Tuesday, July 26, 2011

PUBLIC COMMENT DRAFT FOR WASTEWATER TREATMENT PLANT

The Nisqually Tribe has proposed a new wastewater treatment facility. There is an environmental assessment for the proposed project. This project is OPEN TO PUBLIC COMMENTS and Copies of this Environmental Assessment can be reviewed or obtained at the following addresses:
USDA Rural Development                                    or at the                 Nisqually Indian Tribe
1835 Black Lake Boulevard,                                                                 4820 She Nah Num Drive SE
Olympia, Wa. 98501                                                                              Olympia, Wa. 98512
PUBLIC COMMENTS are taken on THIS project before
AUGUST 1, 2011 and should be sent to either or both of the above addresses.
HERE IS MY SUGGESTIONS FOR COMMENTS REGARDING THIS PROJECT:



Dear USDA Rural Development and Nisqually Indian Tribe,

The purpose of this letter is to address potential environmental impacts as a consequence of improvements to the Nisqually Tribe’s wastewater collection and treatment system. The Nisqually Tribe has obtained an environmental report provided by Parametrix. This document has determined that “the proposal will not have a significant effect on the human environment” resulting in a draft finding of No significant impact. Public Comments are open on this project before August 1, 2011.
Initially, we would like to request an extension of the public comment period. We are finding that there are still residents in the surrounding area adjacent to the Nisqually Tribe’s  proposed public safety project  that are still not aware of that project.  We would like at least an extension of up to 30 days to contact neighbors and the community to allow proper public comments and concerns regarding the Wastewater Treatment facility.
We also would like an unbiased environmental impact statement done for this project before any more damage is done.   Listed below are our concerns regarding this environmental report:
2.1 ALTERNATIVE 1: CONVEYANCE OF WASTEWATER OFF-SITE TO THE CITY OF YELM
It states in this environmental report: “Conveyance to the City of Yelm had several advantages, including the minimal amount of Tribal land required and the fact that the city of Yelm has an established treatment plant with trained operators.”
We would like to explore this option further rather than refute it due to “estimated time required construct the pipeline …”
2.4 NO ACTION ALTERNATIVE
 “Tribal lands used for individual septic systems would remain dedicated to those septic systems and the Tribe would not receive the benefit of additional land for development use.”
Since another alternative is available we believe that using the current City of Yelm system is adequate for the Tribe’s needs.
3.1.1.1 CURRENT PROPERTY USE
“One branch will cross under State Route 510 as it conveys wastewater from the Public Safety Complex to the WWTP, one branch will cross under SR 510 as it conveys wastewater from existing developed areas in the southeast portion of the Reservation. 
This project would impact the environment along the SR 510. What mitigating factors have been addressed if there were repairs needed or maintenance under the State Route 510 due to this project?

3.7.1      WATER QUALITY ISSUES AFFECTED ENVIRONMENT
It states that the “well sites are sufficiently far away from the WWPT that is not anticipated that they will be affected by the effluent infiltration. In order to minimize potential impacts to any surrounding soils or waters, The Tribe is making conscious effort to produce a Class A reclaimed effluent.  
This language needs clarification !
3.10        MISC. ISSUES
3.10.1.1 AFFECTED ENVIRONMENT
It states: “Wastewater treatment plants can be sources of odor. Depending on the types of treatment processes at the site, the odors can range from musty or earthy, to a pungent rotten egg smell. Odors can be carried far from the WWTP under the right weather and wind conditions if appropriate precautions to minimize and/or treat the odors have not been implements.”
3.10.1.2 MITIGATION
It again states “thereby reducing some of the wastewater’s potential to cause odor in downstream treatment processes.” It goes on to state…..”At this time, the exact design of the tanks has yet to be finalized, however it is common practice to cover treatment tanks and evacuate the headspace to a scrubber, much like at the headworks, building; this remains an option for mitigation of any potential treatment tank odor at the WWPT.
…”Consequently, no mitigation for solids handing odors is proposed….”
..”Finally, the WWTP site was selected such that prevailing winds will generally blow any odors away from developed areas, and the forested buffer will provide a level of odor dilution …”

We request subsequent mitigation regarding covering the treatment tanks. We are very concerned to have OPEN treatment tanks and the potential odor and hazards that would associate with such a design. (We are all well aware of the Mushroom Farm smell in Lacey off of Steilacoom Road and do not potentially want something similar or potentially worse in this part of town.)
4.7 NOISE
”WWTP’s are industrial facilities, and there will be equipment running continuously at the site during the course of the life of the WWTP. Efforts will be made during facility design to minimize the noise associated with machinery by providing motors with sound enclosures.”
Since “efforts will be made during facility design”, does this mean that they will be installed or just placed on designs of the project and then not actually utilized?


5.0 SUMMARY OF MITIGATION
E) “Treatment tanks may be covered and the headspace evacuated to a media scrubber.” Again it is stated that the treatment tanks “may be covered”. Again, we request that they in fact are 100 % covered.

Also, there is NO MENTION of an Earthquake and how this structure and project could withstand and sustain in an earthquake. Due to the Nisqually earthquake in 2001, one of the largest recorded earthquakes in Washington state history Earthquake precautions and information regarding another earthquake need to be addressed.

Thank you for your time and attention to these issues,

Justine Schmidt
Concerned Citizen


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