentrations already exceed
the 24-hour average criterion of .000012 mg/1. Therefore,
any increase would further impact the more sensitive fish
species. The maximum EPA criteria of .0015 mg/1 would be
exceeded under Q__ flows and in the dilution zone'(Tables
2-11 and 2-13). '
50

-------
Table 2-19, Resultant Cadmium Concentrations at 30-Day l-in-10 Year
Low Flows Due to Each Proposed Alternative3'11
	Cadmium	
30-Day1	Criterion2		Resultant Concentration (mq/1) Alternative	
l-in-10 Year 24-Hour	Criterion	1992				2002	
Month	Low Flow	Average	Maximum	A	A-l	A-2	A-3	NA	A	A-l	A-2	A-3	NA
January
2, 820
.000012
.0015
.0011
.0011
.0011
.0011
.0010
.0011
.0011
.0012
.0011
. 0010
February
3,971
.000012
.0015
.0011
.0011
.0011
.0011
.0010
.0011
.0011
.0011
.0011
.0010
March
4, 571
.000012
.0015
,0010
.0010
.0010
.0010
.0010
.0011
.0011
.0011
.0011
.0010
Apri 1
5,661
.000012
.0015
.0010
.0010
.0010
.0010
.0010
.0011
.0011
.0010
.0011
. 0010
!lny
6,870
.000012
.0015
.0010
.0010
.0010
.0010
.0010
.0010
.0010
.0010
.0010
.0010
"una
3,360
.000012
. 0015
.0011
.0011
.0011
,0011
.0010
.0011
.0011
.0011
.0011
.0010
July
1,308
.000012
.0015
.0011
.0011
.0011
.0011
. 0010
.0012
.0012
.0011
.0012
.0011
August
742
.000012
.0015
.0012
.0012
. 0012
.0012
.0010
.0014
.0014
.0012
.0014
.0011
September
716
.000012
.0015
.0013
.0013
.0013
.0013
.0010
.0014
.0014
.0013
.0014
.0011
October
1, 266
.000012
.0015
.0011
.0011
.0011
,0011
.0010
.0012
. 0012
. 0011
.0012
.0011
Sovember
2, 058
.000012
.0015
.0011
.0011
.0011
.0011
.0010
.0011
.0011
.0013
.0011
.0010
December
2, 360
.000012
.0015
.0011
.0011
.0011
.0011
.0010
.0011
.0011
.0012
.0011
.0010
1USGS data at Riverside State Park (cfs) ,
•'Federal Register, November 28, 1980,
"Using river water quality at Riverside State Park averaged over January 1978 to September 1979 (USGS).
''Resultant concentrations were calculated by taking into account only the effect of the increase in effluent volume over present
cond itions.

-------
lead. River concentrations already exceed the 24-hour
average and maximum EPA criteria. Thus, at 30-day 1-in-
10 year low flows the maximum criterion would be exceeded
throughout the year (Table 2-15). Under low summer flow
conditions concentrations would increase only 1 percent by
2002. However, once again, any increase would further impair
fish productivity.
Chlovim (Residual). Under low summer flow conditions
chlorine concentrations would be .046 mg/1 by 1992 and .064
mg/1 by 2002 (Tables 2-7 and 2-8). Both values exceed EPA
recommended criteria of .003-.005 mg/1 for protection of
freshwater organisms. The EPA criterion would be violated
during each month of the year at 30-day l-in-10 year low
flow (Table 2-16). In the dilution zone chlorine concen-
trations could exceed .631 mg/1 by 2002, a value over 200
times greater than the safety limit (Table 2-13}. Most fish
species encountering a concentration of this magnitude would
suffer almost immediate injury. However, many adult fish
are able to detect chlorine in the water and would simply
avoid areas immediately downstream from the outfall site
(U. S. EPA 1976). Embryonic and larval stages are generally
restricted to a particular area in the river. Consequently,
an outfall site placed immediately upstream from optimal
spawning habitat could significantly affect resident fish
species during the summer months.
Un-Ionized Ammonia. Un-ionized ammonia concentrations
would increase from .,002 mg/1 to .008 mg/1 by 1992 and to
.016 mg/1 by 2002 under low summer flow conditions. Neither
value exceeds EPA recommended criteria of .020 mg/1 for pro-
tection of freshwater organisms. Resultant concentrations
based on the effects of the entire effluent volume at 30-
day l-in-10 year low flows would exceed criteria from July
through October by 199 2 and July through November by 2002
(Table 2-17). Resultant concentrations based on only the
increase in effluent volume over existing conditions would
not exceed criteria by 1992 for any month but would exceed
criteria from July to October by 200 2 (Table 2-18). Un-
ionized ammonia concentrations in the dilution zone would
exceed .28 mg/1 by 2002. This concentration exceeds the
96 LCvalue for many freshwater species (Willingham 1976) .
Dissolved Oxygen Deo re aces. BOD loading would increase
from approximately 5,526 pounds per day to 7,7 20 pounds per
day (40 percent) by 1992 and to 10,878 pounds per day (97
percent) by 2002 under low summer flow conditions (Table 2-6).
Concentrations would increase from the existing level of
2.9 mg/1 to 3.128 mg/1 by 1992 and 3.453 mg/1 by 2002 (Tables
2-7 and 2-8).
52

-------
Total ammonia loading under low summer flow conditions
would be 2,022 pounds per day by 1992 and 2,849 pounds per
day by 2002 (Table 2-6). Resultant concentrations would
be .250 mg/1 and .466 by 1992 and 2002, respectively.
Fish species inhabiting the flowing portions of the
river should not experience significantly decreased DO con-
centrations. However, fish restricted to the impounded por-
tions of the river could be exposed to concentrations below
the 8 mg/1 standard especially during the summer months.
Suboption A-l. From a water quality perspective this
suboption is virtually identical to the previous Alter-
native A except phosphorus removal would only be implemented
from April to October rather than year-round. Influent phos-
phorus loads would only undergo secondary treatment from
November to March, resulting in a seven-fold increase in
effluent phosphorus concentrations over those during the
summer period (Table 2-4).
As long as algal growth in Long Lake is limited by phos-
phorus only during the summer period and phosphorus discharged
during the remainder of the year is unavailable to algae
during the growth season, phosphorus removal would be un-
necessary during the winter months. The seasonal variations
in chlorophyll a concentrations in Long Lake prior to AWT
indicate that algal growth during winter and early spring
are controlled by physical factors other than phosphorus,
such as low temperature, high flushing rate, and high sediment
loads (Washington DOE 1981). Thus, as long as phosphorus
discharged in winter and early spring is not released from
the lake sediments, the effects of Suboption A-l would be
identical with Alternative A.
Thomas and Soltero (1977) showed that clay particles
entering the lake during periods of high flow (April-June)
seal off the sediments, thereby preventing recycling of phos-
phorus. The reduction in chlorophyll a concentrations
following AWT support this hypothesis.
The DOE (1981) study states that at current phosphorus
loading rates to Long Lake, a mean seasonal chlorophyll a
concentration in the lake of 10 yg/1 could be maintained
if phosphorus removal at the Spokane STP was discontinued
from November through March. This conclusion assumes among
other things that during April-October the Spokane plant
is achieving 90 percent phosphorus removal or all waste
treatment plants on the river are achieving 85 percent phos-
phorus removal.
53

-------
However, under Suboption A-1 effluent volume would in-
crease by 40 percent by 1992 and 97 percent by 2002. With
the projected 1992 phosphorus loading, it would be necessary
to initiate 90 percent phosphorus removal as early as March 1
in order to reach the 10 ug/1 chlorophyll a concentration
in the lake by June 1, the beginning of the critical - algal
growth season (Washington DOE 1981). These conclusions,
however, are dubious in light of information received after
publication of the Washington DOE waste allocation study.
Due to the underestimation of the phosphorus load contributed
by the Little Spokane River and problems with 1980 water
quality data, the Dillon/Soltero model for Long Lake was
altered (Washington DOE 1981a). The ultimate result was
to increase the value for maximum permissible loading to
Long Lake. Whether or not this new information would signi-
ficantly change the date for initiation of phosphorus removal
is unknown at this time,
Thus, Suboption A-l would have the potential for greater
adverse impacts than Alternative A with regard to increased
phosphorus loading. All other pollutant increases such as
heavy metals and toxins, would be in quantities identical
to Alternative A and would have the same impacts as discussed
previously.
Suboption A-2. This suboption would be identical
to Suboption A-l, except that volume of effluent discharged
in 2002 would be different. Forty-four MGD of effluent would
be discharged between April and October with any effluent
volume exceeding 44 MGD stored until the winter months.
Consequently, a volume of approximately 66 MGD attributable
to the treatment plant effluent and storage release, would
be discharged to the river during the winter months (Kermeyer
pers. comm.).
Between April and October 346 pounds of phosphorus per day
would be discharged by 1992. This amount would not change
by 200 2. To maintain the 10 ug/1 chlorophyll a concentration
in the lake, the maximum permissible loading at the Spokane
plant would be 273 pounds per day by 1992 and 280 pounds
per day by 2002 (Table 2-5). Both values exceed permissible
loading, provided a phosphorus allocation scheme is imple-
mented which only requires STP's to reduce loading. This
suboption, however, is advantageous over Alternatives A
and A-l as total phosphorus loading by 2002 in the summer
months would be 29 percent lower.
During the winter months effluent volume would be approxi-
mately 2 MGD greater than Suboption A-l. Consequently,
if phosphorus reduction does not commence prior to April 1,
mean chlorophyll a concentrations in Long Lake have the
potential of exceeding 10 ug/1•
54

-------
Concentration increases of heavy metals, toxic sub-
stances, and parameters causing de-oxygenation would produce
the same adverse effects as previously mentioned for Alter-
native A by the year 1992. However, effluent volume would
remain at 44 MGD by 200 2 during the summer months whereas
Alternative A proposes an increase to 62 MGD by 2002. The
summer months represent the period when fish are most sus-
ceptible to pollutants. By maintaining effluent volume at
1992 levels, the severity of the adverse impacts would be
significantly less than those of Alternative A.
Suboption A-3. This suboption would be identical
to Suboption A-l, except effluent phosphorus concentrations
would be reduced from April to October and chlorine and un-
ionized ammonia concentrations would be reduced if river
levels exceed criteria.
This suboption would be the most advantageous with
regard to phosphorus loading to Long Lake. The projected
loadings at the Spokane plant would be at permissible levels
necessary to maintain the 10 yg/1 chlorophyll a concentration
in the lake (Table 2-5). However, if phosphorus reduction
is not initiated until April then levels above 10 yg/1 could
ensue.
Other pollutant parameters would be in similar quantities
and produce similar results as previously discussed for
Alternative A. If, however, concentrations of chlorine or
un-ionized ammonia during the summer months exceed recom-
mended criteria, methods would be implemented to reduce these
concentrations to acceptable levels. Consequently, Sub-
option A-3 has distinct advantages over Alternative A, Suboption
A-l and A-2, and no-action from a water quality perspective.
Suboption A-4. This suboption would use in-lake
treatment to improve Long Lake water quality. One or more
of the following methods could be used: chemical control,
mechanical treatment, and deep water withdrawal from the
lake. The effect of chemical control or mechanical treat-
ment on the water quality of Long Lake would depend on the
frequency, rate, and area of application and the efficiency
of the method. Deep water withdrawal from Long Lake through
deepening of penstock outlets at Long Lake Dam could remove
oxygen-demanding substances from the Long Lake hypolimnion
and decrease phosphorus accumulation within the lake. It
is not anticipated that water level fluctuations would be
significantly altered by this process.
All of the methods proposed for this suboption have
demonstrated their effectiveness in other locations. However,
their feasibility, design, and operation criteria for use
at Long Lake have not been determined. Until these are known
the effect of this suboption on Long Lake cannot be assessed.
55

-------
Suboption A-5. This suboption would use a well
structured water quality management program to provide options
to evaluate and control water quality in the Spokane River
and Long Lake. This management program could include a com-
bination of monitoring and special studies to expand the
water quality data base, investigate specific contaminants
and their cause/effect, and track the seasonal and future
fluctuations in water quality. The results of this effort
could be used to identify the implementation date of Sub-
options A-l through A-4.
The water quality management program could also include
the use of administrative controls, .local ordinances, and
nonpoint source operational controls in order to reduce phos-
phorus loads at the Spokane STP and in the Spokane River.
This program might include a reduction or ban of phosphates
in all household detergents. Current investigations indicate
30-40 percent of all influent phosphorus at the Spokane STP
is the result of household detergents (Economic and Engineering
Services 1980). Street cleaning practices could be improved
to provide a reduction in phosphorus loadings in urban runoff;
contributions from this source, however, are thought to be
minimal. Urban and rural runoff sources may be controlled,
especially new construction developments, agricultural ferti-
lization, and farm animal wastes. The respective contribu-
tions of these nonpoint sources have not been quantified.
The effect of this suboption on the water quality
of the Spokane River and Long Lake cannot be accurately
assessed. However, any reductions in phosphorus loadings
to the river would be beneficial to the present water quality.
The phosphorus load reduction would depend on the present
phosphorus contribution from nonpoint sources, and the extent
and effectiveness of a phosphate detergent ban and/or control
of nonpoint sources.
Mitigation Measures
The following list includes potential water quality
and fishery impact mitigation measures.
Continuation of On-going Measures.
o A phosphorus load allocation should be established
for the Spokane River basin including a set load
reduction for the Spokane STP.
o Nutrient and algal levels in Long Lake should con-
tinue to be monitored on a regular basis.
56

-------
o Continue the synoptic water quality studies that
monitor the Spokane combined sewer overflows (City
of Spokane/DOE) and other specific waste discharges
to the Spokane River (EPA/DOE).
o Continue routine monitoring of the Spokane River
(WSU/USGS).
Initiation of Future Studies.
o Improve the accuracy of the phosphorus/chlorophyll
a model for Long Lake by defining the loading rate,
loss rate and regeneration rate from storage of
total phosphorus.
o Identify the sources, distribution, and fate of
major toxic substances in the river and aquifer,
and recommend protection criteria and abatement
actions for any specific problems in the Spokane
River basin.
o Define any effects of trace metal reduction on algal
production in Long Lake.
o Identify optimal spawning and rearing habitat for
key fish species inhabiting the river.
o Considering that river concentrations of various
pollutants already exceed EPA 24-hour average criteria,
fish studies, including bioassays, should be conducted
to determine if resident fish species productivity
is actually being impaired. Through this bioassay
work, establish chlorine, ammonia and heavy metal
tolerance 1imits for resident fish.
o Obtain additional input data for a steady-state model
of the Spokane River which provides: 1) quantita-
tive relationships (flow and concentration) between
the aquifer and river on a seasonal basis; 2) quanti-
tative relationships for nonpoint source pollutant
load contributions to the river for a single event,
seasonal, and annual basis; and 3) a defining of
changes in pollutant concentrations from point of
discharge to Long Lake.
o Obtain additional input data for a DO model for
Long Lake which provides quantitative relationships
between the hypolimnetic DO levels and the effects
of river flow, reservoir circulations, and sediment
oxygen demand.
57

-------
o Obtain additional input data for DO model (QUAL-II)
which provide quantitative relationships between
the river DO (above and be low Long Lake) and the
nitrogenous oxygen demand, sediment oxygen demand,
and algal respiration.
o Conduct a survey in the upper river and in and below
Long Lake to determine the effect of low DO on the
spatial and temporal abundance, species composition,
and biomass of the fish community.
o Obtain baseline data on the spatial and temporal
effects of aquatic macrophytes in Long Lake and bene-
ficial uses and control measures.
o Determine the magnitude of the attenuation of phos-
phorus and other compounds discharged upstream from
the Spokane STP.
General Measures.
o Effluent discharged into the river should be adequately
diffused to alleviate any localized effects.
o Plans should be implemented to achieve appropriate
water quality criteria.
o A monitoring program should be established which
samples water quality downstream from the waste
treatment facilities. Only those pollutants which
exceed acceptable levels should be assessed. If
determined that a concentration of a specific pollu-
tant has reached an intolerable level, then addi-
tional treatment of the effluent should be required
or alterations in the timing of discharge (i.e. ,
storage) should occur.
Project Economics
Introduction
Many of the comments on the Draft EIS indicated that
project costs were not adequately defined. While all of
the various cost e 1ements were identified, they were not
summarized at one single point in the report so that the
individual could understand his/her total financial commitment.
The following pages update the cost elements of the original
alternatives and those that are still being considered in
the planning process. This includes a summary of costs to
the individual homeowner.
58

-------
Cost Comparison of Original Project Alternatives
The CWMP described six basic planning options, Alter-
natives A through F. Costs were presented for the entire
project and for first phase construction and operation.
Estimated user fees needed to support first phase construc-
tion and operation and maintenance costs were also developed.
These cost comparisons are summarized in Table 2-20.
New Project Suboption Costs
Chapter 1 describes several suboptions of the county's
preferred Alternative A. These are modifications to Alter-
native A that could be implemented to reduce the water quality
impacts of A. Economic and Engineering Services, Inc. (1980)
projected costs for the suboptions in a supplementary report.
These costs would be additive to those already described
(Table 2-20) for Alternative A. Table 2-21 lists the suboption
capital, operation and maintenance, and user costs. The
engineers included a "no-action" suboption, which assumed
that present waste disposal practices over the aquifer would
eventually lead to a need for water supply treatment.
Summary of Costs
As mentioned in the Introduction to this section, many
readers of the Draft EIS did not feel the user costs of the
projects were adequately presented. The several cost elements
that pertain to users were presented on different pages
of the report. Table 2-22 combines all of the pertinent
user costs elements to rectify this shortcoming. The actual
costs will vary from one location to the next, depending
on local topographic and soils features, housing density
and other features, but the data in Table 2-22 represent
a typical 5-year cost for a dwelling in a medium-density
area. The costs include all factors except .financing charges
for the major Phase I facilities.
If any of the suboptions to Alternative A are implemented,
the monthly user fee for that alternative v/ill be increased.
Table 2-21 lists those monthly increases for the year 200 2.
In developing a financing plan for the county's preferred
alternative, Economic and Engineering Services, Inc. (1980a,
Table V-2) added in the financing charges for the major capital
expenditures of Phase I. As a result, the Alternative A
monthly user charge was raised from $8.56 to $9.28. This
is an $8.64 annual increase in user fees. If financing charges
were added to the costs of the other alternatives, a similar
increase in cost could be expected.
59

-------
Table 2-20, Summary of Costs for Original CWMP Alternatives1
Plan
Alternative
Description
Regional treatment, all
areas to city plant
Separate treatment,
Spokane Valley
Separate treatment,
North Spokane
Separate treatment,
North Spokane and Spokane Valley
Land apolication,
North Spokane and Spokane Valley
Land application, all areas
at Downriver site
Present Worth Cost Comparison'2
Phase I Costs
Phase I User Costs5
Capital	O&M
57,525,000 24,171,000
Total
Annual
O&M1' S /month /servi ce
Capital
81,696,000 50,487,000® 1,462,400 8.56-all areas
83,043,000 25,538,000 108,581,000 84,137,000 1,285,900 10.70-North Spokane
9.08-other areas
63,525,000 24,385,000
87,910,000 60,132,000
684,400 10.75-North Spokane
7.48-other areas
92,609,000 24,751,000 117,360,000 95,582,000 1,736,900 10.70-Spokane Valley
10.75-North Spokane
86,664,000 28,132,000 114,796,000 96,142,000 1,450,900 9,54-all areas
96,214,000 26,391,000 122,605,000 107,892,000 2,099,400 8.68-Spokane Valley
10.62-North Spokane
'SOURCE: Economic and Engineering Services, Inc. 1980a.
"'Present worth -costs prepared in accordance with EPA criteria; June 1980 cost level.
'includes costs uf treatment, storage basins, interceptors and pump stations; does not include cost of collection system.
""O&M coots For treatment, storage basins, interceptors and pump stations; does not include O&M for collection system.
'•"These costs cover only Phase 1 capital costs and O&M costs for, interceptors, pumping, equalization basins and wastewater
treatment. They do not include costs for collection system financing, O&M financing, or financing interest charges on all
capita1 costs.
'Includes cost of acquiring capacity in the City of Spokane treatment plant and interceptor systems.

-------
Table 2-21
CAPITAL, OPERATION & MAINTENANCE, & USER COSTS (1)
for
SUPPLEMENTAL CWMP DISPOSAL ALTERNATIVES
(ALL COSTS ARE ADDITIVE TO CWMP ALTERNATIVE A)
Project Costs
Sub-Alternatives
Requirement
Capital
O&M/vr (2)
User Costs
$7mcu O)
? Year
2002
2002
85% Seasonal (A)
Phosphorus Removal
(Operational Changes Only)
12 month removal
7 month removal
5 month removal
1,360,000
795,000
568,000
0.65
0.38
0.27
A2
Seasonal Storage
(Incremental Flow of 18
MGD) (5)
Storage & 100% Power Generation (7)	12,919,000
Storage & 100% Crop Production (8)	40,210,000
Storage & 50% Power/50% Crop	26,950,000
320,400 (6)
281 ,900
800,000
0.28
0.52
0.64
A
3
Sewage Treatment Plant
Modifications
(Operational & Facility
Changes)
85% Phorsphorus Removal/Filtration
Dechlorination
Ammonia Removal-4 mo.
Operational Changes
Breakpoint Chlorination
10,900,000 (9) 2,920,000
360,000	50,000
1,000,000
58,000
177,000
1.57
0.03
0.03
0.10
a4
In-Lake Treatment
(Seasonal Control In-Lake)
Chemical Treatment (10)
Mechanical Treatment	?
Outlet Modification (11)	1,680,000
135,000
9
2,000
0.06
0.02
Water Quality Management
No Action
(Contaminated Aquifer/
W.-irer Treatment)
Phosphate Detergent Ban	(12)
Non-Point Control
Nitrate Removal	189,000,000
Heavy Metals, Nitrate, Organics Removal 302,000,000
374,000 savings
30,700,000
35,100,000
(13) Net
Household
Expense
i 7 . 7 .5
21 .04

-------
Table 2-21 (cont'd.)
FOOTNOTES
(1)	All Capital and O&M costs are in 1980 dollars.
(2)	Estimates based on projected flows in 2002 unless
otherwise noted.
(3)	Includes annual O&M plus annualized Capital costs but
does not include financing costs. All Capital costs
annualized for 30 years except sub-alternative A2 and A4
- Outlet Modification where 50 years was used. Approxi-
mately 174,000 customers were projected for 2002.
(4)	Assumes that 35% phosphorus removal will be satisfactory
in 2002.
(5)	Flow differential between 44 MGD and anticipated 2002
year flow of 6 2 MGD.
(6)	Net O&M costs shown for all A2 sub-alternatives.
(7)	1059 KW generated during November-March (5 month) at a
rate of 5.9C/KwH.
(8)	Uses 5880 acres of land for alfalfa crop production.
(9)	Capital costs includes effluent filters, backwash
facilities, solids recirculation, and polymer feed
equipment.
(10)	Assumed four treatments per year over 7 50 acres (15% of
Long Lake) using aerial application of copper sulfate.
(11)	Four power penstock inlets submerged approximately 80
feet at Long Lake Dam.
(12)	Assumes approximately 3 5 4 reduction in phosphorus
influent and daily O&M expense.
(13)	Approximately $11.10/year expense per household in 1980
dollars due to increased use of bleach, water softeners,
and reduced clothing life. Therefore, a $1,931,400 cost
to 2002 househoIds or a net; annual cost of approx imately
$1,557,000 in 1930 dollars. Net cost includes savings in
treatment O&M. Using an annual O&M savings of $760,000
in 2002 if effluent filtration is used still results in
net expense to households of $1,17 1,000. No allowance
given to improved detergent formulation.
SOURCE: Economic and Engineering Services, Inc. 1980.
62

-------
Table 2-22. Estimated Costs to System Users
($/dwelling unit)
Alternative
Major Phase I Facilities
Capital and O&M Costs1
Collection System
Capital and O&M Costs
House
Connector5
Total Cost -
First 5 Years
$/month2
5-Yt. Total
$/yr"
5-yr. total
A
8.56
513.60
366
1,830
800
3,143.60
B
10.70-NS3
9.08-AO
642.00
544.80
366
1,830
800
3,272.00
3,174.80
C
10.75-NS
645.00
366
1,830
800
3,275.00

7.48-AO
448.80

3,078.80
D
10.70-SV
10.75-NS
642.00
645.00
366
1,830
800
3,272.00
3,275.00
E
9.54
572.40
366
1,830
800
3,202.40
F
8.68-SV
10.62-NS
520.80
637.20
366
1,830
800
3,150.80
3,267.20
1Costs for Phase I capital and O&M of treatment, storage basins, interceptors, and pump stations;
does not include financing of interest on capital expenditures.
2SOURCE: Table III-4, Economic and Engineering Services, Inc. 1980a.
3MS = North Spokane, AO- all other areas, SV - Spokane Valley.
''SOURCE: Table ¥-2, Economic and Engineering Services, Inc. 1980a; assures 100 percent ULID
financing with a 20-year payback period at an interest rate of 9.5 percent; also assumes
gravity sewering at a density of two dwelling units per acre.
5Cost of connecting house to collection system in the street will vary with location of house in
relation to street and a variety of other factors; $800 represaits the average of a $300-$l,300
range in cost received fran Maxwell (pers. canm.).

-------
Financing
The CWMP recommends financing the local increment of
the interceptor system, storage basin and pump station costs
with a general obligation bond. This bond would be repaid
by assessing all property in the county at an estimated rate
of $0.52 per $1,000 of assessed value (Economic and Engineering
Services, Inc. 1980a). This rate of assessment assumes that
a $2 0 million grant would be received from DOE and EPA in
support of the Phase I efforts. At present, this level of
state and federal grant support is unlikely. Therefore,
the rate of local assessment would have to be increased or
the size of the Phase I project would have to be scaled down.
A third option would be to seek other sources of financing.
The CWMP considered partial or complete financing through
ULID assessments. At 100 percent ULID financing, the assess-
ment rate was estimated to be $4 3.29 per acre per year (Economic
and Engineering Services, Inc. 1980a). The facilities plan/
financing plan comparisons and recommended approach are
attached as Appendix A.
Recent discussions with local officials indicate that
a scaled down Phase I project may be pursued. A final deter-
mination has not been made and no specific plans have been
drawn for a smaller Phase I. The Board of County Commissioners
is also considering the use of councilmanic rather than general
obligation bonds to finance the local share of the project
(Spoerhase 1981).
Relationship of the CWMP to the
208 Water Qual itv Management Plan
The CWMP is a domestic wastewater f ac i. lities plan devel-
oped with the aid of federal funding under Section 201 of the
Clean Water Act. Section 208 of the Clean Water Act is the
basis for regional water quality management plans that deal
with a wide variety of water pollution sources, including
both point and nonpoint sources (e.g., urban runoff, agri-
cultural runoff, commercial and industrial sources, domestic
wastes, and solid waste and sludge disposal). The CWMP and
the Spokane area's Water Quality Management Plan (208 plan)
therefore address slightly different subject matter, but
have a similar goal: water pollution control.
The objective of all 201 planning, including Spokane
County's CWMP, is to identify cost-effective and environ-
mentally sound methods of collecting, treating, and disposing
of domestic and industrial wastewater in order to minimize
surface and groundwater pollution. Spokane County's 208
plan has sought to remedy a groundwater pollution problem
being created in part by domestic waste disposal practices
in use in urbanized county areas surrounding the City of
Spokane.
64

-------
The Spokane area 208 plan, which preceded the 201 plan,
helped to identify this domestic source of groundwater pollu-
tion. It also developed a general framework for management
and control of other pollutant sources likely to affect the
Spokane Valley Aquifer and the Spokane River. The other
pollutant sources include urban runoff over the aquifer;
runoff from commercial and industrial facilities using criti-
cal substances; agricultural runoff and chemical usage; seep-
age from garbage dumps, landfills and sludge disposal sites;
and excavations that penetrate the aquifer.
EPA's role in the 201 and 20 8 programs is to administer
funds in support of local efforts, and to review final plans
to ensure conformance with federal regulations. Under the
201 program, this review must occur prior to providing addi-
tional federal funding for plan implementation. The local
jurisdictions are responsible for actual implementation of
plan recommendations. This EIS is part of EPA's 201 plan
review process.
The CWMP (201 plan) and the EIS have focused their analysis
on domestic wastewater pollution problems. The plan being
recommended by the CWMP engineers will eventually remove
one source of pollution from the Spokane Valley Aquifer,
namely on-site domestic waste disposal. On-site disposal
threatens to contaminate the aquifer not only with nitrates,
but also with a wide range of other potentially toxic substances
(pesticides, cleaning compounds, bacteria, viruses, others).
Other potential sources of surface and groundwater contamina-
tion will remain, but the 208 plan has developed a management
framework and a series of recommendations to curb these other
sources. The CWMP EIS focused its impact analysis on domestic
sources of pollution, but also identified other potential
sources related to urbanization. Because the 208 plan is
the intended mechanism to address the other pollutant sources,
the EIS did not develop a detailed environmental analysis
of urban runoff, toxic spills, landfills and other nonpoint
pollutant mechanisms. The EIS was scoped to identify the
risks of pollution that may indirectly result from the waste-
water facilities plan, and to identify the agencies responsible
for management and regulation of other pollutant sources.
Because public comment on the Draft EIS indicated a strong
concern for control of nonpoint pollutant sources, a brief
summary of control responsibility is presented below.
The domestic wastewater disposal problem (a point source)
is addressed by the CWMP. The effectiveness of this plan
must be analyzed by EPA, DOE, and Spokane County before it
can be set into action. EPA reviews the plan through the
EIS process; DOE is ultimately responsible for approving
the facilities plan in light of federal and state regulations
65

-------
and water quality standards. DOE also makes grant awards
for further work on the plan. The Spokane County Board of
County Commissioners must assure itself that the selected
plan will solve the area's pressing water quality problems
and at the same time be consistent with other piograms to
protect the area's water resources.
Pollution from urban runoff (a nonpoint source) was
addressed in the 208 plan. As stated in the Draft EIS, this
can be a major source of groundwater contamination. EPA approved
the 208 plan with conditions on February 27, 1981. One of
the conditions stipulated that "An agency to oversee, direct,
encourage, and coordinate Plan implementation on a permanent
basis, must be selected and recommended to the Governor and
EPA for approval" by July 31, 1981 (Dubois pers. comm.).
This selected agency will be responsible for moving the 208
plan recommendations for urban runoff control toward imple-
mentation. It is EPA's position that the 208 recommended
control strategies can effectively reduce the groundwater
contamination threat posed by urban runoff, but implementation
is a local government responsibility.
Control of industrial pollutant sources in the Spokane
area is the responsibility of several agencies. EPA is in
the process of inventorying companies that produce, store,
transport or dispose of hazardous wastes. This has been
authorized by the Resources Conservation and Recovery Act
(RCRA). Regulations controlling the development, use and
disposal of these substances are being prepared by EPA.
Spokane County and DOE have the responsibility to direct
the hazardous waste storage and disposal practices of new
industry established over the aquifer. DOE must issue a
new source NPDES permit to all new industrial waste discharges.
The county must approve the plans, including storage and
disposal facilities, of all new industry locating in the
area. These agencies can also stipulate runoff control
measures to be used by industry.
Finally, the variety of potential pollutant sources
that are associated with growth in general are ultimately
controllable through management of growth. The Spokane County
Board of County Commissioners and the Spokane County Planning
Commission are the principal growth management agencies in
the area. The county's comprehensive land use plan and its
implementation determine the location and nature of develop-
ment over the Spokane Valley Aquifer. The land use plan
should reflect the water quality protection measures highlighted
in the county's 208 plan. This includes control of sprawl
over the aquifer, encouragement of in-fill, and strict limita-
tions to development outside of the PSSA. One of the three
conditions of EPA approval of the county's 208 plan is that
the 208 plan "be adopted as a portion of the City and County
Comprehensive Plans. EPA has determined that this is essential
to ensure effective [208] Plan implementation" (Dubois pers.
comm.). This action must be taken prior to December 31, 1981.
66

-------
In summary, EPA recommends that local and state agencies
should implement the 208 plan nonpoint source pollution control
recommendations as a companion effort to the CWMP. The local
land use plans should be modified to reflect the growth control
mechanisms embodied in the 208 plan.
Consistency Between the CWMP and the County
"Generalized Comprehensive Plan"
EPA policy requires that wastewater facility plans be
in conformance with local land use plans. The consistency
between the CWMP and the county's "generalized comprehensive
plan" was evaluated in September 1980 and presented in the
Draft EIS. Since that time, the county has adopted a final
"generalized comprehensive plan". Based on a review of the
final comprehensive plan, certain issues related to the con-
sistency between the two plans appear to be as yet unresolved.
Unlike the preliminary "generalized comprehensive plan"
the final comprehensive plan contains a land use map which
indicates the areas where policies for each land use category
apply. Although a few minor changes have been noted from
the land use map shown in the Draft EIS, the revised map
is essentially the same as originally presented.
The adopted county comprehensive plan provides general
development policies for guiding future growth. Specific
policies in the comprehensive plan concerning the location
and timing of future development, would better assure that
implementation of the CWMP can accomplish stated fill-in
objectives. This would reduce the possibility of fostering
a land use pattern which would perpetuate the existing sprawl
condi tions.
67

-------
	Chapter I
EPA Recommended Actior

-------
Chapter 3
EPA RECOMMENDED ACTION
Recommended Project
After review of the Spokane County CWMP (Economic and
Engineering Services, Inc. 1980a) and supplemental data pre-
pared subsequent to issuance of the Draft EIS (Economic and
Engineering Services, Inc. 1980; 1980b), EPA has decided
to approve, with certain conditions, the county's proposed
project (Alternative A).
Phase I of Alternative A includes trunk interceptors
and related pumping facilities to connect unsewered portions
of North Spokane, Spokane Valley, and Moran Prairie with
existing City of Spokane trunk sewers. The flows would be
transported to the Spokane treatment plant for treatment
and discharge to the Spokane River. Alternative A also in-
cludes construction of wastewater storage/equalization basins
in North Spokane and Spokane Valley.
At the present time the state's priority list for EPA
construction grant funds lists the North Spokane interceptor,
connecting North Spokane with the city interceptor system,
for $1.23 million in fiscal year 1985 or 1986. At a later
date, if additional federal funds are made available through
the Clean Water Act, Spokane County may apply for further
grants to design and construct subsequent phases of the CWMP.
Further environmental analysis will be necessary to comply
with the National Environmental Policy Act.
Conditions of Approval
EPA intends to place two conditions on any award of
Section 201 grant funds to Spokane County. The first condition
relates to the water quality implications of the increasing
Spokane waste discharge. The State of Washington and Spokane
County should cooperatively continue monitoring of the water
quality of the Spokane River and Long Lake downstream from
the city's waste discharge. The monitoring program should
be designed to determine allowable concentrations of various
pollutants, including chlorine and un-ionized ammonia, and
to establish waste load allocations to more fully assess
the impact of the discharge on the Spokane River fishery.
This is consistent with DOE's recent determination that de-
chlorination and ammonia control must be implemented by June
1983 unless monitoring data indicate it is not necessary.
69

-------
The second grant condition is necessary to comply with
the National Historic Preservation Act. Prior to issuing
any additional Section 201 grants for the CWMP, Spokane County
must complete a records search and field survey of all selected
wastewater facilities sites. This should induce interceptor
routes, pump station locations and equalization basin sites.
The research and surveys should be conducted by a qualified
professional archeologist. The findings of the survey must
be submitted to the Washington State Historic Preservation
Office and the Advisory Council on Historic Preservation
for their review, along with a determination of effect.
EPA also believes that it is imperative to embark on
implementation of nonpoint source pollution controls as
identified in the Spokane County 208 plan. An implementing
agency or agencies should be identified and work should pro-
ceed to fully develop and implement measures to reduce the
water quality impacts from urban runoff, industrialization
and storage and transport of toxic materials.
In addition to these grant conditions and recommendations,
EPA suggests that a variety of mitigation measures identified
in the Draft EIS and in Chapter 2 of this Final EIS be incor-
porated into the project. These measures are as follows;
o proceed with the water quality monitoring and
additional studies defined in the revised Water
Quality Analysis section of Chapter 2
o continue groundwater quality monitoring efforts
across the Spokane Valley Aquifer in order to
document changes in the quality of the local
water supply
o discontinue disposal of wastewater sludge at
the city's northwest landfill in favor of reuse
or disposal off the aquifer
o establish and maintain an industrial connections
inventory consistent with the Clean Water Act's
pretreatment requirements
o enforce pretreatment requirements on any industrial
or commercial discharges to the CWMP collection
system
o minimize exfiltration from wastewater interceptors
over the aquifer and the Spokane River by closely
monitoring and control1ing the quality of inter-
ceptor construction and periodically inspecting the
interceptors for leaks
70

-------
o establish rigorous odor-control procedures to be
used in the operation and maintenance of all
wastewater equalization basins
o buffer equalization basins from adjacent land uses
through the use of berms or vegetative screens
o to the extent possible, encourage preservation of
prime agricultural lands
Significant Adverse Impacts Likely to Occur
in Spite of Mitigation
Several significant adverse impacts are likely to occur
with implementation of Alternative A in spite of the mitiga-
tion measures recommended by EPA. These impacts are sum-
marized below:
o algal production in the Spokane River and Long Lake
below the City of Spokane waste discharge will increase
as the level of nutrients in the river increases
o chlorine levels in the effluent plume and in the
Spokane River below the waste discharge will
exceed EPA 24-hour criteria for protection of
freshwater biota under low river flow conditions
in summer months; the anticipated concentrations
could have a major impact on the entire fish pro-
ductivity of waters below the outfall
o un-ionized ammonia and heavy metal concentrations
in the effluent plume of the Spokane waste discharge
will exceed EPA 24-hour criteria for protection of
freshwater biota under low river flows in summer
months; these concentrations are likely to be
detrimental to those early life stages of fish that
are relatively immobile (eggs, fry) and, there fere,
unable to move away from the plume
o odor and aesthetic impacts could affect residential
land uses surrounding the proposed Spokane Valley
wastewater equalization basin
o county residents hooking into the new wastewater
system will face additional costs; this will include
a collection system hookup fee of from $300-51,300,
a ULID assessment to pay for the collection system
averaging $366 per year (will vary considerably with
dwelling density), and a monthly user fee estimated
to be $8.56
71

-------
o urban runoff over the Spokane Valley Aquifer will
increase as development occurs
o chemical and energy use for wastewater treatment
will increase significantly due to increased volumes
of influent
72

-------
	Chapter 4
Letters of Comment on the
Draft EIS and EPA Responses

-------
Chapter 4
LETTERS OF COMMENT ON THE DRAFT EIS
AND EPA RESPONSES
Introduction
The Spokane County CWMP Draft EIS was available for
public review from February 21, 1981 to May 29, 1981. During
this period EPA, Region 10 received 30 letters of comment
on the document. Each of these letters is presented in the
following pages, and responses accompany each letter. The
section is organized as such: each individual comment on
each letter has been given a number in the letter's left-
hand margin. Following the letter, these comments are res-
ponded to in numerical order. If the comment has been res-
ponded to in the text of an earlier chapter, the reader is
referred to that chapter. The letters are organized into
groups of federal, state and local agencies, and individuals.
Material appended to the letters of comment has been included
in Appendix B.
73

-------
Advisory
Council On
Historic
Preservation
1522 K Street. NW
Washington. DC 20005
Reply to:
Lake Plaza South. Suite 616
44 Union Boulevard
Lakewood. CO 80228
April 20, 1981
Ms. Kathryn M. Davidson, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
22 1581
£Wi«MgT«.
zsmin
Seattle, Washington 98101
Dear Ms. Davidson:
| J Thank you for your recent undated request for comments on the environmental
statement for Spokane County Comprehensive Wastewater Management Plan in
Washington. Pursuant to Section 102(2)(c) of the National Environmental
Policy Act of 1969 and the Council's regulations, "Protection of Historic
and Cultural Properties" (36 CFR Part 800), we have determined that your
draft environmental statement does not contain sufficient information
concerning historic and cultural resources for review purposes. Please
furnish the following data indicating compliance with Section 106 of the
National Historic Preservation Act of 1966 (16 U.S.C. Sec. 470f, as
amended, 90 Stat. 1320).
The environmental statement must demonstrate that either of the following
conditions exists:
1. No properties included in or that may be eligible for inclusion in
the National Register of Historic Places are located within the area
of environmental impact, and the undertaking will not affect any such
property. In making this determination, the Council requires:
-	evidence that you have consulted the latest edition of the National
Register (Federal Register, February 3, 1981, and its monthly
supplements);
-	evidence of an effort to ensure the identification of properties
eligible for inclusion in the National Register, including evidence
of contact with the State Historic Preservation Officer, whose
comments should be included in the final environmental statement.
The State Historic Preservation Officer for Washington is Mr. Jacob
Thomas.
74

-------
Page 2
Ms. Kathryn M. Davidson
Environmental Statement
April 20, 1981
2. Properties included in or that may be eligible for inclusion in the
National Register of Historic Places are located within the area of
environmental impact, and the undertaking will or will not affect
any such property. In cases where there will be an effect, the
final environmental impact statement should contain evidence of
compliance with Section 106 through the Council's regulations.
Should you have any questions, please call Brit Allan Storey of my staff
at (303) 234-4946, an FTS number.
Sincerely,
Wall
Louis C5< Wall
Chief, Western Division
of Project Review
75

-------
Response to Comments From the Advisory Council on Historic
Preservation
1. In order to comply with the requirements of Section 10 6
of the National Historic Preservation Act, Spokane County
forwarded preliminary planning descriptions and planning
area maps to the Washington State Historic Preservation Office
(SHPO). After conducting a records search, the SHPO indi-
cated that the identified wastewater facilities were not
located on known cultural resources sites. The SHPO
noted, however, that some of the areas had high potential
for occurrence of archeological resources. Once specific
facilities sites have been selected, an intensive records
search and fie]a survey has been recommended.
Prior to issuing any further grant assistance to Spokane
County for CWMP implementation, the county must complete
the necessary field surveys for proposed facilities and the
information must be forwarded to the Washington SHPO and
the Advisory Council on Historic Preservation for their
review. EPA has included a recommended grant condition to
this effect.
76

-------
United States
Department of
Agriculture
Soil
Conservation
Service
Room 360
U.S. Courthouse
Spokane, Washington 99201
April 6, 1981
Kathryn M. Davidson, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Davidson:
The Soil Conservation Service has reviewed your draft environmental impact
statement for the Comprehensive Wastewater Management Plan, Spokane County,
Washington.
It appears the concerns of the SCS have been addressed and we have no comments
to offer at this time.
Sincerely
LYNN A. BROWN
State Conservationist
APR 10 1981
ENV!r.C-rr--i! -VALUATION
t:;.
The Sod Conservation Service
IV 13 an a9ency °' !he
vy Department ol Agriculture

77
SCS-AS-1

-------
DEPARTMENT OF THE ARMY
Mii^
SEATTLE DISTRICT. CORPS OF ENGINEERS
P.O. BOX C-3755
SEATTLE. WASHINGTON 98124

MAR 9 IS 51
NPSEN-PL-ER
6 March 1981
Ms. Kathryn M. Davidson
Environmental Evaluation
Branch, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Davidson:
We have reviewed the draft environmental impact statement on the proposed
Spokane County Comprehensive Wastewater Management Plan, Washington, with
respect to the U.S. Army Corps of Engineers' areas of responsibility for
flood control, navigation, and regulatory functions. We have no comments.
Thank you for the opportunity to review this statement.
Sincerely,
SIDNEY KNUTSON, P.E
SIDNEY KNUTSON, P.E.
Asst Chief, Engineering Division
78

-------
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
< .
Centers for Disease Control
Atlanta, Georgia 30333

J
(404) 262-6649
rtPR 6 1981
March 31, 1981
ENVIROiwiEIilA' cVALL!ATiuN
BRAN*-,
Ms. Kathryn M. Davidson, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Davidson:
We have reviewed the Draft Environmental Impact Statement (DEIS) for the
Spokane County Comprehensive Wastewater Management Plan. We are responding
on behalf of the Public Health Service.
We have reviewed this DEIS for possible adverse health effects, and on that
issue we have no comments to offer. We believe the impact of the proposed
action will be positive and will eliminate many future potential health
problems that could result from septic tank failures.
It was noted that the DEIS does not consider reducing per capita water use
in conjunction with any of the alternatives discussed. Local codes should
be reviewed and revised to require water saving devices in all new construc-
tion and in the replacement of existing fixtures. The final EIS should
address this issue.
Although the DEIS mentions the 208 Plan recommendations on page 142 that
growth be restricted in the PSSA through land use controls until services are
available in that area, the statement does not consider that recommendation
in the discussion of alternative measures.
While construction of adequate public sewerage facilities will be an important
step forward in public health in Spokane County, we feel water conservation
measures and the prevention of urban sprawl are also important elements of any
final plan development.
Thank you for the opportunity of reviewing this DEIS. We would appreciate
receiving a copy of the final statement when it is issued.
Sincerely yours
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
79

-------
Response to Comments From the U. S. Department of Health
and Human Services
1.	In reviewing the CWMP, the Washington DOE recommended
that additional investigations be made into flow reduction
and water conservation potentials in Spokane. EPA strongly
supports the use of local building code changes and ordinances
to encourage water conservation. Adoption of appropriate
conservation measures could be made a condition of DOE 1s
grant award should the findings of the project engineers
warrant such action,
2.	EPA's position regarding implementation of 208 Plan
land use controls is included in the section of Chapter 2
tided Relationship of the CWMP to the 208 Water Quality
Management Plan.
3.	Comment noted.
SO

-------
villi/
REGION X
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
REGIONAL OFFICE
ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
SEATTLE, WASHINGTON 98101
April 3, 1981
IN REPLY REFER TO:
kPR 6 1981

Ms. Kathryn M. Davidson
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue, M/S 443	EUVl:-:?-
Seattle, Washington 98101
Dear Ms. Davidson:
Subject: Draft Environmental Impact Statement
Spokane County Comprehensive Wastewater
Management Plan
We have reviewed the statement dated January 8, 1981.
As you know we have been working very closely with you to assure the pro-
tection of the sole source aquifer. This is evidenced by the Memorandum
of Agreement currently in force. We also are supportive of the 208 Water
Quality Management Plan and our program actions have been to support the
growth management efforts of local governments.
We feel strongly that the Spokane County Wastewater Management Plan (CWMP)
should be consistent with other local management efforts to plan orderly
growth. Thus, we have some concerns that certain priority service areas
are in land categories designated as low density in the comprehensive plan
and unlikely to be able to support a central wastewater collection system.
Is it possible to identify in the final impact statement the level of
density needed to support a collection system and to revise the priority
areas accordingly? We believe this will be very helpful in the future
implementation of our projects.
The Seattle Area Office has program jurisdiction in the geographic area and
they have comments with respect to growth implication as follows:
Growth Implications - page 129 - The first part deals primarily with a
comparison of the different population projections. The remainder compares
the CWMP with existing land use policies.
The conclusions of this section states the CWMP, which is not intended to be
a land use planning or land use policy document, has adopted the spirit of the
208 phase recommendations of limiting sprawl by designating a priority sewer
area. The text also acknowledges that low density developments are generally
not considered adequate for sewering.
AREA OFFICES
Portland. Oregon • Seattle, Washington • Anchorage. Alaska • Boise, Idaho
81

-------
Page 2.
The CWMP can have a significant influence on growth management and density
of development. Thus, we recommend a land utilization and holding capacity
approach to estimate the amount of land at an assumed density that would
make the CWMP economically feasible.
This concludes our Seattle Area Office and our comments.
We thank you for the opportunity to review your statement.
Go/don N. Johnston
Ragional Administrator
cc; Ed Moger, HUD
Richard Brinck, HUD
Dick Moore, HUD
82

-------
Response to Comments From the U. S, Department of Housing
and Urban Development
1.	It is local government's responsibility to establish
actual priority boundaries and acceptable densities for
sewering.
2.	As stated in response Number 1, EPA feels that establish-
ment of density thresholds for sewering is the responsibility
of local government (Spokane County). The economic feasibility
of sewering specific areas under the CWMP will be determined
in the course of establishing ULID's to pay for collection
systems.
83

-------
United States Department of the Interior
OFFICE OF THE SECRETARY
PACIFIC NORTHWEST REGION
500 N.E. Multnomah Street, Suite 1692, Portland, Oregon 97232
APR 6 2981
ENViftCNi.''
April 2, 1981
ER 81/227
Kathryn M. Davidson, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Davidson:
The Department of the Interior has reviewed the draft environmental
statement for Spokane County Comprehensive Wastewater Management
Plan, Washington and offer the following comments.
I Although the Spokane River is a tributary to Franklin D. Roosevelt Reser-
voir, and the river is to be the recipient of additional wastewater, there
is no discussion of the impacts upon water quality, recreation, and fisheries
in this reservoir. This information would appear to be necessary since the
Spokane arm of Franklin D. Roosevelt Reservoir has already experienced harm-
ful algae blooms as a result of sewerage overflows into the Spokane River.
The statement fails to address impacts downstream from the study area in
anything more than very general and superficial terms. While we recognize
the necessity of focusing attention on the Spokane area, the magnitude of
downstream impacts with Mo Action or under Alternatives A through E fully
warrants detailed and comprehensive discussion in the statement.
As a key part of Coulee Dam National Recreation Area, the Spokane River
Arm provides water-oriented recreational opportunities for over 200,000
people annually. Water quality is thus a critical factor in the contin-
ued public use of the river. We do not agree that discouraging "water-
contact recreation below outfalls," as stated in Tables 2-40 through 2-42,
realistically mitigates the impacts listed ,
Very little information has been presented concerning the impacts upon
wildlife caused by alternatives C-F. It is obvious that the use of 735
acres of open land could have some impacts, possibly significant ones.
General
84

-------
The comparative analysis of the alternative (page 177, Table 2-39)
would be more useful and effective if they could be presented side by
side, rather than on separate pages. Again, the wildlife impacts of
destroying 735 acres of open land is not presented.
Thank you for the opportunity to review and comment on this document.
Charles S. Polityka
Regional Environmental Officer
Sincerely
85

-------
Response to Comments From the U. S. Department of Interior,
Office of the Secretary
1.	EPA agrees that the Franklin D. Roosevelt Reservoir
is a valuable recreational resource and that implementation
of the CWMP will cause additional water pollutants to enter
the reservoir.
However, as a condition of granting additional federal
funds to the CWMP, EPA and DOE are requiring a detailed moni-
toring program in the Spokane River and Long Lake in order
to establish the level of influence the Spokane discharge
will exert on the river system. As additional data are
collected, impacts below Long Lake can be better defined.
2.	Alternatives C through F are no longer being actively-
considered by Spokane County. Therefore, the 735 acres of
open land downstream from Nine Mile Falls Dam will not be
affected by the project.
3.	Comment noted.
86

-------
DEPARTMENT OF TRANSPORTATION
UNITED STATES COAST GUARD
commander vdplj
thirteenth coast tsuarc DISTRICT
*15 SECOND AVE
SEATTLE WASH Mt?4
pHONE 1 f\C A A *7 C 17
206 442-7523
(dpi)
*ST XJUAF
16476
DPL81-119
FEB 23 1981
Kathryn M. Davidson, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Davidson:
We have reviewed your draft Environmental Impact Statement for
the Spokane County Comprehensive Wastewater Management Plan,
dated February 1981. Our review and comments are in keeping
with parts 1508,15, 1508.26 and 1503.2 of the Council on
Environmental Quality Regulations for implementing the National
Environmental Policy Act (40 CFR 1500-1508).
Pursuant to the Council on Environmental Quality Regulations we
have no comment on your environmental statement. Thank you for
providing us with the opportunity to review this document.
Sincerely
RICHARD F, MAO!
RICHARD F, MAO!
Captain, U.S. Coast Guard
Chief of Staff
13th Coast Guard District
Copy: Commandant (G-WS-1), U. S. Coast Guard
fEB 26 1S8I
€Nvi	ewwJATttN
SPEED
LIMIT
87

-------
RICHARD T. SCHROCK
Director
STATE OF WASHINGTON
COMMERCE & ECONOMIC DEVELOPMENT
General Administration Building • Olympia, Washington 93504 • (206)753-5630 • (SCAN) 234-5630
Seattle, WA 98101
Dear Ms. Davidson:
Thank you for the opportunity to review the Draft Environ-
mental Impact Statement for the Spokane County Comprehensive
Wastewater Management Plan. Our remarks are restricted to
the economic impacts of the plan.
In general, we are in support of the Comprehensive Wastewater
Plan for Spokane County given the attractiveness of Spokane's
living environment and the adverse impact on economic develop-
ment should water quality fail to be maintained. However,
equally significant is the impediment to economic growth from
lack of sewered industrial sites. We are concerned that the
plan does not include an alternative which would provide
wastewater treatment to existing industrial sites in Phase I.
Spokane County has been experiencing an upward trend in the
number of persons unemployed. As of March, the unemployment
rate was 9.5 percent versus a national rate of 7.7 percent.
Simultaneously, the percentage of the labor force involved
in manufacturing has been decreasing, currently 11.4 percent
compared with the historic rate of 14 percent. This point
was further illustrated by the location quotient analysis in
the draft environmental statement which stated "that neither
of the two sectors traditionally assumed to be export
industries—mining and manufacturing—plays this role in
Spokane County".
The expansion of Hewlett-Packard's operations will increase
the demand for wastewater treatment as well as substantially
increase employment opportunities for the area. Their demand
is projected to be 415,000 gpd of capacity by 1996, surpassing
Spokane Office - Roon 307 C-roat Wer^srn Suilding
Spokane. WA 99201	(509) 456-5152
May 13, 1981
Ms. Kathryn Davidson
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
fnvironmental evaluation
BRANCH

-------
Ms. Kathryn Davidson
May 13, 1981
Page 2
the capabilities of the Liberty Lake Sewer District.
Employment projections forecast over 1,000 persons will
be employed by 1996. According to the Comprehensive
Wastewater Plan, an interceptor line will not be extended
to Liberty Lake until Phase II or the year 2002 . Any
delay in Hewlett-Packard's expansion plans will cost the
community new jobs.
Under the current economic conditions and the ever-
increasing competition from other areas for economic
development, it is essential that a higher priority be
given to extending sewer services to industrial sites in
a more timely fashion.
Sincerely,
Kathryn E. Snyder
Industrial Promotion Analyst
KES:pm
89

-------
Response to Comments From the Washington Commerce and Economic
1.	The principal concern of the CWMP is groundwater pollu-
tion caused by the multitude of residential on-site waste
disposal systems being used over the aquifer. The CWMP pre-
dicts that 1.34 MGD per day of industrial waste flows will
be picked up in Phase I of the project in addition to resi-
dential sewering.
2.	Federal funds allocated to local jurisdictions under
the Clean Water Act are intended to remedy existing water
quality problems, not to promote residential or industrial
growth.
90

-------
JOHNSPELLMAN	DOnaLDW m<
Governor	.?>/	Director
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
Mail Stop PV- 77 • Olympia. Washington 98504 • (206)753-2800
June 2, 1981
Ms. Kathryn Davidson
Region X, M.S. 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Davidson:
The Washington Department of Ecology (WDOE) has completed its review of the
draft environmental impact statement (EIS) for the Spokane County Compre-
hensive Wastewater Management Plan (CWMP). The following are our comments
on the EIS. Representatives of the WDOE have discussed some of these
comments with your consultant, Jones and Stokes Associates, Inc.
1
The water quality and fisheries impacts of the considered alternatives,
including those additional alternatives which were studied after publi-
cation of the draft EIS, should be discussed in greater detail. Most
importantly, the EIS should include estimates of the concentrations of
phosphorus, ammonia, chlorine, heavy metals and dissolved oxygen which
may be present in the Spokane River as a result of implementing any of
the alternatives. The WDOE prefers that the once in ten year, low flow
for each month be used as the condition under which the EIS should
address potential impacts to aquatic life, public health and aesthetics.
The Spokane River must meet Washington State water quality standards
established for Class A waters (WAC 173-201-045(2)). Long Lake water
quality must attain Lake Class water quality (WAC 173-201-045(5)).
As stated in WAC 173-201-035(12), deleterious concentrations of toxic
substances shall be determined in accordance with the Environmental Pro-
tection Agency (EPA) "Quality Criteria for Water." Therefore, the target
standards to be achieved include 0.017 mg/1 unionized ammonia as nitrogen
and 0.002 mg/1 total residual chlorine.
Please reference the enclosed April 24, 1981 letter to Bob Wubbena for a
more complete listing of the chemical parameters and the corresponding
standards which are of concern to the WDOE.
Calculations by WDOE water quality personnel show that Alternative A will
violate water quality standards for chlorine every month using the once
in ten years low monthly flows. The criteria for unionized ammonia may
be exceeded during the low flow period of July to October with the
91

-------
Ms. Davidson
June 2, 1981
Page 2
addition of treated sewage from Spokane County. The biological oxygen
demand of the Spokane treatment plant effluent under Alternative A may
also cause difficulty in attaining the 8 mg/1 dissolved oxygen standard
for the Spokane River. The total oxygen demand in the river at River-
side State Park during summer low flows may be as high as 11 mg/1.
Phase I of the Spokane River Iv'asteload Allocation Study completed by
URS Company for the WDOE should be referred to for determining the
possible water quality impacts of the various wastewater treatment alter-
natives .
The WDOE is updating the allocation study to include all currently avail-
able information prior to establishing a recommended maximum phosphorus
loading to Long Lake. The recommendation will be made to EPA, Region X
by June 5. Estimates of the phosphorus loadings due to each alternative
should be included in the EIS with comments on the relative likelihood
of nuisance algae blooms.
The final EIS should be expanded to include impact analyses and proper
mitigation measures for the additional alternatives proposed in the
Comprehensive Wastewater Management Plan Supplemental Studies.
Monthly user fees are listed in Table 2-41 for each alternative. These
fees represent the costs to a county user for the construction, operation
and maintenance of the "Phase I" improvements. They do not include the
additional costs for a local collection system nor the individual house
side sewer construction cost. The final CWMP will include a range of
estimates for monthly user fees. -The final EIS should also be revised
to include these estimates and discuss the financial impacts.
The figures which display possible Spokane Valley interceptor routes
indicate that at least one major sewer will cross the Spokane River.
"This crossing will be within the area where the river and aquifer exchange
water. The possible construction and operational impacts should be dis-
cussed .
The EIS does not contain a summary of the projected sewage flows to the
City of Spokane sewage treatment plant from city and county sources. At
a minimum, a table similar to Table 1-1 should be included which would
display the projected 10 and 20 year design flows.
The WDOE commented to Spokane County on the CWMP in a March 18, 1981
letter addressed to Mr. Dobratz, County Utilities Director. A copy of
that letter has been previously sent to EPA, Region X and Jones and
Stokes Associates, Inc. Changes in the CWMP in response to those comments
should be reflected in the final EIS.
92

-------
Ms. Davidson
June 2, 1981
Page 3
Thank you for the opportunity to comment on this EIS. We look forward to
working with your agency in bringing this planning project to a successful
conclusion.
DWM:me
Enclosure
cc: Glen Fiedler, WDOE, Water Programs
John Arnquist, WDOE, Eastern Regional Office
William Dobratz, Spokane Co. Utilities Director
Bob Wubbena, Economic and Engineerings Services, Inc.
Grant file, Gordon Douglass
93

-------
VT" C7*" /
jlOHN SltLLMAN
Governor
do\m;,\\ m.
D.'.. i
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
Mail Stop PV-11 m Olympia. Washington 985(t~) m (20b) 753-201X)
April 24, 1981
Mr. Bob Wubbena
Econanic and Engineering Services, Inc.
P.O. Box 976
Olympia, Washington 98507
Dear Mr. Wubbena:
As outlined in the Comprehensive Wastewater Management Plan (CWMP) and
Wasteload Allocation Study (WAS) schedule, the Washington Department of
Ecology (WDOE) was to provide guidance concerning the water quality
parameters and conditions which apply to the Spokane River and Long
Lake. You have been informally provided with water quality standards
to assume and with background information as developed by URS Company
for the WDOE. This letter serves as the formal correspondence from the
WDOE.
The CWMP must address the capability of any proposed alternative to meet
Water Quality Standards for the Spokane River and Long Lake. The specific
parameters which must be addressed and the corresponding standard for
each are:
1. Spokane River:
A.	Phosphorus: The URS Company study has identified 206 lbs/day
of phosphorus as P as the allcwable load from the city STP to
achieve ten micrograms per liter of chlorophyll a in Long
Lake. The study has also provided the daily phosphorus loading
to the lake assuming an 8, 12, and 14 microgram per liter
standard. Please contact John Bernhardt of the department to
determine the city STP allocation of these total loadings.
B.	Un-ionized Anroonia: 0.017 mg/1 un-ionized ammonia as nitrogen,
as given in the United States Environmental Protection Agency's
(USEPA) Duality Criteria for Water (Red Book), 1976, is to be
used as the applicable standard. This number will be a design
target. An analysis of the downstream river quality, as a
result of implementing any alternative, must show that the
target will at least approsimately be achieved.
Comprehensive Wastewater Management Plan
94

-------
Mr. Bob Wubbena
Page 2
April 24, 1981
C.	Total Residual Chlorine: 0.0020 mg/1 total residual chlorine,
as given in the USEPA Red Book, is the applicable standard.
Garments given above under un-ionized ammonia also apply here.
D.	Dissolved Oxygen: The Standard for Class A waters of 8.0 mg/l
is applicable up to the upstream end of Long Lake. Please
provide an analysis which predicts the dissolved oxygen con-
centration in the river for present, 1992 and 2002 conditions,
for various proposed alternatives.
E.	Metals: We find it very difficult to properly address allowable
metals concentrations given the time frame in which we are
operating. Additional water quality studies should be done on
the Spokane River before accepting the USEPA redbook criteria
for metals. Such studies would take one year at a minimum.
In the' spirit of attempting to bring the CWMP to conclusion by
September 1981, we strongly reccnmend that you consider the
viability of an industrial wastewater pretreatment program as
the answer to a metals problem and in design for additional
metals removal at the municipal STP. However, we must caution
you that additional removal of metals may prove to be an issue
at a future" date.
2, Long Lake:
Please address items I. (a)-(c), and (e).
In the analysis of the water quality inpacts of alternatives, please
use the ten year average monthly low flow condition for each month
as the baseline river flow. One way to determine this flow is to use
the flow data at Long Lake Dam. Subtract from that data the mean
monthly flow for the Little Spokane River, as given in the Wasteload
Allocation Study Report, and subtract the historic City of Spokane
STP flow. Also, for purposes of determining .compliance, assume complete
mixing of the STP effluent and the river downstream of the discharge-
point. Finally, to determine downstream concentrations, please utilize
the background Spokane River parameter concentrations and city STP
affluent concentrations, which are indicated in the URS 'Company supp-
lemental study, as revised by John Bernhardt in discussions with yourself.
If you have any questions please call me at (206) 753-2909.
Sincerely,
T" c -r "«
¦> C"l-1 - v r.' - -c—1	
-------
Response to Comments from the Washington Department of Ecology
1.	See Tables 2-7 to 2-19 and accompanying discussion in
the revised water quality impacts analysis, Chapter 2.
2.	See Table 2-2 and accompanying discussion in the revised
water quality impact analysis, Chapter 2.
3.	See Table 2-2 and accompanying discussion in the revised
water quality impact analysis, Chapter 2. As stated in WAC
17 3-201-035(12) deleterious concentrations of toxic substances
shall be determined in accordance with "Quality Criteria
for Water" and/or other relevant information. In view of
subsequent publications (Ward and DeGraeve 197 8 and Thurston
et al. 1979) EPA feels that a criterion of 3 yg/1 for chlorine
is more appropriate.
4.	These parameters were taken into account in the revised
water quality impact analysis contained in Chapter 2.
5.	See Tables 2-16 to 2-18 and accompanying discussion
in the revised water quality impact analysis, Chapter 2.
6.	The DOE waste allocation study was used to assess the
effects of additional phosphorus loading to Long Lake due
to each alternative (see water quality section of Chapter 2).
7.	See sections on the effects of additional phosphorus
loading in the revised water quality impact analysis,
Chapter 2.
8.	Brief discussions of impacts associated with the recently
proposed Alternative A suboptions are contained in Chapter 1.
9.	Table 2-22 in Chapter 2 presents a summary of all user
cost estimates developed to date by the project engineers.
The financial implications of these costs are briefly addressed
in the accompanying text.
10.	A detailed description of construction technique for
the river pipeline crossing has not been prepared by the
project engineers. Conversations with the engineers indicate
that double jacket piping can be used for the section crossing
the river and cut-off valves can be installed in the pipe
on both sides of the river to reduce the chance of a signi-
ficant sewage spill into the river. Use of these protective
measures could be made a condition of DOE grants to Spokane
County for interceptor construction.
Construction of a pipeline across the river at Palisade
Park could lead to temporary turbidity problems both in the
river and in the aquifer, as the river recharges the aquifer
in this area. Any modification of the streambed or stream-
bank should be conducted in a manner that would minimize
turbidity and subsequent soil erosion.
96
-------
Once the pipe is in place, it could create a serious
health threat if it leaked or was ruptured. City water supply
wells tap the aquifer a short distance downstream from the
proposed crossing. To minimize the risk of contaminating
surface or groundwater supplies, the pipeline should be con-
structed with the extra jacketing and valving mentioned above.
11.	Table 4-1 is attached to present the requested information.
12.	Facilities plan changes received prior to June 15, 1981,
have been incorporated into the text of this Final EIS.
97
-------
Table 4-1. Projected Wastewater
Flows for Phases I and II
(in MGD)

Phase
1992
I
Phase
2002
II
Planning Area
ADWF
PWWF
ADWF
PWWF
North Spokane1
3.6
5 . 4
4 . 7
7.0
Indian Trails1
0.74
1.1
1.23
1. 86
Spokane Valley and
Moran Prairie 1
9.0
13.5
15.5
23. 25
Liberty Lake and
Newman Lake1
*
•k
3.5
5.25
West Plains1
**
* *
2.6
3.9
City of Spokane2
33.28
53
34.66
56
TOTAL
46.62
73
62.19
97.26
~Tributary to the Liberty Lake plant in Phase I.
**Not to be sewered until Phase II.
1SOURCE: U. S. Environmental Protection Agency 1981, Table 1-1.
2SOURCE: Economic and Engineering Services, Inc. 1980a, Table 11-7.
98
-------
STATE OF WASHINGTON
DEPARTMENT OF GAME
600 North Capitol Way, GI-11 • Olympia, Washington 98504
May 28, 1981
(206) 753-5700
Kathryn M. Davidson
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
W1AY 29 1981
envir°^bu.«^uation
DRAFT ENVIRONMENTAL IMPACT STATEMENT:
Spokane County Comprehensive Waste-
water Management Plan
Dear Ms. Davidson:
Your document has been reviewed by our staff as requested; comments
follow.
In general, we concur with comments submitted in the April 17, 1981
letter from Michael A. Kennedy Consulting Engineers to the Liberty
Lake Sewer District commissioners regarding the wastewater manage-
ment plan. Our main concerns center on potential impacts to fish
egg and fry production and the aquatic food chain from chlorine
discharge to the Spokane River.
One problem with- the assessment of impacts to the aquatic environ-
ment is the use of average river flows to determine water quality
impacts. A time-weighed average, a median, or a typical summer
flow should be used to determine impacts of nutrients and chronic
effects of toxicants on aquatic life. Because of the use of
average flows, this EIS does not adequately depict potential impacts
to vegetation, wildlife, and recreation.
We question whether the comprehensive wastewater management
equalization basins will be sufficient to handle increased flows
before storm sewer separation is completed.
Specific comments follow.
Page 56, Mitigation Measures. This section states, "If determined
that metal or toxin concentrations are reducing fish productivity
below acceptable levels, effluent should be disposed of on land
sites or additional treatment should be required" and "If determined
that phosphorus or nitrogen loading is in excess of maximum
permissible levels, then effluent should be disposed of on land
99
-------
Kathryn M. Davidson
May 28, 1981
Page Two
sites or additional treatment should be required." These are listed
in the EIS as possible mitigative measures. We suggest that this
statement be strengthened so that there is assurance these measures
will be employed. It is likely that at certain times and during
certain flows, toxic substances are already reducing fish
productivity and impacting recreation. This would also be true
for chlorine and ammonia as well.
Page 62, Toxic Substances and Aesthetics. The Spokane River is
classified as Class A water. The Washington Department of Ecology
must ensure that water quality standards are maintained downstream
from the City of Spokane. The proposed discharge would likely not
meet these standards for unionized ammonia, chlorine residual, and
effluent dilution during low flow periods. Low flow periods are
critical times for fish and wildlife.
Page-72, Heavy Metal Increases. Again, the assessment of water
quality impacts should consider heavy metal concentrations during
low flow periods.
Organisms may show threshold responses to increases in toxic
substances. Even an increase of .001 mg/1 should be considered
significant.
Page 75, paragraph 1. Increases in unionized ammonia and chlorine
resi"dual will likely compound heavy metal toxicity problems. This
would result in higher egg and fry mortality and further result in
lower fish productivity.
Page 75, paragraph 2. This section states fish would avoid areas
immediately downstream of the outfall site. Other studies indicate
that certain toxins, including ammonia, seem to attract fish. It
should be noted these downstream areas offer some of the best
physical fish habitats.
Pages 76-78. This section should include a discussion of the
interrelationships in the aquatic food web. What impacts will
changes in disolved oxygen (DO) have on aquatic organisms which
serve as food for fish? Decreases in DO may increase the uptake
of heavy metals by aquatic organisms.
Page 142, paragraph 2. There should be planning efforts to ensure
that areas outside of the priority sewer service area maintain
population levels compatible with water quality goals.
Page 154. Small game and non-game wildlife are also threatened by
development. It should be noted that when wildlife habitat is
destroyed or altered, wildlife populations will be reduced or
lost.
100
-------
Kathryn M. Davidson
May 28, 1981
Page Three
Page 18 0, Table 2-41. Under the section of "Spokane River Fishery,"
adult fish and fish productivity would also be affected.
Thank you for the opportunity to review this document. We hope
you find our comments helpful.
Sincerely,
THE DEPARTMENT OF GAME
Mark H. Grandstaff, Applied Ecologist
Environmental Affairs Program
Habitat Management Division
MHG:cv
cc: Agencies
Region
101
-------
Response to Comments from the Washington Department of Game
1.	Water quality impacts have been assessed at three dif-
ferent flow regimes in the revised water quality impact analysis
(Chapter 2): median flow of the critical summer month, Q7-10
flow and 15 percent of the Q7-10 flow which represents the
dilution zone of the wastewater discharge.
2.	During design review of the CWMP, DOE must ensure that
the planned equalization basins are sized sufficiently so
that the existing City of Spokane combined sewer overflow
(CSO) problem is not increased by county wastewater flows.
The county's CWMP indicates adequate capacity will be pro-
vided .
3.	The Preface to this report lists an EPA grant condition
regarding water quality impacts and a required water quality
monitoring program, A monitoring program will be established
if Alternative A is implemented according to Volume II of
the CWMP. This program would provide more definitive data
on the waste discharge impacts to the Spokane River fishery.
If the monitoring indicates that a significant adverse impact
is being created by the discharge, one of the appropriate
Alternative A suboptions must be implemented to mitigate
the impact. For more information on the proposed water
quality monitoring, refer to the water quality section of
Chapter 2.
4.	Refer to Tables 2-2, 2-7 to 2-13, 2-16 to 2-18, and
the accompanying discussion in the revised water quality
impact analysis, Chapter 2.
5.	Refer to Tables 2-7 to 2-15, 2-19, and the accompanying
discussion in the revised water quality impact analysis,
Chapter 2.
6.	Little useful data are available on the synergistic
effects of pollutants on aquatic organisms. Some data
indicate that synergistic effects on organisms are not only
species specific, but also vary with the ratios and absolute
concentrations of the pollutants and the life stage of the
species. Therefore, speculation on synergistic effects has
not been included in the water quality impacts discussion.
7.	The statement concerning avoidance of ammonia by fish
was omitted in the revised water quality impact analysis.
8.	EPA recognizes that benthic invertebrates comprise a
large percentage of the diet of resident fish species.
However, in comparison to fish, very little data exist on
the acute and chronic toxicity values for benthic organisms.
The data suggest, however, that these organisms can tolerate
higher concentrations of heavy metals and toxic compounds
than fish. Thus, the EPA maximum and 24-hour average values
102
-------
should protect invertebrates as well as fish. Consequently,
we feel that a separate assessment of impacts to inverte-
brates is unnecessary.
9.	EPA agrees with this statement, and strongly supports
the county 208 plan recommendations in this regard.
10.	Comment noted.
11.	EPA agrees that adult fish would also be affected by
dissolved oxygen decreases in Long Lake.
103
-------
STATE OF WASHINGTON
'DefiasittKeat
COMMISSI
BERT L. CC
TiatmaC
R. A. 8ESWK
SUPERVISOI
Box 190
Colville, WA 99114
March 9, 1981
Environmental Protection AGer.cy
1200 - 6th Ave.
Seattle, Wa 98101
Attn: Kathryn Davidson - M/S 443
Dear Ms. Davidson:
RE: Spokane Comprehensive Waste Water Management Plan
I have reviewed the Environmental Impact Statement for the
above mentioned project and have no additions to make to the
checklist itself. I do have the following comments to make
to the proponent.
1.	An approved forest practice application shall be required
prior to any development on any of the forest land within the
boundaries of the project.
2.	The proponent should address the question of forest slash
abatement which should be accomplished during the clearing operation
as covered under RCW 76.04.310. The proponent should have a slash
predisposal plan approved by the Department of Natural Resources
prior to any development.
3.	A surface land mine reclamation permit and reclamation plan shall
be required if more than two acres of contiguous land is to be
disturbed or more than 10,000 yards of mineral is removed in any
type mining operation. (For example, the removal of top soil or
any other aggregate type of material to be sold or used for
construction off the proposed development site.)
Si ncerely
Walt Wruble
Sookane Unit Local Manager
WW:bl
& 6 Yl tetc'-te_
12 1981
cc: Phil in Hi 1 debr?.nd•, Are?. Manager
Ross Hesseltine, Arcadia District Manager

AN EQUAL OPPORTUNITY EMPLOYER
104
-------
Response to Comments from the Washington Department of
Natural Resources
1.	Comment noted. The county's preferred alternative does
not directly involve development of forest land.
2.	The county's preferred alternative, as described in the
CWMP, does not include significant land clearing for new
facilities. If clearing does become necessary the county
must comply with RCW 76.04.310.
3.	Comment noted. The county should apply for a surface
land mine reclamation permit prior to constructing its
planned equalization basins.
105
-------
JOHN SPELLMAN
Governor
JACOB THOM.
Director
STATE OF WASHINGTON	lj~) ^ ^
OFFICE OF ARCHAEOLOGY AND HISTORIC PRBHRN^TON^
Li U
111 West Twenty-First Avenue, KL-11 • Olympia, Washington 98504 • (206^^^-4011
p, r}'-:LilATICN
April 8, 1981
Ms. Kathryn M. Davidson, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Ms. Davidson:
A staff review has been completed of your draft environmental impact state-
ment. The project was reviewed previously by this office with reference
to 130-F-EPA-02. We note your commitment to identify, preserve, and protect
cultural resources which are known or anticipated to be present in the project
area and to consult with the State Historic Preservation Officer regarding
the presence of cultural resources and the potential effects of the project
on the cultural environment.
Thank you for your consideration of our cultural heritage.
Log Reference: 130-F-EPA-02
Re: Spokane Comprehensive Wastewater
Management Plan
SheilavA. Stui
Archaeologist
db
106
-------
STATE OF
WASHINGTON
iteSHaSBS11™"
Governor
WASHINGTON STATE PARKS AND RECREATION COMMISSION
7150 Cleanwater Lane, Oiympia, Washington 98504 M.S. KY-11	206/753-5755
February 17, 1981
35-2650-1820
DEIS - Spokane County
Comorehensive Wastewater
Management Plan
(E-2133)
Katnryn H. Davidson, H/'S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Ms. Davidson:
The staff of the Washington State Parks and Recreation Commission
has reviewed the above-noted document and does not wish to make
any comment.
Thank you for the opportunity to review and comment.
Sincerely,
u
David W. Heiser, E.P., Chief
Environmental Coordination
DWH/PJP:sh
107
FEB 18 1981
ENVIRONMENTAL FOUJATKW
B&AJtGH
-------
Ceagiie of Women Voters of the Spokane Area
NORTH 2319 MONROE
SPOKANE. WASHINGTON 99ZD5
IS091 327-BI66
Hie League of Wbmen Voters wishes to commend the different
agencies on their prompt action in developing the 201 Wastewater
Management Plan.
However, even though we view aquifer protection as a high
priority, we feel we must bring up two other concerns.
Hie first is the lack of any regional solution to this
problem between Idaho and Washington. Neither state can protect
this valuable resource alone and we urge a two state agreement
before a sewer plan of this magnitude is approved.
The second concern is the sprawl projected over the aquifer
in the Generalized Comprehensive Flan. As the Land Use Plan
has no mechanism to contain development to fill in areas —
possibly the Wastewater Management Plan should contain ways to
accomplish containing sprawl. We base this feeling on the time
lap already experienced in the North Spokane Sewer Plan.
Again we commend you and hope you will improve the plan
by using our two suggestions.
1] r,
0tuicu L*j-UlC~
' Cl'^L^'rrid'n ' ?
108
-------
Response to Comments from the League of Women Voters of the
Spokane Area
1.	EPA supports the need for a bistate effort to manage
water quality problems in the Spokane River drainage. Although
there is currently no bistate agreement, EPA is coordinating
water quality management efforts in both states through its
208 and 201 programs.
2.	The CWMP is not being prepared as a land use planning
or growth control mechanism. It is intended to provide waste-
water service to the pattern of development being planned
by the local jurisdiction.
109
-------
Liberty Lake Sewer Disfricf	
:e[1dw
April 22, 1981	^
Ms. Kathryn Davidson, M/S 443	ENVIRONMENT* EVALUATION
U.S. Environmental Protection Agency, Region 10	BIMHCH
1200 Sixth Avenue
Seattle, Washington 98101
Re: DRAFT EIS for Spokane County Comprehensive Wastewater
Management Plan (CWMP-EIS)
Dear Ms. Davidson:
Thank you very much for the opportunity to review the CWMP/EIS. We have a
special interest in this particular document because of our involvement in
wastewater management within the planning area but moreover because of our
concern for maintaining a quality environment in Spokane County.
Our general and specific concerns with the DRAFT EIS are contained in the
attached review provided by our technical consultants. Basically, our
review and comment can be summarized as follows (please refer to the
attached information for substantiation):
1.	The methods of water quality and fisheries impact assessment in the
DRAFT EIS are not sufficiently comprehensive nor is the approach
adequately conservative to give a good estimate of the impacts of the
Plan Alternates.
2.	The Recommended Alternate protects the aquifer but would probably
result in unacceptable, water quality in the Spokane River downstream of
the Regional WWTF discharge point.
3.	We feel that the adverse impacts of the relatively small upstream LLSD
discharge are accentuated. It should be made clearer in the EIS what
the relative magnitude of impacts will be from the Regional WWTF and the
LLSD WWTF.
4.	We feel that to a large extent the present water quality in the Spokane
River, particularly downstream of the City of Spokane, is ur.dssireable.
The EIS should better describe and evaluate present water quality in the
River.
5.	We feel that the EIS does not exhaust the reasonable possibilities for
regional wastewater management and disposal, especially with regard to
land application and seasonal river discharge.
LIBERTY LAKE WASHINGTON 99019
110
-------
LLSD has no problem with connecting into the proposed Spokane Valley
interceptor in 2002. However, we would oppose connecting into that
interceptor in 1992. At present, the only effective mechanism available
for protecting Liberty Lake from water quality degradation due to
surface runoff is the sewer hookup authority. We feel, in addition,
that the CWMP implementation schedule may be extremely optimistic, as it
seems unlikely that a Valley interceptor will be completed by 1992.
Thank you again for this opportunity to review and comment. We will
look forward to reading the final EIS and attending the public hearing on
this project.
Sincerely,
LIBERTY LAKE SEWERDISTRICT.
Arthur H. Toreson, Secretary
AHR:jh
cc: Bob Burd, EPa
Cecil Carroll, EPA
John Arnquist, DOE
Claude Sappington, DOE
Gordon Douglass, DOE
Ray Duff, DOG
Spokane County Commissioners
Director, Spokane County Health District
Terry Novak, Spokane City Manager
Director, City Public Utilities Department
Manager, City Engineering Department
Lake Spokane Environmental Association
League of Women Voters
Ray Soltero
111
-------
MICHAEL A. KENNEDY CONSULTING ENGINEERS
-T -ymm ,
III Zi
April 17, 1981
Michael A Kennedy. P E
OavxJ R	PE
Jof"t w Gund'acft. P E
Liberty Lake Sewer District Commissioners	Ri"pn* Wa
South 1827 Liberty Drive
Liberty Lake, Washington 99019
Dear Commissioners:
Enclosed is our review of the DRAFT EIS for the Spokane County Comprehensive
Wastewater Management Plan (CWMP-EIS) as you requested. The review consists
of two sections. The General Comment section gives our overall appraisal
on a number of points. The Specific Comment section gives a detailed,
itemized review of the EIS.
As you may be aware, the public hearing for the CWMP-EIS has been delayed.
It is currently scheduled to take place May 14, 1981, at 7:30 P.M. at the
Spokane County Health Building.
If you have any questions concerning this review, please contact me.
Sincerely,
MICHAEL A. KENNEDY CONSULTING ENGINEERS
Environmental Specialist
PRK:jh
Enclosure
W 1720 - 4th Ave
SPOKANE. WA 99204
112
-------
REVIEW OF CWMP DRAFT EIS
GENERAL COMMENTS
1. The EIS does not adequately describe and evaluate the
present water quality of the Spokane River downstream of
the Spokane WWTF discharge. Except in the case of Long
Lake, we realize that much of this information is not
presented systematically in any available publications,
A brief review of water quality at Riverside State Park
suggests, however, that the chemical and biological
condition of the River is not meeting Class A Stream
Quality Standards. This situation is undesirable in view
of the fact that the River passes through a very
important State Park and recreation area and also flows
into Long Lake, a reservoir already plagued with algal
pr obi ems .
2.	The EIS water quality and fishery impact assessment
procedures are generally unconservative. Water quality
changes are computed primarily as averages. The mean
river flow is used. A time-weighed average, a median, or
a typical summer flow would more accurately depict
"average" conditions. Typical flows during the summer
and fall are near 1000 c.f.s. The effects of nutrients
and the chronic effects of toxicants would be better
assessed using these lower flows rather than the mean
flow which is biased by high flood flows during snow
melt. The acute adverse effects of toxicants should be
assessed using the Q -10 flow and also the
lowest-ever-recorded flows. Acute and chronic effects on
relatively non-mobile organisms such as stream insects
should be assessed as well in the zone of dilution during
typical low flows and the Q^-10 flow.
3.	Because of the items mentioned in "2" above, the EIS does
not contain the water quality information necessary to
predict floral, faunal and recreational impacts resulting
from the proposed effluent discharge. Preliminary
calculations in our office show that effluent dilution ,
total and inionized ammonia, chlorine residual, algal
nutrients and certain toxicant concentrations would not
be in compliance with water quality standards in the
River downstream of the Spokane Regional WWTF. Although
errata subsequent to the Draft EIS publishing date
suggest that un-ionized ammonia and chlorine residual may
exceed safe levels during the Q -10, we feel that both
the frequency and the severity 6f these problems are of
greater magnitudes than suggested. (see attached Tables
A, B and C)
113
-------
4. In many places, the EIS contrasts the predicted water
quality impacts of the LLSD WWTF and the proposed CWMP
WWTF. Some basic information about the relative
magnitude of the two facilities and the dilution ratio of
effluent to river water will give perspective to these
discussions. The LLSD discharge will have flows of 1 to
3 MGD with effluent dilution ratios of 1/130 to 1/44 at
the adjudicated low flow of 200 cfs. On the other hand,
the proposed regional WWTF (Alt A) will have design flows
of 44 to 66 MGD with critical low flow (Q7-10) dilution
ratios of 1/9.2 to 1/6.5. A comparison of the water
quality assessments in the LLSD Facilities Plan Addendum
and the CWMP Draft EIS is shown in attached Table D.
It should be pointed out that not only will the LLSD
treatment facility discharge be a small fraction with
greater, dilution than the proposed regional discharge;
but in addition, the LLSD effluent can be expected to be
more consistent and of higher quality. Reasons for this
difference are the following circumstances and design
features:
a)	The LLSD plant will employ chlorine removal to
prevent chlorine residuals from reaching harmful
levels in the River (including the zone of dilution
during the Q7-10 flow).
b)	The influent flow to the LLSD plant will be equalized
so that consistent, optimum treatment should be
achieved.
c)	Because of "a" and "b" above, disinfection of the
LLSD effluent will be very effective.
d)	LLSD has adopted very strict industrial waste
pre-treatment ordinances which should allow proper
WWTF performance and high quality effluent.
e)	Recent negotiations involving Washington Water Power,
LLSD, DOE and the State Dept. of Game resulted in the
establishment of a required minimum flow of 300
c.f.s. through Post Falls Dam. This flow should
guarantee at least 200 c.f.s. in the River near
Harvard Road Bridge. Therefore,impacts will be
somewhat less than those predicted in the 1978
Environmental Impact Assessment, which discussed
water quality changes during a Q-10 of 103 c.f.s.
5. The Land Application Alternates presented in the EIS do
not exhaust the possibilities reasonably available. The
costs presented also appear rather high. It is difficult
to review Plan Alternative Costs because there is no
breakdown of costs in the EIS or in the CWMP itself. Ho
consideration is given to land application in the West
Plains area (near Airway H t s. } . Also, no consideration
is given to any schemes employing land application during
114
-------
the summer low river-flow periods and river discharge
during the high flow season. Similarly, no consideration
is given to the possibility of using the wastewater for
beneficial use; for example, in some modification of the
Latenzer proposal.
Generally, we feel that the CWMP implementation schedule
may be too optimistic. It is difficult to imagine that
the processes of ULID formation, bond issue approval,
easement procurement and construction for the two
successive phases will occur by 1992 and 2002,
respectively. We also have concern that the CWMP
equalization basins may not be sufficient to allow the
Spokane WWTF to handle increased flows before the Storm
Sewer Separation is completed.
115
-------
SPECIFIC COMMENTS
pg 11 Table 1 (also pg 122 Para. 1,2; pg 123, Table 2-20;
pg 12'4 , Table 2-21; possibly pg 125, Table
2-22
There is an error in adding annual 0 & M costs for Alternate
A on page 124, Table 2-21 which affects the other pages
listed above. Annual 0 & M for Alt. A in the table adds
up to $1,462,4 00 per year, not $1,198,500 per year. This
brings Alternate A from the second lowest to the fourth
lowest alternate ranked according to annual 0 & M costs.
Present worth and user charge computations for Alternate A
should be re-checked to insure that they are not in error.
pg 16 Par a. 2
The existing LLSD wastewater treatment facility, as of
1/1/81, services 739. vice 75, lots. The new 1MGD facility
is under construction presently and will employ secondary
treatment with chlorine removal . Phosphorus removal will be
added if the facility is expanded.
pg 42 Para. 2
Please provide a reference for the proposed draft EPA
criteria for zinc, copper, mercury, and cadmium. The
recommended Maximum Contaminant Levels (MCL's) cited in this
paragraph differ from those in EPA (1976), "Quality Criteria
for Water."
Pg 43-54
The entire section entitled "Influence on Spokane River Water
Quality" cannot be properly reviewed as it is not known
whether the phosphorus concentrations discussed are in terms
of mg/1 P or mg/1 P04	the difference is 3-fold• Please
correct this problem and give us another opportunity to
review the information.
116
-------
PS 16
Expected concentrations as well as loadings of total and
ortho-phosphorus must be tabulated before and after plan
implementation in order to adequately ascertain the impact of
the proposal on both free-flowing and impounded stretches of
the Spokane River. It is the form and concentration of
phosphorus which determines its availability to algae. This
comment is not intended to slight the importance of knowing
the nutrient loadings for assessing the impact on impounded
stretches such as Long Lake.
pg Para. U
This paragraph, entitled "Nitrogen" contains apparent
contradictions. Because of the way it i3 stated, it is not
clear whether the Spokane City WWTF significantly changes the
nitrogen concentrations in the River (either total or
inorganic-N).
Pg
At the beginning of the sub-section entitled : "Impacts of the
Proposed Alternatives on Existing Water Quality," the authors
state that: "...Loading of selected water quality parameters
was calculated for mean and Q7-10...river flows..." A table
similar to Table 2-1 (pg 4 6) should be constructed showing
expected loadings after the implementation of plan
alternates.
pg 55 (Mitigation measures)
"Reaeration and dilution rates in the river should be
calculated to enable better assessment of future discharges
on water quality." This measure is listed as a future study
which could be initiated as a mitigating measure. We feel
that this work should be done as part of the EIS process.
"The source of all toxic substances in the river should be
identified." This measure is listed as a future study which
could be initiated as a mitigating measure. We feel that the
present DOE/EPA/LLSD funded Wasteload Allocation Study should
deal with this problem.
pg 5 6 (Mitigating Measures)
"If determined that metal or toxin concentrations are
reducing fish productivity below acceptable levels, effluent
should be disposed of on land sites or additional treatment
should be required."
"If determined that phosphorus or nitrogen loading is in
excess of maximum permissible levels, then effluent should be
disposed of on land sites or additional treatment should be
required."	117
-------
The two measures above are listed in the EIS as possible
general mitigation measures. It is probable that, in certain
portions of the River at certain seasons or flows,
phosphorus, nitrogen, organic loading, and toxin
concentrations are already reducing fish productivity as well
as other beneficial River uses. This would probably hold
true for chlorine residual and un-ionized ammonia as well as
other toxins.
pg 59 Para. H
(Warren pers. comm.) is not listed in the Reference List.
pg Para. 5
There is a mathematical error in converting units: 2,372 MGD
and 6,387 MGD convert to 3660 c.f.s. and 9,856 c.f.s.
respectively, not 10 c.f.s. and 27 c.f.s. as written.
pg 60 Par a. 1
Omitted from a discussion of Spokane River water withdrawal
rights is a long-standing right (we are not sure of the
category) owned by Inland Empire Paper Company. This right
would allow that Company to divert (into an artificial
channel) the entire river flow from its natural course along
a stretch in the Spokane Valley for the purpose of electrical
power generation.
pg 61 Par a. 1
This paragraph is inaccurate. There exists in the Spokane
Valley a long stretch of the Spokane River bordered by
private land in semi-natural state (owned by Inland Empire
Paper Company). The water in this river stretch Is clear and
swift, flowing in a fairly restricted channel with steep
banks. Several parks and recreation areas are included in
the Spokane Valley stretch of river. It is important from
the standpoint of fisheries, aesthetics, and recreation.
pg 62 last Para.
Fecal coliform concentrations are predicted here using an
effluent concentration of 78 MPN/100ml . It would be safer to
do the assessment of public health risks using <200 MPN/100ml
as an effluent fecal coliform concentration. Also, the
reader loses perspective on the significance of the LLSD
discharge when the EIS contrasts the expected fecal coliform
increase due to the entire ultimate flow of that facility
with only the increment of increase expected from the Spokane
Facility.
118
-------
pg 62 Referring to Paragraphs on "Toxic Substances" and
"Aesthetics"
The Spokane River is classified by the State as a Class A
water. The EIS states correctly that "...the Washington
Water Quality Standard states that toxic, radioactive, or
deleterious material concentrations shall be below those of
public health significance, or which may cause acute or
chronic toxic conditions to aquatic biota, or which may
adversely affect any water use..." (underlining is ours).
The remainder of the EIS, in its approach to discussing CWMP
alternatives and their impacts, does not seem to accept the
necessary implication of that statement—specifically, that
the State Department of Ecology (by Law) cannot allow
violation of the water quality standards downstream from the
City of Spokane, An ultimate discharge of 66 MGD of
secondary treated wastewater (with 85$ phosphorus removal)
will almost certainly not meet standards for unionized
ammonia, chlorine residual and effluent dilution during low
flow. The EIS does not present information sufficient to
determine whether requirements of State water quality law
will be met with respect to other constituents during low
flows. The summer/fall low flow periods are not only those
periods when Spokane River flora and fauna may be most
susceptible to adverse impact, but are also the periods of
most intense human use of the River.
pg 63 Para. 1
. Note that Harvard Road Park is upstream from the proposed
LLSD effluent discharge location.
. On one hand the draft EIS states that the LLSD discharge of
1 to 3MGD will have an important impact on contact
recreation downstream. On the other hand, the EIS states
that the Spokane WWTF (36 MGD in 2002 under No-Action Alt.)
should not significantly influence contact and other
recreation. Besides the greater effluent dilution, reasons
have already been discussed (GENERAL COMMENT NO. H) why the
Liberty Lake facility may likely discharge a higher
quality effluent than the Spokane WWTF or the expanded
facility under Alt. A.
pg 64 Second Para, under Alt. A
The increase in total ammonia shown (.06 mg/1 as N)
corresponds to an effluent concentration of only 9.7 mg/1
Ammonia-N. The EIS shows an expected effluent total
ammonia-N concentration of 14.6 mg/1 in Tables 2-5 and 2-6.
This effluent concentration yields a calculated concentration
increase of .09 mg/1 at mean River flow.
Should the reader re-calculate every number given in the EIS?
How many significant errors have gone unnoticed?
119
-------
pg 64-65
The entire section on fishery impacts of CWM P alternates
ignors the probability that many toxicants will exert impacts
after reaching a concentration threshold. The severity of
impacts, therefore, will not necessarily be in direct linear
proportion to the effluent dilution ratio. It is possible,
for example, that an effluent discharge of 10 c.f.s, in a
given River flow would be acceptable and 11 c.f.s, not
acceptable from a fisheries standpoint. In general , the
analysis of fisheries impacts contained in the EIS must be
more comprehensive and must take into account River flow
variation. Careful comparison with available information on
acceptable environmental contaminant levels should be
undertaken for every known or suspected constituent of
environmental consequence in the effluent. Finally in
addition to'discussion in the text, the information should be
displayed in a systematic tabular format (or something
equivalent) so that it may be effectively reviewed by
decision-makers.
pg 65
Is Upriver Park really considiered more important than
Riverfront Park? Is this from the standpoint of water
contact recreation? Also, is not the importance of Riverside
State Park under-rated here?
pg 65 Para. 3
Toxicants as well as pathogens from the alternate Felts Field
WWTF could affect the quality of well water at the City of
Spokane well 1 mile downstream of that facility's discharge.
This risk is accentuated because there is insufficient
turbulence and distance in which the 19 MGD of discharged
effluent could become diluted in the River flow. It is odd
that the impact of the small upstream LLSD discharge (1 to 3
MGD) on the city wells is accentuated (pg 99) while the
groundwater impacts of a possible 19 MGD WWTF discharging
effluent near Felts Field seems to be treated as a rather
minor impact (see pg 99).
pg 65 last Para
The impact of Alt. E on surface water and groundwater quality
would not be the same as Alt. D as stated in the EIS.
Alternate E does not entail discharging 19 MGD of effluent to
the Spokane Ribver near Felts Field as does Alt. D.
Pg 67-71
This information on water quality standards and existing
water quality conditions should be tabulated as well as
discussed in the text, otherwise it is very difficult to
review. A section dealing with toxic organic compounds
should be added to this section and to the succeeding water
quality impact discussions. 120
-------
Pg 72
The EIS states reassuringly that increases in toxic heavy
metal concentrations below the proposed outfall (Alt. A) will
increase by less than .001 mg/1 and that these increases
should not impair adult fish productivity beyond present
levels. This statement is only one of many separate
instances in the EIS where the reader is misled first by an
inadequate assessment of impacts and second by a biased
presentation of those impacts. Our concern with the EIS's
approach are the following:
a)	The heavy metal concentration increases discussed were
computed using the mean River flow. This flow statistic
(7570 c.f.s. at Riverside State Park) is very much biased
by early spring flood flows. Summer and fall flows are
typically near 1,000 c.f.s. for extended periods of time,
surprisingly independent of the magnitude of previous
winter/spring flows. The EIS should assess future water
quality changes based upon effluent dilution in the Q7-10
and lowest recorded flows. The impact of certain
constituents should be assessed based upon calculated
concentrations within the dilution zone during the Q7-10.
b)	A concentration increase of less than .001 mg/1 is
referred to as a "trace" and is more-or-less dismissed as
insignificant. Resultant river concentrations of .001
mg/1, let alone increases of .001 mg/1 of many chemical
species may be deleterious. For example, .001 mg/1 is
2.5 times the recommended maximum contaminant level (MCL)
for cadmium, 20 times the recommended MCL for mercury,
and 100 to 1,000 times those recommended for many toxic
organic compounds.
c)	The EIS appears to ignore the fact that organisms and
biological systems often show a threshold response to
incremental increases in toxicant concentrations,. An
increase of.001mg/l in a certain constituent may be the
proverbial "straw that broke the camel's back" if River
concentrations of the constituent are near, at, or above
the recommended safe level (MCL).
pg 75 Para. 1
The EIS states that "...although adult fish productivity
should not be significantly impaired below existing levels by
increases [in heavy metal concentrations], the possibility of
increased egg and fry mortality is conceivable....". The end
result--the productivity of adult fish--is likely to be
impaired as a result of impaired survival of immature stages;
especially in light of the increases in un-ioni zed ammonia,
chlorine residual and other unknown factors that will occur
concomitantly and may likely aggravate heavy metal toxicity
problems .
121
-------
pg 75 Para. 2
The EIS cites U.S. EPA ( 1 976) stating	Adult fish are able
to detect low concentrations of these substances [residual
chlorine and un-ionized ammonia at less than ,001 rng/1
"trace" concentration] and would simply avoid areas
immediately downstream from the outfall site..." The cited
reference does contain information consistent with this
statement with regard to residual chlorine (pg 34 of EPA 1976
citing Sprague and Drury, 1969). However, the reference does
not state or imply similar avoidance of ammonia. In fact
Hyr.es ( 1974)* cites information suggesting that some toxins,
including ammonia, seem to attract fish. In addition, while
it may be true that fish avoid chlorine residual
concentrations of .001 mg/1, they have been observed to be
attracted to higher chlorine residual concentrations,
presumeably due to the occurrence of breakpoint chlorination
(oxidation of ammonia) at the gill surface, (we could not
find the reference for this study at this time but could
track it down.)
« Hynes, H.B.N. (1974) The Biology of Polluted Waters,
University of Toronto Press, Toronto and Buffalo pg 77.
pg 75 Para. 4
The EIS states that the increase in ammonia nitrogen
resulting from the proposed LLSD discharge will be in excess
of 90$, qualifying the statement that the actual amount of
increase (.01 mg/1) is rather small. The statement is
accurate, however, it should probably be pointed out in
comparison that river ammonia nitrogen concentrations
increase by approximately 16 0 0% between Harvard Road and
Sullivan Road .
Pg 75-76
The EIS states (pg 75 Para. 4) that insufficient data prevent
accurate calculation of B.O.D. and ammonia deoxygenation
resulting from the proposed regional discharges. These
should be calculated during the EIS review — even if only to
establish the "worst case" condition using conservative
assumptions. Applicable literature could be used for
deoxygenation rate of waste material, reaeration rate of the
river, and the dilution rate in the river. Care should be
taken to err on the side of conservatism, in otherwords on
the side which would yield lower D.O. value in the River.
(To do this, one would use lowest river flows &. dilution, use
warmest temperatures, not over-estimate reaeration, etc.).
The statements in the first sentence on page 76 and in Para.
3 pg 78 that no significant reduction in D.O. should occur in
the flowing portions of the River appear to be "gut feelings"
and may amount to dangerous speculation.
122
-------
pg 76-78
Pertinent to the discussion of impacts of planned B.O.D.
discharges on the Spokane River/Long Lake fishery would be a
discussion of the fish food chain and the impacts on that
system. What and where do the various fish species eat?
Many of the fish food organisms have only limited motility.
Will their survival be impaired by possibly expanded areas of
oxygen depletion? The concern holds true whether the D.O.
depletion is due directly to B.O.D. discharge from the
Spokane Regional WWTF or indirectly due to decomposition of
an increased algal biomass resulting from additional nutrient
loading. It is also possible that decreased D.O. in the
Spokane River reservoirs could release (or make more
available for uptake by bottom organisms) heavy metals
previously precipitated and stored in bottom sediments.
pg 77 Para. 2
The EIS states that "...Heavy metal and toxin increases
at Spokane would be in trace amounts and should produce
effects similar to those mentioned for the No-Action
Alternative...." In the No-Action Alternative the total
wastewater discharge from the Spokane WWTF will increase from
31.5 to appproximately 36 MGD (a 4.5 MGD increase). Under
Alternate A, the Spokane WWTF flow will increase from 31.5 to
approximately 62 or 66 MGD (an increase of over 30 MGD). The
water quality impacts certainly would not be similar with an
increase of at least 7 times the magnitude. A look at the
effluent dilution ratios (during the Q7-10 flow) resulting
from the predictd flow increases is shown in the abbreviated
table below (our calculations). This information illustrates
that Alternate A is likely to be significantly more adverse
in its water quality impacts than the present situation and
the "No-Action" Alternative. It should be pointed out that
the present situation is already undesireable from the
standpoint of effluent dilution. In the present situation,
effluent dilution would be approximately 1 to 20 in typical
summer flows of 1000 c.f.s.
1981
Present
2002
No Action
2002
Alt . A
WWTF Effluent Flow
31.5 MGD
560 c.f.s.
36 MGD
5 60 c.f.s.
62.2 MGD
560 c.f.s.
Spokane River
(Q -10) Flow
Dilution Ratio
1/12
1/11
1/6.8
Q? - 1 0
123
-------
pg 77 Under the title "Alternative A":
The only discussion of dissolved oxygen changes resulting
from this alternative is the removal of an adverse impact
caused by the LLSD plant discharge. The impact (or the
removal of the impact) of' this small effluent discharge is
minor in relation to the expected impact of Alternative A on
dissolved oxygen concentrations in the Spokane River. An
abbreviated table of predicted BOD increases (mg/1)
illustrates the relative magnitudes. It would seem that the
downstream dissolved oxygen impacts of Alt. A should be
discussed thoroughly.
BOD INCREASE DUE TO EFFLUENT DISCHARGE
Spokane River Flow
. a
Mean
Q7-10
15% of Q7-10
Alternative A
(increase only)
Present flow +
Alt. A increase
(66 MGD)
LLSD (3 MGD)
13
28
006
1 . 6
3-2
. 3
1 2
7.6
d
1. r
FOOTNOTES:
a) Note that the Q -10 at the LLSD
discharge point has been calculated
to be 103 c.f.s. The BOD increases
shown correspond to this flow.
However, recent negotiations between
the State and Washington Water Power
have resulted in an adjudicated
minimum flow requirement of 300
c.f.s. from Post Falls Dam, insuring
low flows in excess of 200 c.f.s, at
Harvard Road .
b)	This is the "dilution zone" at
critical flow as defined by
Washington State DOE.
c)	from the CWMP EIS.
d)	Calculated from info, in the CWMP
EIS.
e)	from the LLSD Facilities Plan
Addendum 1978.
124
-------
Pg 79
Discussion of the land disposal	alternatives C, D and E
should include an estimation of	the resultant water quality
changes that might occur in the	Little Spokane River and/or
Long Lake.
pg 91 Para. 3;
Wet process plating wastewater is an important constituent of
both present and projected future industrial wastewater flows
for the Spokane area. This item should be added to the list
of industrial wastewater types in paragraph 3.
pg 92 Para. 2 (Discussing Aquifer Water Quality)
Even though sufficient data may not exist to°make a
"definitive" estimate of the change in aquifer water quality
resulting from sewering, perhaps the EIS could make border
assumptions and estimate a range within which the water
quality changes might fall. If the reason for sewering is
primarily to prevent future inevitable contamination, this
should be clearly stated and perhaps semi-quantified.
pg 92 Para. 3
The EIS preparers should investigate information sources
other than the CWMP report to find out what interim
wastewater treatment/disposal facilities presently exist.
pg 93 Table 2-11
The expected industrial	wastewater flows expected in the CWMP
Facilities do not agree	with industrial wastewater source
information in the CWMP	Report (Table II-1! and pg 11-60 to
11 — 6 3)• The EIS should	explain the reason for the
divergence.
pg 95 Para. 2 and 3
Mention should be made of the problems, including litigation,
that the City of Spokane has been having a connection with
sludge disposal operations.
pg 98 Par a . 4
Our review of the '208' Plan revealed that the Plan, in
short, recommended that NPDES permits for Spokane River
discharges upstream of Upriver Dam should not be issued
without very careful consideration and evaluation of their
potential impact upon groundwater. We did not find a
-icct.p. end at ion that the discharge he potable.
125
-------
pg 99 Para. 2 (Corrections)
The LLSD WWTF discharge will be of secondary effluent
quality with chlorine disinfection and chlorine removal.
Before reaching 1 MGD the facility will be modified to
accomplish 85$ phosphorus removal.
Parallel construction of equalization basins,
clarification basins, chlorine contact tank and
chlorination/dechlorination equipment in the LLSD facility
eliminate the possibility of untreated bypasses. In the
event of unit breakdowns, some degree of treatment will
always be provided.
Public and agency review has been completed on the LLSD
facility. An emergency storage pond was not required by
the appr>povals.
pg 100 Para. 2
Regardless of whether or not the CWMP analyzed the potential
for migration of wastewater contaminants from the land
disposal areas proposed in Alts. C and D, the EIS should do
so. Generally, insufficient information is provided for the
reader to make a satisfactory comparison of alternates.
pg 111 Para . U
The LLSD WWTF will occupy approximately 12 acres rather than
40 as implied in this paragraph. The same comment applies as
well to Table 2-16 on page 115.
pg 113 Par a . 1
We have seen the rare Pilated Woodpecker and also Bald Eagles
along the Little Spokane River near the confluence site.
pg 118 Par a . 2
Mention should be made of existing odor problems at the
Spokane WWTF.
pg 119 Para. 3
The EIS states that long term land use requirements must be
considered in the weighing of alternative plans	then it
does not present any information on long term land use
requirements.
126
-------
pg 125 (Table 2-22)
This table compares user charges for the various alternative
plans. In Footnote (4), the monthly user charge of
$ 15.00/month/service in Liberty Lake Sewer District is
contrasted with those of the CWMP alternatives. It should be
pointed out that $15.00 per month is the total charge for
LLSD customers. In contrast, the CWMP user charges do not
include ULID financing provisions and unique construction
costs.
pg 126 Par a. 3
Replace "LID" in this paragraph with "ULID". In addition,
the costs of on-site wastewater treatment/disposal systems
should be discussed here.
pg 127 Table 2-23
The EIS does not mention the use of large amounts of alum for
phosphorus removal. The Spokane WWTF used 3,100 tons of
liquid alum last year and paid $120 per ton (the cost of the
alum has increased 100$ over the past 2 years). Assuming
that the new plant is approximately 40% larger than the
present one, alum consumption under Alt. A would be
approximately 4,000 to 5,000 tons per year. The cost would
be $480,000 to $600,000. Total cost for phosphorus removal,
including additional sludge dewatering and disposal costs
would add an additional $600,000 to $880,000 (based on
experience at the Spokane Plant	Gale Olrich - pers. comm.).
We are concerned that these costs may not have been
considered in the cost-effective comparison of alternates.
pg 128 Para. 2
It appears from this paragraph that phosphorus removal in
relevant alternative plans will be accomplished without alum
usage, since only polymer costs are mentioned. If so, the
type of phosphorus removal design should discussed. The last
paragraph on the page, however, mentions the use of alum. We
are confused as to what design is planned for phosphorus
removal.
pg 142 Par a. 2
We agree that certain areas of sparse development could be
left out of the Priority Sewer Service Area. However, there
must be a mechanism to insure that population density does
not increase in these areas.
pg 154 (First paragraph under the title "Wetlands")
The shorelines of the Spokane River and the shorelines of
Newman Lake should be added to the last sentence, where
significant wetlands of Spokane County are listed.
127
-------
pg 151 Last sentence on the page:
Not only large animals requiring large continuous areas of
wildlife habitat are adversely affected by encroaching
development. Birds and other small wildlife species become
scarce because of the presence of humans (including their
structures and pets),
pg 177 Table 2-39
Does not summarize downstream surface water quality and
beneficial use impacts of the alternatives.
The table mentions the elimination of public health risks
through the elimination of the LLSD discharge. This
discharge was examined carefully by the EPA and DOE and
other reviewing agencies. The consensus was that the
discharge would not constitute a significant threat to
public health or the aquatic ecosystem. Water quality and
biological testing is ongoing and will continue to monitor
the effects of the discharge. Alternatives B and D will
eliminate the LLSD discharge but will replace it with a
larger discharge of poorer quality in a stretch of the
river where there is relatively little mixing and where
there are very strong indications that the river is
affecting nearby groundwater. This Felts Field discharge
is dangerously close to two very large city water supply
wells, as discussed earlier in the EIS,
Costs of Alernative Plans are not totally represented.
Pg 180 Table 2-M1
Under the Heading "Spokane River Fishery": Heavy metal,
ammonia, chlorine residual and other toxic material
increases will probably adversely affect egg, fry and
adult stages of fish downstream of the Spokane treatment
plant outfall.
Under the Heading "Land Use Impacts": There would
probably be increased odor problems near the Spokane WWTF
and storage basin site.
Under the Heading "Costs": Costs are not completely
represented. The ULID and hookup charge should be added
here.
Under the Heading "Energy and Chemicals": It may not be
possible to pump from storage basins during low electrical
power demand hours because of operational requirements of
the WWTF.
pg 180-18^ Tables 2-Hl . 2-U2, 2-13, 2-tM, 2-U5
Under the Heading "Energy and Chemicals": No mention is
made of alum use in Alternates A through E,
128
-------
TABLE A
CWMP: Calculated Increases in River Concentrations of
Selected Constituents*
RIVER FLOW
Year 1992 (19.25 c.f.s.)	x flow	Q7-10	Q7-10 dil. zone
	for 12.5 MGD Increase fEffl.1	7570 c.f.s.	560 c.f.s.	84 c.f.s.
Dilut. Ratio of Increase	--	1/394	1/30	1/5.4
Total Nitrogen (mg/1 N)	30	.075	.99	5.6
Ammonia-Nitrogen (mg/1 N)	14.6	.036	.48	2.7
Total Phosphorus (mg/1 P)	1.2	.003	.040	.22
T - Chlorine Residual (mg/1	CI) .4 - 1.0	.001 - .0025	.013 - .033	.074 - .185
Fecal Col if. (MPN/lOOml)	<200	<0.5	<6.6	<37
B0D5 (mg/1)	21	.052	0 .69	3.9
Year 2002 (47.3 c.f.s.)
for 30.69 MGD Increase
Dilut. Ratio of Increase	--	1/161	1/12.8.	1/2.78
Total Nitrogen (mg/1 N)	30	.19	2.3	11
Ammonia-Nitrogen (mg/1 N)	14.6	.09	1.1	5.3
Total Phosphorus (mg/1 P)	1.2	.007	.094	.43
T-Chlorine Residual (mg/1 CI)	.4 - 1.0 .0025 - .0062 .03 - .08	.14 - .36
Fecal Col if. (MPN/lOOml)	< 200	<1.2	<16	<72
B0D5 (mg/1)	21	.13	1.6	7.6
*CWMP Alternate A - Regional Facility discharging upstream from Riverside State Park
(calculations by MAK Consulting Engrs.) This table takes into
account only the increase above present conditions.
129
-------
TABLE B Calculated Increases in River Concentrations of Selected Constituents*
RIVER FLOW

Year 1992 Effluent
x flow
Q7-10
Q7-10 di 1. zone

(44 MGD)
7570 cfs
560 cfs
84 cfs
Dilution Ratio

1/111
1/9.2
1/2.2
Total Nitrogen (mg/1 N)
30
0.27
3.3
13.5
Ammonia-Nitrogen (mg/1 N)
14.6
0.13
1.6
6.6
Total Phosphorus (mg/1 P)
1.2
0.011
0.13
0.54
T-Chlorine Residual (mg/1 CI)
.4-1.0
0.004-.009
0.04-0.11
0.18-0.45
fecal Coliforms (MPN/100 ml)
<200
<1.8
< 22
< 90
B0D5 (mg/1)
21
.19
2.3
9.4
	RIVER FLOW	
Year 2002 Effluent x flow	Q7-10 Q7-10 di1. zone
(66 MGD)	7570 cfs	560 cfs 84 cfs
Dilution Ratio
__
1/7.5
1/6.5
1/1.8
Total Nitrogen (mg/1 N)
30
0.40
4.6
17
Ammonia-Nitrogen (mg/1 N)
14.6
0.19
2.2
8.1
Total Phosphorus (mg/1 P)
1.2
0.016
0.18
0.67
T-Chlorine Residual (mg/1 CI)
.4-1.0
.005".013
.06-.15
.22-.56
Fecal Coliforms (MPN/100 ml)
<200
< 2.7
< 31
< 111
B0D5 (mg/1)
21
.28
3.2
12
* CWMP Alternate A. Regional Facility discharging upstream from Riverside State Park.
The table takes into account both the added increase of Alternate A
plus the existing discharge (31.5 MGD) to give an appraisal	of the
total increase in concentrations that would occur comparing	a point
upstream and downstream of the Proposed Regional WWTF. The	ultimate
Phase I and Phase II WWTF design flows are used rather than	the actual
flows predicted for 1992 and 2002. The design flow amounts	would be
achieved slightly later than the given years.
130
-------
TABLE C Calculated Concentrations of Selected Constituents in the Spokane River
(Riverside State Park) at Mean Flow after addition of effluent from the CWMP
regional WWTF Alt. A (Calculated by Michael A. Kennedy Consulting Engineers)
1) Using river water quality averaged over January 1974 to December 1977:
Present** Year 1992 Year 2002
Total Nitrogen (mg/1 N)
Ammonia-Nitrogen (mg/1 N)
Total Phosphorus (mg/1 P)
Total Chlorine Residual (mg/1
Fecal Coliforms (MPN/100 ml)
CI)
.873*
.263
.347*
3.0
.95*
.30*
.35*
,001-.0025*
3.5
1.1*
.35*
.35*
.0025*-.0062*
4.2
2) Using river water quality averaged over January 1978 to September 1979:
Present** Year 1992 Year 2202
Total Nitrogen (mg/1 N)
Ammonia-Nitrogen (mg/1 N)
Total Phosphorus (mg/1 P)
Total Chlorine Residual (mg/1 CI)
Fecal Coliforms (MPN/100 ml)
,832*
.098
.108*
105
.91*
.13
.11*
.001-.0025*
106
1.0*
.19
.12*
.0025*-.0062*
106
* Concentrations in excess of recommended maximum levels:
Total-N	(.3 to .5 mg/1) for prevention of algal blooms
Ammonia-N	(.29 mg/1 as N) This concentration has an equilibrium un-ionized
ammonia concentration of .02 mg/1 at 19°C and pH 8.3
Total-P	(.05 mg/1 as P) recommended maximum for rivers flowing into
reservoirs
Tot. CI. Res. (.002 mg/1) to avoid toxicity to fish
Fecal Coliforms (the median should be less than 100 MPN/100 ml; no more than
101 of samples should be above 200/100 ml)
** Data taken from the CWMP-EIS
131
-------
TABLE D Specific Areas of Water Quality Assessment Covered in LLSD and CWMP Documents
LLSD Fac. Plan Addend.	CWMP-EIS
CO	*
CO TJ CO	"I
-a u	-a	:
S- 03 £-	i
03 "O rO	"<
-o cr	i
c: 03 c	i
 rO	4
4-> CO	4->	t
CO	CO
S-	!
>> CD >>	«
4-> +->	4->	^
•r— 03	-r-	<
^-3	1—	I
fO	03
=3 en rs	I

5


S-

cr
c




S-

cr

0


0


•r—

0


0









J*

1—




i-

Ll_


4->
cr

Ll.

a>
0

a?
4->

S-

cr
,—


r^j

•r—



>

1^1

•r—

5
•r—


"O
I—
x:
JC
5
•f—


-a
\—
_C
O


cr
(U

4-J
4->
O


cr
a>

4->
r—-


0
~o
«—
• r—
• r—
r—


0
XJ
r—
•r—
LU
cr

• r—
s-
03
2
S
Li_
cr

• r—
S-
03


03

4->
0
O



03

4->
0
(J

S-

0
0
aj


r—
a>
4-5
0
>


«r~
en
•r—
CO
CO
>


•r—
a:
•r—
CO
«r—
>>

Q

s-
• r—
•r—
•r—
>.

Q

S-
• r—
cd



4-> O
S-
S-
cc



4->
0
s-

_c
O
O
CO

03
03

sz
0
0
to

03
cr
4->
r—H
1—<
d)
+->
CL
CL
c.

¦ 1
rH

CL
03
C=
1
1

00
E
E
03
cr
1
I

CO
E
OJ
O


0
O
0
O
cu
0
r^
r-*.
O
0
O
5:
ZeL
cr
o-

s:
0
O
s
2:
cr
cr
—J
2:
0
Type of Assessment
Effluent Dilution
X
X
X
X
X


Total Solids
X
X
X


Total Suspended Solids
X
X
X
X


Total Dissolved Solids
X
1
X
X
X


Dissolved Oxygen Sag Analysis
X
X
X
X
X


Fecal Col iforms
X
X
X
X
x

X X
Virus Contamination
X
X
X


Algal Nutrients (T-N, T-P)
X
X
X
X
X

XD
Chlorine Residual
i
X
X
X
X
X

X
0
0
X
Un-ionized Amnionia
X
X
X
X

Xb X
Non-toxic cations
X
X
X


Toxic and non-toxic anions
X
X
X
X
X


Heavy Metals
X
X
X
X
X

X
cr
X
Toxic Organic Compounds
X
X
X
X
X


Combined Effect of Idaho Discharges on
Algal Nutrients
X


a)	Information contained in "Errata"
b)	Information is given in the EIS document, but we feel it is incomplete or inadequate
132
-------
Response to Comments from the Liberty Lake Sewer District
1.	These general concerns are a summary of specific comments
contained in the rest of the Liberty Lake Sewer District
letter. The general concerns are addressed in response
to the specific comments.
2.	See Tables 2-1 and 2-2 and accompanying discussion in
the revised water quality impact analysis, Chapter 2.
3.	Water quality impacts are assessed at three different
flow regimes in the revised water quality impact analysis,
Chapter 2 (median flow of the critical summer month, Q7-10
flow, and 15 percent of the Q7-10 flow which represents the
dilution zone). EPA feels the use of the lowest-ever-recorded
flow to assess water quality is too conservative and is not
indicative of potential adverse impacts.
In comparison to fish, very little data exist on the
acute and chronic toxicity values for benthic invertebrates.
The data do suggest, however, that these organisms can
tolerate higher concentrations of heavy metals and toxic
compounds than fish. Thus, the EPA maximum and 24-hour average
values should protect benthic invertebrates as well as fish.
Consequently, it is felt that a separate assessment of impacts
to invertebrates is unnecessary.
4.	See the revised water quality impact analysis,
Chapter 2.
5.	Comments noted.
6.	Alternative cost breakdowns provided in the Draft EIS
were as detailed as base data from the project engineers
allowed. Several new project suboptions, including a land
application alternative in the West Plains area, were
recently developed by the project engineers; they are
briefly analyzed in Chapter 1.
7.	The scheduling of facilities development presented in
the CWMP is probably optimistic, but it represents the county's
desired time frame. The county should proceed toward the
earliest possible elimination of on-site waste disposal over
the Spokane Valley Aquifer.
During the CWMP's design review phase, DOE must ensure
that the equalization basins are sized properly and constructed
on a schedule that will avoid overloading the. Spokane STP
or increasing CSOs. County flows into the Spokane city inter-
ceptor system cannot be allowed to increase CSOs or primary-
treated stormwater discharge.
133
-------
8.	This addition error has been corrected in both the CWMP
and this EIS. The revised number is included in Table 2-20.
9.	Comment noted.
10.	The updated EPA water quality criteria for protection
of freshwater biota were printed in the Federal Register,
Vol. 45, No. 231, pages 79318-79323, on November 28, 1981
{see Table 2-2 of this report).
11.	This discrepancy has been corrected; please refer to
Table 2-4 and the revised phosphorus discussions contained
in the water quality impact analysis of Chapter 2.
12.	Expected concentrations of total phosphorus due to each
alternative are presented in Tables 2-7, 2-8, and 2-10 through
2-13 in the revised water quality impact analysis, Chapter 2.
Projected river concentrations of ortho phosphorus are not
included, as credible data on effluent concentrations could
not be obtained.
13.	See clarification in the section entitled Nitrogen
in the revised water quality impact analysis, Chapter 2.
14.	See Table 2-6 in the revised water quality impact ana lysis,
Chapter 2.
15.	EPA feels adequate data necessary to calculate these
parameters do not exist. Refer to the discussion in the
water quality section of Chapter 2 entitled Dissolved Oxygen
Decreases Due to the No-Action Alternative.
More studies are necessary to adequately describe the
individual sources and amounts of toxic compounds and pollu-
tants in the Spokane River. The Waste Load Allocation Study
has only begun the process of identification and quantifica-
tion .
16.	See mitigation measures in the revised water quality
impact analysis, Chapter 2.
17.	The missing citation is as follows: Hail, Warren; Spokane
Audubon Society, telephone conversation.
18.	The water use figures listed as "million gallons per
day", should have been listed as millions of gallons per
year, resulting in the 10 cfs and 27 cfs averages.
19.	Comment noted. EPA was not aware of this water right.
20.	Comment noted.
134
-------
21.	The focus of the entire EIS is on the environmental
changes created by the CWMP above and beyond existing
condi tions. This is why the increment of flow beyond
present Spokane STP discharges is considered.
22.	See Table 2-2 and accompanying discussion in the revised
water quality impact analysis, Chapter 2.
23.	Water contact recreation is a popular use of the Spokane
River in the stretch below the Liberty Lake waste discharge.
On the other hand, contact recreation below the Spokane STP
is discouraged because of treacherous water conditions.
24.	Correction noted.
25.	See the revised water quality impact analysis in Chapter 2.
26.	The statement on page 65 was made in the context of
water-oriented recreation. EPA does not feel the importance
of Riverside State Park has been underrated.
27.	No attempt has been made to accentuate the impacts of
the Liberty Lake discharge or to downplay the impacts of
the Felts Field discharge.
28.	The similarity of impacts refers only to the 7.08 MGD
increase in flows from the Spokane STP.
29.	See Tables 2-7 through 2-19 and accompanying discussion of
the revised water quality impact analysis. EPA feels that
a proper water quality analysis should only evaluate those
pollutant parameters that could increase to unacceptable
levels due to the proposed alternatives. A "laundry list"
of water quality parameters which have no relevance to the
proposed project is unnecessary.
30.	See Tables 2-7 and 2-19 and accompanying discussion
in the revised water quality impact analysis, Chapter 2.
31.	Increased egg and fry mortality does eventually result
in decreased adult fish populations. The intent of focusing
on a particular life history stage is to show that pollutants
will produce differential intraspecific imnacts.
32.	The statement concerning avoidance of ammonia by fish
has been omitted in the revised water quality impact analysis,
Chapter 2.
33.	This increase is duly noted.
34.	See the discussion in the section entitled Dissolved
Oxygen Decreases Due to the No-Action Alternative, in the
water quality impact analysis of Chapter 2.
135
-------
35.	Refer to response number 3 on a preceding page.
36.	A revised water quality impact analysis of no-
action and Alternative A are presented in Chapter 2.
37.	Refer to Tables 2-6, 2-7, 2-8, 2-10, 2-11, 2-12,
and 2-13, and the accompanying discussion in the
revised water quality impact analysis, Chapter 2.
38.	Alternatives C, D, and E have been dropped from further
consideration by Spokane County.
39.	EPA agrees that wet process plating should be added
to the list.
40.	The EIS did not attempt to quantify the groundwater
quality implications of Spokane area growth and nonpoint
pollutant sources because these subjects are addressed in
the county's 208 program. Further work at impact quantifi-
cation should occur through the 208 program as specific pro-
jects are proposed over the aquifer.
41.	Compilation of interim disposal facilities was an assigned
task of the CWMP. This effort has not been repeated by EPA
in preparing the EIS. The CWMP list has been reviewed by
both Spokane County and DOE.
42.	Table 2-11 in the EIS lists only the industrial flows
expected to be added to the county waste flows going to the
Spokane STP. It does not include all existing industrial
flows in the proposed service area. Many of the industries
are not expected to hookup to the county's interceptor system.
4 3. City staff indicates that the suits regarding the Spokane
Northwest landfill have been settled in favor of the city
(Robison pers. comm.). The legal actions challenged expan-
sion of the landfill. The city is now under contract to
provide its liquid sludge to a commercial venture that will
compost the material and produce a soil amendment. This
composting will occur off of the aquifer in the West Plains
area. This will reduce the chances of contaminating the
aquifer with sludge leachate.
44. The recommendation for discharge of potable quality
effluent above recharge areas is contained on pages 46 and
4 7 of the April 1979 edition of the Spokane Aquifer Water
Quality Management Plan. This recommendation has subsequently
been deleted, however, on an errata sheet.
4 5. Comments noted.
46. Alternatives C and D have been dropped from further
consideration by Spokane County, so further comparison is
not necessary.
136
-------
47. Comment noted.
48.	Comment noted. Use of the Spokane confluence treatment
site is no longer being considered.
49.	Occasional odor problems are experienced in the vicinity
of the Spokane STP. These problems, however, are not expected
to hinder the implementation of the CWMP.
50.	The relationship of the proposed wastewater facilities
to future land use designations is discussed on page 116
and listed in Table 2-17 of the Draft EIS.
51.	This contrast is duly noted. Table 2-22 presents a
revised estimate of CWMP-related user costs.
52.	The correction of "LID" is noted. Costs for running
a connector from existing homes to a new collection system
in the street is expected to range from $300-$l,300 per
dwelling (Maxwell pers. comm.). Persons constructing new
homes with on-site disposal facilities (septic tanks and
drain field) should expect to pay a $1,500-$2,000 installa-
tion fee and a $100 pump-out fee every 3-5 years.
53.	The costs for alum have been considered, but the alum
poundage was not reported in the CWMP.
54.	Phosphorus removal is planned to continue as at present.
This includes use of alum. Paragraph 2 should also mention
lower alum demands.
55.	Spokane County is the land use planning body with responsi-
bility in this area. The county should control population
densities by following the framework presented in its Com-
prehensive Land Use Plan.
56.	EPA agrees that these areas should be added to the list
of wetlands in the study area.
57.	Comment noted.
58.	This table lists only those impacts that are generally
the same for the six action alternatives. Downstream water
quality and beneficial use impacts are included for each
alternative on Tables 2-41 to 2-46 because they vary with
each alternative.
59.	"Spokane River Fishery" impacts are updated in the water
quality impact analysis of Chapter 2. The possible increase
in odor problems is noted. The ULID and hookup charges are
a common impact; therefore, they were listed only in Table 2-39.
The comment about pumping during low electrical energy demand
is noted.
137
-------
60. Alum use is intended according to Economic and Engineering
Services, Inc., but usage figures are not included in the CWMP.
138
-------
;U I Y ur imhvAINt. WA5MIINU I UN
DEPARTMENT OF PUBLIC WORKS & UTILITIES
'AHk,
\ .-V
•kvk: *»*~~
ALL-AMERICA OTY
'I'll
GLEN A. YAKE. P £
Manager • Engineering
JOHN A. SWANSON
Director o( Public Utilities
May 20, 1981
Kathryn Davidson
Environmental Evaluation Branch (M/S 443)
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Re: Public Hearing May 14, 1981 - DEIS Comprehensive Wastewater
Management Plan, Spokane County
Attached is a copy of the City of Spokane's testimony presented at
the referenced public hearing.
Very truly yours,
^GlenA. Xake, P.E.
Manager-Engineering
Enclosure
GAY:ajg
fe(gfs7]
,VWV 22
CflUBmHCHAmi"3"
139
-------
City of Spokane
Testimony at EPA Public Hearing
Comprehensive Wastewater Management Plan
for Spokane County
Thursday, May 14, 1981 - 7:30PM
Spokane County Health District Auditorium
Thank you for the opportunity to present the City of Spokane's views
concerning the subject of Wastewater Management in the greater Spokane
Metropolitan Area. We will limit our presentation to broad conceptual
ideas which have been embodied in the County's "201" Study.
In the late 1960s the City was advised that its upgraded primary
treatment plant was inadequate and increased treatment to secondary
level was needed. The final order required not only secondary level
but 852 P removal. The City proceeded with state and federal finan-
cial assistance and built its present advanced waste treatment plant.
Additionally we were told we now had a "regional" plant which would
be capable of serving areas outside the corporate boundaries. The
City then proceeded to invest $50,000,000 of local, state, and
federal funds to produce this mandated "Regional Advanced Wastewater
Treatment Plant."
Meanwhile the County was faced with a recurring problem in the
metorpolitan area. The County prepared a plan to attack the problem
in the metro area north of the City. The plan contemplated a County
owned collection system with treatment at a site along Rutter Parkway.
However, two actions shelved this work.
First was the previous declaration that the City's Advanced Waste-
water Treatment Plant was a regional facility. This, the County
was told, meant no federal money could be spent to build another
plant in the area. Second, during the preparation of the County
plan EPA had declared the Spokane Vailey-Rathdrutn Prairie Aquifer
a Sole Source Aquifer. Since the boundary extended north to the
Little Spokane River the'proposed land treatment along Rutter
Parkway was not acceptable.
140
-------
Page 2
Testimony-Wastewater Mgt Plan
May 14, 1981
These actions by the Department of Ecology and Environmental Pro-
tection Agency encouraged the City and County to enter into an
agreement and conduct the study under discussion here. As part of
this work the City and County entered into an interlocal agreement
for the City to provide sewer service to the County under mutually
satisfactory conditions.
All of these past actions have been at the prompting of DOE and
EPA in a mutual effort to protect the surface and ground waters
from contamination. The City has participated in the "201" Study
with the County and concurs in the recommendations of the report.
A disturbing action, however, has come about in the past two months
that has great potential for eliminating the benefits to be derived
from the City/County Interlocal Agreement. This is the publication
by the Department of Ecology of its Spokane River Wasteload Alloca-
tion Study.
A channel view or careless interpretation of this study could lead
one to believe that the City will have to place a moratorium on new
sewer connections to its sewage system. If this interpretation would
prevail there is no way for the County to connect to the existing
City system.
The only apparent other solution is either a multi-mil 1 ion dollar
addition to the treatment plant to increase phosphorus removal
efficiency above 85% and/or an even more expensive construction of
a land disposal system. Both of these alternatives being beyond
financial capabilities.
The City urges that the EPA and DOE focus attention on the Spokane
Valley-Rathdrum Prairie Aquifer. The impression one gets from read-
ing the River Allocation Survey is that the Department of Ecology
has spent considerable time and effort in evaluating the Spokane
River quality to the exclusion of the Aquifer. The City is gravely
141
-------
Page 3
Testimony-Wastewater Mgt Plan
May 14, 1981
concerned that the River Allocation Study not only places the protec-
tion of the Aquifer in jeopardy but also threatens the City/County
cooperative spirit and the recommendations of the "201" Study being
considered here.
| The City recommends, therefore, that the DOE and EPA approve the
Comprehensive Wastewater Management Plan as submitted and place
the design and construction of the facilities outlined high on the
state and federal priority lists. This will allow the area jointly
to rapidly proceed on a development plan toward protection of both
the Spokane River and the Spokane Aquifer. If approval is not granted
the opportunities for meaningful! progress will be diminished. Years
will pass before the citizens of this community will be presented with
an opportunity to support or reject a program as well conceived,
described, reasonable and attainable as the one before them now.
Thank you.
Manager-Engineering
142
-------
Response to Comments from the City of Spokane
1. Refer to Chapter. 3 of this report for EPA' s recommended
action on the proposed project.
143
-------
CITY OF SPOKANE, WASHINGTON
SrOK A
AIL-AMERICA CITY
CITY PLAN COMMISSION
309 Cay Hall
JEAN BHSCHEL. President
VAUGHN P. CALL, A,LP.
Manager — Planning
E. T. CLEGG, A,I.P.
Planning Director
^ *PR 7 1931
April 2, 1981
Eun.- •

i
involve increased discharge
Since the Washington State
Ms. Kathryn M. Davidson M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Ms. Davidson:
Thank you for the opportunity to comment on the Draft Environmental Impact
Statement for the Spokane County Comprehensive Wastewater Management Plan. Of the
alternatives presented in the DEIS, I feel that Alternative A produces the greatest
beneficial impact to the aquifer for the least cost. I feel this spirit of balance
and compromise is essential, and should be the basis of continued work toward a
final solution.
However, all alternatives, except Alternative E.
of treatment plant effluent into the Spokane River.
Department of Ecology is currently studying the phosphorous loading problem in the
River with the intent of establishing waste load allocation limits, any alternative
prescribing River discharge of effluent should be re-evaluated. The analysis of
additional alternatives involving land application of Spokane Treatment Plant,
effluent may be appropriate before the final environmental impact statement is
published.
If additional alternatives are to be considered, I would suggest they include
land application sites beyond the aquifer sensitive area of the Spokane Valley-
Rathdrum Prairie Aquifer. I feel it is appropriate to compare the effects of
land application beyond the aquifer sensitive area to the Rutter Parkway area.
It may also be appropriate to compare the cost and need for seasonal land applica-
tion as opposed to year-round application.
Again, thank you for the opportunity to comment.
Sincerely,
Marion B. Hess
Acting Planning Director
MBH:CLD:skt
144
-------
Response to Comments from the Spokane City Planning Department
1.	A re-evaluation of water quality impacts is presented in
Chapter 2.
2.	Additional land disposal alternative have been considered
by the CWMP engineers. Refer to Chapter 1 for a brief dis-
cussion of these Alternative A suboptions.
145
-------
IPOKANE
jGk"
FFa
AIR POLLUTION CONTROL AUTHORITY
April 2, 1981
Kathryn M. Davidson, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
DjicCli., ns3f]P..vn=?
6 2981
ENWi<0„»ij*7 *j-&MJUATlON
Dear Ms. Davidson:
After reviewing the draft Environmental Impact Statement for the Spokane
County Comprehensive Wastewater Management Plan, we have on primary
concern. That concern is that all possible measures to abate odor be
taken.
The Storage/Equalization Basins have a potential of causing great odor
problems. The fluctuating wastewater levels would seem to make this type
of facility a greater potential problem than a normal sewage lagoon. We
request that odor control be a primary concern in the design of these basins
and that our agency be consulted before any final design is accepted. In
locating these facilities, the odor problem should also be a primary concern.
It appears that the old Acme Gravel Pit at Broadway and Carnahan was not
considered for a storage basin sight. Possibly, because it does touch the
aquifer. However, we request that you consider this sight for two reasons.
First, it is in a more industrialized area than the other sites and second,
it is my understanding that the city already owns this land.
J IThe same design and siting criteria, that of abating odors, should be applied
I to the treatment plants.
The impact due to population growth from this type of project is nearly im-
possible to predict. However, it appears that growth will follow the sewering
of any area. That being the situation, it may be possible to direct growth
to the north by sewering the north area first. Growth to the north may be
ADDRESS REPLY TO: SPOKANE COUNTY AIR POLLUTION CONTROL AUTHORITY
146
-------
Kathryn M. Davidson, M/S 443
Environmental Protection Agency
Seattle, Washington
April 2, 1981
Page 2
more environmentally sound since it takes population away from the
stagnate air basin in the valley and may concentrate urban runoff in
a less sensitive area to the north. Thus, you should consider sewering
the north region first.
Thank you for allowing us to review this draft Environmental Impact
Statement.
Sincerely,
SPOKANE COUNTY AIR POLLUTION
CONTROL AUTHORITY
William T. Mu,^
Air Quality Engineer
147
-------
Response to Comments from the Spokane County Air Pollution
Control Authority
1.	EPA concurs that odor control should be a major concern
in equalization basin design. DOE should consult with the
Air Pollution Control Authority prior to accepting the equaliza-
tion basin design specifications from the county.
2.	The gravel pit at Broadway and Carnahan was considered,
but because it penetrates into the aquifer, it was dropped
from consideration (Maxwell pers. comm.). The chances of
aquifer contamination were felt to be too great.
3.	Comment noted. No additional treatment plants are
included in the county's preferred alternative.
4.	The staging of interceptor construction will ultimately
be agreed to by the county and DOE. The county must establish
its priorities after considering a variety of factors. The
CWMP recommends simultaneous interception of North Spokane
and the western portion of Spokane Valley. While sewering
of North Spokane first may help to relieve an air quality
problem, sewering of the Spokane Valley would reduce the
level of domestic wastewater contaminants affecting Spokane's
drinking water supply. Each of these factors should be con-
sidered prior to initiating interceptor construction.
148
-------
PLANNING DEPARTMENT
BHOAOWAY CENTRE BUILDING
PHONE 456-2205
SPOKANE, WASHINGTON 99260
5PQKAt<£ COU«Tt COUHT HOUSC
May 7, 1981
Ms. Kathryn M. Davidson, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Davidson:
Thank you for the opportunity to comment upon the Draft Environmental Im-
pact Statement for the Spokane County Comprehensive Wastewater Management
Plan. Although Staff has presented comments on the Draft in a letter to
Ms. Elizabeth Corbyn dated February 19, 1981, all Staff comments upon the
Draft E.I.S. document are hereby formally submitted as requested by the
cover letter of the Draft E.I.S. Because a draft County Comprehensive
Plan document was used to develop the Draft E.I.S. document, the major
mis-statements are herein corrected since the Generalized Comprehensive
Plan has been adopted. Generally, all references within the E.I.S. to a
"proposed County Comprehensive Plan," or similar, should be changed to
"adopted Generalized Comprehensive Plan." Other Staff comments are as
follows:
1) Page 13 - In briefly describing the General Sewer Service
Area (GSSA) and the Priority Sewer Service Area (PSSA),
the phrases "which will probably be sewered . . . within
a particular period" leaves the reader with the impress-
ion that sewering will occur. This may or may not be
correct depending upon future development expansion and
activities and availability of funding. If development
does not occur to the extent anticipated, then areas
within the Priority Sewer Service Area (PSSA) and areas
within the General Sewer Service Area (GSSA) may not be
sewered. For this reason, Staff suggests the final two
sentences under the Section "The Study Area" on Page 13
be written to read as follows:
"One is the General Sewer Service Area (GSSA), which
includes areas which may receive interceptor sewer
service by the year 2002. The Priority Sewer Service
mmt-
MAY 11 lisai
ENVIRONMENTAL BIALUr
BRANCH
149
-------
Ms. Kathryn M. Davidson
-2-
May 7, 1981
1) Contd.
Area (PSSA) falls within the General Sewer Service
Area (GSSA) and represents the area which is	pro-
posed for interceptor sewer service in Phase	I of
the Comprehensive Wastewater Management Plan	(CWMP)
as sewering becomes necessary and funding is	avail-
able." '
2} Pages 86-88 - A number of federal, state, and local
regulatory controls which exist to protect the Spokane
Valley-Rathdrum Prairie Aquifer are mentioned on these
pages. But the adopted"Generalized Comprehensive Plan,"
particularly, Section 10.0.0 of the Plan is not men-
tioned. Guidelines outlined in Section 10.0.0 discourage
further development activities particularly within the
Aquifer Sensitive Area (ASA) without appropriate waste-
water management and land use control practices. Com-
bined with the adopted ordinances, many water polluting
activities which have developed over the Aquifer in the
past can be partially prevented or their impacts miti-
gated.
3) Page 91 - It is incorrectly indicated within the second
paragraph of this page that there are no regulations which
currently exist restricting residential development and
restricting use of septic tanks over the Aquifer. How-
ever, the adopted"Generalized Comprehensive Plan" coupled
with existing and future ordinances and other regulations
could be used to mitigate>and even prevent under some
conditions, continued septic tank use over the Aquifer.
This should be correctly stated in the Environmental Im-
pact Statement.
4} Page 116 - Major problems with interpretation of the
adopted "Generalized Comprehensive Plan" begin at this
point in the Environmental Impact Statement. As stated
in the second paragraph under the section of the docu-
ment entitled "Planned Land Use Designations for the
Proposed Sites," treatment facilities would be considered
incompatible with the "Rural" Category. This is not
necessarily true depending upon the environment where the
treatment facilities are being proposed and depending upon
the design of the treatment facilities themselves. As
stated in the adopted Plan text on Page 1 of Section 4.0.0,
" occasionally, small scale commercial and industrial uses
will be found to serve the local needs of the surrounding
populations ..." Within the same Section, Decision Guide-
line 4.5.1 states that "Buffering and/or landscaping will be
used to mitigate the difference between proposed development
150
-------
Kathryn M. Davidson
-3-
May 7, 1981
4)	Contd.
and existing uses;" which suggests that problems will be miti-
gated before facilities are established. Section 10.0.0 deal-
ing with Water Quality and Section 22.0.0 of the adopted
"Generalized Comprehensive Plan" regarding Utilities also en-
courage treatment of water regardless of the Land Use Category.
Depending upon a facility's location, Mitigation Measures des-
cribed on Page 119 and Table 2-19 on Page 121 are means which
can be used to maintain compatibility between a P%ural residen-
tial or agricultural environment and proposed treatment facili-
ties.
5)	Page 138 - The Draft Environmental Impact Statement neglects
discussion of the 1968 Comprehensive Plan formerly adopted and
in use prior to the recent adoption of the "Generalized Compre-
hensive PI an." It is necessary to discuss this 1 968 Plan since
it is much more generalized than the adopted 1980 "Generalized
Comprehensive Plan." In fact, it affords no specific protection
to either groundwater or surface water. It is suggested by
the Environmental Statement document that the adopted "General -
ized Comprehensive Plan" is not concise in its policies. While
problems exist with new plans and their detail, the 1968 Plan
contains only one residential category and provides fewer growth
management policies than the adopted 1980 "Generalized Comprehen-
sive Plan." The reader is not left with this impression after
reading the Land Use "Conclusion" on Page 142.
The Land Use Map (as shown on Page 139 of the E.I.S.) has been
changed. Furthermore, the Land Use Map itself does not function
the same way as a zoning map or other ordinance maps' function.
The Land Use Map shows areas where particular category pol icies
(Sections 1-7 of the Plan) apply. Additionally, while the
adopted Plan Text provides four (4) maps relating to policies
presented in the adopted 1980"Genera1ized Comprehensive Plan",
the Planning Department has numerous public studies and informa-
tional maps which are adopted by reference within the County
Commissioners' Resolutions of PI an Adoption. Such information
can be useful when determining which "Generalized Comprehensive
Plan" policies are applicable to a situation. Therefore, although
not all maps are provided within the Text, maps are abundant and
available to the public through the Planning Department. In con-
clusion, because there are a number of adopted policies and in-
formation is abundant, reference within the E.I.S. to the "land
use map" as "the Plan" is inacurrate. The adopted "Generalized
Comprehensive Plan Map and Text" and all other references and
adopted plans and maps are an inherent part of the decision-
making process and any one element will not be isolated and used
by itself.
-------
Kathryn M. Davidson
-4-
May 7, 19B1
6)	One is left with the impression after reading Page 138 of the Draft
E.I.S. that the Fringe Study Section of the adopted "Generalized
Comprehensive Plan" (now called Section 30.0.0) is the area of the
Plan which pertains most to the Aquifer, the area in question. How-
ever, Section 10.0.0 on Water Quality and Section 22.0.0 on Utilities
contain policies significantly impacting the growth, its timing
and its location in the Valley and in areas north of the City of
Spokane. In the conclusion of the Draft E.I.S. it is indicated
that '203' recommendations are not utilized in the Plan, when in
fact, Section 10.0.0 of the adopted "Generalized Comprehensive Plan"
ARE the substantive '208' recommendations assigned to Spokane County.
There are many policies in effect now which will have a large impact
upon development in the Valley and in areas north of the City of
Spokane.
7)	The Draft E.I.S. for the Comprehensive Wastewater Management Plan
(CWMP) briefly discusses the E.I.S. completed under the State
Environmental Policy Act (SEPA) for the now adopted "Generalized
Comprehensive Plan." While the SEPA document does indicate that the
Plan may set a formal policy for land use sprawl, the SEPA document
is also careful to point out that sprawl costs could be greater
without a Plan than they are with a Plan (P. 201, SEPA document).
Implicit and inherent in the discussion is the principal that harmful
sprawl may indeed occur, but is less likely to occur if various growth
management tendencies associated with utility availability are
implemented. Therefore, the Draft E.I.S. of the Comprehensive
Wastewater Management Plan (CWMP) is incorrect by leaving the
impression that sprawl would be greater under the adopted "Generalized
Comprehensive Plan" than it is currently without the Plan.
8)	The Draft E.I.S. document makes errors in its discussion on popu-
lation projections and estimates. First, the discussion at the top
of Page 141 is a good illustration why only documentable estimates
or projections should be used in a report of this importance. It is
stated in the Draft E.I.S. that a low population projection for
the County represents an increase of around 91,000 persons and
that a high population projection represents an increase of 133,000
people between 1970 and 2000. When contacted by phone, by '201'
E.I.S. Consultants, the Planning Staff hereby reported projection
figures provided by the Bonneville Power Administration and by the
Washington State Office of Financial Management. These figures are:
Total County By
Year 2000
Population
Increase
Bonneville Power
408,000
120,513
Washington State
376,661
89,174
152
-------
Ms. Kathryn M. Davidson
-5-
May 7, 1981
£ 18) Contd.
Secondly, it is incorrectly assumed on Page 141 of the Draft
E.I.S, that the adopted "Generalized Comprehensive Plan" is
based upon population projections rather than upon population
accommodation—there is a serious difference here. Popula-
tion projections were presented to the Citizens Coordinating
Committee, as projected by the State and Bonneville Power, so
that the Committee could compare these projections with the
populations their proposal would accommodate. Again, the Plan-
ning Department has made no official projections, but have only
provided available projections. Therefore, the second para-
graph on Page 141 should begin by explaining how the Planning
Department determined population numbers that could be accom-
modated by the Plan, rather than explaining a growth projection
accompanying, justifying, or substantiating the adopted "Gen-
eral ized Comprehensive Plan"— a projection which did not and
does not exist. This problem exists again on Page 149 and Page
152 of the Draft E.I.S. Also, in the first paragraph of Page
149, .it should be stated that "The Comprehensive Plan is able
to accommodate further industrialization—" rather than "anti-
cipates" further industrialization.
Regarding comments on Page 152 within the first paragraph, the
"growth pattern" referenced is not "predicted", but rather is
"allowed" or "accommodated". Furthermore, the Planning Depart-
ment is not responsible for allowing or accommodating this
pattern since the Generalized Comprehensive Plan is a County-
wide document adopted by County decision-makers and imp! emented
by County Staff. Therefore, it should not be inferred that the
Plan belongs to the Planning Department.
Again, thank you for the opportunity to comment on this important document.
Most Sincerely,
Robert 'Doc' Hansen
Long Range Division
Spokane County Planning Department
RH:wj i
CC: Wally Hubbard
Director of Spokane County
County Planning Department
153
-------
Response to Comments from the Spokane County Planning
Department
1.	EPA concurs with the suggested revision to wording
on page 13 of the Draft EIS. The actual timing of inter-
ceptor construction is dependent on the availability of funds.
2.	The Spokane County "generalized comprehensive plan"
is a planning document and as such does not have the force
of law. It was the intent on pages 86-88 of the Draft EIS
to list laws and regulations that require strict adherence.
EPA agrees that the "generalized comprehensive plan" can
exert a strong influence toward aquifer protection through
strict enforcement of its water quality policy statements
contained in Section 10.0.0.
3.	Although the county has adopted policies in the
"generalized comprehensive plan" which support the pro-
tection of the aquifer, the effectiveness of these policies
is dependent on the implementation of the policies through
local ordinances and regulations. At the present time, there
are no ordinances other than standard permit requirements
which restrict development over the aquifer.
4.	Comment noted. The paragraph on page 116 should read:
"The proposed sites in the county are located in areas desig-
nated primarily as rural in the Spokane County proposed com-
prehensive land use plan; as a result, treatment facilities
could be inconsistent with the rural land use designation.
A determi nation of land use consistency would be made based
on the surrounding environment and the design of the treatment
facilities. If the treatment facilities are determined to
be inconsistent with the rural land use designation, a change
in the Spokane County land use plan would likely be necessary."
5.	Because the 1980 "generalized comprehensive plan" has
been adopted by the county, it is the plan of record and,
therefore, reference to the 196 8 comprehensive plan is not
considered relevant to this analysis. Response to the
remaining comments is presented in the section of Chapter 2
entitled Consistency Between the CWMP and the County
"Generalized Comprehensive Plan".
6.	The policies stated in Section 10 on water quality and
Section 22 on utilities are also recognized (although not
specifically referenced in this section) as pertinent to
the analysis of land use and development policies. The Draft
EIS did not intend to suggest that the 208 recommendations
had not been incorporated into the comprehensive plan but
that the precise wording of certain recommendations had been
changed. Specifically, the 208 plan recommended that the
area outside of the PSSA not be developed at a density greater
than one unit per 5 acres until expansion of the PSSA became
154
-------
necessary. As incorporated in the comprehensive plan, this
recommendation was changed to allow for development at den-
sities greater than one unit per 5 acres under certain condi-
tions .
7.	Comment noted. The paragraph in the Draft EIS should
read: "The county EIS suggests several mitigation measures
to discourage sprawl and concludes, under unavoidable adverse
impacts, that unless the proposed plan is changed or recom-
mended mitigation measures are adopted, the plan may set
a formal policy for land use sprawl. This sprawl would result
in a high consumption of land and would incur service and
facility costs considerably higher than if development was
concentrated."
8.	In the absence of an adopted county population projection
alternative projections had to be sought for the Draft EIS
analysis. As a result of conversations with the county planning
staff, the projections stated in the Draft EIS were assumed
to be correct.
Comment on growth accommodation noted. The section
on Growth Projections in the Draft EIS should read: "The
Spokane County Comprehensive Land Use Plan, which was pre-
pared by the Citizens Coordinating Committee, assumes a growth
accommodation of 155,000 persons in Spokane County from 1970-
2000. A comparison of this growth accommodation with popula-
tion projections prepared by the Bonneville Power Administra-
tion, the Washington State Office of Financial Management,
and the CWMP reveals some inconsistency.
"To determine population numbers which could be accom-
modated by the comprehensive plan, the county planning staff
assumed that 50 percent of all county vacant lands in 1970
would be developed by the year 2000 to the lowest designated
density within each land use category on the land use map
(Figure 2-7) (Hansen pers. comm.). This resulted in a popula-
tion increase of 15 5,000 persons from 197 0-2000. This compares
with alternative population increases from 1970-2000 of about
89,000 persons prepared by the State Office of Financial
Management and about 120,000 prepared by the Bonneville Power
Administration.
The CWMP projects approximately 398,000 persons in the
GSSA (including the City of Spokane) in the year 2002. If
projections for the areas outside of the GSSA but within
the county (50,000 existing population plus 11,000 projected)
are added to the CWMP projections, the total county population
projection for the year 2002 is 459,000 persons. This repre-
sents a projected increased of 171,500 from 1970-2002.
"In summary, the comprehensive land use plan assumes
a population accommodation of 15 5,000 persons from 1970-20 00;
the State Office of Financial Management projects an increase
155
-------
from 1970-2000 of approximately 89,000 persons; the Bonne-
ville Power Administration projects an increase of about
120,000 persons from 1970-2000; and the CWMP projects that
171,500 persons will be added to the county's peculation
between 1970-2000."
No reference can be found on page 14 9 or page 15 2
regarding a population projection by the county.
The first paragraph on page 149 of the Draft EIS should
read: "No estimate has been made of the commercial or indus-
trial development to be sewered by the CWMP. Table 2-11
lists the facilities planner's estimate of industrial flows
to be accommodated by the CWMP wastewater system, but the size,
location, and type of industry has not been specified. The
comprehensive land use plan is able to accommodate further
industrialization in the central portion of Spokane Valley.
With rapid residential development in the valley and North
Spokane, the commercial acreage is also likely to concentrate
in these areas. Table 2-29 lists typical runoff waste loads
from these land use types."
The second sentence in the first paragraph on page 152
of the Draft EIS should read: "The facilities planners have
delineated a 20-year wastewater service boundary (GSSA) for
the Spokane area in response to the growth pattern which
would be accommodated by the comprehensive land use plan. "
156
-------
R
SOT
TRANSPORTATION STUDY DIVISION

Phone 509-456-4325
February 14, 1981
Ms, Kathryn M. Davidson, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Davidson:
Thank you for the opportunity to review the Draft Environmental Impact
Statement on the Spokane County Comprehensive Wastewater Management Plan.
SRPC's Transportation Study staff concurs with your assessment on page
161 that the population projections used in the facility's plan will
have an impact on the existing road system in both the Spokane Valley
and in North Spokane.
On page 170 it states that preliminary data from the 1980 U.S. Census
are available only for the City of Spokane. The preliminary count of
persons in households, persons in group quarters, and number of housing
units was made available to the Spokane County Planning staff for review
last July. However, this preliminary 1980 Census data did not contain
information on the number of year-round housing units.
Table A-6, page 223. "Control Measures for Carbon Monoxide Reduction,"
is from the original Air Quality Implementation Plan report, dated
December 26, 1978. This document has been amended, dated August 25, 1980
and titled "1979-1980 Revisions to the Transportation Control Plan Element
of Spokane's Air Quality Implementation Plan." We suggest using information
per Figure 1, page 3.
Very truly yours,
Robert A, Vaugh^n, P.E.
Transportation Study Director
RAV/jf
Enc:
piEgQM
FEB 17 1981
0
ENVIRONMcNTAl EVALUATION
BJHaCH
157
-------
Response to Comments from the Spokane Regional Planning
Conference
1.	The availability of the new census data is noted.
2.	The availability of a revised carbon monoxide control
measures summary is noted. A copy of the revised summary
has been reviewed in preparation of the Final EIS.
153
-------
I
Spokane Aquifer Study
N.811 leifeison Spokane, Washington 99260
(509) 456-3600
February 18, 1981
Ms. Elizabeth Corbyn, Chief
Environmental Evaluation Branch
Environmental Protection Agency
1200 - 6th Ave.
Seattle, WA 98101
Dear Ms. Corbyn:
I have completed my preliminary review of the Draft Environmental Impact Statement
for the Spokane County Comprehensive Wastewater Management Plan. The document in
general is very well done. However, there are references to local reports that
appear to be incorrect and/or misleading.
I For example, the reader may get the impression from reading the DEIS that County
Planning has the responsibility for implementing the Spokane Aquifer Water Quality
Management Plan. In reality, the County Planning Department is only one of twenty-
six agencies that has been assigned implementation responsibilities and, from reading
pages 138 to 142 and reviewing the map on page 139, the reader gets the impression
that the Comprehensive Plan and '208' are in conflict. Reference should be made to
the Comprehensive Plan text and Chapter 10 dealing with Water Quality. An entirely
different impression could be conveyed.
My specific comments on the DEIS are too numerous to put into a letter. I have
marked up my report and would be glad to meet with you and the drafters of the DEIS
in the near future to clarify discrepencies that appear to me to be of concern.
Thank you for the opportunity to comment on the Comprehensive Wastewater Management
Plan DEIS.
208' Program Manager
RC/set
159
-------
-iRatfidrun^
NewmaivX j
Lake
Spokane Aquifer Study
N.811 Jeffersaw Spohant, Wtshimton 99260 	(509) 456-6024
May 28, 1981
Ms. Kathy Davidson, EIS Coordinator
EPA Region X
1200 - 6th Ave.
Seattle, WA 98101
Dear Ms. Davidson:
I attended the public hearing held May 14, 1981 on the Spokane County Comprehensive
Wastewater Management Plan draft EIS. For the record, I would like to address a
subject that was repeatedly raised regarding the lack of a plan for storm water
collection and treatment.
The original scope of work for the '208' Spokane Aquifer Water Quality Management
Plan dealt with "ground disposal" only. It was never intended that the Plan deal
with surface water. However, during the development of the Plan, it became evident
that aquifer contamination was occurring as a direct result of activities on or near
the land surface. This meant that we must deal with other subjects not originally
anticipated in the work plan. We asked our consultants, dealing with the Corps of
Engineers Metropolitan Region Water Resources Study recommended Sewerage Plan update,
to also look at the costs associated with a storm water collection and treatment
system. They concluded that a storm water collection and treatment system would cost
approximately as much as the proposed sanitary sewer system. Faced with the stag-
gering costs of both systems, we elected to try for a sanitary sewer system and made
the recommendation that stormwater be retained on-site and 80% disposed of through
"grassed percolation areas" to effect the filtering action of the soil and to obtain
biological nutrient uptake through the roots of grasses, thereby taking advantage of
the evapotranspiration process. While this recommendation was only aimed at new
development, we did recommend this process for major reconstruction projects as well.
This, we hoped, would meet our goal of "no further degradation" in the area of storm
water runoff. Again, I would emphasize that the '208' Study concluded that the com-
munity could not afford both a storm water collection system and a sanitary sewer
system. Therefore, we recommended the more effective sanitary sewer system.
160
-------
May 28, 1981
Page 2
Thank you for the opportunity of addressing one of the major concerns raised at the
pub!ic hearing.
Sincerely
&081 Program Manager
RC/set
161
-------
Response to Comments from the Spokane County 208 Program
1.	EPA did not intend to indicate the Spokane County Planning
Department has sole responsibility for implementing the 208
program. As indicated in your letter, a number of agencies
should play a role in implementation. EPA has requested
that one or more agencies accept overall implementation res-
ponsibility by July 31, 1981, prior to EPA final approval of
the plan. In the interim, the Board of County Commissioners
holds implementation responsibility (Dubois pers. comm.).
The discussion of pages 138-142 deals with the compatibility
of the comprehensive land use plan and the CWMP, not the
208 plan. The major inconsistency between the 208 plan and
the comprehensive land use plan appears to be in the strength
of their recommendations for limiting growth outside of the
PSSA. The 208 plan suggests a one-unit-per-5-acre limit
outside the PSSA until the PSSA is sewered. The comprehensive
land use plan allows development outside the PSSA to continue
using approved interim on-site disposal systems under certain
conditions.
2.	The additional information regarding 208 plan recom-
mendations and objectives is appreciated.
162
-------
The Glenrose Association
Route 12, Box 776
Spokane, Washington 99203
May 28, 1981
¦=- r-3 n=n rr" n -p. n rrp r
[

Toj U.S. E.P.A., Region 10	U \i
Re; Draft EI3, Spokane County '201' Wastewater Management Plan	JUM 1
Gentlemen:	ENVIRON-	.'JMIC
i*. ... •»> I
The Glenrose Association represents more than three-fourths of the homes
in the Glenrose Community. We have- "been formally organised and involved
in land use issues for nearly 10 years. We have historically advocated
well-planned growth and conservation/protection of resources, including
ground water quality.
Ve are aware of the expense and difficulty involved in distributing copies
of the DEIS, however we feel it should be more accessable to the public
(library copies were not available and costs of duplication locally would
have run over 325). We would like to suggest that, in the future, publications
of this importance be made available to individuals and community groups
through a process of notification that will afford them the opportunity to
order copies in advance of publication at cost.
V/ith regard to the DEIS, numerous areas of concern and conflict are
identified and many sound and appropriate mitigating measures are suggested.
There appear to be some gaps, however:
1)The	failure of the DEIS to mention the City of Spokane's "Boyle Report"
is puzzling. In view of the acknowledged committment to sprawl in both the
County Comprehensive Plan and the '201' plan, the suggestion of additional
growth and utility extension in the West Plains area adds signifigantly to
land and utility committments and economic considerations.
2)The	alternative of encouraging growth in other than the aquifer area v/as
suggested by some professionals in response to the County Comprehensive
Plan. It is disappointing, therefore,, to find that growth to the west,
which may be both for the immediate future and the long run, the most desirable
approach, has not been addressed.
3)The	DEIS only briefly addresses the broad economic considerations that
accompany the '201' plan. Under the proposed "sprawF plan, the ultimate
economic burden on taxpayers after lateral extensions and hook-up fees,
could be enormous. This is especially important in view of the overcommittment
to low density residential growtli^aoes not pay its way in terms of supporting
local governmental services.
4)There	i:; no mention of the life expectancy of the system. What is the degree
of seepage we could expect over time? Will means of monitering seepage, breakage,
other failures be incorporated in the system?
With respect to the Glenrose Community, the DEIS correctly points out, on
page 142, conflicts between the ~PZZA and the County's Land Use Plan. The
suggestion is made that these areas be left out of the PS.-A. The Glenrose
Community stringly concurs. Left unaltered, utility planning would dictate to
lar.u use rdannin/:.
163
-------
pace 2
The '201* Plan, as it now stands, needs to be sized down and tightened up
to be politically and economically acceptable. The numerous mitigating
measures suggested by the DEIS roust be implemented. Among the most important:
reduction of sprawl and PS3A size, consistency with the County Land Use Plan
(by changes in both '201* and the Land Use Plan, as necessary), consistency
with the stated goals of both the County Land Use Plan and '208', better
coordination between governmental entities, particularly City and County, as
well as with the state of Idaho, measures to protect prime and unique
farmland and provide for adequate open space and recreational land and other
amenities, and also, means of protecting aquifer water quality from contamin-
ation through urban storm runoff.
Sally S. Reynolds
The Glenrose Association
164
-------
Response to Comments From the Glenrose Association
1.	EPA regrets that you had difficulty in obtaining a copy
of the Draft EIS. Copies were mailed to the city and county
libraries in Spokane, Names for our mailing list were taken
from previous lists used in the Spokane area and from lists
maintained by local agencies. In addition, names were taken
at the two EIS public workshops held in Spokane so that
interested persons and groups could receive a personal copy
of the report.
2.	The Boyle Report, otherwise known as The West Plains
Area Water and Sewer Plan, was submitted to the City of
Spokane in November 1980 and has subsequently been adopted.
This plan recommends four phases of sewer and water develop-
ment for the West Plains area beginning sometime in late
1981 or in 1982. Because the city and county have approved
an interlocal agreement to include the West Plains area in
the city's sewer and water service area, the city has
responsibility for the implementation of the plan. At pre-
sent, the city has not taken action to implement the plan.
3.	Neither the CWMP nor the Draft EIS was prepared as
land use planning documents or growth control mechanisms.
The CWMP is intended to follow growth as planned by local
government entities.
4.	The overall economic commitment of the CWMP is addressed
in the Draft EIS on pages 163-172. The extent of development
envisioned in the county's comprehensive land use plan will
undoubtedly require considerable economic outlay to provide
the normal public service and utilities infrastructure.
5.	Economic and Engineering Services, Inc., indicates that
all pipelines will have a life expectancy of 50 years, as
will the equalization basins. Pumps will be expected to
last approximately 30 years (Maxwell pers. comm.).
The amount of seepage to be expected is unknown.
Monitoring wells will be installed adjacent to equalization
basins so that leakage can be detected and corrected in a
timely manner. DOE's specific monitoring requirements will
be developed during the project's design phase.
6.	Comment noted.
7.	Refer to Chapters 1 and 3 for the county's preferred
alternative and EPA's recommended action regarding that
proposal. Conditions of CWMP approval are contained in
Chapter 3.
165
-------
Wale' Quality & Treatment / Wastewater Treatment Studies Design. Operation/Industrial Wastewater .Vs'sgemenr
ESVELT ENVIRONMENTAL ENGINEERING
May 27, 1981
Kathy Davidson, EIS Coordinator
EPA Region X
1200 6th Street
Seattle, Washington
RE: Spokane County Comprehensive Waste Water Management Plan EIS
Dear Ms. Davidson:
This letter is in response to the Draft EIS issued by EPA for the Spokane
County Wastewater Management Plan. My comments are based on my association
with 208 Planning efforts for the Spokane/Rathdrum Prairie Aquifer in Spokane
County, As you know the Spokane/Rathdrum Aquifer has been designated a "sole
source" aquifer under provisions of the Safe Drinking Water Act. This aqui-
fer truly is the sole source of drinking water for the Spokane Metropolitan
area, and concern for its protection is well justified among residents of
the Spokane area.
The Cause and Effect Report prepared during the Spokane County 208 Study was
based on 1 year of data collection from numerous wells and surface water
locations as well as accumulation of existing data from other sources. The
Cause and Effect Report documented the conclusions that:
1)	Water percolates from the ground surface over the aquifer through
the overlying alluvium to the ground waters. This water carries
with it all pollutants accumulated at the ground surface and in
subsurface deposits;
2)	Aquifer water quality has degraded from its original condition and
continues to be degraded as it flows beneath the Spokane Metro-
politan area. This degradation was shown based on historical
water quality variations directly associated with various land use
over the aquifer;
.3) The predominant degradation in aquifer water quality was shown
to occur in areas of the highest density of urbanization. It
was concluded from this that urbanization has a serious effect
on water quality in the Spokane/Rathdrum Aquifer.
eAST 7905 t-iEROY AVENUE SPOKANE. WASHINGTON 992C6/PHONE i509) 926-3049
166
-------
Davidson/Esvelt
Page -2-
4) A significant quantity of pollutants resulting from urbanization
are derived from sanitary sewage disposal through onsite dis-
posal systems.
Since the 208 Water Quality Monitoring Program was completed in 1978, it
has been recommended that an on-going monitoring program be established.
This on-going program has been conducted by the Spokane County Health
District at several well sampling points during the 1980-81 year. This
water quality monitoring was conducted by Health District personnel who
transmitted the samples to the Washington Department of Social and Health
Services Laboratory in Seattle for analysis. A number of wells selected
for the monitoring by the Spokane County Health District are the same wells
monitored by the Health District with analyses run by the DSHS in 1971 and
1972. In addition, several of the wells were sampled by the 208 program.
Based on these specific comparable sampling notations, the following results
were obtained:
1)	Comparison between data from DSHS laboratory results on samples
collected by the Spokane County Health District in the year
1971	- 1972 and in 1980 - 1981 showed ten wells, all owned by
purveyors in the Spokane area, could be compared for nitrate-
nitrogen and conductivity. All of the wells are in the area
east of the Spokane city limits within the Spokane Valley
area. A summary of the comparative mean concentrations over the
year of sampling in each case, are attached in the memo from Mr.
Stan Miller of the Spokane County Engineering Department Office.
The data shows for these ten purveyor wells that the mean nitrate-
nitrogen was higher in all wells in the 1980-1981 sampling period
as compared to the 1971-1972 sampling period. Eight of the ten
samples compared with a Students t test showed the 1980-1981
data to be higher at greater than an 80% significance level. Six of
the ten showed it to be higher at the 90% significance level or
greater. Of the comparative conductivity values nine of the
ten wells showed a higher mean conductivity in 1980-1981 than in
1971-1972, with the remaining mean conductivity only 4% lower,
well within the error possible from the test. Seven of the ten
means were greater in the 1980-1981 sampling period than the 1971-
1972	sampling period at more than an 80% significance level using
the Students t test. Six of the ten were greater at more than
90% significance level.
2)	Comparison of the 1980-1981 monitoring data with the 208 data
showed that the nitrate-nitrogen in six of the eight wells was
higher in 1980-1981 than only three years earlier. Four of the
eight were greater in nitrogen concentration at more than 80%
significance level.
During the 208 sampling program one well on the south periphery of the
aquifer in the West Valley area (Edgecliff Well) was taken out of service
due to the sampling program detecting bacteriological contamination higher
than the drinking water standards. Within the past year the Millwood Hedman
well has been taken out of service and the town of Millwood is in the pro-
cess of constructing a new water supply well to replace it, which will pene-
trate the aquifer to a greater depth and hopefully avoid higher contamina-
tion levels near the aquifer surface. Each of the wells that have been
167
-------
Davidson/Esvelt
Page -3-
taken out of service and documented to be contaminated with bacterial
levels above drinking water standards are located where the aquifer
surface is only 40-60 feet below the ground surface, and each of them
apparently drew water from near the aquifer surface. However, it can be
concluded that since these two wells and possibly others in the area have
been taken out of service due to contamination of higher levels in the
aquifer that it may be only a period of time before additional wells
become contaminated if land use activities continue to evolve as they have
to date and mitigating measures are not put into place. In addition, a
well in Rathdrum, Idaho was recently closed by the Panhandle Health Dis-
trict due to nitrate levels occuring above the drinking water standard.
This well was one which was shown to contain nitrate levels higher than
surrounding areas but within the drinking water standards during an
earlier Panhandle 208 Study (1975-1976) In the interim two housing
developments have occured in the vicinity of the well. The City of
Rathdrum has had to seek out a new water supply source.
I must concur with the EIS statement on pages 80-92 that No Action will
result in a ground water quality which continues to decline and which will
eventually pose a health threat to those drinking the water. I must also
concur with the assesment that the proposed sewering effort would create
a positive change in aquifer water quality.
During the past three or four years that I have worked with the 280
Citizen's Representative Corps committee (CRC) I have observed a group
of citizens highly representative of all factions in the Spokane metro-
politan community seriously consider the effects of activities on water
quality in the Spokane Rathdrum aquifer. These citizens, after two
years of intensive self education on water quality matters and after
thorough review of the findings of the Cause and Effect Report and other
monitoring programs, set forth several policy recommendations to be fol-
lowed during the development of the Water Quality Management Plan for
the Spokane Rathdrum Prairie aquifer:
1.	They recommended that there be established a policy for no
further degradations of ground water quality in the Spokane
Rathdrum Prairie aquifer.
2.	They recommended means of control of known and potential
sources of pollution be installed at their source in order
to preserve aquifer water quality.
3.	For sanitary sewage controls they recommended;
(a)	collection of all sewage and treatment for its discharge
so pollutants cannot enter the aquifer,
(b)	development of central sewer planning,
(c)	sewering of all areas that are urbanized.
168
-------
Davidson/Esvelt
Page -4-
4. For the Spokane Valley area they recommended;
(a)	central sewer planning for sanitary sewage,
(b)	that all interim industrial, commercial, and multi-
family wastewater facilities be intercepted as soon as
possible with a central sewer system,
{c) that all new development provide sewers for connection
to the central sewer system,
(d)	that a ban on all new and increased sewage discharges
to the Spokane River upstream of the aquifer recharge
area be established, and
(e)	that proposals be initiated on an area by area basis
for sewering for existing urbanized areas which would
then be responded to by home owners in the area.
On February 19, 1981, the CRC, after reviewing recommendations in the
Comprehensive Wastewater Management Plan (CWMP) and after reviewing
the Draft Environmental Impact Statement, resolved to confirm their
conviction that drinking water quality should take the highest priority
among alternatives considered, and recommended the alternative of
sewering the aquifer sensitive area should be implemented in as timely
a manner as possible.
After conducting the 208 monitoring program, preparing the Cause and
Effect Report, reviewing subsequent data that has become available, and
being a participant in the comprehensive wastewater management planning
effort, I must concur with the recommendations of the 208 CRC committee
and strongly urge that the CWMP be approved for implementation. I recog-
nize that there may be a slight impact on receiving water quality down
stream from the City of Spokane as a result of decisions for protecting
the drinking water supply. However, I and I believe much of the Spokane
Community, feel that protection of the drinking water supply is essential
and protection of the surface water for recreation and other purposes,
although highly desirable, must take a lower priority. I believe that
water quality in the Spokane River and impoundments downriver from the City
of Spokane will not be excessively jeopardized so as to restrict its use,
but will still enjoy a much higher level of quality than was in place prior
to construction of the Spokane Advanced Wastewater Treatment Plant. Fishing
and other recreational uses, including body contact, in my opinion, would not
be jeopardized if the CWMP is certified for implementation.
169
-------
Davidson/Esvelt
Page -5-
Thank you for the opportunity to present my verbal statement at the EIS
hearing in Spokane on May 14, 1981 and to provide you with this written
follow-up for your consideration.
Sincerely yours,
Esvelt, Ph.D, P.E
LAE/vssj
170
-------
HISTORIC TRENDS IN DSHS DATA FOR 10 WELLS
s-t - y i
For approximately one year beginning in the Fall of 1971, the Spokane
County Health District collected water samples on a monthly basis from 12
wells. A wide range of chemical analyses were performed on these samples at
the Department of Social and Health Services laboratory in Seattle. Ten of
these wells were sampled by the SCHD and tested by the OSHS quarterly during
the Fall and Winter of 1980-1981. The exact details of sample collection,
preservation and shipping or chemical analysis procedures used are not avail-
able. However, known differences in analysis and in data reporting procedures
significantly reduce the number of chemical parameters which can be compared.
Specific conductance and nitrate-nitrogen were chosen for comparison since the
data is reported comparably, the test procedures produced consistent data and
replications performed on samples during the 1971-1972 period indicate good
laboratory precision.
Means for 1971-1972 and 1980-1981 data were compared using a t-statistic
calculated for unpaired observations with equal variance. The mean concentra-
tion of nitrate-nitrogen in all ten wells increased between 1971-1972 and
1980-1981. One well, CID 2, showed a slight decrease in conductivity; the
others indicated increases over the time interval. As indicated in Tables 1
and 2, increases significant at the 5% level for both nitrate-nitrogen and
conductivity occurred in the WWP-2-4, Vera 4 and East Spokane 2 wells. The
increase in conductivity observed in WWP-1-5A is also significant at the 5%
level. The wells showing s ign i f icant increases in dissolved materials were
examined in an effort to explain the increases in dissolved materials. The
Vera 4 well, in addition to several other wells, was noted as showing an his-
toric increase in conductivity in the Spokane Aquifer Cause and Effect Report.
171
-------
This and other water quality conditions observed were attributed mainly to
urban development in that report. An examination of historic housing develop-
ment revealed considerable growth in the period between 1971 and 1980 in the
vicinity of the wells showing significant increases in both nitrate and con-
ductivity. Two other wells, CIO 11A and Modern 9, are also located in areas
of housing development. Sizable (about 0.4 mg/1), though not statistically
significant, increases in nitrate-nitrogen was noted in these two wells. Only
small increases in conductivity occurred.
In general, since the wells for which comparison data is available are
scattered throughout the aquifer area east of the city limits, it can be
concluded that a measurable increase in the annual average dissolved salts
concentration has occurred in the Valley portion of the aquifer in the past 10
years. At at least three locations, the increases are statistically signifi-
cant at the 5% level. Only one well, CID 2 does not show a pronounced in-
crease in at least one of the parameters examined. This well is located in an
area known to be influenced by river flow, a factor which could account for
the difference. The fact that the three wells showing the greatest change are
located in areas subject to rapid residential growth suggests that conversion
of land from agricultural to residential use can cause measurable aquifer
degradation.
172
-------
oi 197? -7^ 208 * /9S<5 S/	NOj-W
wu/P 2-^
uj £*J)P I - 5a
/"laOeMAj I
/"ocCAiO ^
Of-XH*£0 i
B, 5«3 2
C/D //A
x/s
7 7-78
3X1
6.53
Z9 2.
o 30
z.fd
ozo
0.9b
o-n
Z.5Z
0-l'i
1.	V-f
O I 7
4 N9
0 51
1-oS
C-2H
SO -8/
*J.2b
OMH
3 03
OHO
3.31
I Z9
/./*
MS'
2.3/
6 51
ISO
o 20
4 97
t /
1.27
Oil
to*
1.1$
df
fo
0. 5fc>	12
i.te 13
n
- 0.5^	Li
0. 33
/ V* «
A
5iqn.fi<.dncc
I svte)
.O Ito
-O 25


0. |M
ao'i
•0. SO
•0.50
0,09
o.i>
173
-------
TABLt 1
I'J/1-13/2 vj. 1980- 1981 Nitrate Data





Significance

/1 -J 2
"x 80-81 x
t
5LL
Level
WWP 2-4
2./0
4.2b
2.76
12
0.01
WWP 1-5A
2.42
3.03
1.42
12
0.09
WWP 1-bB
2.61
3.13
1.14
11
0.11
Vera 4
2.03
3.3/
2.56
12
o. oz
Modern 1
1.11
1.17
0.17
13
0.M3
Modern 9
1.91
2.37
0.83
13
D.Zt
Orchard 1
1.24
1.50
1.38
13
0. to
East Spokane 2
3.64
4.97
2.36
10
0.02. ]
CID 11A
0.87
1.27
1.41
12
0.09
CID 2A
0.90
1.05
0.39
11
035



TABLE 2



DSNS
1971-1972
1980-1981
Specifc Conductance






Significance

71-72
x 80-81 x
t
d.f.
Level
WWP 2-4
334
385
2.71
12
O.OI
WWP 1-5A
311
337
1.79
13
005
WWP 1-5B
317
343
1.20
12
0./3
Vera 4
330
453
4.31
13
0.0OO<|
Modern 1
267
283
0.73
13
O.ZM
Modern 9
285
287
0.07
13
O.fl
Orchard 1
308
333
1.76
U
0.15
Eaut Spokane 2
393
490
7.20
10
0*0001
CIO 11A
240
257
1.58
12
on
CIO 2A
167
160
-0.87
11
0.86
174
-------
environmental evaluation
BRANCH
February 25, 1981
Kathryn H. Davidson M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1206 Sixth Ave.
Seattle, WA 98101
Dear Miss Davidson:
I wish to acknowledge receipt of a copy of the draft Environmental Impact
Statement (EIS) on the proposed Spokane County Wastewater Management Plan
(CWMP).
Having served as a member of the citizens advisory committee on both the
CWMP, Federal 201 Facility Plan and the Spokane Aquifer Water Quality
Management Plan, Spokane County, Washington 208 program I have the advantage
of a very close familiarity with both programs which in my opinion are
intregal in their ultimate goals of protecting the Spokane-Rathdrum Aquifer
from further inroads on the quality of the Spokane City and Counties sole
source water supply.
This EIS covers, in depth, all of the aspects proposed by the 201 CWMP
and in its detail explains the ramifications and results of the study
upon all facets of man's living in close proximity to a vital resource.
1 I cannot agree that a "no action" philosophy, see page 5, can be considered
as even a temporary solution to the promulgation of any type of action for
the protection of a God given resource. Financial means MUST be found
to insure that the proposals as outlined are not only accepted but that
action is begun forwith to implement one of the several alternatives
outlined in the EIS. Based on my association with the CWMP I endorse
Alternative A as the more logical of the proposed solutions.
By actively persuing the methodology of wastewater disposal through a
series of collection basis so as to preclude periodic overloading of the
175
-------
Kathryn M. Davidson
Page 2
City of Spokane's sewage treatment plant I am of the opinion that not
only will money economies occur but that certain projects such as the
Liberty Lake Treatment facility (page 16) now under construction could
be eliminated and the funds allocated to accomplishing an overall program
that will exceed the proposed 20 year life span anticipated for that
plant.
Since the publication of this draft EIS the subject of influence on the
quality of the Spokane River has become a matter of controversy as regards
the disposition of the wastewater through the current methods, that is
returning the refined effluent to the river. This subject was discussed
at some length during several 208 Citizens Committee meetings in view of
the interaction between the river and the Aquifer, see pages 82 and 98
and I am disappointed that the EIS fail to give this aspect more than
a cursory glance most particulary in view of the "trend to poorer quality"
as refferred to on page 84.
In conclusion I find an incongruity between the cost figure for Alternative
A as noted in the EIS, page 123 and the figures proposed by the CWMP
yet both figures are attributed to Economic and Engineering Service,
Inc. To preclude future discussions on dollar amounts, especially when
attempting to promote a financing program at the local City-County level
I feel that the planned cost estimates should be brought into some
conformity.
I endorse the EIS, accept as noted above, and strongly urge that activation
of the proposed programs be undertaken as expeditiously as is comensurate
with accepted policies and philosophies. We have just about worn this
subject out with studies, NOW is the time to most energetically activate
and pursue the programs for the ultimate benefit of all of the citizens
of the Spokane City and County areas.
E. 1922 36th
Spokane, WA 99203
176
-------
Response to Comments from M. E. Hay
1.	EPA is not promoting a "no action" approach to the Spokane
County wastewater treatment problem. Refer to Chapter 3 for
EPA's recommended action.
2.	The interaction between the Spokane River and the Spokane
Valley Aquifer has not been well defined. Drost and Seitz
(1978) and Esvelt (1978) provided the basis for interchange
discussions in the Draft EIS. Their findings were reported
at several points in the EIS. The water quality implications
of this interchange are a primary reason for CWMP rejection
of a Felts Field wastewater treatment plant and river discharge.
3.	Project costs have been revised and updated several
times in the last 6 months. Table 2-20, taken from the latest
facilities plan summary, presents the latest revision of
project costs.
177
-------
Kay 14, 1981 - Presented to EPA Hearing in Spokane by JOAN HONICAN
As one who has spent an inordinate amount of my life on aquifer problems, I don't
aooreciate recent attempts to "fast-track" the 201 Plan after years of total neglect.
Now, under the guise of "saving the aquifer" we are hearing the same people who have
consistently opposed any special protection of our underground water supply rallying
around the Phase I Interceptor System known as Alternative A in the DEIS. Have they
really gotten religion or have they found a new way to con the public so they can
continue business-as-usual and the obliteration of the entire recharge on the Wash-
ington side of the State line? Since environmental and co3t effective considerations
are uppermost in EPA's responsibilities under NEPA and as a reg. and funding agency,
you must be aware of serious problems in Spokane and the interrelationships between
the 208, 201, Comp Plan, Classification Hap and the coming Underground Injection
Control (UIC) program. The recent adoption of a Cora? land Use Plan by two lame duck
county commissioners is still embroiled in litigation and extensive documentation is
available if anyone is interested. Since the 201 admittedly follows the lead of the
Com plan and the 208 it is apparent that if they are seriously defective so is the
2015 To demonstrate the problems I have attached as Exhibit A the aquifer portion
(which I authored) of a "Citizen's Report" which went to our Board of County Commiss-
ioners. I would be happy to answer any questions and to meet with those from EPA
charged with the responsibility of developing an adequate EIS.
After reading the DEIS numerous questions and comments came to mind. I have attempted
to summarize them as followsj
1)	Due to expressly incomplete cost data and the implications of the DOE
Wasteload Allocation Study an amended and recirculated EI3 is certainly in order.
Will this be done?
2)	Without sufficient background data your mitigating measures are inadequate.
3)	When dealing with Spokane County it is imperative that the most stringent
mitigating measures must be CONDITIONED to avoid adverse environmental impacts.
4)	Page 29 of the DEIS shows a map of our gerrymandered aquifer recharge
boundaries. Three other sludge dumps are not even on the nap and do you really
believe it is just a coincidence that the two major landfills just happen to be
outside the boundary? How does this square with EPA's Sole Source recharge map?
5)	Why isn't the contribution of industry discharges (Pg. kz) known? Aren't
they all on NPDES permits?
6)	On pages 86, 8? and 88 you cite federal state and local regulations which
you state, "...act to protect the Spokane Valley Aquifer...". I could do a book on
each citation and its abuse in Spokane County. Since time doesn't allow, I am
requesting a meeting in Spokane to discuss the true state of affairs in relation to
these regulations so the author can revise the entire section to conform to reality.
When can the meeting be arranged? (See Exhibit fl)
7)	With the recent adoption of a Classification Map encouraging the development
of Spokane County, predominantly over the aquifer, we cannot discuss dealing with only
one as^ct of our increasingly serious pollution problem. How can we talk of sicking
up only sewage and ignoring urban runoff which was determined almost equally signifi-
cant at today's density by the 208? With the new classification expressly encouraging
17 housing units ner acre and heavy industry directly over the major portion of the
aquifer I, for one, do not accept grassed percolation areas as the selected treatment
method for the volumes of surface wastes such densities will nroduce. rfith our ground
frozen or saturated much of the year we obviously have a serious underground injection
problem to deal with.
-------
Pa.ge Two - May 1^, 1981 - Presented to EPA Hearing in Spokane by JOAN HONICAN
"I
8)	According to page 1^2, EPA cannot subsidize sprawl. The statements from
SDokane County's planning staff in its DEIS on the recently adopted Corap Plan says
it all. The staff did an excellent job in analyzing the situation we are up against
and the Community Press' Jim Wavada did a well informed analysis of how our so-called
Land Use Plan evolved. (See Ex. C and D)
9)	The 3 units per acre data on page l*+8 is invalid in light of Spokane's
expressed intent to maximize development to help on the payback of the system.
To support their position they adopted a hugely expanded definition of "fill-in
development" in the Comp Plan which completely undermines the 208's definition
of "fill-in" specifically confined to the Priority Sewer Service Area. In Chapter 10
of the Comp Plan they also inserted a waiver clause which will effectively undermine
the intent of the 208's recommended 5 acre limitation on lots outside the PSSA.
10)	Spokane County's recent response to Elizabeth Corbyn's comments on Monte
Del Rey are representative of local, historical fun 'n games with the public health.
Response #1? (See Exhibit E) clearly expresses the effect of the old Soara of County
Commissioner's action in "accepting" not "adopting" the 208 Plan.
11)	Over $1 million was spent on suitability and capability data which is not
reflected in the Comp Plan or Map. The use of such data would show very clearly
where Spokane County should direct its growth.
12)	An interstate committee must be formed to oversee the continued viability
of the Rathdrum-Spokane Aquifer.
13)	EPA's DEIS consistently states we are only using 20% of the aquifer.
According to the 208 we may be using $0% of recoverable water. Everyone does seem
to agree that the aquifer is a finite resource with development limitations. The
critical question obviously—what are those limitations?
Please respond to:
Joan Honican
S. 3904 Bowdish Rd.
Sookane, WA. 99206
Phone: (509) 926-0172
179
-------
May 27, I98I
MAY 29 1881
TO; EPA Region X, Lead Agency for Spokane's 201 Plan
FRCHs Joan Honican— 3, 3904 Bowdish Rd. - Spokane, WA. 9920^L_
REj Additional questions and comments for inclusion in the FEIS
environmental evaluation
BftANCH
Having attended an unresponsive public hearing (May 14, I98I) on Spokane's
201, I feel, more than ever, that EPA's DEIS is seriously deficient in
numerous areas. Due to the fact that much significant new data impacting
directly upon the 201 has recently become available, it is imperative an
amended or revised EIS be recirculated so the public might have an opportunity
to comment for publication in both the NEPA and SEPA final EIS's.
Since EPA is the lead agency and also an agency with expertise, we must
have your assessment of the Supplemental Study, Volume II which was dis-
tributed at the public hearing before composing our own questions and
comments. We really don't need another multi-million dollar, white elephant
(like the Liberty Lake fiasco) at taxpayers* expense.
All of the following need to be thoroughly assessed in relation to the 201
and also to EPA's and DOE's responsibilities under the law	
lb
II
It
I*
20
*.j
1)
2)
3)
4)
5)
6)
?)
8)
9)
2*|lo)
affn)
12)
**113)
*511*)
Mb |15)
JtJ |16>
The Spokane River Wasteload Allocation Study
Spokane County's adoption of a new Comprehensive Land Use Plan
Spokane County's adoption of a disastrous Classification Map
Spokane County's failure to adopt the 208 Plan
Refusal of the only agency (Dept. of Ecology) with statutory and
jurisdictional authority to assume its responsibility for seeing
that the 208 is implemented
Implications of EPA's coming Underground Injection Control (UIC)
¦program and urban runoff problems mentioned on pages 148 and 149
of the DEIS
Acknowledgement that the aquifer is a finite resource with limita-
tions but no data to determine same
Obliteration of clean recharge to a sole source aquifer and no
assessment of huge quantity diversions of recharge on quality
Wholesale loss of prime agricultural lands underwritten and glaringly
reflected in the Classification Map
Gross violations and loopholes in state laws which purport to protect
"waters of the state" (Particularly WAC 248-96 and RCW's 90.48.110,
90.48.162 and 58.1?)
Complete cost data including a realistic appraisal of federal and
state funds available and the mechanism for providing sewering for
those who genuinely can't afford the additional cost (Over tO%
unemployed, thousands underemployed and a high elderly population
on fixed incomes)
Alternative funding plans if bond issue and LID's fail
Assessment as to this 201*s compliance with WAC 173-240 and RCW
36.94
How the city of Spokane intends to dispose of its stormwater after
separation of its existing system
Gerrymandered aquifer recharge boundaries
Status of the congressionally approved 3ureau of Reclamation scheme
to irrigate tne Rathdrum Frairie in Idaho (E. Greenacres Project),
180
-------
Pg. 2
I'm requesting the above sixteen items be addressed in a revised EIS. If,
as I suspect, the final EIS's are "fasttracked" for both NEPA and SEPA then
I will expect written responses in the FEIS to all of my expressed concerns
including those presented at the public hearing May 14th.
In addition to the sixteen listed above, there are numerous other gaps and
unanswered questions regarding the 20i. They are as follows	
A.	Knowing Spokane County has historically abdicated its responsibility
to protect such a precious resource as the Spokane-Rathdrum Aquifer, does
EPA intend to mandate mitigating measures? To do less is to commit us to
accelerated degradation of our drinking water.
B.	What does EPA recommend as mitigating measures for the dangerous
and persistent urban runoff of Spokane County's projected growth directly
over the aquifer? Who ruled out stormwater sewering as too expensive in
this precarious area?
C.	DEIS Page 20 - How do you intend to monitor equalizing basins for
leaks? And, will there be any pre-treatment and how will settling solids be
handled?
D.	Page 35 - It's interesting to note that the county now appears to
have found suitable fill for the gravel pits proposed to be used for equali-
zing basins. During the 208 study period we were continually told it would
take decades to find such material. What specifically is proposed to be used
in these extremely permeable areas?
S. Page 59 - Who and what is the Defense Plant Corp and how much of its
44 cfs does it presently use and what is it used for?
F,	Page 66 - How much power is generated at 9 Mile and Long Lake dams?
G,	Page 85 - You state the USGS has developed a model to be used in
forecasting long-range changes in groundwater quality. It was my understanding
the model was not developed even though contracted under the 201. Please
send me specifics on this and the name of a contact person in USGS responsible
for the model? Would such a model include West Plains even though our 208
didn't?
H,	Is EPA aware of the Bureau of Reclamation project mentioned in #16
above and its implications for Spokane?
I,	Page 105 - In light of EPA's responsibility stated in the last para,
how can half a project (ignoring urban runoff) be approved?
J. Page 106 - Please sendaa list of "those industries, in Spokane County,
which have registered with EPA as required under RCRA. Also send a copy of
the document referred to in paragraph 2,
K. Page 120 - The 3rd para states, "...a combination of financing
mechanisms ... are still being worked out by the facilities planners".
Cn page 126 you also state residents must also pay to tie into the
collection system from their houses. Has a cost estimate been worked out
on replumbing of most homes since septic tanks are usually in the backyard?
L. What is EPA's position on overclassifying enough land for 40 to 50
years, mainly over the aquifer?
M. Has EPA reviewed Chapter 10 of the new Comp Flan? If yes, what are
your comments and please send me copies, requested under the Federal Freedom
of Information Act, of all communications with Spokane County regarding its
new Land Use Plan and Classification Map.
M, Since the Priority Sewer Service Area (PSSA) was too large in the
208 how does the 201 justify enlarging it still further? And, has EFA done
a comparison of "fill-in policy" definitions in the 208 and the Comp Plan?
0. Since the PSSA, unless revised, is gigantic, phasing is mandatory
as sewers become available. Will EPA require phasing and also the 5 acre
181
-------
Pg. 3
HI I minimum lot size (with no Chapter 10 waiver) in the General Sewer Service
(Area (GS3A)?
P. Page 148 - In light of the Classification Hap, projected density,
the "fill-in policy" and maximizing payback, does EPA accept the 3 unit per
acre formula for estimating urban runoff waste loads? Inflate development to
the maximum and refigure. Page 14-9 - The Land Use Plan doesn't "anticipate"
further industrialization in the central portion of Spokane Valley. It
expressly encourages, classifies and leaves no other alternatives since
West Plains isn't viable without utilities,
ifjl Q. Page 159 - In the last paragraph you again use the 20^ figure for
I aquifer water currently utilized. The 208 stated we may be using 50%, How
• do you intend to deal with this significant difference?
R, What are EPA's mitigating measures for sludge dumps and chemical
1 dumps in the EPA designated recharge areas?
tfg	S. Have agencies considered the feasibility of generation of electricity
by the City's and Liberty Lake's outfalls and storage of methane on site
rather than burning it off in summer?
T. Why does Alternative F consider only disposal in Stevens County when
the Spolane County Parks Dept. is putting together a proposal for an off-road
vehicle area (200 acres) in West Plains? Spokane County has its own options
available and "F" always considers moving the entire discharge-"to land dis-
posal rather than retaining the city's present Jl mgd to the river. Why are
we continually given polarized options rather than the more sensible variations
between?
U, Recognizing the urban density already living between the city limits
and Sullivan Road dual sewering for sewage and stormwater would appear to be
a minimal requirement to protect the public health and such sewering should
demand the highest priority from all of us in an attempt to rectify serious
past actions or inactions. Where I part company with the proposed Valley
portion of the plan is in that area from Sullivan Road east to the Idaho
state line. We allowed the approval of Homestead, Highlands and Hewlett-
Packard, a classic example of spot zoning, in a terribly environmentally
sensitive area. And, they grabbed the Liberty Lake i mgd sewage system,
originally intended for lake property, like so many leeches. As a result of
the lack of planning and Hewlett-Packard's propensity for scenic view lots
(regardless of environmental consequences) we are face with an undersized
$6/gallon treatment plant and hysteria over H-P's plans for expansion which
axe forging ahead. Recognizing the inevitability of this situation, we
should use the abandoned railroad right-of-way but the Interceptors should
be scaled down considerably and a moratorium instituted on additional
development over the major recharge area. To approve an interceptor to
support the Classification Map densities and uses is to abdicate totally
Washington State's and Spokane County's responsibilities to protect what's
left of our recharge,
to protect "our1
great it i
We cannot continue to"congratulate Idaho on its steps
our" aquifer or to pat thein on the back by telling them how
that we aren't upstream,	[<•-> rf	^

rv	182 {/
-------
00
UJ
posal practices discussed by state, county
okane Valley woman
1 in writing to the State
t of Social and Health
•out approval of a re-
gion for a proposed
iile home development
?na Park in the Valley,
ilaint by Joan Honiean
it community septic
ms were being ap-
the county health de-
Uthough they did not
quirements of portions
ington Administrative
248-96).
review of the rezone
data and after a ic-
ier systems approved
>kane County Health
do believe that viola-
C 248-9S are occurring
;ing regularity," Gary
Plews of the State Department of
Social and Health Services wrote
in a letter dated April 9.
"Ms. Honiean also suggested in
her letter that various water qual-
ity violations are occurring and
have been caused by actions or
inactions on the part of the Spo-
kane County Health Department,"
Plews wrote.
But Dr. Mary Luther, county
health officer, said she believes
the disagreement is "probably
based on professional differenc-
es" and not willful violations of
state laws.
Of the dispute, she said, "1 think
that it's in the process of resolu-
tion."
A recent meeting to discuss the
matter was "very productive,"
Dr. Luther said. "All of the con-
cerns expressed by Mrs. Honiean
were considered and, in anticipa-
tion of new slate and local on-site
sewage disposal regulations, the
problems identified are being re-
solved." A follow-up session is
planned.
Dr. Luther also said she was un-
aware of any "identifiable health
hazard" as a result of the practic-
es allowed here.
Edward M. Pickett, environ-
mental health director for the
Health District, said county regu-
lations approved by the state in
1976 permit impervious surfaces
to be placed over drainfields un-
der certain conditions.
Pickett said it's done "all the
time" in Spokane County, but is
authorized by local regulations.
"There doesn't appear to be
anything that's bad about black-
top" over drainfields, he said. In
fact, said Pickett, there may be
some benefits, including addi-
tional protection for the drain-
field from the asphalt above.
He said the loading rates issue
also is a matter of interpretation.
The U.S. Public Health Service
guidelines are based on the as-
sumption that there are two occu-
pants per bedroom in each dwell-
ing, Pickett said. But more cur-
rent information indicates that
formula overstates actual occu-
pancy rates, lie said.
Pickett said Spokane's situation
is unusual because in other Wash-
ington counties there either are
sewer systems to handle sanitary
wastes or wide expanses for
drainfields. Here, a large portir.n
of the urbanized area is un-
sewered, but space is at a premi-
um, he said.
The Health District is prepar-
ing new on-site sewage disposal
regulations which will address the
various practices at issue, Pickett
said. The state will have an oppor-
tunity to review those regulations
once local action is completed, he
said.
Mrs. Honiean called for an in-
vestigation of local sewage dis-
posal practices last November af-
ter county commissioners ap-
proved the rezone application for
the mobile home park.
At the time, she said well water
in the area, which is near an old
waste disposal site, already was
below federal drinking water
standards.
TPTTiai
-------
Response to Comments from Joan Honican
1.	This Final EIS is being recirculated for public review
and comment. It contains revised cost data and additional
water quality analysis in Chapter 2. All comments on the
Final EIS received prior to the close of the comment'period
will be considered in EPA's decision on funding of the CWMP.
2.	The mitigation measures EPA feels are necessary for
approval of Phase I of the CWMP are contained in Chapter 3.
EPA feels these measures are adequate to mitigate the signi-
ficant impacts of the proposed project.
3.	The mitigation measures that are to be made conditions
of the EPA grant award are listed in Chapter 3.
4.	The Mica and Northwest landfills are within the EPA-
designated aquifer drainage area mapped by the U. S. Geo-
logical Survey (Drost and Seitz 1978). The Colbert landfill
is not within the aquifer drainage area. Only the Northwest
landfill is within the EPA-designated aquifer recharge area.
EPA's "sole source" designation applies to both the recharge
and drainage areas.
The aquifer sensitive area has been identified by Spokane
County through the 20 8 program. The northern portion of
the Mica landfill is reportedly within the sensitive area.
For this reason Spokane County is now monitoring groundwater
in the vicinity of the landfill and is controlling surface
runoff from the site (Card pers. comm.).
5.	The paragraph at the bottom of page 42 discusses nutrient
inputs to the river. This includes phosphorus and nitrogen
compounds. The industrial waste dischargers do have NPDES
permits, but they are not required to routinely monitor
for nutrients (except orthophosphorus) in their effluent.
Therefore, DOE has limited information on industrial nutrient
inputs to the river.
6.	The laws and regulations contained on pages 86-88 of
the Draft EIS are all capable of aiding efforts to protect
the aquifer. EPA has previously held a number of meetings
with state and local officials and with the public on those
programs for which we have jurisdiction. State and local
regulations must be implemented by the appropriate agency
or agencies.
7.	Point and nonpoint sources of water pollution are
addressed by two separate sections1of the Clean Water Act
(201 and 208). The differences in focus between these two
sections are described in Chapter 2. (Relationship between
184
-------
the CWMP and the 208 Water Quality Management Plan.) The
CWMP is attempting to remedy the sanitary sewage threat to
the aquifer. Urban runoff control strategies are addressed
by the 208 plan, A letter from Mr. Ray Card, the 208 plan
manager, is contained in this chapter. It describes the
reasoning behind progress toward sanitary waste control rather
than urban runoff control at this time. EPA, however,
encourages immediate action toward implementing the urban
runoff control measures recommended in the 208 plan.
8.	Comment noted.
9.	The 3-unit-per-acre figure listed on page 148 is an
average figure for the entire GSSA. This includes some
areas that will be developed to densities of up to 17 units
per acre and others that will remain undeveloped. Therefore,
the "per acre" loading criteria for calculating the content
of urban runoff are to be used only in estimating runoff
from the entire area. It would not be representative of
densely developed urban areas.
10.	Comment noted.
11.	Comment noted.
12.	While no interstate committee has been formed to oversee
aquifer protection, the EPA has coordinated both states"
efforts to protect the aquifer through its funding of 208
and 201 projects. EPA supports and encourages the concept
of an interstate committee to oversee aquifer protection.
13.	The 208 plan (Spokane County Office of County Engineer,
1979) states that the U. S. Geological Survey has been working
on an aquifer flow and quality model. Preliminary work on
the model has suggested that flow in the aquifer may be about
one-half of that described by Drost and Seitz (1978). If
this preliminary data proves to be accurate, the water with-
drawals may approach 50 percent of the flow recorded at the
state line. However, work on the model has not yet been
completed.
14.	EPA feels that the presentation of added facilities
plan information at the EIS public hearing in May 1981
and republication of much of that information in this Final
EIS allows adequate public review. The material presented
simply allows for refinement of an alternative (A) evaluated
in detail in the Draft EIS. Persons wishing to comment
further on these suboptions may do so by submitting written
comments on the Pinal EIS to EPA in Seattle within the desig-
nated comment period.
185
-------
15.	An analysis of the supplemental facilities plan informa-
tion is presented in Chapter 1. The water quality implica-
tions are discussed in Chapter 2.
16.	The implications of the Spokane River waste alloca-
tion study are discussed in the revised water quality
analysis, Chapter 2.
17.	Refer to the discussion of CWMP-land use plan relation-
ships in Chapter 2.
18.	Refer to discussion of CWMP-208 plan relationship in
Chapter 2. Also, see EPA's recommended action in Chapter 3.
19.	The relationship between the Underground Injection Con-
trol (UIC) program and Spokane's urban runoff control efforts
must be addressed by the DOE as they pursue primacy for the
UIC program and through ongoing efforts of the county 208
program. The implications of UIC should be reflected in
the county's implementation of urban runoff control strategies.
20.	EPA acknowledges that the Spokane Valley Aquifer is
a finite resource. Implementation of CWMP and 208 plan recom-
mendations will serve to protect that resource. In the interim,
the U. S. Geological Survey efforts to better define the
limits of the resource should continue. When their modeling
is complete, it should be possible to more clearly define
the effects of urbanization on the aquifer.
21.	To the extent possible, EPA encourages preservation
of prime agricultural land. EPA has included a recommenda-
tion to that effect in the list of mitigation measures con-
tained in Chapter 3.
22.	Comment noted. EPA is not responsible for monitoring
compliance with Washington state codes.
23.	Refer to the Project Economics section of Chapter 2.
Spokane County must consider the ability to pay when developing
a specific revenue plan for Phase I of the CWMP.
24.	The Washington DOE is responsible for judging the CWMP1s
compliance with both WAC 173-240 and RCW 36,94. EPA must
ensure that the CWMP fulfills the environmental analysis
requirements of the wastewater facilities preparation guide-
lines established under the Clean Water Act.
25.	Present plans are to discharge storm runoff to the Spokane
River.
186
-------
26.	The aquifer recharge boundaries were set by the U. S.
Geological Survey at the outside perimeter of the aquifer
itself. The aquifer sensitive area boundary, established
by the county's 20 8 study, was set roughly at the top of
the first ridgeline upslope from the aquifer. This is slightly
larger than the recharge area, but smaller than the entire
drainage area in order to make the 208 land use restrictions
feasible.
27.	The East Greenacres project has been in operation for
the last 5 years. Water is extracted from wells in the Post
Falls area and used for agricultural and domestic water supply.
In 1980, the project serviced 3,113 irrigated acres of crop-
land and provided domestic water for a population of 1,120.
There are currently no plans by the U. S. Bureau of Reclamation
to expand the project (Pearson pers. comm.).
28.	EPA1s required grant conditions are listed in Chapter 3.
The means of solving urban runoff problems in the study area
must be developed by Spokane County through its 208 planning
efforts. The 208 plan report has recommended percolation
of urban runoff through grassed areas rather than construction
of stormwater sewers. See the May 28, 1981 letter from Mr.
Ray Card, 20 8 Program Manager, on page 160.
29.	The county intends to monitor the equalization basins
for leaks by monitoring adjacent wells (Maxwell pers. comm.).
There is no pretreatment planned for waters held in the equaliza-
tion basins. The means of solids disposal has not been deter-
mined. Settled material may simply be washed back into the
interceptor or it may be given to the commercial composting
company that will be handling sludge from the city's treatment
plant.
30.	The latest information from the facilities plan engineers
is that the storage basins will be excavated from land adja-
cent to the existing gravel pits rather than be constructed
by filling in the pits. This will avoid the need for fill
material (Maxwell pers. comm.).
31.	Although its water right is still in the state records,
the Defense Plant Corporation is no longer in existence.
Its water right to 4.4 cfs was obtained by Kaiser when it
purchased the Trentwood aluminum plant. The right is now
used by Kaiser to extract cooling water from the Spokane
River.
32.	Nine Mile Falls generates electricity at a maximum hourly
rate of 18 megawatts during high river flows; Long Lake Dam
generates at a maximum rate of 72 megawatts (Washington Water
Power pers. comm.).
187
-------
33.	You are correct in stating that the USGS model has not
been completed. For further information on its status contact
the Deputy Director of the U. S. Geological Survey, Tacoma,
Washington office.
34.	Yes, EPA is aware of the Water and Power Resources Service
East Greenacres project and its implications.
35.	The CWMP is designed to alleviate a wastewater disposal
problem that is affecting aquifer water quality. The urban
runoff control measures that are needed to protect the aquifer
from growth in the area are being formulated through the
county's 208 program. EPA strongly recommends that the 208
plan runoff control strategies be implemented to ensure aquifer
protection.
36.	This information has been forwarded as requested.
37.	The facilities plan engineers estimate that connection
of houses to the street collector system will cost homeowners
from $300-$l,300 (Maxwell pers. comm.). The cost will vary
with local topography, current plumbing design, the location
of the house in relation to the street, and other factors.
38.	EPA generally does not provide funding for facilities
with a capacity in excess of 20 years of anticipated growth.
The planning time frame for local land use plans is not subject
to EPA aporoval. As stated in the Draft EIS, it appears
that the county's land use plan allows for growth beyond
that which is projected by the 208 planning effort and state-
EPA aproved facilities planning projections.
39.	EPA's comments on the county's comprehensive land use
plan were published in the county's Final EIS on that plan.
A copy has been forwarded as requested. EPA has not made
separate comments on Chapter 10.
40.	The "fill in" policies of the two plans have been com-
pared. The broader definition in the comprehensive land
use plan could apply to lands outside of the PSSA.
41.	Project phasing is being planned by the county (refer
to the Phasing section of Chapter 1). Additionally, only
the local government can impose the 5-acre minimum land use
control referred to.
42.	The three-unit-per-acre formula for estimating runoff
waste loads is only acceptable for estimating overall average
loading (development densities from less than 1 unit per
acre to over 17 units per acre). Different criteria would
have to be used for analyzing runoff from the denser develop-
ment allowed by the comprehensive land use plan. The urban
runoff potential of specific developments should be assessed
using adjusted criteria when the specific developments are
proposed.
188
-------
43.	Refer to Response Number 13.
44.	Sludge disposal facilities are regulated by DOE or the
county health department, unless the facility were to accept
sludge determined to be hazardous, in which case the facility
would have to comply with federal regulations regarding new
hazardous waste land disposal facilities (40 CFR Part 267).
These regulations require that an impervious liner be in-
stalled to prevent the infiltration of leachate. In addition,
the regulations require that an acceptable leachate and runoff
control system be included in the facility.
45.	There is insufficient head to generate a significant
amount of electricity at the two outfalls. Suboption A-2
in Chapter 1 considers power generation by the pump-storage
method. According to the facilities plan engineers, there
is not sufficient need for methane in the summer months to
make it cost-effective to use or store all that is generated
(Maxwell pers. comm.).
46.	Refer to Chapter 1 for a discussion of suboptions that
include seasonal land application in the West Plains area.
47.	The CWMP is not being prepared as a land use planning
or growth control mechanism. It is intended to provide waste-
water service to the pattern of development being planned
by the local jurisdiction.
189
-------
May 21, 1981
MICHAEL A. KENNEDY CONSULTING ENGINEERS
IT\Zi
Ms. Kathryn Davidson, M/S 443
U. S. Environmental Protection Agency,
1200 Sixth Avenue
Seattle, Washington 98101
Region 10	
I ,~
I'—i
Re: DRAFT EIS for Spokane County Comprehensive
Wastewater Management Plan (CWMP-EIS)
Dear Ms. Davidson:
n
Op=Jf]t\/7ra
Li CJ ' i
«AAY 26 1981
chae« A Kennedy P E
David R Welker P E
Jonn W Guneiach. PE
Ralph B Warner. P.E
EMvlROf
**!. '¦ %' i
BftHNCH
VALUATION
Our firm provided technical review of the CWMP-EIS for Liberty Lake'
Sewer District. This letter will reiterate the major points which we
presented orally at the May 14th public hearing.
We do presently and have in the past strongly supported the overall
concept of sewering the aquifer-sensitive areas.
We carefully reviewed the CWMP and have several concerns. They are
discussed in detail in the Liberty Lake Sewer District formal written
response which has already been submitted. Our four major concerns are
discussed below:
1 1. We feel that the present condition of the Spokane River is not
adequately described in the EIS, especially with respect to
toxicants such as ammonia and chlorine and how these affect the
River fishery. A brief review of water quality at Riverside State
Park, downstream of the present Spokane treatment facility, suggests
that the River is not presently meeting designated Class A stream
water quality standards.
2. We feel that the EIS water quality and fishery impact assessment
procedures are generally unconservative.
In most of the water quality predictions, the mean River flow (7570
c.f.s.) is used in wastewater dilution calculations. Typically,
river flows in the critical summer and fall seasons are near 1000
c.f.s. for extended periods of time. The impact of the wastewater
discharge should be assessed during a time-weighted average flow or
a typical summer flow to more accurately depict "average" water
quality conditions. The acute effects of toxicants should as well
be assessed using dilution calculations at very low River flows.
The effects on relatively non-mobile organisms such as stream
insects should be assessed in the zone of dilution during typical
flows and low flows.
W. 1720 - 4th Ave.	SPOKANE. WA 99204
190
i=09! 338-6456
-------
Ms. Kathryn Davidson, M/S 443
May 21, 1981
Page 2
Our preliminary calculations show that effluent dilution, un-ionized
ammonia, chlorine residual, algal nutrients, and several toxicant
concentrations would not be in compliance with water quality
standards in the River downstream of the proposed Regional
Wastewater Treatment Facility.
Because of the method of water quality assessment used in the EIS,
we feel that it does not contain information necessary and
sufficient to predict floral, faunal and recreation impacts
resulting from the proposal.
3.	We feel that the Land Application Alternates presented in the EIS do
not exhaust the possibilities reasonably available. For example, no
consideration is given to any options employing summer land
application and winter discharge to the River.
4.	We feel that neither the EIS, nor the Comprehensive Wastewater
Management Plan itself adequately addresses the problem of
stormwater runoff. The findings of the '208' study demonstrate the
groundwater quality and public health risk of continuing present
stormwater management practices in the aquifer-sensitive area.
There is abundant literature demonstrating the adverse impact of
stormwater runoff on both surface water and groundwater.
Contaminants in stormwater include oxygen-demanding material,
suspended solids, pathogens, algal nutrients, toxic heavy metals and
exotic organic toxicants. We feel that the Plan should do more than
simply establish administrative and managerial structures to deal
with the stormwater management problem. This problem is not only a
serious present concern but will become a crucial one in the future.
Thank you very much for the opportunity to comment on the County
Comprehensive Wastewater Management PUn EIS.
Sincerely,
MICHAEL^ A. KENNEDY CONSULTING ENGINEERS
/ / / •'¦•**
y /' /. t, / - -
irLs~/y	^v_
Philip Ryi^aufmann
Environmental Specialist •
L
PRK:jh
191
-------
Response to Comments from Michael A. Kennedy Consulting
Engineers
1.	Refer to the revised water quality analysis contained
in Chapter 2.
2.	Refer to the discussion of Suboption A-2 contained in
Chapter 1. A summer land application suboption was recently
developed by the project engineers.
3.	EPA agrees that stormwater runoff is an important water
quality issue in the Spokane area. We feel, however, that
the 208 planning process is the appropriate vehicle to address
this issue. Please refer to the discussion of 208-CWMP
relationships in Chapter 2 for additional comments.
192
-------
May 15, 1980
Ms. Kathryn Davidson
U.S. Environmental Protection Agency, Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Be; DRAFT EIS for Spokane County Comprehensive Wastewater
Management Plan
Dear Ms, Davidson;
| It seems Long Lake is the scapegoat for everyone elses ells. It
has been used for years by the city of Spokane as its final dumping
ground for sewage and is still used for the strom water runoff.
Liberty Lake is solving its lake problems but adding the Long Lakes.
Now we have an either/or situation where officials seem to be
saying we must protect our drinking water and ignore surface water
problems. In fact, surface water problems will be actually deterior-
ating even further.
Those of us living on or near Long"Lake also have the right to a
healthy environment. R.C.W. if3.210.020 (3) expressly provides that
each person enjoys a "fundamental and inalienable right to a health-
ful environment." The fact that particular environmental interests
are shared by the few rather that the many does not make them less
deserving.
I feel that the protection"of the Spokane River and Long Lake is or
should be the concern of everyone and just as important as the aquifer
problem. With todays inflation, more people are staying home to enjoy
their leisure and vacation time. Where better to do this than on the
Spokane River land Long Lake, If these areas are allowed to deteriorate
even more, the day will come when we face massive clean-up costs.
Perhaps the no-action plan is best for now. Don't allow the growth of
Spokane County until the health of everyone can by protected.
Vk
MAY 21 1981
ENVIRONMENTAL EVALUATION
BRANCH
193
-------
Response to Comments from Marianne Phillips
1. Neither DOE nor EPA intend to allow protection of the
Spokane Valley Aquifer to proceed at the expense of Long
Lake water quality. In order to rectify an existing health
threat in the form of on-site waste disposal over the aquifer,
EPA and DOE are supporting plans to begin sewering of the
areas using on-site systems. Simultaneously, the city and
county must increase their water quality data collection
and surveillance efforts to better define the impact of the
Spokane STP discharge on water quality in the Spokane River
and Long Lake. If the monitoring indicates that increased
discharges of waste to the river are causing a significant
adverse impact on the beneficial uses of the receiving waters,
alternative methods of treatment and disposal will have to
be implemented. The CWMP includes proposed alternatives
if monitoring data indicate that adverse impacts to Long
Lake are occurring.
194
-------
Ms, Kathryn M. Davidson, M/S ^3
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle. WA 98101
West 817 Crestview Road
Route 1
Spokane, WA 9920--4- _
May 21, 1981^ p	jj r^nr
MAY 26 1981
ENVlaOMfcKNTAL EVALUATION
BRANCH
Subject: DEIS on Spokane County Comprehensive Waste Management
Plan.
Dear Ms. Davidson:
As a consulting engineer in the Spokane area, I read with great
Interest and anticipation the DEIS on the Spokane County Compre-
hensive Waste Management Plan. To date I have prepared, or
should I more properly say attempted to prepare, two ground
water impact evaluations for projects overlying the Spokane
Aquifer. At least one of these attempts (for which I might
point out was done without any formal guidelines promulgated
by the SPA) met with severe criticism from the water staff at
EPA because I failed to present enough data in support of the
projected ground water Impact (Summerfleld East GWIE) . Ultimately,
the EPA indicated that the background nitrate level in the aquifer
at the project location was such that the EPA could not support
any type of substantial discharging facility. I am not complaining
about EPA's actions on that particular project so much as my
concern that the EPA has now had drafted for it an EIS without
any substantial material in it on the projected ground water
Impact from sewering a significant portion of the aquifer surface.
As stated on page do of the DEIS, "(t)he effect of the proposed
Spokane County CWMP on the Spokane Valley Aquifer ... is one of
the major environmental Issues of this project." However, on
Da see 102 the DEIS continues by stating that "(a)s noted through-
out the preceding pages, it is difficult to quantify the ^round-
water impacts of any of these options." The impact on ground
water is then discussed in general, subjective terms. I am greatly
disappointed in the manner in which the. EPA itself has approached
doing a ground water impact evaluation for a project anticipated
to cost the public taxpayer tens of millions of dollars. There
aosears to be a great disparity between what the EPA expects
consulting engineers to prepare for it for 90 lot subdivisions
in comparison to what the SPA expects from itself for a vastlv
larger and much more significant project.
When the secondary impacts from providing a sanitary sewer system
is fully evaluated, I am sure that the^e will be agreement that
onl7 one source of pollutants to the aquifer is being addressed.
It is true that individual, and small domestic, waste treatment
195
-------
Page 2
and disposal systems represent a slgnifleant contribution of
nitrates to the aquifer. However, is the nitrate problem the
only problem of pollution that needs to be corrected? The
answer is obviously an emphatic NOi On page 1^9, the D5IS
states very succinctly that "(t)he CWMP deals only with the
sanitary waste problem. It does not include recommendations
for urban runoff control." The DEIS depends on the 208 plan
to mitigate the potential impact from urban runoff and really
discusses this source, and industrial spills, very minimally.
Even though runoff might contain substantially less nitrate,
phosphorus, BOD, TSS and fecal coliform organisms than the
discharge from sewage disposal facilities, runoff contains
other constituents of perhaps much more significance than
sewage. Such pollutants include oil, heavy metals, pesticides,
bacteria from animals, delcing compounds including chlorides,
and hazardous materials spilled on the ground or washed into
drywelis.
I realize that installing a sewer system will correct the major
source of nitrates. However, in my view, the availability of
a sewer system will lift a burden from the county1s conscience
of aoproving substantial growth in the areas sewered and justify
such growth on the basis of: (1) need to offset the cost of the
sewers by additional users; (2) with excess capacity built in to
the sewers, there is no need to limit growth; (3) sewers have
corrected the problem of pollution; and (M the 208 plan can
correct all the other problems. However, with growth comes
other problems of urban development; in particular, urban runoff
and increased hazards from industrial and transportation related
spills. To place such a burden of protection on the 208 plan
recommendations is great indeed because if these measures do not
work, or are not fully implemented, then the public has just
invested a great deal of money into a sewer system that perhaps
has corrected one source of pollution but has allowed and promoted
the pollution of the aquifer from other sources that the sewer
system Itself Induced. The DEIS conveniently brushes these
concerns aside by stating simply that the 208 program will do
the job.
My concern is that in the past there have been material spilled
onto the surface of the ground that the 208 program miarht not
have prevented even if it were fully operational. This material
found its way, sometimes very quickly, into the aquifer and once
therein, I feel became Impossible, or extremely impracticable, to
remove. Specific Instances include approximately 20,000 gallons
of diesel fuel spilled at the Milwaukee Railroad shop in the
Valley, phenol at the Spokane Industrial Park, chlorides at
KACC-Trentwood, cyanid.es at KACC-Mead and TGS found in various
wells in the Spokane area. The course overburden which forms
the Spokane '/alley is highly susceptible to the transmission of
pollutants to the aquifer — no matter what the source is.
196
-------
Page 3
SPA places much emphasis on the 208 stormwater runoff management
scheme. This plan uses the concept of grassed percolation areas
(GPA's) for the treatment of urban runoff. In my second ground
water impact evaluation (for the Sullivan Park Center Shopping
Mall), I questionned the long term performance of such GPA1s
which continually receive oil and heavy metals. These GPA's
are being required as a panacea with noone paying any attention
to the need for monitoring their performance over the years.
Since the DEIS places such a burden on the reliable performance
of these systems.to offset the secondary Impacts from the
construction of a sewer system and anticipated growth induced
therefrom, the DEIS should evaluate critically the anticipated
benefits and shortcomings of the 208 program. What has happened
is that the 208 plan has recommended mitigating measures and
then proclaimed these measures as being adequate to protect the
aquifer from runoff and spills — rather a self-serving analysis
in my opinion. Now EPA comes along and prepares an SIS on a
massive sewer system which greatly depends on the 208 plan to
effectively work without any further analysis. It is the full
integration and effectiveness of all control measures that is
required and essential for the protection of the aquifer.
What I am questionning is the wisdom of a massive investment
of public funds to correct a source of nitrates to the aquifer
when such an investment may directly contribute to the pollution
of the aquifer from other sources which it very likely will
induce. Correcting the nitrate, or should I more properly say
the sanitary sewage disposal, problem by sewering the Valley
will also result in a possibly significant Impact on the Spokane
River system as indicated In the DEIS. Are we really solving
the problem or are we simply taking an irrevocable step towards
creating a bigger and more costly problem In the future?
My specific questions and comments on the DEIS contents follows:
1. It always appears that all the discharge from municipal
and industrial dischargers in Idaho mysteriously disappears
as soon as the state line is crossed. EPA has authority in
Idaho that the Washington DOS and Spokane County do not
possess. Very little is mentioned about these dischargers
and the fact that they all discharge to the river system
above all. points in the Spokane River that discharge to the
aquifer. Why then is the Liberty Lake STP always pointed
to as the culprit in upstream pollution. What benefit is
gained from intercepting Liberty Lake when all Idaho dischargers
continue to dump into the Spokane River? As mentioned in the
DEIS, there are plans to dispose municipal wastewater onto
land during the summertime from Coeur 4'Alene and Post Falls.
If we are exoecced to pay for a sewer system in ths Valley,
the DSI3 should indicate what problems we can and cl Date
197
-------
Page k-
to be background created by sewer induced development In
Idaho and different methods of sewage and industrial waste
disposal totally upstream from the Washington portion of
the aquifer.
2.	What are the results of the USGS study on the aquifer and
the computer models developed to simulate pollution from
surface sources? Why are the results from other studies
such as the USGS absent from this DEIS? I really don't
care that the problem is that the USGS is a different
agency from the EPA — you are all financed by public
taxes and we have an absolute right to the best and latest
information available before we are required to vote on
funding a massive sewering program. I would think that
information developed by the USGS would be a critical
inclusion in assessing the true ground water Impact from
the proposed sewer system. If the statement on page 80
of the DEIS (mentioned previously) is a true feeling of
the EPA, then the omission of such studies is a glaring
error. If that information is not yet available, then
is the publication of the DEIS and the potential decision
to approve government funding of this project premature?
In short, what are the results of the USGS study on aquifer
pollution?
3.	The use of storage ponds during wet weather flows appears
to almost sanction continued indefinite combined sewer
overflows from the City of Spokane. One of the primary
reasons, albeit politically induced, to embark on a sewer
separation program was to give additional capacity for
regional service. Combined overflows is a major source
of raw sewage to the Spokane River even during the summer
months (contrary to the indication on page kb of the DEIS)
from rainfalls exceeding .03 inches or whatever is necessary
to create surface runoff. Any proposal that would be counter
productive to eliminating this source of raw sewage should be
rejected as being totally inconsistent with the goals and
objectives of the state and federal water pollution control
laws.
4.	If however storage basins are approved, it is indicated that
an ideal location would be at existing gravel pit sites which
presently penetrate the aquifer. The DEIS mentions that back
fill would be required but no mention of the quantity or
sources of such fill material is made in the DEIS. This is
a most critical oversight since a crash program to backfill
these pits could create a substantial health hazard. The
quantity required to backfill is essential to know and
possible sources of fill need to be identified to evaluate
the feasibility of the use of gravel pits as storage basins.
198
-------
It Is mentioned that the storage basins would be sealed.
For an area the size that needs to be sealed, it would
be extremely difficult, if not impossible, to prevent
leaks from the basin into the aquifer. This impact was
completely left out of the DEIS. Why? Even if the answer
is difficult, is it not the function of an SIS to explore
such problem areas and to discuss impacts, even if only
speculative? Will soil moisture monitoring beneath such
basins be required and what will then happen if leaks are
detected?
I question the inference that the Spokane STP was originally
approved as a total regional treatment facility. The original
30VAY report, as well as the ESV3LT report of the early 19701 s,
both indicated that the north Spokane and Spokane Valley areas
were not intended to be served by the city plant. It was not
until certain political decisions were made regarding funding
for the combined sewer overflow program that the concept of
a regional treatment facility came to be. The original plan
was for the city to serve the Moran-Glenrose prairie area,
the Geiger Field area and future city growth. Since the
decision was made to assist the financing of sewer separation
on the basis that this would be the most cost-effective
regional treatment program (to eliminate treatment facilities
for the Valley and North Spokane areas), how does the EPA
now rationalize the construction of storage basins that
appear to take the pressure off from the separation program?
Dr. Todd's report for the SPRISCO study indicated that he
believed there was a layering of pollutants on the surface
of the aquifer. The 208 study followed up on this concept
and apparently verified this phenomenon. Most of the wells
of major public service are relatively shallow (eg., the
City of Spokane wells adjacent to the river). Since the
aquifer in some areas is several hundred feet deep and it
is highly transmissive, why is the concept of drilling deep
wells and constructing a water supply system from these
sources not considered as an alternative with the 'do nothing'
alternative? I realize that this suggestion does not sit too
well with the goals of the water pollution control laws, but
how does it square with water supply objectives? Can we
really expect to protect the aquifer from all sources of
pollution or should we instead implement growth controls,
208 recommendations and depend on a 'protected' deeo water
supply source in an area of the aquifer that possibly can
be protected and construct a water distribution system rather
than Invest in a costly sewer system that may not protect the
aquifer at all. I" think we have to be completely honest in
evaluating the goal of this program — to insure a safe supply
of drinking water for the future. To reach this sroal, why
can we not have a realistic approach to pollution control and
199
-------
Page 6
water supply. Why must we forever work with blinders on
to hinder the true objectives. Just because the FWPCA -
allows the federal funding of sewers and treatment facil-
ities, must sewers be the only alternative evaluated in
an EI5 if they are not going to solve the real problem
of aquifer protection? Is a deep well in a protected area
a feasible and viable alternative to Installing costly
sewers? Again, look at and evaluate the objectives of
all of the regulatory programs and assess the realistic
affect of installing a sewer system and the effect of all
sources of pollution on the aquifer,
8,	What percent of waters applied from all sources to the
surface of the aquifer will be intercepted by the sewer
system? Even though these other waters are not from
sanitary sewage, they do and will continue to carry
other significant pollutants to the aquifer. The one
aspect of the 208 study that I believe Is Irrefutable
1s the absolute conclusion that surface waters reach
and recharge the aquifer — from whatever source. What
pollutants might these other waters carry even with the
208 controls operational and what will the impact on
ground water quality be from these sources? This is
a direct impact created by the construction of a sanitary
sewer system and the lifting of any growth controls that
might be in place if one were not provided. The DEIS needs
to present a very realistic picture of just what the people
of this county are faced with In the future if indeed a
sewer system is constructed.
9.	Page 1^-9 refers to Table 2-29 as a source of factors that
can yield areal pollutant loadings. I believe the correct
reference should be to Table 2-30.
This concludes my initial comments on the DEIS and I would
appreciate careful consideration of them in the preparation
of the final EI3. I am co-president of the Preserve Our
Paradise Homeowners Association which is located south of
Spokane on Paradise Prarle. Our aquifer is relatively shallow
and In 3asalt and Is separate from the Spokane-Rathdrum Prarle
Aquifer. If we are going to be expected to vote on a county-
wide GO bond issue, then we need to be assured that a sewer
system is absolutely essential to safeguarding the Spokane
aquifer and that we will not be voting to tax ourselves for
a system that promotes pollution rather than eliminating it.
I Also included for your information is the GWIE which I prepared
on the Sullivan Park Center. As you can see from its contents,
the sanitary sewage discharge to the aquifer represented only
200
-------
Page 7
^6 percent of the total surface water projected to reach the
aquifer. This means that the actual major source of water •
recharging the aquifer under the conditions of the study was
other than sanitary sewage. This other water, while definitely
not a major source of nitrates, is the carrier of other
materials possibly much more dangerous to public health. If
you read my report, you will note that I too had an extremely
difficult time in attempting to truly define the impact on
groundwater quality — but at least I tried! For a study that
took only 2 weeks to complete at a cost of $ 850, I believe that
this report comes close to what is expected by EPA of a private
project under your GWIE guidelines. I have to believe that
EPA's budget and time frame were much more extensive than mine
and yet EPA has failed to give the public a realistic picture
of what we are getting ourselves Into. It Is nice to read about
the Impact of this project on the flora and fauna, education,
employment and air quality, but the primary purpose of this
DEIS, as stated on page 80, is totally lacking. I find the
absence of this assessment on ground water quality totally
unjustifiable when compared to my experiences in trying to
satisfy EPA personnel on projects I have worked on. I am
also enclosing the comments I received back from SPA on the
Summerfield East project (a proposed 266 home development)
for your information. If the EPA truly expects this kind of
a GWIE from private consultants, then the least we can expect
is that the EPA will prepare a comparable assessment itself.
Thank you for the opportunity to comment on the DEIS and to
get several things off my chest. If you have any questions
on any of the materials I am enclosing to you, please feel
free to contact me at any time.
Sincerely,
Rhys A. Sterling, P.E
Consulting Engineer
Enclosures
201
-------
West 817 Crestview Road
Route 1
Spokane, WA 99204
15
»fe
Kay 25, 1981
Ms. Kathryn M. Davidson, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Subject: DEIS on Spokane County Comprehensive Waste Management
Plan.
Dear Ms. Davidson:
Attached is an article from the May 24, 1981, SPOKESMAN-REVIEW
that should be considered together with my comments to you dated
Kay 21, 1931, Specifically, my comment #1 refers to the impact
of continued discharge from Idaho municipalities and industries
in light of the pressures put on the Liberty Lake Sewer District
to be intercepted by a general Spokane Valley sewer system. What
restrictions are being placed on the NPDSS permits for Idaho
dischargers to monitor toxic compounds that may be detrimental
to surface and ground water quality? Again, I feel this Is very
Important because of the burden of financing a costly sewer
system that is going to be asked of the Spokane area residents.
The sewer system is being 'sold' to the people on the grounds that
it Is the panacea to protect water quality of the aquifer — will
it really?
I would support a general sewer system in certain areas of North
Spokane due to soil limitations that render on-site sewage disposal
ineffective after several years of operation. However, In the
Valley we have a different problem entirely (except for those
community type sewage disposal systems installed under old county
regulations that allowed overloading of the drainfleld area and
resultant premature failure).
The question needs to be addressed and answered to the best of
your ability: will a general sewer system in the Valley solve
a real pollution problem and protect the aquifer or will it
eliminate the sole problem of nitrates from sewage disposal and
allow the pollution of the aquifer to occur via other Induced
sources that the 208 plan cannot In all honesty adequately
mitigate? As stated In the DEIS on page 80, this 1s the question
and major environmental Issue of the project; and it was never
answered.
Thank you for considering these additional comments.
Sincerely,
'Vj-. v''
Rhys A. Sterling, ?.
n
r-X
j \i
FO|
t-n
onsulting Engineer (J	28 1981
Attachment	202	ENVIRONMENTAL EVALUATION
BRANCH
-------
Shared sewer plant proposed
By MATTHEW COLLIN
Spokesman Review correspondent
COEUR D'ALENE, Idaho - Most Kootenai
County residents now accept the premise that
sewage shouldn't be dumped into septic tallica
.located oyjeEtheBalhdruro Pcairle_Aaui£S".~tfie
area'sunajor source of drinking .water.
Instead.- the ideal is to collect the sewage,
tJD^JLanitheft dump what isiefUnto the Spo-
kane Rivet Coeur d'Alene already has a plant
on the river that it must expand.
North of the city — uphill, it is important to
note — are the rapidly growing cities of Havden
and HaydenJakfi, as well as the Coeur d'Alene
Airport, all of which will need sewers soon.
fluent into the Spokane River.
~TETsTeads some local engineers and health
district officials to ask why the two cities and
the county-owned airport don't get together with
Coeur d'Alene and build one big sewage plant.
Building one large plant would achieve "econ-
omy of scale", meaning that it's cheaper than
building two to four smaller plants.
But Coeur d'Alene city officials aren't very
excited about the idea. They say their neighbors
to the north won't need to build their plants for
another decade, but Coeur d'Alene has a prob-
lem now — a problem that has resulted in a
moratorium on all new sewer hookups.
Last fall, the city thought it had a 20-year so-
lution to that problem in the form of a brand-
new, $22 million. 6-milhun-gaIlon wastewater
treatment plant
Now, because of federal budget cuts, the best
he city can expect is a $1 million "quick-fix"
expansion of its existing plant.
But wen if Coeur d'Alene does get money to
¦xpand that plant, it will only be a stop-gap
neasure; sometime in the not-too-distant future
t will hiive to face the problem again.
The city does not want to have to use the ex-
iting site permanently, however, both because
esidonts of that a; . 3 are complaining about
iat plant's odor ami because North Idaho Col-
jrc's long-range plans direct campus growth
ward the plant
What the city would like to do is move its
Unit a mile or two downriver — to about the
> place Hayden, Hayden La!
would bring their sewage. ¦,
Lake and the air-
same
port
"It'i all a matter of timing," sap Jim Kim-
ball, a consulting engineer working with Hayden
and Hayden Lake on their sewer plans.
Kimball admitted Coeur d'Alene has to come
up with some immediate solution to its dilem-
ma, but he predicted that if the city doesn't
come up with a "20-year solution" by the time
its counterparts to the north are ready to get
into the sewer business, the smaller communi-
ties will find themselves in "a good bargaining
position."
But Coeur d'Alene Mayor Don Johnston says
talk of a regional sewer plant amounts to "going
back over ground we walked on three years
ago."
At that time, Coeur d'Alene had just recog-
nized the need for a new plant, and the federal
On the river, Coeur d'Alene already
has a plant that it must expand.
Environmental Protection Agency was encour-
aging it and Post Falls to work together on a
single plant.
The idea was to build the big plant in Post
Falls, which is downhill from Coeur d'Alene,
thereby making it possible to move the larger
city's waste to the new plant by means of gravi-
ty-feed sewer trunk lines.
Johnston says that when the EPA discovered
the interceptor wonlrt enst nearly as murh as the
plant Itself, the agency ouickly ruled-jQllL_that
alternative as not being cost-effective and it de-
plants.
Kimball, however, says Coeur d'Alene has
never looked into the possibility of a regional
plant shared with cities to the north.
He says his research has shown that running
. port area down Ramsey Bond to the river would
hft far ]ps
-------
Response to Comments from Rhys A. Sterling
1.	The reasons that EPA has relied on 208 plan data and
analysis for its EIS groundwater impact analysis are stated
in the section of Chapter 2 entitled Relationship of the
CWMP to the 208 Water Quality Management Plan. EPA realizes
that the potential for groundwater contamination from urban
growth is significant. It is felt, however, that the 208
plan has identified and addressed this concern. Implementa-
tion of the 208 plan's water quality protection policies
should rightfully include detailed analysis of individual
projects that have any potential to affect the groundwater.
2.	Wastewater facilities plans, including the CWMP, are intended
to address water quality problems created by sanitary waste-
water disposal practices. As you have indicated, sanitary
wastes are a primary source of nitrate pollution. Nitrates,
however, are not the only constituent of concern. A wide
variety of other toxicants are typically found in sanitary
wastes, including household cleaners, solvents, pesticides,
and pathogenic organisms. By collecting and treating these
wastes, the toxic materials are not allowed to percolate
into the local drinking water supply. The proposed interceptor
system will also be collecting a small amount of industrial-
source wastewater, which can also contain a variety of hazardous
materials.
EPA is not ignoring the significance of urban runoff
and its effects on water quality. As stated in several sections
of this Final EIS, EPA strongly supports efforts to continue
with the county's 208 program; this includes timely implementa-
tion of strategies to control- urban runoff.
3.	Protection of the environment in general and the Spokane
area's groundwater in particular requires that all responsible
agencies use their authority to prevent and abate pollution.
EPA contributes financial aid and technical expertise to
local jurisdictions in planning for control of water pollu-
tion through the 201 and 208 programs. EPA must rely on
local agencies to use their powers and energies to implement
the planning recommendations.
Work completed on the 208 plan to date is only one segment
of the work that is necessary to abate and prevent pollution.
The county must now proceed to use its land use planning
and growth management capabilities to see that aquifer
pollution is not increased.
204
-------
The county should continue to pursue the recommendations
contained in the 208 and modify them as necessary to ade-
quately protect the area's drinking water. This includes
methods of treating urban runoff and dealing with the
potential for toxic spills over the aquifer.
4.	The Spokane County 208 plan has been rigorously reviewed
by EPA Region 10 in Seattle, and has recently been approved
with conditions. The positive and negative aspects of the
entire program were carefully weighed before the conditioned
approval was granted. All of the threats that exist to ground-
water quality will not be automatically eliminated by adoption
of the 208 plan, but it does contain positive measures for
aquifer protection. Local efforts must now refine the 208
work so that the goals of the program can be achieved. This
could include a program of monitoring grassed percolation
areas to determine their long-term capacity for filtering
out urban runoff pollutants.
5.	No attempt has been made to identify the Liberty Lake
treatment plant as a culprit. EPA realizes that discharges
from the present Coeur d'Alene and proposed Post Falls, Idaho
treatment plants are also upstream from Spokane. For this
reason, EPA is placing waste discharge restrictions on those
plants that are similar to the controls placed on Liberty
Lake. In their long range 20-year plans, the Idaho plants
must include facilities for 8 5 percent phosphorus removal
and dechlorination as well as Best Practicable Wastewater
Treatment Technology (BPWTT).
Neither of the facilities plans being pursued by Post
Falls and Coeur d'Alene currently include land application
of wastewater as a preferred action. The land disposal option
was investigated by both cities, but plans are now proceeding
for year-round discharge to the Spokane River. These discharges
must meet the same rigorous effluent quality standards being
applied in Washington.
6.	The USGS groundwater study has not been completed. When
the results of this study are available, they can be used
to guide ongoing 201 and 208 planning efforts. EPA does
not feel it is premature to proceed with 201 planning in
the absence of the USGS report data.
7.	The use of storage basins during wet weather flows is
not intended to sanction continued combined sewer overflows
(CSOs) from the City of Spokane. The city is currently pro-
ceeding with the design phase of their CSO project and is
on the state priority list for further funding of this
project.
20 5
-------
8.	Since publication of the Draft EIS, the facilities plan
engineers have determined that excavation of storage basins
adjacent to the existing gravel pits would be preferable
to filling in the existing pits. This will not require a large
amount of fill material; in addition, it avoids the use of
an area that penetrates the aquifer. The exact locations
of the new excavations have not been identified.
9.	The facilities plan engineers indicate that a double
seal will be placed under each storage basin. PVC or clay
will be used as an underline and the basin surface will be
asphalt. The basins will also be constructed as a series
of cells so that maintenance and repair can be accomplished
without draining the entire basin. While these measures
will not eliminate the possibility of a leak, they should
minimize the chances of a significant contamination occurring
below the basin.
The project engineers indicate that observation wells
adjacent to the basins will be used to detect leakage. The
DOE must determine if more precise monitoring, including
soil moisture monitoring, is needed to protect the aquifer.
The impact of leakage from a basin could be severe
because of the large volume and untreated nature of wastes
involved. Before the basin designs are approved, adequate
contingencies should be built-in to protect the aquifer from
leaks. This should include an effective surveillance and
monitoring program at each basin site and a means of rapidly
isolating and repairing leaks.
10.	Please refer to Response Number 7 above.
11.	Allowing the top portions of the aquifer to become con-
taminated while drilling deeper wells to tap drinkable water
is not a feasible alternative under the "sole source" aquifer
program. Moreover, the variation in contaminant density
provides a mechanism for more dense contaminants to reach
the deeper portions of the aquifer, thereby making the
deeper water unfit for drinking purposes without treatment.
12.	The percentage of all water applied to the surface within
the project study area is unknown. It is safe to assume,
however, that a large percentage of the water that is not
intercepted will eventually percolate to the groundwater.
This percolate will contain a wide range of substances, de-
pending upon its source and its path into the ground.
Table 2-30 of the Draft EIS lists a few of the contaminants
expected in runoff.
206
-------
These nonpoint sources of pollution will continue to
affect the aquifer as long as water percolates from the sur-
face into the aquifer. The 208 plan has identified methods
of controlling some of the runoff inputs.
There is no guarantee that growth controls will be insti-
gated in the Spokane area if centralized wastewater service is
available. The lack of a regional sewer system has not limited
development to date. Therefore, to take no action toward
solving the sanitary wastewater problem on the pretext of
limiting the extent of the nonpoint pollution sources is
not in the best interests of water quality protection. EPA
feels that Spokane County should proceed on both fronts to
contain sanitary waste and nonpoint sources of pollution that
affect the local water supply.
13.	The reference to Table 2-29 is in error. As you indicate,
Table 2-30 contains areal pollutant loading factors.
14.	Refer to response number 1. EPA has focused its impact
analysis on the CWMP's sanitary wastewater collection and
treatment aspects. The county 208 plan has addressed the
issue of growth and its potential impact on the Spokane Valley
Aquifer. Specific development proposals over the aquifer
should be reviewed in detail in light of the findings and
recommendations included in the 208 plan. EPA feels the
groundwater impact analysis contained in the CWMP EIS is
sufficient to indicate the ramifications of constructing
wastewater interceptors in Spokane Valley and North Spokane.
15.	EPA has just completed a technical assistance program
for the City of Coeur d'Alene to identify industrial waste
dischargers to the city system. The city is also currently
completing a pretreatment program to control toxic and
chemical substances. Implementation of controls on industrial
dischargers will be through local ordinances. The City of
Post Falls currently has no industrial waste dischargers
and does not require a pretreatment program.
16.	EPA feels that sewering will abate an existing water
quality problem-contamination of the Spokane Valley Aquifer.
This includes more than just nitrate contamination; it is
becoming increasingly evident that domestic and industrial
wastes contain a wide variety of potentially toxic substances
that should not be allowed to contaminate a sole drinking
water source.
Extension of interceptors further into the Spokane Valley
should occur in conjunction with methods of controlling urban
runoff (and other nonpoint) sources of pollution. This imple-
mentation is the responsibility of Spokane County and a variety
207
-------
	Chapter!
Oral Testimony on tht
Draft EIS and EPA Response;
-------
Chapter 5
ORAL TESTIMONY ON THE DRAFT EIS AND EPA RESPONSES
Introduction
A public hearing on the Spokane County CWMP Draft EIS
was held in Spokane, Washington on May 14, 1981. The follow-
ing pages contain the transcript of the oral testimony pre-
sented at that hearing. Each comment requiring a response
has been identified by a line and a number in the left-hand
margin of the transcript. Following the transcript, each
comment has been responded to in numerical order. If the
comment has been responded to in the text of an earlier chapter,
the reader is referred to that chapter.
209
-------
I
z
I
4
5
S
7
(
M '
(->
O 10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
25
PUBLIC HEARING
OH THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR THE
SPOKANE COUNTY COMPREHENSIVE WASTEWATER
MANAGEMENT PLAN
PREPARED BY
THE ENVIRONMENTAL PROTECTION ACENCY
PUBLIC HEALTH BUILDING
SPOKAN'E, WASHINGTON
MAY 14, 1981
JAMES E. S-TACM
COUNT «*PO*few
SPOKANE, WASHINGTON
PMitL HK'Sa-'J'i;
LLIZALLTti tX»a.Y.;, iiearine Officer
u.vironntiital rrat,;el;ion /.gency
axa; C0IX1IS, Collins 1-ud Ryder. Inc.
M3HiYd.aiWluSUi, Lnviornaental Protectiai j'sgeucy
lEQAil. Jd&h*KJu, Jones aid ScoliiS Assoc i*Cu:», Inc.
iiDLLKl LULiliii, Ixoaciidc and Liy.inam ir^ Services
JAMES 6. STACK
«Ou»t *|»OOT(«
&POKANC. WASHINGTON
-------
1
2
1
4
5
«
7
S
NJ 9
M
(—* 10
11
12
13
14
15
16
17
ia
19
20
21
22
21
24
25
PROCEEDINGS
Lisa CORBYM: I would like to call this
meeting to order, please. My name is Lisa Corbyn, and I
am with the Environmental Protection Agency in Seattle,
Washington, Mr. Donald Dubois, our Regional
Administrator, has designated me to be your Hearing
Officer for tonight's proceedings. We appreciate your
attendance tonight and we are pleased that many of you
have taken the time to come here and share your views
with us. I am sure that many of the issues to be discussed
tonight are of direct concern to you all.
For purpose of the hearing record, I would like
to note that this public hearing was convened at 7:35 p.m.,
May 14, 1981 in the Spokane County Public Health District
Auditorium in the City of Spokane, Washington.
As Hearing Officer, I would like to take a few
minutes to tell you the purpose of tonight's haaring and
describe the hearing agenda which will lead to orderly
presentations by each of us here. Even though this is an
informal public hearing, I would like to pass along a few
rules of procedures which will assist us in making sure ths
everyone has the opportunity to participate in tonight's
discussion. Our primary purpose tonight is to provide
the opportunity for local citizens to comment on two
t
JAMES E. STACK
C0u"»T REPORTER
SPOKANE WASHINGTON
2
1
2
3
4
5
s
7
•
9
10
11
12
13
14
15
IS
17
I*
1»
20
21
22
23
24
25
recently published documents;
1)	The Comprehensive Wastewater Management
Plan for Spokane County, prepared by
Spokane County, and;
2)	EPA's Draft Environmental Impact Stat.c-.tr.vnl
on that plan.
The County of Spokane has applied to die
Environmental Protection Agency for grant assistance in
accordance with Section 201 of the Clean Water Act for
purposes of 'initiating a plan to identify ways to elinl-
nate onsite waste disposal facilities in the highly urban!?.
unincorporated areas surrounding the City of Spokane.
EPA has previously awarded to Spokane County a Step 1
planning grant to develop the Comprehensive Wastewater
Management Plan which outlines a nurr.ter of alternative
for providing these facilities.
The Draft Environmental Impact Statauunt has
been prepared by EPA. It consists of a ccuvaluation cf
each of the alternatives identified in the County's
Comprehensive Plan. The EIS has been prepared pursuant
to the National Environmental Policy Act. The*
Environmental Protection Agency is required to prepare
such statements on major Federal actions which could have
a significant impact on the quality of the environment.
The Federal action in this case would be rPA grants to tie
JAMES E. STACK
COUHI t AEPOWTE*
SPOKANE. WASHINGTON
3
-------
1
2
3
4
5
6
7
S
K) '
h-1
N) 10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
County of Spokane which, along with State of Washington
grant funds, would assist the County in Step 2: designing
the selected facilities; and Step 3: actually constructing
the selected facilities. Before any decision can bo made
regarding the award of additional grant funds for these
projects, the EIS process must be completed. The remain-
ing steps in the process include receipt and review of
public comments on the Draft EIS, both at this public hear-
ing and through written submissions, followed by the prep-
aration of a final Environmental Impact Statement and re-
ceipt of comments during a 30-day review period following
the final publication.
For those of you who would like a more detailed
account of the remaining steps in the EIS process we will
have an opportunity to discuss It later this evening.
Again, let me emphasize that the purpose of
tonight's hearing is to receive oral coiranents on the pro-
posed facilities and EPA's CIS. We are not going to
limit the scope of your inquiries or your input, but I
hope that each of you in your comments and statements
will keep our purpose in mind.
Those wishing to testify at this public hearing
have been encouraged to review the draft EIS. The EIS
has been on file at the City of Spokane Public Library
since February 20, 1981. Copies were also mailed to State
JAMES E. STACH
COURT »C»ORTC«
SPOKANE. WASHINGTON
4
1
2
3
4
5
6
7
t
9
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
25
and local officials, and to numerous citizens of the area.
Persons unable to testify at tonight's hearing or wishing
to furnish comments after the hearing may Jo so by writing
Kathy Davidson at EPA's Regional Headquarters, 1200 Sixth
Avenue, Seattle, Washington 98101. The close of the com-
ment period is Hay 29, 1981. Kathy Davidson is the
Project Monitor on this EIS for EPA. This is Kathy. If
you did not get EPA's address, please see Kuthy sometime
during tonight's proceedings.
I Vould also like to mention at this time that
questions from the floor should be held until the third
stage of this hearing. A question and answer period will
be held after all interested parties have had the oppor-
tunity to present oral comments. And given the amount of
people we have so far who have signed up to lt.ake presen-
tations, we should have sufficient time to answer all your
questions.
I would next like to give you the agenda for
tonight's hearing and introduce the other people sitting
at the table with me. This is Mr. Robert KiiSSuna from
Economic and Engineering Services (EES) and Mr. Bruce
Collins from Collins and Ryder consulting engineers.
They will give a brief presentation on the various alter-
natives presented in the Comprehensive Wastewater Manage-
ment Plan. Economics and Engineering Services are
JAMES E. STACH
COURT RIPOOTIR
SPOKANE. WASHINGTON
5
-------
1
2
3
4
5
6
7
8
W 9
1—1
CO 10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
25
consultants to the County of Spokane and prepared the plan.
Over here i9 Mr. Michael Rushton of Jones and
Stokes Associates. Mr. Rushton will make a brief presen-
tation outlining the more significant environmental impacts
associated with each of the alternatives. Jones and
Stokes are the consultants who assisted EPA in the prep-
aration of the EIS.
After these short presentations, we will receive
oral comments on the projects and documents. I will call
on the individuals in the order that I have received their
cards. However, if anyone needs to leave early, I would
appreciate knowing so I can schedule you early in the
hearing. Following the presentation of testimony, we will
begin the question and answer period. Questions may be
asked of the panel through me. As Hearing Officer, I re-
servo the right to limit questioning, call recesses, ad-
journ and reconvene the meeting. I am going to a3k that
presentations be limited to 10 to 15 minutes. Written
material should be left with me following your presenta-
tion or sent to Kathy Davidson at EPA's Regional Office in
Seattle for inclusion in the record. You are under no
obligation to submit written material. A written account
would help us consider your statement more fully and keep
our record in order. Written comments received on or
before the close of comment period on Hay 29 will be
JAMES E. STACM
COU"T RCPOMTIft
SPOKANE WASHINGTON
6
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
responded to in the final EIS.
A record of the hearing is being made by the coui
reporter, therefore, I ask that when you speak, you cone
up to the podium» secondly, that you speak clearly, state
your name, address, and affiliation, if any. Also, It
will be helpful if you would come forward so that the
audience may hear your comments and you will be wore easily
picked up by the court reporter.
Copies of this transcript will be made available
for your Inspection at EPA's Seattle office and the City
of Spokane library.
Are there any questions as to the procedures that
I have outlined? If not, I will a3k Mr. Wubbena to begin
his presentation.
BOB WUB3EWA: Thank you, Lisa. Our firm, in
response to the scope of work that was prepared for the
County and for the City, and approved by DPHS, .?PA, doe,
and the regulatory agencies involved, proceeded to develop
the Comprehensive Wastev/ater Management Plan in the fall
of 1979. We had several major objectives involved that
are represented through the various graphics on the wall
here.
One of our major objectives was to attempt to
consolidate and to integrate the various facility plans,
JAMES E. STACH
COUNT ft£PORT(*
SPOKANE, WASHINGTON
7
-------
1
2
i
4
5
«
7
<
M 9
M
^ 10
11
12
13
14
15
t«
17
ia
19
20
21
22
2]
24
2$
wastewater facility plans that have been developed for the
north potential facility area, the Newman Lake area, the
City of Spokane, and numerous other studies that had been
developed for wastewater management in the Spokane area.
In addition to that, and a very important aspect
of our study, and a follow-on to a very intensive citizens'
involvement plan was the 203 Mater Quality Management
Program was to integrate the findings, and to develop a
capital improvement response program to the findings of
the 208 study. In addition to the coordination and inte-
gration of the facility plans, and the 208 Water Quality
Management Plan, we were also, by virtue of the need and
the demand that was Incorporated within our scope of work,
to essentially Integrate, and involve, and coordinate the
development of the comprehensive land use planning acti-
vities in both the County and the City. Now, since this
was an entitling process, it was an effort in terms of trying
to develop a facility plan that was both responsive to the
demonstrated, existing need for wastewater management, as
well as the projected wastewater management needs that
would evolve from the comprehensive land use planning
activity.
Another parallel activity that was a part of
our consideration was the ongoing activity with the
coordinated water system planning activities because one
JAMES E. STACK
COuAT OfPOBte#
SPOKANE. WASHINGTON
8
1
2
i
4
5
6
7
•
9
10
11
12
11
14
15
IS
17
18
19
20
21
22
21
24
25
of our following objectives was to develop a Wastewater
Management Plan that was consistent with the other utility
planning activities within the study area.
We looked at the whole study from throe major
approaches. It took three approaches to the development
of the study, and many of you have participatcd in pre-
vious committee meetings, or citizen mc-tings, or public
information meetings, and have heard the outline that I
am talking about at t!i!s points but basically It'a to be
divided intq the management element, the uror-edure or
administrative element, and the capital facility ulownt
of the facility's plan.
It was our perspective that tin extnn^iv.! ntuJlog
that had been done were'in many ways dona with u sort of
a specific purpose in wind and objective in i that did
not necessarily consider all the wastewati.-r management
needs or the total involvement in ths Spokane-: ai'uaj end,
therefore, our objective was to integrate these into a
program that was represented by the riana.-ione.it procedures
of both the County and the City, and the other local
government agencies. So, through this pcocoa9 we have
outlined in the Comprehensive Wastewater Management Man
a major program that attempts to lay out i • vry s-iacific
management process that takes advantage of and utilizes
the existing management procedures and adnlsij strative
JAMES K, STACH
COURT RC»ORTI«
SPOKANE. WASHINGTON
9
-------
procedures of both the County and the City, as well as
the State and Federal Government.
The administrative procedure then was the need
to follow on with a management program to insure that each
of the recommendations, each of the programs that we
recommended in the Comprehensive Wastewater Management
Plan would also fulfill the local. State and Federal
requirements in a way that once we were through with this
process, that the implementation program would comply with
the various laws, and would hopefully proceed in a fairly
streamlined and consistent manner, and consistent with the
objectives that those laws are set forth in. In response
to the management and administrative procedures we incor-
porated within the plan, than, and we integrated the
capital facility recommendations of the individual plans;
we looked for conflicts in those respective capital facility
plans; and where those conflicts may or may not occur,
we attempted to resolve those conflicts and put forth the
capital improvement plan that we felt would respond to
both the identified needs for existing situations, as well
as the projected needs as reflected in the policies of
local and State Government, and came up with a series of
alternativus, which are on tho side wall over there.
Following ma, Bruce Collins will present briefly to you
those alternatives and talk specifically to the recommendec
JAMES E. ST ACM
COyw*
SWOKAMC. WASKtNGTON
10
1
2
i
4
5
6
7
S
9
10
11
12
»
14
15
IS
17
II
19
20
21
Z2
21
24
25
alternatives that we arrived at in December of last year.
Following the conclusion of th<* Comprehensive
Wastewater Management Plan, utilizing the data available*
to us at that time, we printed Draft CWMP. In January of
this year then Wasteload Allocation stuay was issued by
tha Department of Ecology, which was prepared by
URS Company, and following the preliminary analysis of
that Wasteload Allocation Study we asked to do some addi-
tional or supplemental studies, to again direct some of
these specific issues that were raised in that particular
study. So, since early in this year we have pursued addi-
tional information and developed soma additional su».-
alternatives to the recommended alternatives on how to
respond to the Wasteload Allocation issues that were
raised in that particular study, ftgair,, ftru.u- •¦•ill td.iresa
that information and the summary documents that vcre placsi:
on the back tables, Thore are two documents. One is
Volume I, and one is Volume II. Volume I is the informa-
tion that we prepared, and represents basically the
Comprehensive Wastewater Management Plan that was com-
pleted in December of 1980, The Volume II, supplemental
studies aspect, represents the work we have completed since
that time and submit here as our response to thu informa-
tion that was incorporated in the Wastulo^u Allocation
Study and further supports the recomr-eiKTe ti -.'fin that will b«
JAMES E, STACK
tCUBTRC»OnT(«
$PQK*hE. WASHINGTON
3 1
-------
Incorporated into the final Comprehensive Wastewater
Management Plan following the hearing here tonight, and
in oar final process.
So, the process or the program that we have
followed then is to, again, develop a management system
that integrates the individual studies that represents
and integrates the 208 Water Quality Management Study that
was done early on and had extensive public involvement,
and then developed a capital facility response to those
respective studies.
I would like to turn this over to Bruce at this
time to briefly go over these individual alternatives,
and to discu.'is some of our findings and our recommenda-
tions, and then I will follow on, from Bruce, with our
final rec-omniendatlons and our discussions tonight.
*****
MR. BRUCE COLLINS: Thank you, Bob. Briefly
to summarize the alternatives, X think it would be proper
to initially indicate that the range of alternatives we
have looked at divide into possibly very basic categories:
One, a range of alternatives which utilizes the existing
capacity available for regional purposes in the City of
Cpukanc Central Wastewater Treatment Plan. Second would
be a range of alternatives which provides facilities
JAMES I. ST ACM
cou«r »o*T*"
SPOKANE, WASHINGTON
12
1
Z
1
4
5
6
1
$
9
10
11
12
13
14
15
!<
I?
II
19
20
21
22
23
24
25
which either supplement or provides separate t roabr.cnt
capabilities. And, also, we can break the range of alter-
natives Into two other broad categories, one where we are
utilizing conventional, mechanical, chenical treatment
as with the existing advance wastewater trentnent plan,
and those which deal with some kind of ultimate disposal
by land application, which again minlnize^ loth the
mechanical and eheifical treatment aspect:-, a:; >•,; fin.I it
at the existing plant.
Also by way of preliminary cui.tm.jnc, the r«i:v;e
of alternatives, again, deals very carefully with tUa
issue of to what extent the existing conveyance facilities
of the City of Spokane can be utilised 'or r-; j tonal ser-
vice purposes to tha outside or outlyirtit aroas of the
County. This becomes a very complo:: r.rol.l-n, which I
won't go into in detail tonight, involving the "act that
the existing conveyance facilities of the City of .Tpol-nno
are old faculties, they v«re designed and <:..r.sitruoted
at a time when there was no particular attempt t uide to
exclude ground water or storm water. Thu City of rpolrane
is presently about two-thirds a conbi'ietl syiicran. f.o, the
big question: Mow do we use those conveyance facilities
to servo outlying areas which would !>¦„• c.» in-j in under
tight specifications for elimination of ground water, and
30 on?
JAMES E. ST ACM
CO«»T REKONTl*
SPOKANE. WASHINGTON
13
-------
N>
M
-J
*
JO
11
12
13
14
15
18
IT
I*
19
20
21
22
21
24
25
Without going into a lot of detail, the concept
that has been generated out of this study, and the one
which really permits the alternative to work that we, as
the staff are recommending, involves the use of the exist-
ing conveyance facility in the City of Spokane only during
that period of time when there is no wet weather flow into
it. To do this—and 1 will show you when we briefly look
at the alternatives—, to limit the inflow from the out-
lying areas to the existing City conveyance system re-
quires a system of equalization basins with sufficient
capacity to hold those flows during a period of wet weather
So, we can bridge the flow, release the flow following the
wet weather, and so on.
vjith that, I will briefly go around the room
and invite you at break time, or whenever, to look at the
naps closely. But, to give you a very quite summary of
what the alternatives are, starting down the wall—
(Please see description on
insert.)
JAMES e. ST ACM
COv«T	EH
SPOKANE. WASHINGTON
14
1
2
i
4
5
6
7
•
9
10
11
12
II
14
15
1«
17
I*
l»
20
21
22
23
24
25
with that, we will come back quickly to a sum-
mary of the alternatives. These are not listed in alpha-
betical order, but in order of cost effectiveness, based
upon the combination of effluent coat, and/or annual cost
to give us a total economic value for each plan.
Again, the borders as they come out in terms of
cost effectiveness, at a total value of 72.2 million.
The second most effective would be Plan C, providing for
separate treatment In North Spokane, essentially breaking
it down rather than pumping it back. The third moat pros-
pective plan is substantially to provide separate treatment
for the Spokane Valley. I might add that from an environ-
mental standpoint it would entail a discharge to the
river, upstream from the City of Spokane, find, from hare
we continue to escalate to land application, SJorth
Spokane, the Valley, Spokane Valley combined, nn
-------
1
2
3
4
5
6
7
I
K> 9
M
00 to
11
12
13
14
15
16
17
1«
19
20
21
22
23
24
25
As Bob indicated, and again wo always seem to be
a little bit out of sequence in our planning as far as
wastewater, hopefully we would have had something like the
Wasteload Study up front to give ua an idea of what the
impact would be of the various loads on the Spokane River,
and on downstream, along the lakes, from all of the input
including the City of Spokane, and up into Idaho. As it
turned out, the preliminary draft Allocation Study was
made available just a few weeks ago, but it did point
to a very serious concern in terms of how far wa continued
to grow in terms of both critical nutrients and toxic
elements. This became the basis then of taking a look
at those impacts, and determining an element of the
Comprehensive Wastewater Management Plan, which would re-
spond to the planning of the Wasteload Allocation Study.
So, this has sponsored a family of several
alternatives which we have tacked on to Plan A recommended
alternatives, and indicates the things that may have to be
done in the event that the DOE, or the EPA determines
the allowable allocation of waste in Long Lake, or what-
ever reaches the Spokane P.iver be such that we would have
to either incorporate or provide soma other type of treat-
raent relative to Plan A.
Starting with A-l, we are looking at the poten-
tial for going to seasonal removal of phosphorus. It's
JAMES E. ST ACM
COU*f HEPOWTt,*
SI»0KA*£ WASHINGTON
IS
1
2
3
4
5
6
7
t
9
10
11
12
13
14
15
ie
17
II
19
20
21
22
23
24
25
something that has been discussed for many years on the
basis that the mechanics of Long Lake, the hydraulic flow
through Long Lake suggests that the critical introduction
of nutrients starts discharging in the spring, that t l-.-j
heavy flow through the wintertime really passes on through
and does not contribute to the reservoir nutrients and
biological activity in Long Lake. Anyway, we compnred
what is the existing situation with possible removal of
85 percent, year-round, which runs about 1.36 million
dollars, as -against what would be the cost every five
months, and removing just over a five-month period, start-
ing essentially the 1st of May, and on into October,
fhis last column I won't go through. It indicates what
the Impacting of these dollars would be in t.«-ma of uaur
cost and the added increments of a sewer bill to provide
financing for the supplemental requirements.
The second thing we looked at, in tna event that
we get to the point where we can't take any lucre phosphorus
into Long Lake is, what do we do, put it m a bn.j and
shoot it to the moon? You know, what are the alternatives
One of the alternatives that we looked at on this wall—
there is a more detailed nap and slides made available—
is a very Intriguing alternative from a putuLy speculative
point of view, and it extends from the initial look at
the land application at least during the seasonal period
JAMES E, STACH
COUftT NCBOMtlK
SPOKANE. WASHINGTON
17
-------
1
2
1
4
5
8
7
S
9
10
11
12
II
14
15
IS
17
18
19
20
21
22
23
24
25
that we can't tolerate other nutrients or other phosphorus
into Long Lake.
We did look at the sites available, providing
for storage or irrigation to the west area, and that would
require for us to provide storage to provide for proper
distribution to irrigation. Without going into detail,
we looked at the alternatives, primarily based upon either
total power generation or irrigation, the idea of our
power generation being that we pump it up to the reservoir,
it might be more valuable to return that through a turbine
and generate power on the way back than to put it up on
the land irrigation.
One of the problems we have with Irrigation up
in the west area now la that a lot of that land has been
chalked up in five-acre parcels. It's very difficult to
assume that we could put together a large enough block
of land to provide large enough disposal. If you have
questions on that, I would like to discuss it with you.
The power generation coat about $13 million, and would
add 5300,000 a year,- and irrigation is substantially more
costly, at about the same operation and maintenance.
Ooing on down the list, and I will run through
the rest of these fairly rapidly, and there are addi-
tional things that we can do, such as the dechlorination
wastewater treatment plant. In two of the areas
JAMES E. STACM
count ne»OMT«n
SPOKANE . WASHINGTON
IS
1
2
3
4
5
6
7
I
9
10
11
12
11
14
15
16
17
It
19
20
21
22
23
24
25
identified the Allocation Study deals with chlorine
toxicity and ammonia toxicity, and these are elements
that can be dealt with, within the framework of the ..list-
ing plant. Another thing we can do would be to do in-
lake treatment, which would involve chemical treatment.
Another thing that shows up ia the modification of the
outlet of Long Lake Dam, which provides a deeper outlet,
which gets down into the deeper strata of that lake, and
possibly do some good things to get at one of our very
serious problems, and that is the lack of oxygon in the
deeper layer of the lake. Washington Water Power is in-
trigued that this could be incorporated into a fifth powor
base. It is a possibility. Another thing we looked at
ia water quality management areas like banning detergents
in households, and the ban would not yield a sufficient
cost savings because again we are squeezing	the
stage line of 85 percent, and it would cost the householder
more for a more costly detergent.
Looking at another thing, non-point control,
which is certainly a good idea in dealing with the lojiHnq
of phosphorus. The last thing which may bcs academic is
to do essentially an abandoning of the aquifer in tenia
of a no-action plan, recognizing that ultimately we are
going to deteriorate our ground water, where treatment
of that ground water. This would be extrentely costly.
JAMES E. STACK
COURT R*»0"Te»*
SPOKANE, WASHINGTON
19
-------
1
2
1
4
5
6
7
I
»
10
11
12
13
14
15
IS
17
It
1»
20
21
21
21
24
25
This is not a fictitious number. We are talking some-
thing around $300 million for a network treatment plant
to deal with very exotic removal of very difficult con-
stituents .
Another possibility along the same line would
a new source of surface water and transmission dis-
tributions into the existing water system.
With that, I will return to Robert.
* * * * *
ROBERT WUBBEMA; Just a quick summary. On the
bottom of the very last page is a flow chart that he re-
ferred to as the Water Quality Control Response Plan,
basically, we returned to Alternative A, and we laid out
a progran of utilization of the alternatives that we think
are moat practical at the local level in responding to
this. It's tine dependent and flow dependent, and not
dependent upon a specific standard in Long take. A final
decision will bo dependent upon the degree the decision
of the n?,\ in terms of the water quality requirements for
the local program.
So, with that X will turn it back to you.
* * * * *
LISA CCRBYN: I would like to introduce Mike
JAMES K, STACK
C9u"TMC»ORT£M
SPOKANE. WASHINGTON
20
1
z
3
4
5
6
7
•
9
to
11
U
13
14
15
16
17
It
I®
20
21
22
23
24
25
Rushton.
MICHAEL RUSHTONt I am going to speak from
here. If anybody has any problem, I will move over to the
podium. I will speak loud enough for everybody to hoar me.
EPA got involved in the project, in the
Environmental Impact Statement, back in January of l'JUO,
shortly after the facility plan proce3a was started, ar.J
the idea being that to prepares an environmental aoci.ii.ont
on this plan, simultaneously with developing a plan.
This is done in an effort to save tin.;, than doing an
environmental project analysis after it's done.
Scoping meetings. Two public scoping meetings
were held in Spokane during the last year, and we talked
about the EIS that was going on, and talked about the
facility plan, and these meetings talked ah cut the
environmental issues that had been raised in the earlier
parts of the facility plan, and sought public input to
what we eventually published as a Draft Environmental
Impact Statement. That document was distributed to the
public in February, shortly after the facility plan was
distributed.
Originally we had planned to have a hearing
on the document in March, the end of March, but because
of the Wasteload Allocation Study being completed, and
additional information being sought frora the facility
JAMES E, STACK
cotjmi nk.t>o»TCft
SPO«ANC WASHINGTON
21
-------
1
2
3
4
5
6
T
I
11
12
1}
14
15
16
17
II
19
20
21
22
23
24
25
planners, that hearing was postponed to tonight, so we
can take advantage of this planning Information that has
been developed here in the last few months.
The Draft DEIS, which the hearing is about
tonight, analyzed seven alternative*: the six that you see
on the wall, plus a no-action alternative, basically doing
nothing. The no-action alternative requires topics of
discussion in the DEIS, prepared by the Federal
Government.
The six action alternatives, which I will call
action alternatives are h through F, and some of those im-
pacts of those alternatives are common to each one, and
these are some of the more important environmental impacts
on the project. And, those alternatives would eventually
result in eliminating all the domestic waste discharges to
the Spokane River upstream of the City of Spokane at least
as far as the State Line goes. This includes the elimina-
tion of the Liberty Lake discharge.
This is obviously beneficial from both a water
quality and public health point of view to the river as it
flows through the City of Spokane, all of these alterna-
tives eventually allow for the servicing of up to 81,000
residents now living on the Spokane Valley Aquifer and
using the on-site community waste disposal system. This
impact, both septic tank and drainfield elimination is an
JAMES E. ST ACM
COU1T RtCONTCR
SPOKANE. WASHINGTON
22
1
2
3
4
5
6
7
•
9
10
11
12
13
14
15
IS
17
1*
19
20
21
22
23
24
25
obvious benefit, water quality benefit, of all six of the
alternatives.
All six alternatives will greatly reduce the
number of new on-site systems that would be Installed in
that area. And, the planning and eventual construction
of sewers and connecting sewers, fewer new hones in that
area would be going on a 3eptlc tank system. They would
be going onto a single collection system.
In order to construct those collection systems
out there, each Individual homeowner essentially connected
to that system would be faced with a cost of anywheres
from $3200 to §6600 through a local improvement district
for the wastewater collection system. Each would also
pay an undetermined fee of tying their house Into that
collection system. This Is In addition to any costs that
would be assessed to provide money or the major facilities
that we are discussing here in terms of major interceptors
and equalization basis.
I am going to run through briefly sore of the
more specific impacts that are related to each of the spe-
cific alternatives. The first alternative Is Alternative
A, which is the recommended plan in the Wastewater
Management Plan. As Bruce mentioned, it has the lowest
present worth cost of the six action alternatives, and I
won't go through the cost numbers since he has already
JAMES E, STACK
COut T RKPOMTtN
SPOKANE. WASHINGTON
23
-------
1
2
I
4
5
6
1
8
9
K3
NJ jg
W
11
12
13
14
15
1<
17
IS
19
20
21
22
21
24
25
done that.
Alternative 2 would increase the waste discharge
to the City of Spokane Treatment Plant from its current
32 million gallons per day to about 59 million gallons
per day by the year 2002. So, there would be a gradual
increase In the discharge from that treatment plant to
the river. This would increase the nutrients loading into
the river and would eventually stimulate the increase in
algae growth immediately below the outfall into the river
and also downstream impoundment. This increase will be
detrimental to the recreational uses of the river and
lake, and in extreme situations could be a public health
nuisance.
In low river flow and warm weather conditions
the effluent arononia and chlorine concentration could
exceed EP7» recommended criteria for protection of cold
water fish existing in that river. I am talking about the
cold water fisheries, which in this case, below the
Spokane City Plant are planted trout fish. Brown trout
and Rainbow trout, and they are planted.
The raw sewage storage reservoirs of Alternative
A, which would be 3 identified in the Comprehensive Plan,
is one in the Valley, an existing gravel pit, and there
would be on in the Indian Trail area, and the—lagoon.
'.iose storage areas will create odor and aesthetic Impacts
JAMES E. ST ACM
COURT
if>QKANE, WASHING T ON
24
1
2
1
4
5
«
T
•
9
10
11
12
13
14
15
IS
IT
18
19
20
21
22
23
24
25
in residential areas.
Alternative B, which is the separate treatment
for Spokane Valley, has a present worth cost of approxi-
mately $26 million more than Alternative A.
Alternative B would increase the wastewaters
discharge to the river. Actually it would split the dis-
charge to the river, some of it going to the City of
Spokane Treatment Plant and another discharge would occur
at the new plant near Felts Field. The discharge at Pelts
Field, which is upstream from the City, would detract from
the water contact recreation and aesthetic river uses
through the City of Spokane. It could also affect the
quality of City drinking water extracted near the river
downstream frora the proposed Felts Field aiscnarge.
The treatment plant location at Ti_lts is identi-
fied near Felts Field in the residential area.
Alternative C, which Is separate truatnent for
North Spokane, has a present worth cost of $"5.2 million
greater than Alternative A. It would incr&aue the waste-
water discharge from the Spokane Treatment Plant by about
23 million gallons per day by the year 2002. This is about
5 million gallons per day less than Alternative A. So,
you can conclude from that the impact of th,_- discharge,
or increased discharge on the Spokane River ill the way
down to bong Lake, downstroatn would b« slightly less than
JAMES E, STACK
COURT
SPOKANE. WASHINGTON
-------
1
2
3
4
5
6
7
8
to *
to
U> 10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Alternative A.
The land disposal of North Spokane's wastes would
eventually affect Spokane's aquifer on the northwestern
portion of the aquifer. But, the disposal is over the
area designated by EPA as the sole source of drinking
water supply for Spokane, so that would be an environmental
impact and contamination to the aquifer. It's also pos-
sible that eventually the percolating wastewater would get
into the Little Spokane River, which in turn feeds into
the main Spokane River. And, the disposal facilities
themselves would adversely affect the present open space
nature of the Butler Parkway area, so that there would be
some aesthetic impact frcm that type of operation.
Alternative D, which is a separate treatment
for both !Jorth Spokane and Spokane Valley, would be a
combination of what I have just mentioned earlier,
Alternative B and Alternative C. You would have the Felts
Field discharge, and you would have the Morth Spokane
land application which eventually would affect the Spokane
Valley Aquifer and the Ruther Parkway. The cost of
Alternative D wa3 about {35 million higher than Alternative
A.
Alternative E, which is land disposal of County
wastewater at Ruther Parkway, again it's in the riorth
part of Spokane, would have similar but proportionately
JAMES e. STACH
COUKT RCBOOTIR
SPOKANE. WASHINGTON
26
greater impact from the land disposal optratlon on the
aquifer in that area. You would have a larger voluni? of
water being disposed of through the gravel in that part
of the aquifer.
Alternative F, which is land disposal of all
City and County wastes doimctream into Stevens County,
wo are talking about S40 million greater than Alternative p.
It would take about 700 acreu of open space land for the
treatment and infiltration facilities; but, it would renove
most of the wastewater influences frcm the Spokane !>ivr-r,
with quality benefits to both the river and I.ong Lake.
This would benefit the use of the river ar.d remove public
health and aesthetic concerns.
Finally, the no-action alternative, vhich Is
do nothing, would have no immediate capital cost for waste-
water facilities obviously, and the only w.iat^ discharge
Increase to the Spokane River would be from vlio City*',
own expansion, or from Liberty Lake Sanitation District
Treatment Plant? but you would have a continuing problem
of the Spokane Valley Aquifer, of the ftxistir.ij septic
tanks out there with no action. You would have a con-
tinuing problem and potentially a significant problem In
the future with the drinking water supply over the aquifer
on the on-site disposal.
Now I am going to briefly touch on t.hn supplement. 1
JAMES E. STACH
court MePonre*
SPOKANE, WASHINGTON
27
-------
I
i
1
4
5
6
7
¦
NJ 9
fO
10
11
12
13
14
15
IS
17
IS
19
20
21
22
23
24
21
nubalternativea that Bruce mentioned, that are really
sufaoptions of Alternative A. And, we don't have a detailed
analysis of these alternatives at this time. I will give
you a survey, a quick sketch of some of the things that
we came up with in the last week that we are considering
about these subalternatives.
Alternative A-l is seasonal phosphorus removal,
t/nder this option the increased discharge of nutrients
to the river would increase algae production both in the
river and downstream impoundments. This includes Long
Lake and the Spokane arm of Lake Roosevelt.
Preliminary information presented in the
Waste load Allocation Study indicates that the algae levels
would eventually exceed—that report identifies a desir-
able algae level—and Bruce again went over the costs,
if that phosphorus removal occurred in seven months rather
than twelve, the and OSI-1 cost savings is projected to be
about $565,000 in the year 2002. The other water quality
and fisheries impacts associated with Alternative A,
in terns of ammonia toxicity and chlorine toxicity, and
so forth, would be similar in A-l as in A.
A-2, which is the seasonal 3torage option, has
two suboptions: either power production, or land irriga-
tion. Mostly it requires construction of a dam and
reservoir in Old Trails Canyon in West Plains area and
JAMES E. ST ACM
court xr.fl.Tt.
SPOKANE. WASHINGTON
23
1
2
3
4
5
6
7
<
9
10
11
12
13
14
15
l<
17
II
19
20
21
22
23
24
25
those sites are identified as suitable for that purpose
in the Corps of Engineers study; and thu wastewater dis-
charge to the river would remain at currant levels unless
power generation was adopted, and then all flows above
32 million gallons per day would be discharged back to the
river after the secondary treatment, during the five-i,.or,th
powar generation season. This would lit- basically ir. the
winter months. And, this eventually would generate up
to about 30 million gallons per day back into the river
after the powar generation occurred. And, powar genera-
tion estimates were somewhere between 1,000 and 2,00ft
kwh of electricity, but would also require sizeable energy
input to pump up to the storage area in tho first place.
There hasn't been a major analysis of the cost
ratio of pumping it up and letting it run \„-,ck down, «t
least in terras of energy.
If the crop irrigation suboption of A-2 wero im-
plemented, you would have—I forget the amount of v.wte
flows from Spokane—going to irrigation of ctopk in	the
airport area. This would be beneficial	and
would augment the scarce water supplies in tha '.-'.;st	Plains
area; a group capital cost ranging froi.i $13 to $40 million
from power, or land irrigation.
Subalternativa A-3 modifying the Spok.r.io
Treatment Plant to meet water quality criteria. If	you
JAMBS E. STACH
CQuWT
SPOKANE. WASHINGTON
29
-------
T
2
3
4
5
6
7
S
fO 9
ru
U1 to
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
2$
went through offluent filtration to reduce phosphorus
load from the plant, it would coat about $10.9 million.
This would ba consistent with what the Kaatelond
Allocation Study Identified as maintaining an average
chlorophyll concentration of about 10 micrograms in Long
Lake. This la fairly similar to what Long Lake is at right
now.
If the phosphorus removal is not increased as
the SpoV.ann Treatment Plant discharges increase, thare will
be a gradual increase in algae standing crop in Long Lake.
The second treatment plant modification we looked
at u&a dechlorination at a cost of about $360,000, and
what this would do is reduce the chances of occasional
fish hills in the river that might occur from high chlorine
residuals and concentrations in the river, especially
during low flow periods, and warm periods In the summer
months.
tat"., similarly, the ammonia removal process
could be adde-i to the plant for *bout $1 million, and
would have the same basic goal in mind of producing less
toxicity in the river, and would benefit the fish popula-
tion in the river.
Alternative A~4, lake treatment. There haven't
been any detailed costs or operational plana developed
for that yet. Bruce nentioned what they have been thinking
JAMeS E. STACH
COM" * *«»©*f(*
3POHANC WASHINGTON
JO
2
I
4
5
C
7
f
9
10
11
12
13
14
15
U
11
IS
19
20
21
22
23
24
25
abouti the chemical treatment, some modification in the
outlet structures to the dam down below. But, there really
isn't sufficient Information right now to do much as far
as determining the impact of that particular plan.
A-5—water quality management strategies. Bruce
mentioned the phosphate soap ban and so forth would all be
aimed at reducing phosphate levels in the river, obviously
to benefit the water quality situation in the river down-
stream, in the City of Spokane.
I "think that is about all 1 will say now, other
than the fact that the final EIS is going to give more
detail to the mutually developed suboptlor.s that we are
talking about here at the last of the meeting. It will
bo covered in more detail in the final EIS.
* # * * ~
LISA CORliYN: Me will proceed to the second part
of the hearing, which is to take oral testimony and got
your comments. Again, I would like to ask '..hat you come
up and state your name and address, and if you have an
affiliation, your affiliation. I will go down the list.
If anybody would like to make a statement, please talk to
Charlie in the back, and he can bring up the card to me.
Again, the court reporter has asked that we take a recess
at about 9:00. So, we will comply with hia request, and
JAMBS S. STACH
count
SPOKANI . WASHINGTON
31
-------
I
z
1
4
5
6
7
I
M »
K>
ST> 10
11
12
13
14
15
IS
17
IS
19
20
21
22
21
24
25
if wa are not completed by then, we will take a short
recess and come back and continue with the testimony.
And, with that, I would ask for Glen Take.
GLEN YAICE: I am Glen Yake, Manager for
Engineering, for the City of Spokane, 303 City Hall,
Spokane, Washington 99201.
Thank you for the opportunity to present the
City of Spokane's views concerning the subject of the
wastewater management in the greater Spokane metropolitan
areas. Wo will limit our presentation to the broad con-
ceptional ideas that are embodied in the County's 201
study. In the late 1960's, the City was advised that
it's upgraded primary treatment plant was Inadequate and
increased treatment to secondary level was needed. The
final order required not only secondary level treatment,
but 85 percent phosphorus removal.
The City proceeded with State and Federal
financing assistance, and built its present treatment plai
Additionally, we were told that we now had a regional
plan which would be capable of serving areas outside of
the certiorate boundaries. Tha City then proceeded to in-
vest $50 million of the local. State and Federal funds to
produce this mandated regional advanced wastewater
treptment plant.
JAMES E. ST ACM
COUNT
SPOKANE. WASHINGTON
32
Meanwhile, the County was faced with a reoccur-
ring problem in the metropolitan area, and the County pre-
pared to attack the problem in the metro area north of
the City. The plan contemplated a County-owned collertion
system with a treatment at a site along Ruther Parkway.
However, two actions showed this work.
First was the previous declaration that the
City's wastewater treatment plant was a regional facility.
This, the County was told, meant no Federal funds could
be spent to'build another plant in the area.
Second, During the preparation of tha County
plan, EPA had declared the Spokane Valley/Jsathdrum Prairie
Aquifer a sole source aquifer. Since the boundary ex-
tended north of tha Little Spokane River to the proposed
land treatment area along Ruther Parkway, It wjj not
acceptable. These actions by the Department of Ecology
and the Environmental Protection Agency encouraged the
City and the County to enter into an -agreement and con-
duct the study here.
As a part of this work, the City and the County
entered into an inner local agreement for the City to pro-
vide sewer service to the County under a mutually satis-
factory condition.
All of these past actions have been at the
prompting of tha Department of Ecology and the Environment*
JAMES E. STACH
COUNT	HT(h
SPOKANE. WASMiNOTO*
33
-------
1
2
3
4
5
6
1
I
NJ 9
to
-J 10
11
12
11
14
15
16
17
It
19
20
21
22
23
24
25
Protection Agency in a mutual effort to protect the sur-
face and the ground waters from contamination. The City
has participated in the 201 Study with the County and con-
curs in the recommendations of the report. A disturbing
action, however, has cone about in the last two months
that has a great potential for eliminating the benefits
to be derived from the City and County's inter-local
agreement: This is a publication of the Department of
Ecology of the Spokane River Wastewater Allocation Study.
A channel view, or a careless interpretation of
the study could lead one to believe that the City will have
to place a moratorium on new sewer connections through
its sewage system. If thi3 interpretation would prevail,
there is no way for the County to connect to the existing
City's system.
The only other apparent solution is either a
multi-million dollar addition to the treatment plant to
increase phosphorus removal efficiency above the 85 per-
cent level, and/or even a more .extensive construction of
the land disposal system. Both of these alternates appear
to be beyond the range of financial capability.
The City urges that tha EPA and the DOE focus
its attention on the Spokane Valley/Rathdrum Prairie
Aquifer. The impression that one gets from reading the
River Allocation Study is that the Department of Ecology
JAMES e. ST ACM
COURT RIPOITCN
SPOKANE. WASHINGTON
34
1
2
3
4
5
S
7
$
9
10
11
12
13
14
15
K
t7
IS
19
20
21
22
23
24
25
has spent a considerable time and effort in evaluating
tha Spokane River quality to the exclusion of the aquifer.
The City ia gravely concerned that the River Allocation
Study not only places the protection of the aquifer In
jeopardy, but also threatens the City/County cooperative
spirit and the recommendations of the 201 Study being
considered here.
I	The City recommends, therefore, that the
Department of Ecology and the Environmental Protection
Agency approve the Comprehensive Wastewater Management
Plan and place the design and construction of the facilitle
outlined by the State and Federal priority list. Tl.ia
will allow the area to jointly and rapidly proceed on a
development plan towards protection of both the Spokane
River and the Spokane Aquifer. If approval is not granted,
the opportunities for meaningful progress will be dim-
inished. Years will pass before citizens of this com-
munity will be presented with an opportunity to support
or reject a program as well conceived, described, reason-
able and tangible as the one before then now.
Thank you.
# # # * *
LISA CORBYN: Thank you. I would like to
ask Larry Esvelt to come up here.
1
JAMES E. ST ACM
count »C«»0«TE«
SPOKANE, WASHINGTON
35
-------
1
2
3
4
5
6
7
S
M »
NJ
00 10
11
12
13
14
15
1«
17
18
19
20
21
22
23
24
25
LARRY ESVELT: Thank you. My name is Larry
Esvelt. I renide at East 7905 Heroy Avenue in Spokane,
99206. That is in the Spokane Valley and near the City
of Millwood. I am the owner of Esvelt Environmental
Engineering, and I was fortunate to have participated in
the Water Quality Studies of the Spokane County 208 pro-
gram, which addressed water quality management for the
Spokane Valley-Rathdrum Aquifer.
I would like to at this time just remind every-
one that the findings of the study were essentially as
follows: One, that the water, the surface water and
water that applies to the surface of the ground over the
aquifer does percolate to the Spokane Aquifer. It car-
ries with it a pollutant of any kind that is placed or
disposed of on the land's surface.
Secondly, that the Spokana-Rathdrura Prairie
Aquifer has degraded from its original quality based on
comparison of historical data with data acquired during
the 203 study, also based on variations both laterally
and vertically of water quality within the Spokano-
Rathdrum Aquifer.
Thirdly,' that we concluded that the predominant
degradation of the Spokane Aquifer was occurring because
of urbanization and urbanizing pressures.
Fourth, a significant quantity of the pollutants
JAMES E. STACH
COUAT•e»OATl«
SPOKANE. WASHINGTON
36

from urbanization were incorporated into sanitary sewage
which is disposed of over the aquifer through on-site
disposal systems.
1 would like to present now a couple of new
findings that were not available, incidentally, cor prep-
aration of the EIS, which is under consideration toniijht,
based on ongoing monitoring data that has been acquired
by the Spokane County Health District. A comparison of
trace contaminants indicates a further degradation of
aquifer water quality in two comparative areas. Or.e,
the ongoing monitoring data compared with data acquired
by the same laboratory from the same wells. The l.-»;,orator^
that conducted the test was the Department of Social and
Health Services' laboratory in Seattle on the ten ccmr.ara-
tive wells at comparative times of the year. All of the
mean values for nitrate nitrogen have increased between
the two sampling periods. And, theae sampling periods,
incidentally, were 1971, '72 to 1980/81. Those are the
periods when the DSHS samplings were run.
Eight of the ten were slightly greater at the
80 percent level, and six of the ten were slightly greater
at the 90 percent significant levels.
Conductivity. Nine of the ten wells showed
an increase of conductivity during these comparative sampl-
ing periods; seven of the ten had greater than the 30
JAMES E. STACH
COURT RCPO«T(N
SPOKANE WASHINGTON
37
-------
1
2
3
4
5
6
7
i
»
10
u
12
11
14
15
IS
17
It
19
20
21
22
21
24
25
percent significance level: and six of the ten, again,
greater than the 90 percent significant level.
Secondly, the data was compared with the 208
data taken just two years earlier. There were eight com-
parable walla compared at the same time of the sampling
during the year. Nitrate nitrogen increased in six of
the eight wells, and four of the eight increases were
greater than the 30 percent significance level.
During the 208 Water Quality Studies one well
was taken out of service because It exceeded drinking
water contaminant drinking level, and that was detected
during the 208 water sampling. Since that time an addi-
tional well has been taken out of service, and the muni-
cipality that owns it is in the process of replacing it
now. Both of these wells are in what is called the
West Valley area in the vicinity of the cross-section from
Millwood to Dishman.
The aquifer la at a depth of approximately
40 feet in this location. The implication is that the
pollutants are breaking through the overlying alluvium
into the aquifer in our current time frame.
Incidentally, the Panhandle Health District
recently closed a well In the City of Rathdruia for exactly
the sane reason—that the increase of pollutants have taken
it beyond the drinking water standards.
JAMES E. ST ACM
COUNT RR«0«TE«»
SPOKANE. WASHINGTON
38
1
2
1
4
5
6
7
t
9
10
It
12
11
14
15
16
IT
t«
19
20
21
22
21
24
25
Referencing the EIS under question, I would like
4
to concur with their summary under the no-action intact,
that the aquifer water quality has degraded and will con-
tinue to degrade with no-action alternative. 1 concur
with the assessment that the proposed sewering effort
would create a positive change in aquifer water quality.
The EIS indicates a negative impact on the
Spokane River quality especially in the Long Lake area
from the loading of phosphorus. The loading of phosphorus
has increased. I would like to reinforce the cautions
that have already been placed and will be placed tonight
on misinterpretation of underlying assu-iptions that were
placed into the Waste load Allocation Study to derive tills
conclusion.
I had a long and very gratifying relationship
with a citizens' committee that was seated to rwiew
the 208 program, and to come up with recommendations tased
upon the 208 findings. I would like briefly to sumr.<>rile
soma of their actions, especially with reference to the
particular items in question tonight. They did address
the relative priorities for water quality in the Spokane
area, and in my interpretation unequivocally expressed
themselves that the aquifer, which is the drinking water
for the area, to take priority over other waters in the
area, although they did express concern for an overall
JAMES E, STACN
coguf *£«"OBT|*
SPOKANE. WASHINGTON
39
-------
2
1
4
5
e
7
a
9
10
11
12
13
14
15
IS
17
18
I?
20
21
22
2)
24
25
environmental quality for the Spokane area.
Included In their recommendations were the
following! One, that no further degradation of ground
water quality occur. Secondly, that the control of known
and potential sources of pollution to the Rathdrura
Prairie, the Spokane-Rathdruro Prairie Aquifer, be a means
of controlling the aquifer quality.
Specifically, they recommended collection of
all sewage and treatment so the discharge of pollutants
could not enter the aquifer. Further, that this be accom-
plished through development of a central sewer planning
and sewering of all areas that are urbanized was recom-
mended. For the Spokane Valley area specifically, they
called for central sewer planning; that interim industrial,
commercial, multi-family, multi-residential wastewater
facilities be intercepted as soon as possible; that new
developments be provided with sewer connector interceptor
3yste.-r.sj and that all new and Increased sewage discharges
to the Spokane River upstream of the recharge area for the
aquifer be banned.
Finally, they recommended that the means for
implementation of sewering existing single-family resi-
dences with on-site disposals be the initiation by govern-
mental entities for action by the homeowners to conduct
their own sewering opportunities, in other words through
JAMES E. STACK
COURT HtPOIirC,
l«QK*Nl, WASHINGTON
40
1
2
3
4
5
6
7
«
9
10
11
12
13
14
15
16
17
It
19
20
21
22
23
24
25
tha LID process.
As a most recent action, the Citizens Represen-
tative Corps Committee, which was comprised of residents
of the Spokane area, and that occupied a wide-range of
interests and a wide geographical distribution that covered
almost the entire metropolitan area, including Idaho—
they raccnnended in February of this year, or they resolved
rather, to confirm their conviction that drinking water
quality should take the highest priority among alterna-
tives considered in the Comprehensive Wastewater Management
Plan, and that the recommended alternatives of sewering
tha aquifer sensitive area should be implemented in a
timely manner as possible.
That concludes my statement. Thank you.
* * * 4 #
LISA CORBYN: Julie Coelho.
JULIE COELHO! My name is Julie Coelho.
South 2406 Timber Lane in Veradale,, and I am speaking
for the League of Women Voters.
The League of Women Voters wishes to commend the
different agencies on their prompt action in developing
the 201_Wastewater Management Plan.
t I	However, even though we view tha aquifer protec-
tion as a high priority, we feel we must bring up two
JAMES *. STACK
count wipowte*
SPOKANE WASHINGTON
41
-------
1
2
3
4
5
6
7
S
M »
CO
M 10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
25
j other concerns. The first ia the lack of any regional
solution to this problem between Idaho and Washington.
Neither State can protect this valuable resource alone,
and we urge a two-state agreement before a sewer plan of
this magnitude is approved.
^	The second concern is the sprawl projected over
the aquifer in the Generalized Comprehensive Plan. As the
Land Use Plan has no mechanism to contain development
to fill in areas—possibly the Wastewater Management
Plan should contain ways to accomplish containing sprawl.
We base this feeling on the time lap already experienced
in the North Spokane Sewer Plan.
Again, we commend you and hope you will Improve
the plan by using our two suggestions.
Thank you.
LISA CORBYN: Joan Honican.
JOAN HONICAN: My name is Joan Honican, South
3904 Bov/dish Road. I did prepare a statement, but I think
it's probably too negative based on my experience in
Spokane County to even submit or subject this audience to.
So, I'm going to submit it for the record.
I have attached numerous questions, documentation
of local atrocities. I think that this will help fill the
JAMES E. STACH
COUNTBEPORTtR
SPOKANC. WASHINGTON
42
gaps in some of the local data that was missing in your
EIS. And, with that, I will save my questions, I suppose,
for the question session.
Thank you.
LISA CORBYN: Joanne Venneraa.
JOANNE VENNEMA: My name is Joanne Vennena,
930 East 19th in Spokane 99203; and I came tonight to
speak just as an interested citizen who, over a long perio-i
of years, figured it out—34 years—and has been very con-
cerned about our aquifer and the protection of it, and
have seen the actions in this County move, to my mind,
very, very slowly, but it is moving at this point, and
we have come up with a Wastewater Treatment Plan which I
feel is well thought out, and adequate, and should nova
to implementation as soon as possible.
And, I would like to second Mr. Yake's statement
to ask for your approval as submitted, and to place it
high on your developmental list so that we may get on with
the business of protecting our resources of our drinking
water, and to handle our other problems which have been
presented.
So, I am a little, should I say, suspicious of
some of the data on the problems which have come up at
this late date, but that they would be handled in a
JAMES E. STACH
COUNT R(»0*T(l
SPOKANE. WASHINGTON
43
-------
I
z
i
4
5
s
7
t
9
10
11
12
13
14
1$
15
17
11
19
20
21
22
23
24
25
reasonable manner along the lines to meet our service
water quality standards.
Thank you for your attention.
* * # ~ *
LISA CORBYN: Sally Reynolds.
SALLY REYNOLDS: I an Sally Reynolds,
Route 2, Box 776, and I am speaking oil behalf of the
Glenrose Association. The Glenrose Association repre-
sents more than three-fourths of the homes in the Glenrose
community. Wa have been formally organized and involved
in the land use issues for nearly ten years. We have
traditionally supported the well-planned growth and pro-
tection of resources, including ground water quality.
I have a question to ask. I did not realize
tonight's hearing would be on the sewer plan as well as
the Draft EIS. Do I submit written comments on the sewer
plan to the same location, the same address. Region 10,
in Seattle?
LISA CORBYN: Yea.
SALLY REYNOLDS: Thank you.
LISA CORBYN: If there are other places
the EPA needs to get them, other appropriate people, we
will forward them.
SALLY REYNOLDS: thank you. I would like to
JAMES E. ST ACM
COURT P>(PO»TI«
SPOKANE, #ASM*NGT0N
44
mention before I make my comments that I had a great deal
of difficulty in obtaining a copy of the Draft EIS. It is
not at the Public Library. I wrote in ear!y April and was
informed that I could find It at the Public Library, or I
could contact Tom Hosier. I contacted Tom after several
phonecalls to ascertain that it was not at the library.
Their copies were in short supply as well.
Copying costs would have been approximately 10
cents a page that size. I was finally able to borrow a
copy from one of the planners, but I do have two suggestion
for public officials to avoid this kind of thing in the
future.
I would like to suggest that you keep a current
list of interested groups and individuals; and, two, offer
them the opportunity to order publications at cost, prior
to printing perhaps, with notification through a postcard
even prepayment.
Now, with regard to the Draft Environmental
Impact Statement itself, there are numerous areas of
concern and conflict that are identified, and riany appro-
priate and sound mitigating measures are suggested.
There appear to bo some gaps that I have questions about,
however. One, the failure of the DEIS to mention the
City of Spokane Doyle (phonetic) Report i3 puzzling to
me in view of the acknowledged commitment to sprawl in
JAMES e. tTACH
tOUBt HIOOIIT1R
SPOKANE. WASHINGTON
45
-------
I
2
J
4
5
6
7
S
9
10
II
12
13
14
15
16
17
IS
19
20
21
22
23
24
25
both tha Spokane Conference Plan and the 201 Plan, The
additional suggestion of growth and utility extension in
tha West Plains area adds a significant dimension on the
land and utility commitments, and economic considerations.
Interrelated matters. Secondly, the alternative
of encouraging growth to the west and discouraging growth
over the aquifer area, which was suggested by some profes-
sionals in response to the County's Comprehensive Plan is
not addressed at all, and it's disappointing that this
alternative has not been suggested or explored in the
DEIS.
Three. The Draft EIS only addresses briefly
the broad economic cons iterations that accompany the 201
Plan. Under the proposed sprawl plan the ultimate eco-
nomic burden on taxpayers after lateral hookup fees could
be enoraous. This is especially important in view of the
overcommitment to low residential growth, since it's widely
acknowledged that such growth does not pay its way in terms
of supporting the local governmental services.
And, four. There is no mention made of the
life expectancy of the system. I have always understood
that such systems do have a limited life expectancy, after
a period of time neeps begin to occur.
Now, my cocar.ents on the sewer plant itself.
With respect to the Olenrose community, the Draft EIS
1
2
3
4
5
S
7
t
9
10
11
12
II
14
15
1*
17
!•
19
20
21
22
23
24
2$
10
correctly points out on page 142 that there arc- conflicts b
tween the priority sewer service area and the County
Glenroae Plan. The Draft EIS suggests that these areas
be left out of the PSSA. The Glenroae community 3tron.|ly
concurs with that suggestion.
We believe—and these are general comments on
tha plan—we believe that the 201 plan as It now stands
needs to bo sized down and tightened up to ta politically
and economically acceptable for consideration as a bond
issue. Among the most important reduction of sprawl and
PSSA size, consistency with the County Land Use Plan by
changes in both tha 201 Plan and the Land Use Plan as neces
sary, consistency with the stated goals of both the County
Land Use Plan and 209, better coordination between the
governmental entities, particularly the City ami the
County, and the State of Idaho, measures to protect prime
farmland and provide adequate, open space, ana recreational
land and other amenities, and also means of protecting
aquifer water quality from contamination.
Thank you.
LISA CORBYN: Thank you. He have about
five minutes to 9:00, and what I would 3 ike *-.
-------
K>
GJ
20
2t
22
23
24
25
about a 10-minute recess to give the court reporter a
break, and then we will come back.
(After the recess the public
hearing continued.)
LISA CORBYN: I would like Margaret Portman
to come up and give her presentation.
MARGARET PORTMAN: I am Margaret Portman.
My address is East 13503 - 2Rth Street, 99216.
I have served on the Citizens 208 Committee, on
the 201, and the Wastewater Allocation Study for the river,
so I have been to more meetings on this subject than I can
probably recount. Needless to say, I was one who approved
the selection of Alternative A in our citizens committee,
thinking this is the way to no.
One of the things that I thought wa3 the most
heartening was in reading the EIS statement on page 149.
There is a very significant statement:
"The wasteloads in urban runoff can be
just as damaging to surface and ground
waters as sanitary wastes if not prop-
erly managed."
And, this is further developed in the EIS. It explains
that the 208 recommendations which are contained in full,
in Appendix C, and are part of the recommendations that
our 208 committee worked long and hard on, and that these
JAMES E. STACH
COURT REPORTER
SPOKANE. WASHINGTON
48
should be implemented. My feeling is that while I am
wholeheartedly in favor of the sever plan, 1 think thi:;
should be concurrent with it; that we do imed protection
for the urban runoff because it can be just as serious
a problem. Many people are even speculating at this
point that the sewer in the Valley will being an influx
of people which vie really hadn't anticipated, because it
will be a help to the developers; and	ere tho prob-
lems of urban runoff will probably escalate at a vc-r/,
very rapid rate. And, wo need to think in terms of all
of the measures that we possibly can take--probably a
collection system and disposal of urban runoff lan1t oven
a reality, but there are measures that ore tujgested in
the 208 management recommendations, d.vl t.hii.e cert.ui.nly
should be put as a requirement along with the ujnitary
sewer.
I think one of the things that one of us who
served on the 208 citizt-ns committee was i.'.ut proud of
was the fact that very early on the citiinai coi.mitteo was
the one that came out in favor of the nomlegradation goal
for the aquifer. We worked long and hard on the: wording
of this, and we adopted this as a goal against which all
of our reconvnendations and all of our decisions in the
management plan were evaluated.
This certainly should be kept uppenno«t. In fact
JAMES E, STACH
COURT RCPORTCR
SPOKANE. WASHINGTON
49
-------
1
2
3
4
5
6
7
«
NJ »
UJ
Ui 10
It
12
13
14
15
t«
IT
IS
19
20
21
22
21
24
25
I think one of the most disheartening things I felt when
I attended the ground water hearing in Denver in January
listening to the head officer say that EPA had devoted
about 90 percent of its time, money and energy to surface
water, and now they realized that 50 percent of the people
in the country drink ground water, and suddenly we haven't
done the study on ground water that we should have done.
We are ready and willing to do the job to protect this
valuable ground water here; but, we do need some help, and
part of it is the necessary ongoing testing and that kind
of thing that has to be done, plus the protection from
urban runoffs, spills, storage of critical substances,
and all that kind of thing. And, we feel—and X think 1
speak for the 208 committee in saying--that our greatest
concern lis that we hold tlila nondegradation goal high in
all decisions that we make.
Thank you.
* * * A *
LISA COREYN: Dan Knlerim.
DAS KNIERI.M: My name is Dan Knierim. I
live at 4130 Sundown Drive in the Valley, and I am not here
representing any particular group, although I am affiliated
with several.
I have just a few spoken comments to make, and I
JAMES E, 1TACH
COURT BBPORTCR
S*OKANS, WASHINGTON
50
a
i3

would like to submit a written comment after 1 get a char.ce
to look at the Draft EIS, which I also had trouble finding
a copy of.
I think the studies and the proposals have l;<;en
well thought out within the limits of alternatives that
they started from, but It 3eems to me that there are seve-
ral occurrences that were not considered that I would like
to see considered. One of them is to restrict the priority
sewer service area to a smaller piece of the Valley in
particular, .and to restrict the development outside that
area, either simply banning further on-site disposal, or
requiring possibly high-intensity or high-level local
treatment for developments outside the area of sewering,
or possibly incorporating the possibility of composing
toilets of the nonsurface disposal by biological disposal.
And, I also think that composing toilets could
be considered as a possibility even within the sewered
area, within areas that currently would need sewering just
due to the existing density in order to reduce the neces-
sity for sewering.
I aslo think that part of the proposal could be
to skip the future density. One of the impacts of the
proposal is to encourage development, low-density develop-
ment over the sewers areas, in particular over the Valley
rather than over the West Plains because that wouldn't be
JAMES rn. STACK
count «c»e*iTCR
SPOKANE. WASHINGTON
51
-------
•1 sewerage until later. Perhaps the sewering could be
accelerated over the West Plains and combined with re-
stricted sewer area over the Valley.
That would end my spoken statement.
LISA CORBYN! Tom Hogara.
TOM ROGERS: My name is Tom Rogers, East
10820 Maxwell, 99206.
I am probably 150 years too late on this. I
apologize for that. I had no control over it. I have
the firm belief that if biologists had designed our
sewage !,/ntera in the first place, we wouldn't be talking
about any of these plans here at all. Unfortunately,
somebody else designed it. I don't know, I understand
even the Romans had a system like this, although we are
kind of copying the Romans, even though the Romans dis-
appeared somewhat after the dinosauers. To meet our pre-
sent means of handling sewage just doesn't make sense
biologically, ecologically if you wish. It's grossly
wasteful of resources. There should be no such thing as
wastewater. There should be no such thing as human waste.
I don't mean that we shouldn't go to the bathroom, I mean
these things are resources. It's no wonder that we are
running out of fertilizer. The farmers scream at the high
JAMES e. ST ACM
COU»T
SPOKANE. WASHINGTON
52
1
2
t
4
5
6
7
•
9
10
11
1Z
13
14
15
IS
I?
t*
19
20
21
22
21
24
25
cost of fertilizer. You know where the fertilizer goes.
It goes down the toilets, that's where it goes. That's
where it is.
A couple of nights ago this program here on
channel 2, about these new ideas. He was talking about
building these living places out in space, orbiting the
earth, you know, because we are running out of space down
here, you see. He is going to build these whole living
communities out there, but he says everything will have
go be recycled, obviously. Everything will ba recycled.
Well, even industrial waste instead of throwing them down
the sewers—someday we will have to recycle all of those
and reuse them. But, I bet we don't. I bet we throw them
away. And, of course, an awful lot of them are toxic.
As far as the wastewater and the human wastes,
which are resources, are concerned, we take one resource,
water, mix it with another resource, human waste, trans-
port the two of them many miles to an expensive sewage
plant, separate both, and throw there both away. To me,
well, to put it mildly, It just doesn't make sense.
I mentioned this thing here several months ago
at a previous hearing of this. I don't expect it to make
any impact on the way we do things, but I do have to speak
out anyway, because I think the whole systen as we have
gotten into it, it just doesn't make sense. However, I
JAMES E. STACK
COuHTKICOnrgB
SPOKANE. WASHINGTON
53
-------
15
think I am just a voice crying in the wilderness, if you
will forgive the expression. I don't expect to be lis-
tened to. I am rather synical about it, but I really think
that I'm not the only one in the world that thinks this
way by any means, and I'm not an authority on it by any mea
Sweden has not put a man on the moon, but Sweden
has a legal composting toilet over there, and in some place
in this country it is legal. I understand in this county
we can get a permit if there is no other way available,
we can get a permit, and there are a few existing in the
County, Or. Gibson of Eastern Washington University
Biology Department—I talked to him a couple months ago
about it. He had some experience with them. He made the
statement that he thought that wa could shift over to the
method of taking care of our human waste and it would be
considerably less expensive than the sewage system for
domestic waste; and then, of course, at the same time it's
going to save a lot of water, it's going to save the
fertilizer. It should be put back on the land for use in-
stead of being thrown away.
So, I would really like to see the County invest
a little, the County and City invest some money into
looking into this possibility. I would like to see them
do a little research on it for a few thousand dollars.
They could try this. They could try seme of these. Of
JAMES E. STACM
COUHT K|*OHTIM
SPOKANC. WASHINGTON
54
1
2
i
4
5
6
7
S
9
10
11
12
13
14
15
t<
17
IS
1»
20
21
21
21
24
21
course, maybe you don't know what a composting toilet is.
It'a an aerobic system. You depend upon bacteria to
break down these so-called wastes. It's not stinky like
a septic tank which is anaerobic. It takes place without
free oxygen. And, the aerobic process is sealed up so it
doesn't smell up your house, and it does not require vater.
When you get all through with it, you have some fertilizer
that you can put on your garden, excepting the difficulty
is that since our foods, practically all of it comes from
way out in the country someplace, a city is a ecological
monstrosity, I guess you might say. It's not self-
sufficient at all. So, our food comes from far away.
Well, that waste ought to be put back on the soil.
So, I think it would be a more economical way
to do it as dry waste than to transport it with mi]lions
of gallons of water, and to pump it out someplace. The
dry waste should take a very small amount of energy to
transport, compared to all that water when we want to
pump it out that way.
I think we ought to be at least giving a look
at this sort of thing, but we seem to be no committed in
our thinking that we don't really want to change. When
we look at the big cost of sewering this whol« area,
the big cost, I think that alone should tell ua that there
must be something fundamentally wrong in our basic concept
JAMES E. STACH
COUflT RCPOMTCft
SPOKANE. WASHINGTON
55
-------
1
z
3
4
5
6
7
t
NJ 9
UJ
00 JO
11
12
13
14
15
16
17
It
19
20
21
22
23
24
25
of placing all of our waste Into one central spot, and
then providing water and separating it, and throwing it
away. If any natural community were based on that—what
if all the deer had to go to the toilet and flush the
toilet, and have it all collected in a separate place?
My good heavens, you could see how ridiculous it would be.
So, I would like to see us look at some other system be-
sides this, which I consider unsound, biologically, anti-
quated, far too expensive. It's just too expensive in
money and resources.
Thank you very much.
* ft * * *
LISA CORBYN; Mauri Hagen.
MAURI HAGEN: My name is Mauri Hagen, 15418
Little Spokane River Drive,
I, like Mrs, Vtuntma have been at this for many,
many years. In fact, long before there were other studies
made, why soua of us were busy trying to do something
about this problen. Personally, I am getting a little
weary o£ talking about severs, and septic tanks, and
cesspools, and so forth. I would like to reach a point
where I could talk about nusic, art, or sex, or something
else for a change. But, anyhow, it does seem to be coming
to a close finally a little bit. It's getting a little
JAMES E, ST ACM
«t,eRTEH
SPOKANE. WASHINGTON
56
1
2
J
4
5
6
7
I
9
10
11
12
13
14
15
1C
17
II
19
20
21
22
21
24
25
closer.
I was a member and identified with thi; organiza-
tions that applied to the EPA for sole source classifica-
tion of the aquifer, and this started the ball rolling
really towards doing something about a sewer aystctu. ."r.
Rogers just pointed out that we have dona lots of funny
things, and there are problems that we haven't attempted
to solve, but as late as the close of the s,?.:ond MarJd War
there were over 4,000 toilets Inside the City limits in
the capitol. city of the world, Washington, D.C. There are
a lot of things that you don't like about outdoor privies,
but one thing that we are always assured of—vo knew where
the problem was. We never had any difficulty in identify-
ing the problem. How We do, of course.
I started with Bruce in the Amy corps stu'iy, and
I think that was seven years ago, or so, ana I don't think
that in that period I have mlosed mr>re than one or two
meetings of the Army Corps study, and Muh. the 218. And,
I have kind of faithfully hung in there, trying to solve
this problem, and trying to bring it to a conclusion so
that we can have public health protected in the community.
I also received a copy of the Draft t;tS , and I
read it, and I have even given it to some other people to
read it. And, it was lacking in some respects, and I think
Mrs, Reynolds pointed out those shortcomings v.iry welJ
JAMES m. STACN
COtf*? »£P0HT£S
SPOKANE, WASHINGTON
57
-------
lb
«7
awhile ago. In the Army Corps atudy they recommended the
Alternative A, and we thrashed that out for a long time.
We worked on all of the alternatives, and It did seem to
be the only viable one. But, some of us fought rather
hard against the Liberty Lake Sewer System that is in fact
planning to dump its effluent into the Spokane River at a
point where there is a number of interchanges in the river
and the aquifer from there to Monroe Street. And, I think
this is a very bad weakness. I think it could have been
addressed very carefully in the EIS. It wasn't. And, I
still think we need to take a real stand against the intro-
duction of sewage effluent in the river above the inter-
change axeas.
I am certainly opposed to the storing of raw
uewage in any gravel pit. My gosh, you might as well put
it in our drinking water as well. That's a stupid method
of handling that problem. There are gravel pits presently
right in the aquifer, and I think that's a very bad weak-
ness, and I think that neec*s to be spoken to very carefully
if you are going to store raw sewage someplace. It should
be in a vessel of some kind that's air-tight and clean.
As far as the phosphorus is concerned, I have a
feeling that we can have both a low phosphorus content in
this surface water and also have a sewage system for the
Valley as well. I don't think it's an either or else kind
JAMES E. STACH
COU»T XEPOPUH
SPOKANE. WASHINGTON
58
IS
of thing. I discussed this today with Mr. Arawjuiat. I
believe that it's possible to have both.
I also have some misgivings about any kind of
method of financing this thing, and I'm really kind of
concerned about it because I don't see at this point that
there are people that are Idealistic enough to vote a
bond levy for a project that is not presently botherin.3
them. This disturbs me soma. I think it nteds to bo done
and I certainly feel that people should be concerned enough
to do it ideallstically. In fact, there wasn't even a
single person that even gulped when the Highway Department
said it would cost 5130 million to build the North-South
freeway. They weren't concerned enough to holler about
that. But, the business of spending 590 million for
a sewer system to protect public health seas to te r«nklin
in the citizens.
I am not going to say any more on this at this
time, I am going to present a statement to the EPA.
Thank you,
*****
LISA CORBYN: Philip Kaufmaiin.
PHILIP KAUF»nMNs My nar.ie ia Phil Kaufnann.
I work for Michael Kennedy Engineers, who vjs responsible
for providing technical input to the Liberty Lake Sewer
JAMES E. ST ACM
COURT *EPO«T(«
SPOKANE. WASHINGTON
59
-------
H
District in their response to the Draft EIS. I would like
to preface my comment with a statement that we in the
sower district have certainly in the present and in the
past supported the general concept of sewering the aquifer
sensitive areas. We carefully reviewed the County
Comprehensive Wastewater Management Plan EIS and have
several concerns. Some of these have been responded to
in the Volumes I and II of supplemental studies, so I be-
lieve that my comments will still be germane perhaps to
a discussion of subalternatives of Alternative A. We have
already submitted written, formal written response, and
I'll outline three broad areas of concern that we addressed
in those comments.
We feel that the present condition of the
Spokane River is not adequately described in the EIS, es-
pecially with respect to toxicants such as ammonia and
chlorine and how these affect the river fishery. A brief
review of water quality at Riverside State Park, downstream
of the present Spokane treatment facility, suggests that
the river is not presently resting designated Class h
stream water quality standards.
We feel that the EIS water quality and fishery im
pact assessment procedures are generally unconservative.
In moat of the water quality predictions, the mean
river flow (7570 c.f.s.) Is used in wastewater dilution
JAMES E. STACH
cou«r «e*»o»rcft
SPOKANE. WASHINGTON
60
H
ic
calculations. Typically, river flows in the critical
summer and fall seasons are near 1,000 c.f.s. for extended
periods of time. The impact of the wastewater discharge
should bo assessed during a time-weighted average flow or
a typical summer flow to more accurately depict "average"
water quality conditions. The acute effects of toxicants
should as well bo assessed using dilution calculations at
very low river flowa.
The effects on relatively nonmobile organisms
such as stream insects should be assessed in the zone of
dilution during typical flows and low flows.
Our preliminary calculations show that effluent
dilution, unionized ammonia, chlorine residual, algal
nutrients, and several "toxicant concentrations would not
be in compliance with water quality standards ir. the river
downstream of the proposed Regional Wastewater Treatment
facility.
Because of the method of water quality assess-
ment used in the EIS, we feel that it docs not contain
information necessary and sufficient to predict floral,
faunal and recreation impacts resulting from tha proposal.
Our last overall concern is that—and this has
been addressed I think in the supplemental alternatives—
is that we feel that the land application alternates pre-
sented in the EIS do not exhaust the possibilities reasonat
JAMES E. STACH
COunr nc»oetT(«
SPOKANE WASHINGTON
61
-------
1
2
1
4
5
«
8
W 9
M 10
11
12
13
14
15
16
17
It
19
20
21
22
21
24
25
ID
available. For example, no consideration Is given to any
options employing summer land application and winter dis-
charge to the river.
Our formal comments have already been submitted.
LISA CORBYK: Thank you. Skip Toreson.
SKIP TORESON; My name is Skip Toreson.
My address Is 1513 Lilac Lane, Liberty Lake. I am one of
the Commissioners In the Liberty Lake Sewer District,
and I was as usual in awe of Phil's presentation. He is
most skilled technically, and I don't pretend to be an
expert In lake biology or river studies. I am really
primarily Interested In taking care of Liberty Lake. I
have been on the Commissioners Liberty Lake Sewer District
since 1973 when it was formed.
I would like to maks a couple of comments that
are really more from the political point of view and the
economic point of view rather than the environmental
point of view, although I suppose they have to interact
to a certain extent. First of all, and I suppose it's
not particularly germane here, but 1 was upset with Mr.
Hagen's comment about the Liberty Lake plan. We have,
of course, received commissions from the State and Federal
agencies, and local agencies to proceed with our plans.
JAMES e. ST ACM
count KCPonrK*
SPOKANE. WASHINGTON
62
1
2
I
4
5
6
7
8
9
10
II
12
13
14
15
16
17
18
19
20
21
22
23
24
25
and we feel that the plant as it's being constructed, and
the effluents to be discharged from there is going to meet
the highest standards that have been set down, and we will
comply with those.
A couple of comments. Speaking for myself, and
I believe for the sewer district because we are carrying
forth this thought, we are 100 percent in favor of sewers
in tha Valley. He always have been. We formed a district
at Liberty Lake in '73, and we are now completing construc-
tion of the.treatment plant, which is the final phase of
putting all of us together, because we felt it was impor-
tant, and we felt that if we couldn't do it: for the Valley
wa could at least do it for our low corner of the world.
However, I do have a couple of concerns that are follow-ons
to what Phil said.
I sat on the CKMP Advisory Cronn, and 1 stated
to that group, and 1 state here again tonight that 1 see
a serious problem with the economics of funding this
alternative the way it's bean proposed to be funded.
I seriously question that it can pass the vote of the
people to fund a general obligation bond, which is the
proposed method of funding a portion of this program.
I hate to even bring that criticism up, because you should
offer some alternative if you say something won't work,
and I am not sure what will work. But, I think that the
JAMES e. STACH
C0UHT
SPOKANE. WASHINGTON
63
-------
21
plan as good »3 it nay be la going to run Into acme serious
problems because of that.
The second area I am concerned with, and Phil
alluded to this, I think it seriously ought to be looked
at, the land application alternative rather than the
Spokane River alternatives. The numbers I have been able
to look at in my limited ability to perceive these numbers
tells ne that you can't put up to 60 million gallons of
effluent into that river with tho kind of treatment ability
that we have projected and planned without there being a
substantial impact, a negative Impact on the organisms of
the river. I guess that's the simple way of saying what
?hil did in mora complicated terms.
1 compared some of the things that Liberty Lake
Treatment Plant will do when it aoes on line early next
year compared with what the Spokane Treatment Plant as
programmed or existing now will do, and some of th« dif-
ferences for example are that we have dechlorination al-
ready planned in our plan, and it's not in the City,
t'a hava phosphorus removal plan3 when the level gets to
R0 percent of our million gallon first phase of construc-
tion. We have testing both now and after the plant is
in operation on the river. He have flow equalization
into the plant, which will make the plant operate more
efficiently, and ultimately reduce any poor quality that
JAMES E. ST ACM
COURT REMOTE#
SPOKANE WASHINGTON
64

would result in the effluent. And, as the other side of
the coin, we don't have a bvpass, that will still exist
in the City Plan.
So, while I am on the one hand very, vary con-
cerned about sewering in the Valley because I work in the
Valley, and I live just on the outskirts of the Valley, I
am very concerned about this type of tre.itr,u:nt, that is,
treatment where you are putting the effluoric into the river
and secondly the economics of the plan of how to pay for
it. And, I-just see that politically--! don't think it's
going to succeed. And, I am almost embarrassed to say
that, because I don't have a better alternative as far as
funding. I know it's the devil's problem to iio that,
because we just finished the final sale of our bonds for
our sewer treatment plant, and it was a long, bitter,
difficult struggle to get our funding straightened out,
and thankfully the State and the Federal govera-ient have
participated quite substantially in our plan. And, we
thank them again for that. But, it's a vary, very expen-
sive process. It calls for some re«l imagination and
hard work to come up with a plan that will work.
Thank you.
*****
JAMES E. STACH
COUNT AE'ODTCK
SPOKANE WASHINGTON
65
-------
1
2
3
4
5
e
?
8
9
10
11
12
II
14
15
16
n
is
19
20
21
22
21
24
25
LISA CORBYH: Is there anyone who has not
given any comments or testimony that would Ilk# to at this
time, formally? If not, I will put us into our third
phase of the question and answer. I would like to say that
there is someone here from the Washington Department of
Ecology who has offered to respond to any questions from
the State's standpoint.
I ask that you address the questions to me,
and then I will refer then to particular people.
Would you please identify yourself,
JOAN HONICAH: Joan Honican again. I wanted
to know why the urban runoff problem, which is a very serioi
problem, which was also addressed in the 208 study, is not
dealt with in this plan? 1 feel very strongly that it talk>
about it, and I feel very strongly that we have to pick up
at least at Sullivan Road with the density that is already
there, that it has to be sewered, that I think we are
only dealing with a small portion of the population, I
wish we had tha County classification map on the wall also
showing what is projected in the way of additional roads
over t'f.'-s aquifer. And, I know that this issue was raised
earlier, but I can't remember who It was. But, how can
we even talk about sewering and protection of the aquifer
when it was determined that this urban runoff was a very
significant contributor?
s
JAMES E. STACH
COU»r BE»OftTefi
SPOKANE. WASHINGTON
66
1
2
3
4
5
8
7
I
9
10
11
12
13
14
15
1«
17
It
19
20
21
22
23
24
25
LISA CORBVTNs I will give that to Bob
Wubbona to respond,
BRUCE COLLINS J Just a couple of connionts.
First, when we approached the study, the project that was
handed to us was to cone up with a Comprehensive wastewater
Management Plan as It ralated to the 201 section of the
portfolio. A part of the requirement wa3 also to incor-
porate the 208 findings and proceed on that basis. We
proceeded under the premise that there were many different
issues as identified by the 208 water quality control
study, but that there was no way to deal with the whole
program all at one time, and to make progress. It was
for that reason we identified the management 3ystera within
tins first phase, or the first step, or major components.
So, it wasn't that we didn't recognize the Importance of
the water management and storm facility program as identi-
fied in the 208 water management program, but it's a mat-
ter of how you get from where you are today if.to a program
that is going forward. So, the management system and the
administrative system that we outlined her.-, (he County and
the City has basically endorsed the program. I would like
to point out one key component related to that because
there are some comments that ware raised ureas that wore
covered or identified in the panning wat^r project aa low
density, and should not be included in the--. It is vary,
JAMES C. ST ACM
countKEMOATES
SPOKANE. WASHINGTON
67
-------
1
2
1
4
5
6
7
t
9
10
u
12
13
14
15
16
IT
It
19
20
21
22
21
24
25
very important for you to review and look at the manage-
ment systems and how the management decisions are intended
to ba made because in that system it is recognized that
the land use decisions that have been made now will be
made and will constantly be made by the local government
structure. And, it doesn't mean within that sewer area
la going to be (inaudible). We believe that the manage-
ment system that we have outlined here can proceed to
address the storm water program in the sequential fashion
along with it.
That is how we approach the problem, rather than
trying to solve all the problems identified in the 208
study all at one time. We are trying to put the system
Into motion and pragmatically deal with those issues.
ALICE MILLS: If you marry the two systems,
one or the other has to prevail. In reading the draft
EIS, I didn't really get a feeling of how those two were
to be merged.
BRUCE COLLINS: The reason 1 hesitated to
a certain extent is because I'm not sure if you are asking
a quf.M'ion about the EIS or the plan. As everyone in the
roar, recognizes, as a development occurs in the undeveloped
areas of the City or County, various decisions will be
made by government in terns of long use, whether residen-
tial now, and going to eoeimercial, or many different
JAMES E. STACK
COURT BEPO""!*
SPOKANE. WASHINGTON
68
1
2
I
4
5
6
7
I
9
to
II
12
13
14
15
1<
17
It
IS
20
21
22
23
24
25
changes occur. Our charge wan not to make planned policy
decisions, but to try to prepare a planned program that
responded to the decisions that will ba made. So, since
there will be changes made even as we develop the plan,
the plan is under evolution, we attempt to set up a deci-
sion making process for providing utility services, and
then when local government makes a decision, then a parti-
cular piece of property to be of a certain density would
require a certain type of wastewater management. We cannot
get down to'specific lot-by-lot decisions, because it is
constantly evolving.
llow, there is a marriage there in the decision
making process, maybe not a direct marriage in terms of
a sewer line and how the land develops, but we felt that
that is the more specific decision that will have to be
made by local government.
WALL* MATLOCKI I am Wally Hatlock of
Nine Mile Falls. Is local funding to be a general obliga-
tion bond, to be paid for by the whole County: Liberty
Lake, Deer Park, Cheney?
BRUCE COLLINS: After the capital improve-
ment plan was prepared and the cost estimates were
developed, it was our responsibility to make a recommenda-
tion to the County Commissioners as to the approach of
financing. Me approached it from the standpoint of saying
JAMES E. STACH
COUNT »t»ORltS
SPOKANE WASHINGTON
-------
1
2
I
4
5
6
7
I
K) '
U1 '0
II
12
13
14
15
1«
17
It
19
20
21
22
23
24
25
that—many of the issues that were raised hare tonight
dealt with the protection of the aquifer, and wastewater
management, and how that contributes to the environmental
economic growth of the area--and wa felt that using a
general obligation bond was one approach, and in our opin-
ion is a very desirable approach. If the County
Commissioners decide to accept our recommendation and
present a general obligation bond issue to the voters,
then it would be Countywide.
WALL* MATLOCKs Then the City people would
vote themselves a bond to support the Valley?
BRUCE COLLINSi Yes. This is our recommen-
dation based upon the rationale that I touched on briefly.
What the County Commissioners and the City people have done
is they have appointed a citizens committee to now take
a look at our recommendation, which they may reject,
modify or whatever the case may be, to make a final
decision as to how they would like the capital improve-
ment olarw "hey nay choose not to follow the general
obligation bond, and they may go to a different route of
financing. But, this is now being looked at by a broad
section of the citizens group to say how do we best meet
this need, and our recommendation was the general obliga-
tion bond, tut that has not been the final decision of
the County Commissioners at this point in time.
JAMES e, STACH
count mooofts
SPOKANE. WASHINGTON
70
1
2
I
4
5
6
T
•
9
10
II
12
11
14
15
lfi
It
1*
19
20
21
22
21
24
25
AUDIENCE MEMBER« !:o indicated that thoy
would handle the storm water problem when the development
took place. The storm water is a problem today just like
the sewer problem is. They are both exactly the ssim,
It contributes to the quality of the wat. r right now in a
high percentage, not as high but nearly as high as a per-
centage of the problems as the septic tanks do, ant! It's
a present problem. It's not one that develops «•*. ti:ie goes
on, I would like to have him comment on that, because
this ia the'answer. You can't project it In the future.
It's here.
BRUCE COLLINS: Mv point is that we recog-
nize it as a problem, but because of the hitrh cost of
whatever solutions we see, what we are saying is that you
need an effective, iraDlementing water msnng-ii.-enr: sy.itor.
to attack the oroblem. We are not trving to avoid It,
we are saying we have to have the system going ! a fore we
can effectively manage the program. I am not trying to
sidestep, it's juflt our recommendation of ho-./ vnu approach
the problem.
WALLY MATLOCK: That is exactly the position
the City took SO years ago, and now we are faced with the
same problem. IIow do they finance the storm water separati'
ROBERT lTUBBE.'JA! I would like to respond to
the last two questions, I think as far as thn runoff issu-;
•n?
JAMES B. STACH
COtJtt T f»CPO«Tl*
SPOKANE WASHINGTON
71
-------
1
z
3
4
5
6
¦?
S
M	»
er* jo
n
12
n
14
15
1«
17
IS
19
20
21
22
23
24
25
it ha* been identified and quantified in terras of the
environmental impact within the river system and so on.
You may recall that th# testing that was done at that tine
concluded in general terms that the water quality impact
from the runoff was roughly of a magnitude of one-fourth
the water quality impact from the advance wastewater
treatment—. So, we are recognizing that we are not deal-
ing with something that is not of great raacrnitudc, 1 think
we hear so much about the runoff Impact. It is true.
At certain times we are getting a fairly high concentration
relative to what we have in the sanitary sewage, but in
terras of total pounds contaminants over the years, it is
a much smaller problem, and it's a much more technical
"rol-lce to deal with. It happens on a certain basis. We
can't treat it with filters, we can't treat it biologically
but it has been dealt with and there have bean increasing
studies encouraging over-land slope flow, and this type of
thi.no, rccorr.endatioat for good housekeeping, street
cleaning by vacuum method, and so on. It is also not a
public health problem.
Back to the previous question, in terns of the
oeneral oblioation bond financing, we realize that the majo:
problem of the City of Spokane is the urban runoff. One
concept in a Coontywido bond issue, the County doesn't
have any choice, they can't go to a general bond just for
JAMES E. STACK
«»»'	?2
SPOKANE. WASHINGTON
1
2
3
4
s
6
7
8
9
10
11
12
II
14
15
1C
17
l>
19
20
21
22
23
24
25
tha Valley or the Horth Spokane area. Politically they do
not have that choice. The second problem is the alloca-
tion of the proceeds of the general obligation bond Issue
where revonues would be earmarked to lie applied to Ci t ,•
problems. Certainly everybody has a pro).lop. And th«
general obligation bond is looked at as some-thing that coul
generate the funding basis for local funding for each of
the communities—Medical Lake, Cheney, and others that havu
a localized problem, on the basis that it would not deny
the County the opportunity to utilize earmarked fundir.g
for their particular problems.
LISA CORBYJIs Any other questions?
JOAJJ HONICAi;> I have a whole Buries if no
one else does. I wanted to know if there is a l.Ackup fund-
ing plan that was contemplated or considered if the Co
bond were voted down, which most of us expect, or if the
State is not able to give the amount of funds that is con-
templated for a financial package. What would K» your
backup funding to finance? What is the mechanism?
BRUCE COLLIHS: The program is looked at in
two different structures: The CO bond and the Ut.TD bonds,
or financing through the ULin. So, we have looked at both
of those, which are basically the normal approaches to
financing. And, another option that exists, and one of
the considerations that we gave in Alternative A, w«i have
JAMES E. STACH
COURT «|PO"t£«
S*»OKAKE. WASHINGTON
73
-------
z
3
4
5
6
7
t
NJ 9
-O 10
It
12
ti
14
15
ti
17
It
19
20
21
22
23
24
25
recommended Alternative A with the Stage 1 sewering program
If either of thoao two financing methods are not endorsed
to the degree that we have recommended to the Stage 1 level
financing, the other option that is available to the County
and the City i3 to reduce the Stage 1 protram to a smaller
scale.
So, By response is two things: Number one is
that if the GO bond approach is not selected or is not
endorsed by the voters, the other option is then going to
be UJ.TD financing, and/or a reduced phase program on the
first stage of the construction program. Those are the
options available to the City and the County, and they ore
really the only options available.
AUDIENCE MEMBER: One of the things that I
am wondering about since funding is such a great issue, and
I don't think I have heard it addressed, what do you think
about private industry taking over your treatment plant?
BRUCE COLLINS: I don't think that I an
really the person to respond to that because I think that
that is a management decision at the local level. I would
pr-jsume, and this la a personal opinion, that if private
industry could achieve the objective at a lessor cost, I
think you would have a good client here in Spokane County.
I think that is the only response I can give you.
IJSA CORBYNs We don't have anyone from the
JAMES e. ST ACM
COU«T MIBDt'C*
SPOKANE. WASHINGTON
74
1
2
s
4
s
6
7
<
9
10
11
12
13
14
15
16
17
1*
19
20
21
22
23
24
25
County on the panel. If he doesn't want to respond to that
I suggest you call him at a later date. You do not want
to? I would suggest that you contact someone in the County
MICHAEL KENNEDY: I an Michaal K.ir.nody.
I am a consulting engineer as such for t-'« • Liberty Lafca
Sewer District. And, I would like to maV.f a eo-c-.ont <;s to
the contrent Bruce made about the problem that mjena to
exist with the storm drainage as a public h<..iltr. proi.lem.
I strongly disagree with that. I think there arc signi-
ficant health effects accruing from the discharge of storm
water drainage into areas that might seep Into the aquifer.
It does pose a public health hazard.
The District, as well as planners for the
District recognize (inaudible). We have developed and are
developing very substantial water nanvi"™r.t pl
-------
13
It
didn't have a copy of our recently adopted Land Use Plan,
and tho Input Chapter 10, which is supposed to protect
the drinking water of the County. I understand th.-t there
has been a little correspondence going back and forth to
that effect. I don't have copies of any of it. But, one
of tha major points I wanted to make is that there is a
terrific interrelationship between the 208 study, the
classification map, which is an absolute atrocity, and the
201 plan, and if these are all not looked at and hov: they
interrelate, we wind up with an inadequate EIS. tod, based
upon the information we had, we put that document toqether.
(Inaudible) I think it i3 very important that we go back
and amend the Draft EIS at this point so that we have a
chance to submit comment?!, because I sec the Dr.f.TS as
being totally inadequate to today's situation in light
of the new information that we have. When I walked into
the meeting tonight, I was given a copy of Summary n.
I haven't had an opportunity to read it, so obviously T
can't comment intelligently on anythinq that has bcnn dons.
We have to have sone time in the conrncnity, be-
cause we are talking about the largest capital outlay we
have gver contemplated, and some very strong environmental
implications for our children, our grandchildren, and gene-
rations to coma.
I would like an opportunity to deal with the
JAMES E. STACH
coubtoEPonTsn
SPOKANE. WASHINGTON
76
2*1 phosphorus data reflected in tho amended DEIS. Is there
any chance that we can get some more time, and to amend
the DEIS?
LISA CORBYM: I suppose I an the appropriate
person to respond to that, and I don* t h.«»*'e an answer for
you right now. A schedule has been set for processing the
Draft EIS, but based upon comments that we have rec-»iv«».i,
the process could change. I would like Michael to respond
initially to the question about the Cor.oreh->nsive I.and Use
Plan and revisions of data.
MICHAEL RUSHTOM: In the last stages of the
production of the Draft EIS we learned there was a n^w
addition, and we have since received that nsw addition
along with a list of comments from tho County on the
DEIS that reflects the changes that have occurred m their
planning. And, our process would be to taVe tho.se consents
and also take the changes that have occurred In planning,
and discuss those in the final EIS in depth, and in as much
depth that we feel necessary to respond to th*i comments
we have received, and those changes, and that document Is
a public review document also* and it will b.-* sal-ni tt«*J to
the public for comment.
LISA CORBYN: I would like to say that wa
do have a process that if new information docs cor.e up in
the EIS process and wo have gone through the steps of issui:
JAMES E. STACH
COURT KCPONTCD
SPOKANE. WASHINGTON
77
-------
1
2
3
4
5
6
7
t
N) 9
KD 10
11
12
II
t4
15
1«
17
IS
19
20
21
22
21
24
»
a final for public review and comment, we do have a process
called the supplemental draft, which would take that addi-
tional information, with new information, and put it into
the decision making process, and that supplemental draft
would also go through a similar public raview and comment
period.
Are there any other questions? If th«ro are no
other questions, I think 1 will adjourn the public hearing
at lfi:i5. Thank you all very much for coming and partici-
pating .
* • * * *
JAMES C. ST ACM
eou« r hc*»oo'K*
SPOKANE. WASHINGTON
78
-------
Response to Oral Comments
Glen Yake
1. Refer to Chapter 3 of this report for EPA'c recommended
action on the proposed project.
Julie Coelho
2.	Refer to Response #1 in the "Response to Comments from
the League of Women Voters of the Spokane Area" section of
Chapter 4.
3.	Refer to Response #2 in the "Respone to Comments from
the League of Women Voters of the Spokane Area" section of
Chapter 4.
Joanne Vennema
4. Refer to Chapter 3 of this report for EPA's recommended
action on the proposed project.
Sally Reynolds
5.	EPA regrets that there was difficulty in obtaining a
copy of the Draft EIS. Copies were mailed to the city and
county libraries in Spokane. EPA attempted to contact all
interested groups prior to issuance of the Draft EIS; persons
attending the two public workshops on the Draft EIS were
asked to submit requests for copies of the report prior to
its publication. We are sorry that the Glenrose Association
was not placed on our mailing list.
6.	This comment is addressed in Response #2 to the Glenrose
Association letter of comment (Chapter 4).
7.	Refer to Response #3 to the Glenrose Association letter
of comment (Chapter 4).
8.	Refer to Response #4 to the Glenrose Association letter
of comment (Chapter 4).
9.	Economic and Engineering Services, Inc., indicates that
all pipelines will have a life expectancy of 50 years, as
will the equalization basins. Pumps will be expected to
last approximately 30 years (Maxwell pers. comm.).
250
-------
10. EPA1s recommendations and conditions for issuing grant
funds to Spokane County are contained in Chapter 3. This
includes implementing recommendations of the 20 8 plan.
Margaret Portman
11. EPA has strongly recommended implementation of 208 plan
urban runoff control measures. Other measures to limit the
impact of growth are contained in EPA's recommendations in
Chapter 3.
Dan Knierim
12.	Development restrictions both inside and outside of
the PSAA are the responsibility of Spokane County. The types
of on-site systems that are acceptable is determined by the
Spokane County Environmental Health Department and the
Washington Department of Social and Health Services. The
advisability of using composting toilets should be reviewed
with these agencies.
13.	See Response #12 above.
14.	Refer to Response #3 to the Glenrose Association letter
of comment (Chapter 4).
Tom Rogers
15. State and county health agencies are responsible for
regulating the use of on-site waste disposal systems. The
use of composting-type on-site systems should be reviewed
with these agencies. EPA encourages the use of alternative
wastewater treatment technology in the interest of conserving
water and energy as long as public health protection is not
compromised.
Mauri Hagen
16. The Draft EIS discussed the water quality implications
of the Liberty Lake plant discharge in considerable detail
(pages 42-108). The CWMP indicates that the Liberty Lake
251
-------
discharge is an interim situation; it is planned to be con-
nected to the regional city and county system by 1992. The
implications of increasing waste flows through the Spokane
STP have been redefined in Chapter 2 of this report (Spokane
River Water Quality).
17.	The facilities plan engineers have revised their proposal
for constructing a storage basin in existing gravel pits.
Their latest plan is to excavate a new, relatively shallow
basin adjacent to the Spokane Valley site identified in the
facilities plan. They indicate that the double-sealed basin
will be able to store untreated wastewater without threatening
aquifer water quality.
18.	The latest information available on proposed project
financing is contained in the Project Economics section of
Chapter 2 of this Pinal EIS.
Philip Kaufmann
19.	The Spokane River Water Quality section of Chapter 2
contains a revised water quality impact analysis that addresses
these concerns.
20.	A seasonal land application suboption is addressed in
Chapter 1.
Skip Toreson
21.	The latest information available on proposed project
financing is contained in the Project Economics section of
Chapter 2 of this Final EIS.
22.	A seasonal land application suboption is addressed in
Chapter 1.
Joan Honican
23.	The 20 8-CWMP-Generalized Comprehensive Plan interrelation-
ships that were discussed in the Draft EIS have been updated
in Chapter 2 of this Final EIS.
24.	Refer to Response #14 to Joan Honican"s written comments
in Chapter 4.
252
-------
BIBLIOGRAPHY
References Cited
American Fisheries Society. 197 9. A review of the EPA Red
Book: quality criteria for water. American Fisheries
Society, Water Quality Section, Bethesda, MD. 313 pp.
Cairns, J., Jr., N. H. Cromer, T. K. Bahns, and W. T. Waller.
1971. A confirmation of Mount's autopsy technique for
zinc-caused fish mortality. Water Resour. Bull. 7 (5):956-968.
Chapman, G. A. n.d. Unpublished data available at the National
Water Quality Laboratory, Diluth, MN.
Cooper, A. C. 1965. The effect of transported stream sediments
on the survival of sockeye and pink salmon eggs and alevin.
International Pacific Salmon Fisheries Commission.
Bulletin 18:1-71.
Cunningham, R. K., and R. E. Pine. 1969. Preliminary investiga-
tion of the low dissolved oxygen concentrations that exist
in Long Lake located near Spokane, Washington. Technical
Report No. 69-1. Washington State Water Pollution Control
Commission, Olympia, WA. 24 pp.
Davies, P. H. 1976. The need to establish heavy metal standards
on the basis of dissolved metals. Pages 93-126 in R. Andrew,
P. V. Hodson, D. E. Konasewich, eds., Toxicity to biota of
metal forms in natural waters. Proc. Workshop, Diluth, MN,
October 7-8, 1975. Prepared for Int. Joint Comm., Great
Lakes Res. Advisory Board. 329 pp.
Dillon, P. J. 1975. The phosphorus budget of Cameron Lake,
Ontario: the importance of flushing rate to the degree of
entrophy of lakes. Limnology and Oceanography 20(l):28-39.
Drost, B., and H. Seitz. 1978. Spokane Valley—Rathdam Prarie
aquifer, Washington and Idaho. U. S. Geological Survey Open
File Report 77-829. U. S. Geological Survey, Tacoma, Wash.
7 9 pp. + app.
Economic and Engineering Services, Inc. 193 0. Spokane County
comprehensive wastewater management plan—supplementary
studies. Summary, Vol. II. Prepared for Spokane County.
	. 193 0a. Draft Spokane County 201 comprehensive
wastewater management plan. Prepared for Spokane County.
253
-------
	. 1980b. Spokane County comprehensive wastewater
management plan—supplementary studies. Summary, Vol. I.
Prepared for Spokane County.
Esvelt, Larry A. 1978. Spokane aquifer cause and effect
report. Summary report of '208' water quality results and
cause and effect relationships for water quality in the
Spokane-Rathdrum aquifer. Spokane County Office of County
Engineers.
Federal Register 45(231) F. R. 79318-79323 (11/28/80) Section
307 (a) (i) toxic pollutant criteria.
Funk, William. 1980. Unpublished data. Washington State
University, Pullman, WA.
Funk, W. H., F. W. Rabe, R. Filby, et al. 1973. Biological
impact of combined metallic and organic pollution in the
Coeur d'Alene—Spokane River drainage system. Joint
Project Completion Report to OWRT. u. S. Dept. of the
Interior, Office of Water Res. Tech.
	. 1975. An integrated study on the impact of metallic
trace element pollution in the Coeur d'Alene—Spokane Rivers—
Lake drainage system. Title 2, Joint Project Completion
Report to OWRT. U. S. Office of the Interior, Office of
Water Res. Tech.
Gasperino, A. F., and R. A. Soltero. 1977. Phosphorus reduction
and its effects on the recovery of Long Lake reservoir. Final
Progress Report. D.O.E. Project 77-108. Battelle, Pacific
Northwest Laboratories, Richland, WA. 100 pp.
Jones, V. R. E. 1952. The reaction of fish to water of low
oxygen concentration. J. Exp. Biol. 29(3).
Maxfield, P., J. M. Rodriquez, J. Buettner, et al. 1974.
Heavy metal pollution in the sediments of the Coeur d'Alene
River delta. Environmental Pollution 7:1-6.
McKim, J. M., and D. A. Benoit. 1971. Effects of long-term
exposures to copper on survival, growth and reproduction of
brooktrout (salvelinus fontinalis) Jour. Fish. Res. Board of
Canada 28:653*:	
Mink, L. L., R. E. Williams, and A. T. Wallace. 1971. Effect
of industrial and domestic effluents on the water quality
of the Coeur d'Alene River Basin. Pamphlet. Idaho Bureau
of Mines and Geology. 149 pp.
Moyle, P. B. 1976. Inland fishes of California. University
of California Press, Berkeley, CA. 403 pp.
254
-------
Patten, B. G. , and P. T. Rodman. 1969. Reproductive behavior
of the northern squawfish, ptychocheilus oreqonenis. Trans.
Amer. Fish. Soc. 98(1):108-11.
Rabe, F. W., and C. W. Sappington. 1970. The acute toxicity
of zinc to cutthroat trout salmo clarki. Pages 1-16 in
Biological productivity of the Coeur d'Alene River as
related to water quality, completion report. Water Resources
Res. Inst. University of Idaho, Moscow. Sport Fish. Abs.
13665, 1971.
Rast, W., and G. F. Lee. 1978. Summary analysis of the North
American {U. S. portion) OECD Eutrophication Project:
nutrient load-lake response relationships and trophic state
indices. EPA-600/3-78-008. U. S. Environmental Protection
Agency.
Savage, N. L., and R. W. Rabe. 1973. The effects of mine and
domestic wastes on macro-invertebrate community structure
in the Coeur d'Alene River. Northwest Science 43(3):159-168.
Sheppard, J. C., and W. H. Funk. 1975. Trees as environmental
sensors monitoring long-term heavy metal contamination of
Spokane River, Idaho. Environ. Sci. Tech. 9 (7) : 638-642.
Sinley, J. R., J. P. Goettl, Jr., and P. H. Davies. 1974.
The effects of zinc on rainbow trout (salmo gairdneri) in
hard and soft water. Bull. Environ. Contam. Toxicol.
12:193-201.
Soltero, R. A., D. M. Kruger, A. F. Gasperino, J. P. Griffen,
et al. 1976. Continued investigation of eutriphication in
Long Lake, Washington: verification data for the Long Lake
model. Project completion report. D.O.E. Project WF-6-75-081.
64 pp.
Soltero, R. A., D. G. Nichols, G. A. Pebles, and L. R. Singleton.
197 8. Limnological investigation of eutrophic Long Lake and
its tributaries just prior to advanced wastewater treatment
with phosphorus removal by Spokane, WA. Project progress
report. D.O.E. Project 77-108. 67 pp.
Soltero, R. A., D. G. Nichols, G. P. Burr, and L. R. Singleton.
197 9. The effect of continuous advanced wastewater treatment
by the city of Spokane on the trophic status of Long Lake, WA.
Final project report. D.O.E. Project 77-108.
Soltero, R. A., D. G. Nichols, and J. M. Mires. 1980. The
effect of continuous advanced wastewater treatment by the
city of Spokane on the trophic status of Long Lake, WA during
1979. Completion report. D.O.E. Project 80-019. 86 pp.
255
-------
Spoerhose, Jim. 1981. Bonds eyed for sewers. Spokane Daily
Chronicle, May 27, 1981, p. 3.
Spokane County Office of County Engineer. Spokane aquifer
water quality management plan. Spokane County Engineers
Office, Spokane, WA. 102 pp.
Thomas, S. R., and R. A. Soltero. 1977. Recent sedimentary
history of a eutrophic reservoir: Long Lake, Washington.
J. Fish Res. Board Can. 34:669-676.
Thurston, R. V., R. C. Russo, C. M. Fetterolf, Jr., T. A. Edsall,
and Y. M. Barber, Jr. (Eds.) 1979. A review of the EPA
Red Book: quality criteria for water. Water Quality
Section, American Fisheries Society, Bethesda, MD. 313 pp.
U. S. Environmental Protection Agency. 1976. Quality criteria
for water. Office of Water and Hazardous Materials, U.S. EPA,
Washington, D. C. 256 pp.
	. 1981. Draft environmental impact statement—
Spokane County comprehensive wastewater management plan.
U. S. EPA, Seattle, Washington. 304 pp.
U. S. Geological Survey. 1972-1980. Storet water quality and
flow data. Sacramento, CA.
Vollen Weider, R. A. 1968. Water management research.
DAS/CSI/68.27 mimeographed. OECD, Paris. 183 pp.
Washington Department of Ecology. 1981. Spokane River wasteload
allocation study. Phase I. Seattle, WA. Prepared by the
URS Company.
Willingham, W. T. 1976. Ammonia toxicity. EPA-908/3-76-001.
U. S. Environmental Protection Agency, Region VIII, Control
Technology Branch, Denver, CO. 19 pp.
Yake, W. E. 197 6. The impact of effluent from the Renton
wastewater treatment plant on the dissolved oxygen regimen
of the lower Green/Duwamish River. Final draft. Washington
State Department of Ecology, Olympia, WA. 18 pp.
1977. Heavy metals in aquatic ecosystems: with
special reference to the fish of the Spokane River, WA. M.S.
Special project report.
	. 197 9. Water quality trend analysis—the Spokane
River Basin. Project Report No. DOE-PR-6. Water and
Wastewater Monitoring Section, Washington State Department
of Ecology. 39 pp.
256
-------
Personal Communications
Bernhardt, J. May, 1981. Washington Department of Ecology.
Card, Ray. June 15, 1981. Program Manager. Spokane County
208 program. Telephone conversation.
Collins, Ryder, and Watkins. June 20, 1980. Letter and
attachments from Allen Fitz of Collins, Ryder and Watkins to
Michael Rushton of Jones & Stokes, Assoc.
Collins, Ryder and Watkins. July 18, 1980. Letter and attach-
ments from Allen Fitz of Collins, Ryder and Watkins to
Michael Rushton of Jones & Stokes, Assoc.
Dubois, Donald. February 27, 1981. Regional Administrator.
EPA Region 10. Letter to Governor John D. Spellman.
Economic and Engineering Services, Inc. June 17, 1981. Letter
from John Maxwell of EES to Michael Rushton of Jones &
Stokes, Assoc. containing revisions to the Spokane County
CWMP.
Maxwell, John. June 9, 1981. Economic and Engineering Services,
Inc. Telephone conversation.
Pearson, Lester. June 17, 1981. U. S. Bureau of Reclamation,
Boise, Idaho Regional Office. Telephone conversation.
Robison, Daniel. June 16, 1981. Director of Environmental
Programs. City of Spokane. Telephone conversation.
Singleton, L. November 10, 1980. Washington Department of
Ecology, Tumwater, WA. Telephone conversation.
Soltero, Ray. November 21, 1980. Professor. Eastern Washington
University, Biology Department, Cheney, WA. Telephone conver-
sation.
Washington Department of Ecology. March 18, 1981. Letter from
Edward J. O'Brien of DOE to William Dobratz, Director of
Spokane County Utilities containing comments on CWMP.
Washington Water Power Company. June 17, 1981. Spokane, WA.
Telephone conversation.
257
-------
ACRONYMS AND ABBREVIATIONS
ADWF	-	average dry weather flow
AWT	-	advanced waste treatment
BOD	-	biochemical oxygen demand
BOD5	-	5-day biochemical oxygen demand
C	-	celsius
CaCO^	-	calcium carbonate
CFR	-	codes of federal regulations
cfs	-	cubic feet per second
CI	-	chloride
CSO	-	combined sewer overflows
CWMP	-	Comprehensive Wastewater Management Plan
DOE	-	Washington Department of Ecology
DSHS	-	Washington Department of Social and Health Services
du	-	dwelling unit
EIS	-	Environmental Impact Statement
EPA	-	U. S. Environmental Protection Agency
GSP	-	general sewerage plan
GSSA	-	general sewer service area (projected 20-year
service area)
lbs/day	-	pounds per day
LID	-	local improvement district
MCL	-	maximum contaminant level (contained in NIPDWR)
MGD	-	million gallons per day
mg/1	-	milligrams per liter
MPN/100	-	most probable number per 100 milliliters
ml
259
-------
N
NEPA
nh3
nh4
NIPDWR
no2
N03-N
NPDES
O&M
P
pers.
comm.
PL
P04
PSSA
PWWF
07-10
RCRA
RCW
SDWA
SHPO
SIP
SRPC
STP
lflid
USGS
WAC
nitrogen
National Environmental Policy Act
ammonia (un-ionized)
ammonium (ionized)
national interim primary drinking water regulations
nitrite
nitrate measured as nitrogen
national pollutant discharge elimination system
operation and maintenance
phosphorus
personal communication
public law
phosphate
priority sewer service area (projected 10-year
service area)
peak wet weather flow
lowest average 7-day flow recorded in a 10-year
time span
Resource Conservation and Recovery Act
Revised Code of Washington
Safe Drinking Water Act
State Historic Preservation Office
State Implementation Plan
Spokane Regional Planning Conference
sewage treatment plant
utility local improvement district
U. S. Geological Survey
Washington Administrative Code
260
-------
WMA	- wastewater management area {facilities plan
study area)
WWP	- Washington Water Power Company
yg/1	- microgram per liter
yg/gm	- microgram per gram
96 LC5q - 96-hour, 50 percent lethal concentration (con-
centration that will kill 50 percent of test
organisms in a 96-hour period)
201	- Section 201 of the Clean Water Act (wastewater
facilities planning)
20 8	- Section 208 of the Clean Water Act (areawide
water quality management planning)
261
-------
INDIVIDUALS AND AGENCIES COMMENTING
ON THE DRAFT EIS
Federal Agencies
Advisory Council on Historic Preservation
U. S. Department of Agriculture, Soil Conservation Service
U. S. Department of Army, Corps of Engineers, Seattle Office
U. S. Department of Health and Human Services
U. S. Department of Housing and Urban Development, Seattle
Office
U. S. Department of Interior, Office of Secretary, Portland,
Oregon
U. S. Department of Transportation
U. S. Coast Guard
State Agencies
Washington Commerce and Economic Development, Spokane Office
Washington Department of Ecology
Washington Department of Game
Washington Department of Natural Resources
Washington State Parks and Recreation Commission
Local Groups, Agencies
League of Women Voters of the Spokane Area
Liberty Lake Sewer District
Spokane City
Spokane City Planning Department
Spokane County Air Pollution Control Authority
Spokane County Planning Department
Spokane Regional Planning Conference
Spokane County 20 8 Program
The Glenrose Association
Individuals
Julie Coelho
Ray Duff
Larry Esvelt
Mauri Hagen
Marion Hay
263
-------
Joan Honican
Philip Kaufmann
Michael Kennedy
Michael A. Kennedy Consulting Engineers
Dan Knierim
Wally Matlock
Alice Mills
Marianne Phillips
Margaret Portman
Sally Reynolds
Tom Rogers
Rhys A. Sterling
Skip Toreson
Joanne Vennema
Glen Yake
264
-------
LIST OF REPORT PREPARERS
U. S. Environmental Protection Agency - Region 10
Elizabeth Corbyn - Chief, Environmental Evaluation Branch,
Seattle, Washington
Roger Mochnick - EIS Preparation Coordinator, Environmental
Evaluation Branch; Seattle, Washington
Kathryn Davidson - Project Monitor, Environmental Evalua-
tion Branch, Seattle, Washington
Jones & Stokes Associates, Inc.,
Sacramento, California
Charles R. Hazel - Vice President, program management
Michael D. Rushton - Environmental Specialist IV,
project manager
Mark Cudney - Environmental Specialist I, water quality
Thomas Wegge - Environmental Specialist II, land use
26 5
-------
Appendix A
FINANCING PLAN COMPARISONS AND
RECOMMENDATION FROM THE CWMP
SOURCE: Economic and Engineering Service, Inc. pers. coram.
267
-------
TABLE V-2
FINANCING METHOD COMPARISON
Capital Costs
Genera] Facilities
COUNTY CUSTOMER CHARGES
1980
1990(1)
DUE TO DELAYED
CONSTRUCTION
Method 1.
100%, G.O. (2)
Method 2
50% G.O. (2)
5 0% ULID Assessment(3)
Method 3
1001 ULID Assessment (3)
Capital Costs
Collection System (4)
Method 1
100*. ULID Assessment (3)
Method 2
75*. ULID Assessment (3)
25* Revenue Bond (5)
Annual O&M User Charaes
$ 52C/$1000/yr
$ 26C/$1000/yr
$ 21.64/acre/vr
$ 4 3.29/acre/yr
$366/dwelling/yr
$27 5/dwel1 ing/yr
$7. 30/dwel 1 ing/'mo
$ 2.43/51000/vr
$ 1.22/51000/yr
5101.62/acre/yr
5203.23/acre/yr
$1 , 14 0/cwel1ing/yr
5 855/dwel1ing/yr
52 2.66/dwel1ing/vr
County Customer Class for
City Facility L Equalization
Basins O&M, & Acquisition(6)
County Interceptor System
Counts' Collection Lines
5 6.00/mo
5 1.45/mo
5 1.83/mo
Household Connection Charges
Costs to connect house with
existing septic tank/crain-
field to collection system
5300-51300 (7)
(1) 1990 vaJues illustrate the impact of inflation on project financing.
Costs associated with capita] construction were inflated at 12% per
year. The $20 million grant for capital costs associated with thi_-
i n t uj'cept or/La s l ns was assumed to remain constant. Annual debt
service wi i] depend on the interest rate when financina is arrancea
and wi ] ] L i- fc<_-t for the period of financing; i.e., 20 or 30 years.
was not projected to 1990 because of the potential change in
treatment j t-qu i rements at th«. City plant and problems associated
with project jng labor, energy and chemical costs ten years into the
future.
269
-------
TABLE V-2 (CONT'D)
FINANC1NC METHUD COMPARISON (CONT'D)
FOOTNOTES
(2)	General Obligation Bonds have a 30 year maturity period with an assumed
interest rate of 9-2%.
(3)	UL1D assessments were assumed to apply on an	area basis. Bond maturity
is 20 years with an assumed interest rate of	9'/4,. It should be noted
that assessment for collection systems would	be calculated on factors
in addition to area.
(4)	These values are bused on costs for a collection system serving 660
dwellings on 320 acres. County customer charges include $3233/dwelling
for the installed system plus financing charges which vary between
UUD and Revenue Bonds.
(5)	Revenue Bonds are repaid through increases in user charges. The bond
maturity is 30 years with an assumed interest rate of 10^%,
(6)	b. 00 per month is assumed to compensate for City 0&M costs for the
sewage treatment p]jiu , in-City interceptors, operating the equali-
zation/storage basins, and acquiring capacity in the City system.
(7)	Range of costs will vary with soil conditions, depth to collector sewer,
amount of restoration work needed. Costs assume approximately 75 feet
between house sewer and collector sewer, moderate amount of lawn and
pavement restoration.
270
-------
rt 1 intr.iU X /
TABLE V-3
RECOMMENDED FINANCING PLAN COST ESTIMATES
PHASE I
The CKMP recommends a two-phased general facilities construction
program with the collection system for specific areas constructed
as required. The Phase 1 program outlined, provides for inter-
ceptor service to the North Spokane, Spokane Valley (to Sullivan
Road) and Moran Prairie areas. The following costs incorporate
the entire Phase I program. It also provides sub-elements that
would allow for a reduced Phase 1 program if local government
chose to implement the program in smaller segments.
General Obligation Bond Financing
and State and Federal Grants -
See Table IV-3 and V-2
General Facilities			
I960 Project $
Spokane Valley Conveyance(1)
. Havana-Sullivan Interceptor,
Railroad R/W and Valley
Equalization Basin	$19,636,000
. Dishman-Mica-Sullivan Interceptor 6,124,000
. Millwood-Pasadena Park
Interceptor
North Spokane Conveyance(1)
Moran Prairie(1)
Total Cost of General Facil-
ities (2)
Collection System - ULID Financing
6,900,600
13,112,000
714,000
$46,486,600
Estimated
Financing $
21
-------
TABLE V-3 (CONT'D)
FOOTNOTES:
(1)	Financing costs presented as a % of total general facilities
cost based on Table IV-3 and V-2. Each element can be
further reduced depending on service desired.
(2)	Total cost shown includes 100% of railroad R/W cost, does not
include acquisition of City capacity (included in O&M user
charges) and assumes a $20 million grant will be obtained
from the DOE and EPA.
(3)	Cost based on 660 customers in a 320 acre unit. Cost could
be less if developer installs facilities as part of initial
subdivision development program.
(4)	O&M costs would be increased or reduced depending on service
area and density included in Phase I. Estimate acquisition
cost of 10 MGD capacity in City waste treatment plant and
interceptor system included in user charge.
272
J
-------
Appendix B
MATERIAL APPENDED TO LETTERS
COMMENTS ON THE DRAFT EIS
273
-------
Material Appended to Letter
from Joan Honican Dated
May 14, 1981
275
-------
" fi (J )ri'^/£/'-' /\£7">XT- M TXL
s cff£ri?fiLizi?T>  // 7) ,J ^ ,7 £ v ]-j
**>s
/ /- /? AJ,'j ,/c J
\
r ' (Z L lO N/ ! ' ' t- 
-------
Urban stormwater runoff was second only to sewage in its negative impact upon the
aquifer. Nevertheless, only sewage will be picked up by the proposed interceptors. With
high density, fill-in we can only accelerate the stormwater runoff problem. The only
mitigating measure recommended is grassed percolation, about which little if anything is
known. We do know there will be "no treatment when the ground is frozen or saturated
which can be many months of the year.
Little data is available on other area aquifers but due to extensive documented problems
with retaining an adequate water supply in Cheney, Four Lakes, Medical Lake, Airway
Heights, Colbert, etc., it is apparent they will eventually have to tap the major aquifer
for a dependable supply.
The 208 stated we may already be using 50% of recoverable water. It also stated the
aquifer is a finite source with development limitations but the USGS Model which was
supposed to give us some figures relating to this critical area was never completed. We
are, therefore, left in limbo not knowing anything specific but at the same time classify-
ing eight times more land than required for the next five years.
Throughout the 208 process there appears to be no awareness of the fact that congress
approved a Bureau of Reclamation project to irrigate the Rathdrum Prairie, the major
holding area for the Spokane-Rathdrum Aquifer. This would be Idaho's counterpart (or
extension) of our Spokane Valley project (Consolidated Irrigation). Spokane Valley was
"sold" to congress and the general public under the guise of promoting agriculture. As
is so often the case, the availability of a dependable water supply resulted in speculation,
subdivisions and the forcing out of farmers through enticement, increased appraisals or
conflicts with urban density development The '67 start-up of Consolidated was the be-
ginning of the end for aquifer protection and recharge in Washington State. Now,
waiting in the wings, is another project, on the Idaho side of the border, already
approved and just waiting for an appropriation to begin construction. Interesting to
note also, is the fact that Consolidated's staff and attorney have testified at public hear-
ings in favor of subdivision development expressly because it helps their payback rate.
Domestic users (subdivisions) pay a higher user fee than irrigation users (farmers).
#**#*#~**#
RECOMMENDATIONS
An amended 208 study must be begun immediately to include West Plains and its poten-
tial impact upon aquifer quantity and quality. The 208 law encourages enlarging of
boundaries, additional studies and amended plans as new information and deficiencies
come to light.
No local governmental entitites (including the Regional Planning Conference) have the
required legal authority to oversee implementation of the 208. The only governmental
entity with the responsibility to protect all the waters of the state from pollution is the
Department of Ecology (RCW 90.48). We must insist they assume their resoons.blity
under that statutory charge 'rorp the legislature.
277
-------
Either EPA's recharge boundaries are inaccurate or our 208's are. We cannot afford to
be arbitrary when we are making such decisions as the proper location for landfills,
sludge disposal and toxic waste storage. With the projected huge increase in population
and its attendant wastes, it is imperative that boundaries not be arbitrary.
With about 90% of our drinking water originating in Idaho, we must assume responsi-
bility for protecting the 10?'o on the Washington side. In order to do this, all tributaries
must immediately be identified and given special protection from adverse land use.
Those major tributaries already recognized in the 208 Plan must be declared "environ-
mentally sensitive" and included in the Aquifer Sensitive Area boundaries. The exclu-
sion of these tributaries is a major deficiency in the 208.
Now that wells adjacent to the Colbert landfill are seriously contaminated, 8100,000 has
been allocated by various agencies for much needed testing at both Mica and Colbert
dumpsites. Another site that deserves the same scrutiny, but is being ignored, is the Bo-
nenko sludge dump on Argonne Road in the Pasadena Park area. Due to the fact that
the Health District has assumed little if any responsiblity over private pumpers, it is im-
perative that we determine what potentially devastating wastes have been dumped at
this site over the last five or six years. "Septic tank pumpers" is nothing short of a
public deception as citizens have not been made aware of the fact that these same
pumpers have consistently been pumping wastes from chemical holding tanks in addi
tion to human wastes. Wells and springs surrounding this site must have an immediate,
complete, chemical analysis including tests for solvents such as trichloroetnans.
The MAIS section of 208 must be analyzed to prioritize responsibilities based upon
their urgency. After prioritizing, an assessment must be made to determine whether
the appropriate agency has been charged with the implementation and whether or not
that same agency has the statutory authority to follow through. Development must be
held in abeyance in sensitive areas until such prioritized ordinances and regulations are
an actuality.
A decision appears to have been made by some one (?), somewhere along in the process
(?), that stormwater sewering, particularly over the aquifer, was not economically
feasible. A thorough public discussion of the known treatment capabilities of urban
runoff by grassed percolation is long overdue. We are presently being asked to make
some of the toughest environmental and economic decisions to protect generations to
come and we cannot do it in a vacuum or without all the information for an informed
judgment A convocation on the stormwater issue alone is mandatory.
Before we blindly continue following "trends" in development over the aquifer as
reflected in the current Comprehensive Land Use Plan, we must have definitive answers
to the following questions. Are we using 50% of recoverable aquifer water? What,
recognizing the aquifer as a finite resource, is the development limitation? Can the
expansion of the original 208 PSSA boundary be justified? What are the implications of
the new federal regulations regarding underground injection wells?
Either the County Commissioners or the Governor must initiate a proposal for "Inter-
state Management of the Spokane-Rathdrum Aquifer."
The "208 Plan" must be officially adopted by the Board to give it legal status as a plan-
ning tool for Spokane County. All that work and expenditure of taxpayer funds must
not continue to be ignored!
278
-------
201" COMPREHENSIVE WASTEWATER MANAGEMENT PLAN
The 201 study area boundaries conform to the Critical Water Supply boundaries, not
the 208. We therefore see the 201 study incorporating the same West Plains area that
was excluded from the 208 study without the necessary data to determine interrelatiorv
ships and best decisions for long range planning for the region.
Admittedly the 201 Plan follows the Comprehensive Land Use Plan. It also automati-
cally follows that if the Comp. Plan is not technically sound neither is the 201,
The consultant on the 201 expressly stated the final document would meet the legal re-
quirements for sewage plans for both federal and state law. We now learn that this is
not the case. The 201, as presently printed, does not have sufficient detail to meet the
requirements of state law and therefore cannot be approved by the Depts. of Ecology
and Social and Health Services.
The public has continually been given polarized alternatives to select from. The
numerous variations in between (e.g. the Latenser Plan) which have been ignored or
slipped by are relatively unknown to the majority of the people.
We're being told a General Obligation Bond Issue will probably be on the ballot this
Fall. But, we are not being told the total costs to the taxpaying public and we're not
being told how such a system will be sized. If it follows the Comp. Plan it would have
to maximize the size to conform to the potential maximum population growth contem-
plated by the adopted Classification Map of Spokane County. Since developers have his-
torically triad diligently to maximize the density on each postage stamp lot in Spokane,
the new Comp. Plan with its 17 unit per acre, commercial and heavy industrial classifica-
tion (over the aquifer) and its expressed encouragement of high density fill-in makes sa-
turation development inevitable.
The 201 expanded the PSSA which was already too large in the 208.
There is a built-in funding problem under both federal and state construction grant pro-
grams in that they are not supposed to fund projects which will encourage sprawl and
the escalating loss of agricultural lands.
We don't see any fallback position if the proposed funding package doesn't materialize.
Someone, somewhere obviously made the determination not to include sewering for
urban runoff even though the 208 stated that such runoff, at existing densities, contri-
buted almost equally to the degradation of our Sole Source. The 201 deals with only
one source of the overall problem. EPA's Draft EIS on the 201 states, "The metals, sol-
vents, herbicides, pesticides, and numerous other chemical compounds that are fre-
quently found in runoff from urban areas may be just as significant a threat to
Spokane's drinking water supply as sanitary wastes considering the extent of develop-
ment planned over the aquifer east of the city."
279
-------
RECOMMENDATIONS
In light of severe deficiencies and conflicts in local planning for land use over the sole
source aquifer, the 201 in its present form is premature and incomplete. A capital cut-
lay of this magnitude and with the most complex environmental, economic and social
considerations should not be rushed precipitously to a vote, or irretrievable commit-
ments. We therefore recommend the formation of a knowledgeable, working committee
of agency representatives, and lay citizens to determine the implications of the following
studies for which huge sums of public monies have been expended: (1) Comprehensive
Land Use Plan and Classification Map; (2) 208, (3) VVasteload Allocation Study (Dept.
of Ecology), (4) Underground Injection Control Report and (5) Draft EIS comments on
all documents.
A public hearing is needed to determine whether or not the 201 as it now stands does or
does not meet state requirements for the County Services Act and WAC 173-240. We
also need to know if it's appropriate for a hired consultant to personally lobby officials
in Olympia or are they only to do an objective study?
Since we, the taxpayers, are going to be asked to pay for the project we had better be
given all information necessary to make the best informed decision. A public debate
must be arranged between the major entities involved (City, County, Dept. of Ecology,
EPA, etc.) to air the critical issues presently being discussed behind the scenes in
Olympia and Spokane. We would assist in such arrangements.
How would a system be sized with a 40—50 year Classification Map? How does ths
City's required separation of stormwater and sewage fit into the overall scheme of things?
How does 201 justify the expansion of the 208 PSSA boundaries? Can we realistically
expect funding for a system which perpetuates sprawl and loss of agricultural lands?
Can we realistically expect any other than minimal federal funding? Why is urban run-
off over the aquifer being ignored? How can funding be acquired without a vote of the
people? What can we realistically expect from state Referendum monies? Where will
the trunk lines and lift stations be located for the total collection system? Who deter-
mined the "Phasing" of 201 and how? What is the bottom line as far as cost to both
City and County residents? Will an assessment be made, and a mechanism developed, to
protect those who genuinely can't afford additional costs? Until the above minimal
questions are dealt with, up front, by those with the answers we cannot envision blind
support for such a multi-million dollar capital outlay. We expect straightforward
anwers.
We need to know if a scaled down demonstration project has been considered in light of
present serious economic conditions? We need to prioritize on a smaller scale for
various fallback positions.
280
-------
GENERAL COMMENTS ON THE AQUIFER
Good planning does not follow disastrous trends; it directs growth to the appropriate
areas with the least physical, economic and social detriments.
During the recent court arguments-on the Stay of the Comprehensive Plan, a County
planner when asked directly what Spokane County had done to protect such a valuable
resource as the aquifer, replied, "Very little," These words sum up perfectly the abdi-
cation of responsibility so prevalent in Spokane. We have overclassified "more of the
same" in a region with no data on carrying capacities, no groundwater standards, no
watershed protection, no subsurface discharge permit system, no control over Idaho's
plans to develop its own area, practically no historical background data in any area, no
margin for residual buildup of contaminants in our soil, uncounted thousands of under-
ground injection wells on every corner. Are you aware one-half (500) of the entire
State's total sewage systems which discharge over 3,500 gallons per day into drainfields
are in Spokane County? Also, that numerous drainfields are paved over in direct vio-
lation of state law?
Recognition must be made that local studies are starting from someone's preconceived
idea of what is "politically feasible" rather than from a position of neutrality and objec-
tivity. We resent paying for political documents that are not in the best interests of the
community as a whole.
As a group we are convinced the Spokane Aquifer is not a sponge with unlimited capa-
city for absorbing or diluting pollutants and neither do we feel that the law of gravity
has been repealed.
We cannot afford to play Russian Roulette with a Sole Source drinking water supply by
encouraging high density "fill-in" development over such a huge area as the FSSA. A
rational demonstration project must be developed to see if anything other than rural
plumbing is even feasible.
We paid a million dollars* for Capability maps and data that are nowhere reflected in
the adopted Land Use Plan and Map. We demand an accounting!
A thorough analysis is in order and long overdue as to how we overciassified eight times
more land than projected to be needed for the next five years.
How does the Plan Commission and the Board explain the fact that each and every
agency with expertise sees the same defects in the recently adopted Comprehensive
Land Use Plan? Are we all out of step, or is the County? And, why were there no
responses to comments and questions submitted at the public hearings?
The 5 acre waiver (10.1.3) in the GSSA must be removed from the Comprehensive Plan.
Since the 208 proved conclusively that drainfields were insidiously contaminating the
aquifer, how can interim systems allowed in the Comprehensive Plan ensure protection
of that same aquifer (10.1.1)?
281
-------
KNOWN CONTAMINATION EVENTS IN SPOKANE COUNTY
26,000 gallon diesel spill from storage over the aquifer.
Millwood, Model Irrigation and Edgeciiff all had to close wells due to persistent bacterial
contamination. Other systems have required periodic flushing and chlorination.
Some excellent private wells were lost due to cyanide infiltration from the Kaiser
Mead potlining dump.
Contamination from 1.1.1. trichloroethane in Colbert wells adjacent to the Colbert land-
fill, sludge and chemical dump. EPA tests have detected such solvents in drinking water
sources along Trent also.
Tordon, an herbicide, has been persistent in the Airway Height drinking water system.
Heavy concentrations of chloride polluted the Kaiser Trentwood and Great Northern
wells decades ago. The Kaiser Trentwood chloride dissipated relatively quickly due to
the fact that it is in direct line of flow of the major portion of the aquifer and received
more dilution. The Great Northern is still unusable to this day as there has been insuffi-
cient infiltration of clean recharge to dilute the heavy concentration of chloride. The
aluminum dross which caused the previous problems has also ruined a private water su
supply in the foothills resulting in litigation and an out-of-court settlement for a new
water supply for the property owners. Another dumpsite for aluminum dross (Heglar
and Kronquist roads) has been posted by the Health District as a dangerous area. There
is a cave-in potential and the site is venting ammonia fumes. A mountain of the same
material is now being built at the Mica landfill by daily trips from Kaiser. The dross is
extremely water soluble and is being dumped within the Sole Source Recharge boun-
daries of the aquifer.
High nitrates, very damaging to newborns, are especially prevalent on fringe areas of the
aquifer. Consistently high readings have been taken at Hutton Settlement, Mead wells
(near the abandoned North Star dumpsite), the Miller well in the Pasadena Park area, the
Gerimonte well in South Opportunity and the Pleasant Prairie well.
An ex-chemistry teacher living in the Orchard Prairie area with a 160' private well dis-
covered an oil slick in her bathtub. In checking, she learned several oil pipelines run
through her general area. Although none admitted to any awareness of a leak, the oil
gradually dissipated. But for many months she had to import bottled water.
Uncounted thousands of drainfields have failed in the North Suburban, Ferris and hill-
side development areas. Raw sewage has run down the hills from Ponderosa, Painted
Hills, Dishman Hills and the Red Lion Motor Inn. Numerous lagoons have eroded and
overflowed such as Fairwood into the Littie Spokane and Deer Park's system into
Dragoon Creek. Cheney's system has also had persistent overflow problems. Major
drainfields have all had to be replaced at: University City, Hillview Estates, Aioha and
Castle subdivisions, to name only a few.
282
-------
ovenber 10,
(JsC7?"R "P^ ^ ^ ^
7>£7 STO.
\ j* i-fiT!<>*>&
-^BC-rS.
"2 its ?'itiauns li Spokane bounty.
7ne local Health District has consistently a P. oweJ pavirvr and vehicular traffic
av?r irainfields and loaii!;? rate3 three or four tin:e3 higher than DSH3 and
i-isirn criteria, A- a direct consequence, numerous systons 'nave failed and revis
i-. atrr c;.-al r^stsnsf cil Ity of DSHD has been circumvented.
?r?rite cu- rest efforts, the Spokane County health District refuses to ec~tiy
~ i-.h >i*2ticr.s 1.C4, >s0 and	of its state aprrcvcd refrul\tieh3 and con-
•i'.zes allow in.? installations that do net rcet the r ~ •e .ninlru.as. Hujre a tart-
rsr.t sanplexei have sprung up ovctnljjht with trair.f!elds ur.der raved, postage-
« nv;"-- lzzzr.zl-3 is the Moraine of n'A" 24o-^''-0^0(£i, "...at any eohaor. point".
:-»ry Flews a?:" the entire Spokane staff can detail rr.-merous exastles of " .'"lr.e
•:r.Lt installations" such as Fil-l{'Jrccn Hollow Jubdivlsicn} and the start-
-rtt crsplex at Pines ani 32nd.
*- .-.crs rcrert example and one for rfhich I*& requesting your personal and imedint
-s"; is tar.ee is a ponding .":Ocilo Ho.?.e Park ("r.'-yo-SCj. This Jar> will be located
r. rsrticularly sensitive area vnere numerous wells are aireidv runnirx ever
!? m nitrate. The site is an intrsral part of a raj or roch.ar.~3 area to the
.* :1« jr-vrre atuifer and has a leitrtny history of surface water drainage rrcblers,
Zr. 'art, the eriiro area is presently under study Ly CHZ'A Hill to decide- he*
to deal with r-:r.off. Desnlte all of tho above adverse er.vironr.-3nt.sl proolezs
ant rzany nere . an 213 uaa not even required and approval Is fcr-injr ahead.
Trr addition: 1 information wo are attaching a cory of curstantiatiryr data to
•-•.rtrrr-. cur ™c?,!.tion on a Hoquect for F.eccnnIderati cn to the Spokane 2card cf
: r-j n t y - c-_t. : n ? 1 c no rs.
aeotir x
.... ,r -y fir"t -vie* Ccmtttegf'at S'm-Tac, T learned otr.er areas of the stats
zr-i -~z f.ictd w'.th such a;uses cf Iccil pcyer. Hut, the viclaticr.s in Spc'iane
"."cunty are rannar.t and d-?rj»ni ir.nndiate, eaer^ency action. Ipc-r^ne, irith a j-ole
: yjzz-i ariuift-r. cannot a'ftrd to rait for the Movie a "--mittce to accomplish ita
•as'*:, Ar. er%.—e.ncy directive is i.xp.*native!
283
-------
STATE OF
WASHINGTON
Dixy Lie S.»y
Gcs.
DEPARTMENT OF SOCIAL AND HEALTH SERVICES
OiV'PM. A hMn^iuii *w><>i
December 10, 19-S0
Ms. ran ican
5az'z 5? j- Bcvdish Road
Sprkar.a. "ashington 99206
Dear Ms. Konican:
Thar.k you for alerting me to the proposed mobile home park, identified
presently as ZN-96-80 in Spokane County. I am directing staff ir.er.bers of
the Water Supply and Waste Section to review not only the proposed mobile
hone park, but the general application of KAC 248-96 where it appears
that violations have occurred.
Z'r.a z re; act' s most significant problems and conflicts with the state on-site
savage regulations appear to be as follows:
1.	•£•.•=:= application rates exceeding WAC 248-96-095(5).
2.	Hizh density - WAC 248-96-050 and KAC 248-96-090.
2. Protection of potable water supply source - WAC 248-96-050.
Paving ever drainfields - WAC 248-96-100(C2).
If the issues you have identified in your
direct the Spokane County Health District
c\ic	'~c-:cu"^nce
request are verified, then I will
not to approve the project vith-
The present Spokane County Health District regulations were approved by ._e.
The conflict clause of the Health District, Section 1.04.390 mandates the
local department to enforce more stringent standards if there are conflicts
with the provisions of other health standards including WAC 248-96. Mv
approval of the existing local regulations was made based upon Section 1.04.390
j-;ini useu Tor projects such as the propose' "inh i i,» home nark.
Ad pr=vi:usly noted, the matter will be investigated and directives issued
if t'-.= ficts presented arc verified.
S i nceri'l v,
^	¦<- '
John A. Bean-, M.I).,
¦) fcv i s i .->n 1) i roc tor OB-44.1
Health	Division
r-?:.: Ju.-jtus, Regional Engineer
1. Marashi, M.D., Spokane Countv Health District
John Sneneer, DOE
284
-------
ST.-YI! OF
WAf-I li.N'G I'ON
i • y
CJ Z.-C	
DEPARTMENT OF SOCIAL AND HEALTI I SERVICES
April 9, 1981
Kory Q. Luther, M.O., Health Officer
Spcktfie CoLii-iy Health District
West 1101 College Avenue
•Spokane, Washington 99201
Attention: Mr. Edward M. Pickett, R.S., M.P.H,
Di rector of Environmental Health '
^ ¦ r-1K &


Deer Dr. Luther:
A written complaint concerning your staff's action on rezone application
#ZN9680 was received by Dr. Beare on November 10, 1980. The letter was
written by a Ms. Joan Hcnican who expressed several concerns about viola-
tions of WAC 248-96. More specifically, Ms. Honican has al legated that
community septic tank systems are being approved by your department which
do not specifically meet the requirements of the following:
2.
3.
4.
WAC 248-96-100(2)
WAC 248-96-095(5)
WAC 248-96-110(3)
•"-96-050(3)
WAC 24o
Dr. Beare replied to Ms. Honican's letter and* directed me to review the
situation and to recommend appropriate action if there was substance to the
allegations suggested by Ms. Honican. If you recall, we discussed this
matter on my 1st trip to Spokane on February 10, 1931.
After a revie./ of the rezone application data and after a review of other
systems approved by the Spokane County Health District, I do believe that
violations of WAC 248-96 are occurring with surprising regularity. The
violations appear to be confined to tlie following items:
1.	Drainf icJs ai e being covered with impervious surfaces.
2.	Sewage eppl'¦cation rater, exceed limits established by the Interim
Soil Evaluation Guidelines and are computed incorrectly.
3.	Design loading differs significantly frcm standards established
in USPHS #526 and other documents.
f.'.s. Honicun also suggested 'n her letter that various water quality viola-
tions are occurring and have been caused by actions or inactions on the
Za'i -jt the fpekane County Health District. Section 050 of the State Board
'J *.n ku'c*. <:"U Kt-gu 1 -it ioris tor Un-site Sewcge Disposal discusses to
ce-,:ree tne st..ndaros relating to ground water pollution. Section US0
r:.jre specifically relates to ha/yiMous sites, treat::,ent potential of 50'Is,
285
-------
Mcry Q. Luther, M.O., Health Officer
Spokane County Health District
April 9, 19S1
Page Two
end soU depth requirements. The proposed mobile home park is located
in an area identified as a direct recharge zone for the Spokane aquifer.
Recent studies conducted by the Spokane County 203 organization have
concluded that significant nitrate accumulation is occurring downstream
from the proposed mobile home site. I believe this issue should also be
of concern to you and to the Department of Ecology.
Admittedly, the Spokane County Health District rules and regulations allow
for some deviation from the state standards. Your local rules were approved
by Or. Beare in 1976. However, your regulations contain a conflict clause
in Section 1.04,390. If, according to your local rules, there is a con-
flict with another set of rules, the more stringent will prevail. In the
cases cited concerning violations of specific WACs, the state rules ere
more stringent and should be enforced. Local deviations from the state
standards are allowable for those sections in the state regulations
where this is permitted. In the specific sections identified, local
deviation is not permitted without specific qualifications.
If convenient for you, I would be available to discuss the apparent con-
flicts and hopefully achieve a resolution of the issues. Our Spokane
regional staff should also be part of any discussion since they work
more closely on a day-to-day basis wUh your staff. Would you please
call me at (206) 753-3407 to arrange a mutually convenient time for
such a meeting?
GP:mh
cc: Ken Kerry
Jim Pluntze
Eric Slcgle
Tom Justus
DOE
Sincerely,
Gary Plews
Water Supply and Waste Section
Health Services Division
286
-------
j^Xdif^TT FP\C/» Ttf£ 2>£~/S
OF T5"?<5. dC OA)TV C&M ?¦
J. A AJD V S = ~PL-AAj
retailed -aps of existing County-wide 1 ar.d use patterns are
available within the Planning Department. These maps show tnat
major cornercial activities in the County are primarily exten-
sions of the commercial activities in Spokane City. The major
thoroughfares of Division Street, extending north of Spokane,
and Scrague -venue, running eastward in Spokane Valley, extend
outside the City and are primary supporters of commercial acti-
vities. Large shopping centers exist in the Valley, and more
centers are being proposed there and north of Spokane. Commercial
activities within the County are also found east of the Spokane
International Airport and sparsely along State Route 2 runnir.c west
of Spokane. Comercial zoning follows very closely with exist-
ing land use patterns suggesting that commercial uses follow
srortly after ccmnercial rerones are requested. Lands in the
valley along Trent Avenue, in addition to lands adjacent Sprague -
Avenue, are zoned primarily Commercial or Industrial. Other com-
mercial zoning is located north of Spokane adjacent Division
Street to the area around the intersection of State Route 395 and
Stats 3cute 135. Other lands west of Spokane in the Airport Vicinity
areas are also zoned Commercial. Most of the industrial devel-
opment occurs east of tne Spokane City boundaries between Trem
and S-rague Avenue. Sparse, large industrial developments also
occur in the '*ead area north of Spokane, east of Division Street,
ar.c in areas west of the Spokane International Airport. The
-resent pattern of existing Industrial toning is very similar
geographically to industrial development patterns.
• -.viromental Impacts:
''"-zzczz fe Comprehensive Plan has uoon the area's '.and
jse	depend jpon the decision makers use of tre -
i'Cul t tre dec: v'or -a^ers adcot the ?1an tnrougn resent:.:-.
r.5."	r-5v-:- substantial influence uron future decisions,
fe 2Iar re "accePtec', its impact could be snail ccmcarec :c
an "adoption",	287
gy.M%rrO_
-------
for the Plan may not be used in any decision-making.
The Plan may also be rejected or amended by the present
decision makers (Board of County Cormi ss-'oners) ir. v,rnc'
case the Plan as presented will have little or no im-
pact. As mentioned in the introduction and sumzry.
the assumption is made that the Plan will be acootec
as presented and guide future land use decisions made by
various decision makers.
Should the Plan be adopted, the largest impact upon lane
use will most likely be connected with what is temed
"development sprawl", or the expansion of various future
land uses over a large area rather than the concentrate
of land uses. Such scrawl may occur from several aspect-
of the Plan, first, the future peculation which can
acconmodated within the existing categories is 2 t-~es
that population whicn is projected ever the next 2C
years. If one assumes that the Plan will be updated
every 5 years, that suggests there is 8 tir.es rore de.-:'
opment land indicated on the Plan Mao than is needed.
multipliers suggest that policies do net er.ccurage :=v=':
ment close to existing facilities and services, but a:t.:
encourage expansion over a broad area (es:ec"'al*y ;
land away rrom these services is often less expensive
land near these facilities and services).
Secondly, in many places there is "Suburban" classifies"
land surrounding "Urban" cUssifiec land accordi?
Plan map this can result in "leap-frog" c'evelopr
the 31 an is updated. Once Suburban -and is develcr&d *:
Suburban densities, Urban densities are unable to e.xpar:
into the Suburban categorized land. The Urban categcry •
must expand beyond the Suburban category or ex;arc
an area whicn has net been developed
exists south of Opportunity, .vest c
of Millwood, and east of "ead.
' 3
- '
288
-------
Thirdly, commercial activity is encouraged by the Plan Mao to
continue in its "strip" format since few Commercial "nodes' :*¦
centers are designated. The Ma? sirnDly outlines major Corrr.ercial
lines along Division Street, Trent and Sprague Avenues, Argcnne
and Sullivan Roads (See Map 1). Such Commercial develooment may
precipitate traffic congestion and also encourage residential devel-
opment along commercial activities, thereby possibly encouraging
spreading of future development.
Fourthly, major Industrial categories are being proposed in two
najor areas—one east of Spokane City in the Valley, and one
west of Spokane where little Industrial activity presently exists.
Encouraging Industrial activities over a broad area can continue
to encourage development supporting such Industrial activities
also over a broad a*-ea.
This development sprawl potential becomes an important issue when
considering agricultural and/or natural land oreservation. energy
costs, service costs,.and facility costs. .The more land develop-
ment consumes, the less land there is available for agricultural
production or natural amenities. Also, it has been shown in
studies that more concentrated development consumes less energy
ana costs less to service with public facilities (such as roads,
water, utilities, etc.) than does sprawled development.
~ne generality of the land use categories of the Plan ~,ay a"so
create problems with tne County's land use. Several land use
categories do not provide guidelines to decision makers on a
-.-re soeci-'c basis. While this allows flexibility for the
decis*"cr rr.c'sr, it produces less certainity for f-: "
*cr zre dec::*.on r.a'rer under various circunstances.	~a;.es "t
ocssible T'or inconsistent land use decision	r;.^ 2 ~r" e.
'".tz jr. * classifi ration pro cosed within the - Ian 1 «€**_. zrzzz
:ategor/. Whi • e within 
-------
no policies giving local business locations! direction wit
the Urban classification. Such criteria must be fcurd wit
the Major Commercial Category.
The "Industrial" classification is anotner example c* arct
land use category which makes it di*f icy-It to dstsr-.i-s z~
actual land use impacts. The classificaf'c-	:-c
heavy and light industrial activities—each having /i-y--
impacts. The impact of a series of storage units, *cr ex a.
will be entirely different than will the impact of a heavy
manufacturing plant employing hundreds of workers on sever
work shifts.
A large amount of Semi-Rural classification is ore rosed ;n
Plan. Such a Category when develooec reouires the same a~
of some services as the more intense categories. For exam
the fully developed Semi-Rural lanes will reouire --cacs tc
school services and developed areas, however, lower z="S'
populations in such areas will mean higne*- ird:vic-;l cost
such roads and services than if tne lane were ~c*s ''".rnSc
developed.
Another impact of the Dlan relates to the Sural arc -cricu'
land use classifications related to the Plan's agricjlturi'
preservation intent. A1 though t^e ~ajor •'rtsr-t C" t'e -cr'
culture classification is to crotec: aor'cjltura' 'ft, zri
Rural classification may have as ~ucn a caoac'ty t; crese'%
agricultural land. The .-.ural classif'•cat'on limits deve'er
density to a maximum of 1 unit per 1C acres of larc. Whi't
density is established within the Agriculture Category, ty
sites of variable size ire allowed on "marginal f^ml = nc"
according to Decision Guideline 6.2.1. *Jc where ir trs ~e,<
however, is the term "marginal11 defined, "hus, c~\ e" z?~f.
density on ¦ Agr icul ture classified lanes ma/ -"esc •
tansir.y in seme areas.
290
-------
Mitigative Measures:
Sprawl problems mentioned above can be handled e^t'-e^ by
adopting new ordinances or by changina the Plan as it
now exists to keep future development as close to existing
services as possible. Adoption of ordinances which
encourage develooment on lards closest to existing
development before other lands are developed, or "phased
development" will reduce many of the potential sorawl
problems. This can be accomplisned by planning public
facilities only in areas where development is desired, by
allowing higher development densities than the °lan
defines in areas closest to places of settlement {referrec
to as "bonus densities"), or providing other economic
incentives which would encourage phased development and
would discourage sprawl. Phased development could also
be important in preventing Droblems created by large areas
being classified Semi-Rural.
To address the "leap-frog" problems created by Suburban
classifications surrounding Urban classifications, the
Plan Map can be adjusted or continued detailed planning
can aid in graduating Suburban lifestyles into Urban classi-
fied areas. Areas along the fringe of Urban classified
lands may be placed into another category having ceve'rb-
re°t intensity similar to the Suburban category. Trp's
permits gradual transition between Uroan anc 3-.. Durbar. cate-
gories. Higher density Urban categories .-/cu'c be cerm->:e:
adjacent ?ural classifications tnus allowing expansion into
Rural categories should it become necessary in t-.e T"uture.
Detailed planning will reduce seme of ct~e<"	ers
orevicisly identified. Further o'anrirc nr	t'e
mere • a 1 , ir.c : :."t *r;custrial categories
291
-------
thereby reducing generality and providing mere definite ].r
policy guidelines for future development in Urban class'
fied areas. Also dividing Industrial categorized zr-i-
into "light" and "heavy" industry categories v.ill a*
aid in projecting those areas potentially hav'ng the
est physical impacts.
Rather than stringing Commercial activities alone
roadways, Future detailed planning "light cluster Sub-
categories into several areas. Future Industrial acrr
ties might be classified on one side of Spokane or z'-.z
other thereby preventing the sDreading of such act"vit\:
throughout the Metropolitan Area.
To prevent someone from taking advantage of tre exist*^;
Agriculture classification, it may become necessary to
provide a definition if Lie term 'marginal" as used wir
the Plan Text.
d) Unavoidable Adverse Impacts:
Without changes in the Plan as crooosed c-r without tre
adoption of mitigative measures outlined abo>/e, tre
may set a formal policy for ;and use straw*, res-'f>:
in increased service and -acility costs and ciusi-r n"';'
consumption of land.
292
-------

planaMlm
frEasto°ate€l
Editor's Note: Mr. Wavada has been studying and
reporting on land use planning in Spokane County and
North Idaho since 1975. Before joining our staff in May, ho
was the public information specialist for the Spokane
County Planning Department. Much of the following
analysis is drawn from his personal experience with the
Spokane County planning process.
by Jim Wavada
The Spokane County Planning Department recently
published an environmental impact statement (EIS) on the
county's proposed comprehensive land use pian. What the
¦AiBsalysas'
bulky document says, in so many professional buzz words,
is thai the plan, as developed by the appointed Citizens
Coordinating Committee, is a travesty.
The message is buried amongst the "mitigates, com- .
patibles and implements," but it's there. The plan, which
has been six years in the making, simply won't do what a
comprehensive plan is supposed to do — provide for
orderly, efficient growth.
The most damning indictment of the plan in the EIS is
couched in planning terminology on page 100, the land use
section of the document:
"Should the Plan be adopted, the largest impact upon
land use will most likely be connected with what is termed
'development sprawl' or the oxpansioh of various future
land use:, over a large area, rather than concentrated land
uses."
"The future population which can be accommodated
within tho existing categories is two times that population
which is projected over the next 20 years," the EIS says.
"II Kiic assumes that the Plan will be updated every five:
yean;, thai suggests there is eight limes more develop-
ment I.'hhI indicated on the Clan Map than is needed. Such
multipliers suggest thai policies do not encourage
development close to cxtMmq facilities and seivieef,, but. ¦
nctuallv ¦ m.-outagos expansion over a broad aiea
(especially since land away from these services ir, often
less expensive than land neat those facilities and :iei
; travesty. In claiming to plan lor 7.0 yenra* population, Iho
i Citizens Coordinating Commlllee would hnve uo bollovo
It's possible to predict population trends that far In ad-
vance, or that It's deslreable now to commit land for oach
of these presumed families to have tholr homos on one
acre lots, built over our only source ot drinking water.
Moieover, the realities of Spokane County land
development is that county land uso committments
amount to contracts between landowners or dovelopers
and the county. If a developer subdivides 100 acres into
half-acre lots for homes 20 miles from town and the
county okays that plat based on lis land use plan, the
developer has the right to proceed with his plan no matter
how circumstances may change over the next 20 years.
What this has meant to Spokane County in the past and
will mean in the future, unless the Plan is changed, is a
green light for leapfrog development to continue unbridled.
And why is this happening? Who does it serve? To be
sure, Spokane County needs to plan for more people in its
future. Professional planners say that can be done by
planning in five-year increments, making changes at the
. end of each of those periods to reflect changes in
lifestyles, transportation, population. Further, they point
out that development will cost taxpayers less to support if
it occurs near existing sewer lines, water systems and
other amenities found where city services already exist.
Professional planners aren't espousing "no-growth"
policies, they're urging "smart-growth" policies.
So why does Spokane County's land use plan show
housing miles from any sewage disposal systems
adequate to handle it? Why is commercial and industrial
development planned only along freeways and highway
stops? Why are good-sized chunks ol undeveloped
agricultural land committed in this plan to urban and
suburban density housing?
To answer these questions, the reader need only look at
the genesis of this latest planning effort and tho people
involved In it throughout,
Spokane County Commissioners decided the county
needed to do a "real" comprehensive land uso plan six
years ago after the state, prodded by n lawsuit in western
Washington, advised tho county lis zoning otdinartce
'stood on shaky ground when backer) by such a vague and
sketchy plan as the one it had then and still has.
Hut planning is a controversial subject, especially In a
county where development tradition.-Ily hat. been a no-
holds-baned proposition, where population growth hod
been modest, and wlteie political philosophies ol those In
Continued on Page AB
-------
The Community Press. September 3,
Continued from Page A1
'9 cc'jrfc jse ~.ad tended to conservative.
5~s tne p:annmg ef'ort became nec*
isary, he.-.ever. two narrow interest groups
-.arced »v?h :heears. however, was just right, in-
s^tead c ';s vng a teo-cbv
-------
'ZD^i. "71 s 03iv4 s< c,v
U.S. ENVIRONMENTAL PROTECTION AGENCY
^tosr4^	REGION X
1200 SIXTH AVENUE
 \i t.
»t?ir ro M/c 14.-3	•:-» - • •«	-
*n,s Of:	. 1/ j tt J	ij
*: 1 1350
. JUL 28 1380	SP0MNE CJUNTj
PLV-JN1NG DEPARTiV,
Wall is Hubbard, Director
Spokane County Planning Department
'.crtn 721 Jefferson
Src.one, Washington 99260
RE: Comments on Monte Del Rey EIS
Dear Mr.. Hubbard:
4
*
We appreciate the opportunity to review the Draft Environmental Impact
Statement (EIS) for the Monte Del Rey Planned Community in Spokane.
We are concerned with the potential impact of this project on the
Soekane Valley - Rathdrum Prairie Aquifer and the lack of detail in
tne Draft EIS on this issue.
Since the Spokane Aquifer has been designated as a sole source of
potable water supply under Section 1424(e) of the Drinking Water Act,
EPA has been involved in several studies to protect this groundwater (n)
sucoly. In addition, the recently adopted "208 Plan" for the aquifer
essentially establishes a policy of nondegradation to protect the
acuiTer.
The Draft EIS contains little specific information on the impact of
placing a tirainfield from a treatment plant over the aquifer. For
instance, it is stated that "some of the treated wastewater (which
contains dissolved nitrates and phosphates) will percolate down to the
aauifer level" but does not provide specific details, or even esti-
mated amounts.
©
The Draft EIS also indicates that the potential for contamination of
the Aquirer should be considered an unavoidaole adverse impact of the —^
project. This statement is inconsistent with the goal of the State- fw)
scooted 2C3 olan and the result cannot be considered acceptable.
295
-------
2
We suggest that this project be coordinated closely with Ray Card
of the Spckar-e County Engineering Office who is the 2C8 ?Un
coordinator and that the Final EIS contain the level of detail neeced
to adequately determine the impact of the project on the water supoly.
If ycu wish to discuss our comments, please contact Kathy Davidson
at (226) -U2-4011.
Sincerely yours,
H>. ,tUik —
Elizabeth Corbyn, ChiefJ
Environmental Evaluation Branch
cc: A.
Ewi ng
0.
Robison
R.
Card
296
-------
Comment noted. The project's impact on the Spokane VaIley-Ratheru-
Prairie Aquifer will be substantially mitigated by the use of a sewage
treatment plant which will degrade organic matter into CO2 and H2O, and
will remove bacteriological contaminants from the effluents dispersed
through the plant's drainfield. Chemicals, such as nitrates and phos-
phates, entering the drainfield soils will be acted upon there by micro-
organisms to some extent. It is highly likely, as found in the 208
study, that some undesirable constituents will reach the aquifer fron
this hillside location. However, to the extent the 208 racorrendaticns
are policy of those making decisions regarding Monte Del Rey, the project
will be consistent with the 208.
Comment noted. The "208 Plan" does establish a recommended nondegradation
policy to protect the Spokane Valley-Rathdrum Prairie Aquifer. As noted,
the U. S. Environmental Protection Agency has recently adopted the
"223 Plan" recommendations. It should be noted that no federal funds
or financing will be employed. Guidelines and recommended actions
espoused in the proposed text of the Spokane County Comprehensive Plan
and the Spokane Aquifer Water Quality Management Plan, April 197S, nave
not been formally adopted by Spokane County. It is recognized that
project's drainfield is located adjacent to the Aquifer and within the
Aquifer Sensitive Area, and is in conflict with several 208 policies. It
must also be recognized that the "208 Plan" guidelines and policies may
not be directly applicable to the licensing or approval of the proposal,
although many of the recommendations are appearing in agency rules.
Comment noted. Please reference response 16 above.
Comment noted. Please reference response 17 above.
297
-------
Material Appended to Letter From
Rhys Sterling Dated
May 21, 1981
298
-------
Con^en." noted. No response required,
299
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
ATTN OF: tf/S 409
March 28, 1980
Mr. R. C. Brinck
Service Office Supervisor
Department of Housing and
Urban Development
West 920 Riverside Avenue
Spokane, Washington 99201
Dear Mr. Brinck:
This confirms a March 21 telephone conversation between Harold Scott, a
member of my staff, and Mr. Bob Giesa regarding our preliminary review
of the February 1980 Ground Water Impact Evaluation for the Summerfield
East Addition S.P. #415.
In accordance with our September 1979 Memorandum of Understanding, the
project is unacceptable under our "Sole Source" Aquifer Protection
Program. The project, as designed, could create a significant hazard to
public health because of the increase in the nitrate level in that
portion of the Aquifer. Three wells in the general area show elevated
ambient nitrate levels of 6.3 and 7.8 mg/1 as (N) and the Evaluation
Document shows that the 266 homes on septic tanks will increase those
nitrate levels.
I have attached a list of specific concerns regarding the Evaluation,
and I have sent a copy of this letter to Mr. Rhys Sterling for his
information. We would be glad to review the project again after our
concerns are addressed.
I hope this information is helpful. Your concern and interest in pro-
tecting the Aquifer are appreciated. If you need additional information
please contact us.
Si ncerely,
V.'i 11 iaw A. Mullen, Chief
Drinking Water Programs Branch
Atndvent
cc: Rhys Sterling, DOE
(with ropy of attachment)
300
-------
Comments for Preliminary Review of the
Summerfield East/Spokane Project
Specific Comments
Page 1
1.	The geometry and scale of the site as illustrated in Exhibit A
does not match that of Exhibit B.
2.	"If a control treatment system is selected, the drainfield would be
be located in the PSA type soil" (Phoebe sandy loam", 0-5% slope). An
examination of Exhibit B shows that no type PSA soils are located within
the proposed project site boundaries (some Ps^ soils are directly adjacent
however).
3.	The method by which the data in Exhibit C were generated should
be explained - including the validity and adequacy of the sampling.
Page 3
1. The method by which the loading rates were determined should be
explained - including how the loading rates relate to the permeabilities.
Page 8
1. "During any month, this daily discharge equals approximately 1.14
inches of water applied over the entire 91 acres, as would be the case
if individual septic tanks are used." This statement is not valid.
Other than during the initial capillary zone advancement, percolation
of septic drainage is essentially vertical with only very little
lateral travel prior to encountering the zone of saturation/ground water.
Therefore, because the septic tanks and their drainfields are normally
located entirely on-site, beneath the residential lawns, the 350 gal x
266 dwellings should be applied only to the actual surface areas of the
drainfields. A generous assumption would be to approximate those surface
areas by equating them with the total residential lawn surfaces, or 36.64
acres (from 6000 ftVlot x 266 lots).Then the daily discharges would
total 2.81 inches/month.
Page 9
1. A comment similar to the page 8 comment would apply to calculation of th
monthly quantity of irrigation. Since only the 36.64 acres of lawns
are irrigated, the volume of irrigation water should be divided by
this figure and not by the total 91 acres. In this case the daily
irrigation discharges would total 5.77 inches/month rather than the
2.33 inches/month suggested in the impact evaluation.
301
-------
2
2.	"From the discussion on soils, water-holding capacity of about 0.08
inches/inch (0.96 inches weter/foot soil depth) may be used. From soil
logs, a depth of about 5 (five) feet to cobbles generally exists on the
project site and as a result the root zone and evaporation zone may
by assumed to be the same 5 feet." This assessment is incorrect. Firstly,
two soil logs, one for each of the two principal soil types identified
within the project, are inadequate to define such a critical parameter.
Several replicate samples, each set at one of several representative
sites, should be collected and analyzed. Secondly, the actual root zone
beneath the surfaces (lawns) through which available waters will percolate
certainly cannot be assumed to extend the full five feet (grass root
zones may extend 10 to 20 inches at best) and the evaporation zone will
similarly be severly limited by the surface cover (grass lawn). What
these concerns signify is that the estimates of depth and magnitudes
of water-holding capacity/field capacity/soil moisture storage are too
high. Percolation with resultant loss to ground waters should be more
rapid and proceed with less demand for water retention than is suggested
in the Report. One means of obtaining a more realistic assessment
would be to have soil moisture tests (with depth profiling) performed
at the same time as additional soil core samples are collected. Note,
however, that conditions as close to those which will be in effect
following completion of the project should be chosen; i.e. moisture tests
should include grass covered sites. Data obtained previously, but which
meet these criteria, are of course perfectly acceptable substitutes (e.g. Soil
Conservation Service data). A depth profile of soil moisture retention
capacity is desirable because the overburden varies in composition with
depth, making the assumptic" of constant retention difficult to justify.
3.	As used in the Report evaluation, the evapotranspiration estimates
(PET values) are weighed ec_ally against all sources of water (septic drainaqe,
irrigation, and runoff — -unoff was not included in the evaluation, but is
important). This is not realistic because that drainage occurs well below
the surface of the ground a-d therefore has less overburden to percolate
through. It also has less effect from evapotranspiration processes, and
is discharged on a relative"/ continuous basis.
4.	The water budget as prtrosed does not include consideration for runoff
from impermeable surfaces (-oadways, sidewalks, house roofs, etc.).
Naturally, the runoff from "npermeable surfaces must be added to the
irrigation waters, the sepf'c drainage, and the precipitation which
occurs directly over the ir.-iltratable surfaces (grass lawns). This means
that the precipitation falling on impermeable surfaces must be factored into
the water budget; i.e., all of the precipitation falling on the 91 acres
of the project will pass di-ectly through only the 36.64 acres of in-
f i 1tratable surfaces. It is suggested that the precipitation values given
in the report/evaluatic~, be -ultiplied by the factor 2.484 (from 91 f 36.64)
to obtain the effective ar,c_^t of precipition which will actually undergo
infiltration and evapcvans:;ration. Alternatively, a separate class of
available water (desic'-sfcec 'runoff contribution") may be inserted into
the- water budget; in v.hi en ziss the factor 1.484 (from (91-36.64)^36.64)
would be multiplied by zne :-ecipitation values given in the Report to
yield the runoff contr.— jf:estimates.
302
-------
3
Page 11
1.	The revised water budget Indicates that substantial waters would
percolate to the ground waters during the period of May through October
and would therefore be available for transportation of fertilizer nitrogen.
Estimates regarding the potential for this transportation need to be
revised.
2.	"From this discussion, it is apparent that Nitrogen from domestic
sewage is available for plant uptake and should remain in the root zone
with the soil moisture."
This statement is challenged for several reasons. I Firstly, the
root zone of the anticipated ground cover (grass) will not likely reach
the depth of the septic drainage. Secondly, the septic drainage will
occur beneath the portion of the overburden which has the greatest
potential for retention/attenuation of the nitrogen compounds and other
septic drainage constituents. Lastly, the infiltration of precipitation,
runoff, and irrigation waters will wash downward through the overburden
overlying the septic drainage, reducing the likelihood of significant
upward capillary movement of the septic drainage (except during the
winter, when the uppermost 18 inches or so of the overburden is frozen
and the ground cover is dormant, so that potential interactions with the
septic drainage would be severly limited anyway).
It is suggested that typical retention and leaching characteristics,
respectively, be tabulated for the grass/soil and fertilizer combinations
in response to these objections.
Page 12
1. The basis for assuming a specific percentage of carryover ("25%) from
summer activity should be explained. This analysis will have to be revised
according to previous comments (allowances made for additional nitrogen,
etc.).
Page 13
Exception is taken to the assumtpions used with the numerical model given.
Thorough ground water mixing cannot be assumed. The conditions under
which optimum mixing would occur include an uniform spacing of ground-
water contribution sources, alignment with the groundwater flow direc-
tion, high permeability, and a high gradient. The model given would
have to account for a variable length of the integration slice (with
the "length" of the slice perpendicular to the direction of flow, with
the width of the slice held constant, and with the depth of mixing de-
pendent on the gradient).
303
-------
4
2.	The pore space velocity, Vs, should not be used in lieu of the
Darcy velocity, It is not clear whether or not this is being done,
but the numerical solution implies that it is. The pore space velocity
(termed seepage velocity in the Impact Evaluation) cannot be directly
substituted for the Darcy velocity when using the Darcy equation to pre-
dict flow from known permeability and gradient. By doing so, an arti-
ficially inflated estimate of flow would be arrived at.
3.	The adequacies of the Numerical Solution Model and Appendix B cannot
be addressed until they are based on more realistic assumptions. Con-
sideration should be given to accounting for plume effects and the geo-
metry of the sites in relation to the flow regime, as well as to increased
percolation estimates.
General Comments
1.	Although it is appreciated that the impact evaluation should not
needlessly include materials presented in the Final December 1978 Spokane
Aquifer Cause and Effect Report, it should be appreciated that geologic
and hydrologic information should be presented which adequately detail
the ground water parameters necessary for complete evaluation of potential
impacts. The strati graphic and 1i thologic profiles of the project site
should be descirbed.
2.	The specific ground water flow directions and gradients of the
project site and surrounding areas which influence the hydrologic
activity at the project site should be detailed. Estimates of aquifer
depth and variations, thickness (given), transmissivity (given), storage,
recharge, and boundaries/discontinuities should be provided. These data
should then be used to project impacts regarding both quality (contamin-
ation) and quantity (flow, recharge, and gradient changes, etc.).
3.	The source and adequacy of water supplied to the project's dwellings
should be identified and addressed. The nitrate levels and impacts
thereof from that source must be addressed. For example; if the anti-
cipated source of drinking water is withdrawal of local ground waters by
pumping wells on-site or in the immediate vicinity of the proposed project,
then what would the nature of the interaction between the pumping wells
and the septic drainfields be? We are particularly concerned with
the "recycling" of wastewaters with concomitant concentration of
contami nants.
4.	The impact evaluation should list any active or abandoned wells on
the project site and the impact these have on the ground water flow
direction and gradient. The proposed project's impact on such wells
should also be detailed.
304
-------
5
5.	Alternative treatment systems need to be presented in detail. The
allusions to consideration of an alternative central treatment and dis-
posal facility (page 1) and the cost analysis given on pages 19 and
20 are insufficient. That presentation must be as carefully considered
and detailed as the chosen method (re: ground water impacts, operation
and maintenance, secondary impacts, etc.;.
6.	The availability and adequacy of the propored method of solid waste
disposal and any potential effects on ground water need to be addressed.
An estimate of 5 lbs./capita-day may be used in the calculations.
7.	The discussion regarding Exhibits D and E (which are based on
Plates 1 and 2 from the "Cause and Effect" report) fails to recognize
some inherent limitations of the proposed site. The project is located
at the extreme northermost edge of the Aquifer. The Aquifer receives
very little recharge in this locale (from the drainage areas to the
north of the proposed site; which are +9 and +11 cfs according to
USGS Open File Rep. 77-829 Plate 4). The direction of ground water
flow there is primarily to the southwest where the Aquifer subsequently
discharges significant flow to the river (330 and 230 cfs, again acord-
ing to Plate 4 of USGS Open File Report 77-829). The topography of the
drainage area immediately north is also characterized by rapidly rising slop
showing that area to be an apparent impermeable ground water divide.
These facts, together with the "Cause and Effect" findings that the
edges of the Aquifer are low flow zones (typified by a propensity for
stagnation, accumulation of contaminants, lower permeabilities, and
diminished saturated aquifer thickness), indicate that the proposed
site is expected to have actual transmissivity and flow rates much
below those assumed in the impact evaluation. High nitrate concentrations
in the Joe Danelo and Trentwood-Mayhew wells (cited on Page 7) confirm
these expections. From EPA analyses June 26, 1979 the Trentwood well
should be reported as 6.3 mg/1 nitrate nitrogen instead of the 3.3 mg/1
indicated in the Report.
8.	Secondary effects, such as induced commercial and residential growth
need to be addressed -- the project needs to be presented in perspective.
9.	The impact evaluation does not address the potential for ground water
contamination via chemicals used for road maintenance (i.e. de-icers,
pesticides, and herbicides) and septic tank maintenance (i.e. degreasing
organics).
10.	Fuel oil, heating gas and other chemicals which will require on-site
storage need to be addressed in terms of potential contamination, pre-
ventative measures, and clean-up in the event of accidental discharge.
11 • The aciency(s) responsible for regulation and pertinent design
criteria of the various facets of the construction and maintenance of
the project should be cited and their control/interaction summarized.
305
-------
Revised Water Budget - Summerfield East
Jan	Feb
Prec.	+1.7	+1.5
Runoff1	+2.5	+2.2
W.W.	+2.81	+2.81
I rr.
P.E.T.
F.C.2	(4.8)	(4.8)
G.W.3	7.01	6.51
July	Aug
Prec.	+0.4	+0.5
Runoff1	+0.6	+0.7
W.W.	+2.81	+2.81
Irr.	+5.77	+5.77
P.E.T.	-5.5	-4.7
F.C.2	(4.8)	(4.8)
G.W.3	4.08	5.08
Mar
Apr
May
June
+1.3
+1.0
+1.0
+1.2
+1.9
+1.5
+1.5
+1.8
+2.81
+2.81
+2.81
+2.81
_
-
+5.77
+5.77
-0.6
-1.6
. -3.1
-4.1
(4.8)
(4.8)
(4.8)
(4.8)
5.41
3.71
7.98
7.48
Sept
Oct •
Nov
Dec
+0.9
+1.3
.+1.9
+2.2
+1.3
+1.9
+2.8
+3.3
+2.81
+2.81
+2.81
+2.81
+5.77
-
-
-
-3.0
-1.6
-0*2
-
(4.8)
(4.8)
(4.8)
(4.8)
7.78
4.41
7.31
8.31

Total =
75.07 inches4

(1)	Runoff is the result of precipitation encountering 54.36 acres of impermeable
surfaces and is assumed to infiltrate the 36.64 acres of grass lawns. It is
in addition to the precipitation already falling directly on the 36.64 acres of
1 awn.
(2)	Field capacity (referred to in the report evaluation as "held in soil"); it is
equal to the amount of water held in the soil after gravitational water has
drained away (includes both hygroscopic and capillary waters). Note that the
figure used (4.8) is disputed and is considered to be too high an estimate,
based on an examination of the soils discussion.
(3)	Ground water (GW); this is the net contribution to ground waters after field
capacity has been satisfied. It is contributed by gravitational drainage
(also referred to as "pellicular" drainage/movement).
(4)	This figure represents the total net contribution (in inches of water) to the
ground water via infiltration and gravitational drainage through the 36.64
acres of premeable surface. The total volume of water is therefore 75.07
inches X 36.64 acres = 2751 acre-inches.
306
-------
SULLIVAN
PARK
CENTER
fdAY 26 1981
Report On
ENVIRONMENT*". EVALUAIiGN
BRANCH
-Wastewater Control
-Stormwater Runoff
-Groundwater Impact
Original Report By
Arger, Yake & Wright
Consulting Engineers
Modified By-
Rhys A. Sterling, P.E
8/20/80
307
-------
SPOKANE CWMP EIS DISTRIBUTION LIST
Federal Agencies
Advisory Council on Historic Preservation
U. S. Department of Agriculture
U. S. Department of Commerce,
National Marine Fisheries Services
U. S. Department of Army, Corps of
Engineers, Seattle District
U. S. Department of Health and Human
Services
U. S. Department of Education
U. S. Department of Housing and Urban
Development
U. S. Department of Interior
U. S. Department of Transportation
State Agencies
Washington Department of Ecology
Washington Department of Natural Resources
Washington Department of Game
Washington Department of Social and
Health Services
Washington Ecological Commission
Washington Department of Fisheries
State Historic Preservation Officer
Washington State Parks and Recreation
Commission
Washington Department of Financial
Management
State and Local Officials
Office of the Governor
Ron Bair, Mayor of Spokane
Terry Novak, Spokane City Manager
Spokane County Planning Commission
Jerry Kopet, County Commissioner
Keith Shepard, County Commissioner
John McBride, County Commissioner
Director, Spokane Regional Planning
Conference
Commissioner of Public Lands
Director, Spokane County Utilities
Department
Director Spokane County Health District
Spokane County Engineer
Spokane County Public Library
Director, City Public Works Department
Director, City Public Utilities Department
Manager, City Engineering Department
Director, City Planning Department
Spokane County Air Pollution Control
Authority
Spokane County Planning Department
"208" Spokane Aquifer Study
City Administrator, City of Cheney
Board of Stevens County Commissioners
Spokane County Prosecuting Attorney
Organizations
Washington State Sportmen's Council
Washington Environmental Council
Spokane Area Development Council
League of Women Voters
Audubon Society
Dishman Hills Association
Valley Chamber of Commerce
Lake Spokane Environmental Association
We The People
Liberty Lake Sewer District
The Glenrose Association
309
-------
Local Distribution
Ray Soltero
Morey Haggin
Marion Hay
D. H. Phillips
Carl Maxey
Margaret Portman
Bruce Collins
Jan Wendle
Phyllis Lamb
Julie Coelho
Bob Wubbana
Larry Esvent
Joan Horn'can
Tom Rogers
R. A. Loosmore
Art Toreson
Lynn David
Roger James
Marlys Higgins
Donald Cutler
Rhys A. Sterling
Dan Knierim
Tom Richardson
John Leopard
Dan Rowley
Jim Correll
Eric Cutbirth
Frank Brougher
Lynn Tennican
Marguerite Johnson
Kristen Straight
Mr. and Mrs. W. R. Hoi berg
Dean Logsdon
John Chervenell
H. Allen Lewis
Michael A. Kennedy, Consulting Engineers
George Ramsey
Mike Stachofsky
Joanne Vennema
Karen MacLeod
Gordon Johnson
Sue Kaun
William Funk
Skip Toreson
Everett M. Dickson
310
~ CPO 798 -729 19 81
-------