Linda L. Stoll
Superintendent, Wind Cave National Park

I have followed over the past months the dialogue about the proposed wastewater transmission line project from Wind Cave NP to the City of Hot Springs. There has been a great deal of editorial misinformation printed in the Star and Journal, and some clarifications need to be made. The citizens of Custer and Fall River Counties deserve to hear the facts. What follows is lengthy, but if you want some FACTS here they are.

BACKGROUND:
FACT: Wind Cave National Park’s wastewater treatment facility is undersized and poorly located to accommodate the wastewater generated by park facilities and rainfall inputs. The lagoons’ present location is shielded from the sun and wind, so they do not evaporate adequately. Two lagoons were built in 1964 but rarely held more than a couple of feet of effluent. This lack of volume lead park officials to believe the lagoons were leaking untreated sewage into the aquifer and undiscovered cave below, so they were lined with impermeable liners in 1989. They immediately began filling, proving they had been leaking. To prevent them from overflowing in 1993, an emergency irrigation permit was issued by the state. A third lagoon was added in 1996 to increase storage, but due to site constraints, it was not large enough. Since then, the lagoons would have overflowed two more times if not for additional emergency irrigation permits in 1996 and 1999. When the last permit was issued, the park was told in a letter from the South Dakota Department of Environment and Natural Resources (SD DENR), dated July 13, 2000, that future requests for irrigation of wastewater in this area will likely not be granted. With the State no longer allowing emergency irrigation, the park began seeking funding for a permanent solution.

FACT: Properly designed lagoons should rarely fill to the brim. The lagoons are presently operating at near their design capacity considering the SD DENR criteria requires three feet of freeboard to prevent discharges due to extreme precipitation years and dike and liner damage due to high winds and water levels. The reason that the ponds have not overfilled since the spring of 1999 is because land application in 1999 and 2000 drew the ponds down to minimum levels. Over the past three relatively dry years, the ponds have gained back over a million gallons. If nothing is done, the ponds will again fill to the top at which point they will overflow simply from daily use.

FACT: Some have suggested we should obtain a permanent discharge permit to reduce the cost of this project. Permanent permits do not exist. Discharge permits must be renewed every five years. Such a permit would not come without substantial cost due to the alterations that would be required by SD DENR. We chose not to request such a permit, since surface discharge of wastewater has a potential to negatively impact cave resources which are believed to exist under the current lagoons and the area used for irrigation. In addition, an unnatural water and nutrient source would result in undesirable changes in plant and animal ecology in the area of discharge, creating an unnatural environment in a natural setting.

In the past, the SD DENR Ground Water Quality program raised concerns over the suitability of our site for the irrigation of wastewater. They have seen cases in the Southern Black Hills where water moves very quickly through soil formations making the site unsuitable. If the SD DENR were to grant a permit, there is no guarantee that every five years the permit would be renewed. If the permit is denied, we would be back where we started but without the current funding to solve the problem. The bottom line is that surface irrigation from the existing lagoons does not meet the purpose and needs identified for the project even though it may be less expensive.

THE PROCESS:
FACT: While developing potential alternatives, we discussed the project with City officials to determine if connecting to the municipal system was a viable alternative. As a result, the Common Council of the City of Hot Springs passed Resolution 2002-10 on February 19, 2002, stating that the City would receive the sanitary pipeline installed between the City and Wind Cave National Park if that was the alternative selected by the park. This resolution was published in the Hot Springs Star on February 26, 2002. Had the City not made this commitment to provide wastewater treatment service, the alternative would have been dismissed from further consideration at that time.

FACT: The Park sought public comments early in the development of possible alternatives with a front page article in the Hot Springs Star on March 5, 2002. The article explained the problem, possible solutions, and asked for public input regarding the alternatives being considered, issues or concerns related to each of the proposed alternatives, and any new alternatives that should be considered for wastewater treatment. We received no comments. We strive to work together with our stakeholders to meet the project’s objectives; yet we received no comments during the critical formation period which set the project’s direction and alternatives.

FACT: Prior to issuing the Draft Environmental Assessment (EA), an interdisciplinary team comprised of representatives from Rothberg, Tamburini & Winsor, Inc., Parsons Corporation, the National Park Service (NPS) Denver Service Center, and park staff analyzed 10 different alternatives during a Choosing by Advantages/Value Analysis session, April 16-17, 2002. The alternatives analyzed in the EA are those that met the project objectives to a large degree, although not necessarily completely. The primary objectives of the project are a) to protect public health, safety and welfare by compliance with state and federal regulations in regard to wastewater handling and treatment, b) to protect natural resources in the park by eliminating surface discharge of wastewater, c) to provide for visitor enjoyment by removing the highly visible and unsightly wastewater treatment lagoons from their current site immediately adjacent to the park’s main access highway, and d) to provide a cost effective, environmentally responsible long-term solution for the park’s wastewater treatment needs.

The Value Analysis (VA) study evaluated how well each of the 10 alternatives met the objectives of the project with consideration given to initial capital costs and long term operational costs. The process identified the pipeline to the City of Hot Springs as being the alternative with the best benefit to cost ratio, i.e., over the long run, this alternative best met the project objectives for the least cost.

The top three alternatives identified from the VA process were then evaluated as part of the EA: building a sewer line into town; building our own treatment plant; or relocating and building new lagoons.

FACT: The EA was available for public review and comment from April 4 to May 15, 2003. A public open house was held on April 24, 2003, at the park’s visitor center. Comment periods provide the public another opportunity to review and comment on proposed actions having the potential to significantly effect the environment, but they are not votes. The park received eight letters and three identical petitions with 47 signatures during the comment period.

Out of all the responses, there were two letters with substantive comments that added substantive issues or facts to the debate. In this case, as a result of one of the comments, an enhanced leak detection system was added to the plan. Eventually, a point is reached in project development when a decision has to be made and work begun to fix the problem. In this case, the decision document, the Finding of No Significant Impact (FONSI), was signed by the NPS Regional Director on November 13, 2003.

On December 3, 2003, a contracting officer for the NPS signed a contract with the City of Hot Springs and gave notice to proceed with the plant certification and the design. Once construction drawings are completed and approved by the State, construction of a sewer line from the park boundary to the City limits can proceed.

PROJECT RESPONSIBILITIES:
FACT: The NPS relies on the technical expertise of contractors in preparation of many of our documents, including engineering design and/or compliance. In this process, NPS staff are contributors, reviewers, and approvers but generally not authors. For this project, the NPS contracted with Parsons Corporation (www.parsons.com) to evaluate the environmental impacts of the various alternatives to ensure compliance with the National Environmental Policy Act (NEPA) and to produce the EA. Parsons is a leading science and engineering consulting firm. They did not do the engineering work associated with this project but instead consulted with another NPS contractor working on the project as stated on page 103 of the EA. Parson’s role was to evaluate the environmental impacts of the various alternatives presented in the EA to ensure compliance with NEPA. We have said all along we hired one of the top firms in the country to produce the EA. However, some misinterpreted that Parsons also did the engineering. The NPS and Parsons Corporation stand behind the document.

FACT: The VA and preliminary engineering design in the EA was done by Rothberg, Tamburini & Winsor, Inc. (RTW) of Colorado (www.rtweng.com). They specialize in providing professional consulting and engineering services for the water and wastewater industry. RTW is an award-winning firm that has received recognition at both the local and national levels.
COST:
FACT: The project was funded at $3.9 million, part of which is available for construction. To date, we have spent well over $400,000, not counting salaries of NPS staff working on this project, in development of the preferred alternative in good faith based upon the resolution passed by the City Council and the contract that was signed between the NPS and the City. To change directions now would result in a substantial loss of a financial investment when some are saying their concern is the expense of the project. At this point in time, the cost of implementing another alternative, which will happen should the contract with the city fail, would be considerably greater than completing the sewer line into town.

PUBLIC SAFETY:
FACT: This project will add about 2.5 million gallons of wastewater per year into the city system. On an annual basis, this is equivalent to the amount of wastewater generated by about 70 people, or 30 single family homes. The city plant has a design capacity of 1.54 million gallons per day. On the peak day in 2002, the city plant treated 795,000 gallons of wastewater which is about 52% of total capacity. The peak flow from the park will be about 25,000 gallons per day, less than 2% of the design capacity of the plant.

Another concern expressed in the frequent editorials is about pollution of the Hot Springs potable water well if this project is completed. They wrote that the EPA estimates that 100,000 gallons of Wind Cave sewage will leak into the Hot Springs groundwater per year from leaking city sewer lines. The fact is, the EPA has never inspected, tested, or evaluated the Hot Springs sewer lines to determine how much sewage, if any, leaks from the lines. The estimate published in the editorials is solely the opinion of that author. Apparently this estimate is based on a statement in an appendix of an Environmental Protection Agency (EPA) Report to Congress from 1977 which he says reads: “Based on available information, sewer leakage on the average is probably around 5% of the total, with wide variations from system to system.” This statement was vague even when it was written 27 years ago, and today is very misleading when used in this manner.

If someone were going to make a responsible estimate of how much wastewater is leaking from the city sewer system, the first thing should be to determine the condition of the system, probably by talking to the people that operate and maintain the system. If his estimate is accurate, in 2002 while the city plant treated about 200 million gallons, 10 million gallons leaked into the ground water. If there is a valid concern about the amount of Wind Cave sewage leaking, the concern should be at least 100 times greater for the existing conditions. If the amount of wastewater generated by 30 new homes puts the city’s water supply in jeopardy, should all development in Hot Springs be stopped now? The facts do not seem to support the writer’s claims since the Hot Springs wastewater treatment plant is in complete compliance with the permit issued by DENR and is also well run as evidenced by its winning an Excellent Operation and Maintenance Award from DENR in 2001. For the project at hand, it is the responsibility of the SD DENR, through the process of engineering design review, to ensure the project proceeds in an environmentally safe manner. In a letter written by SD DENR Secretary Steven M. Pirner, he states “DENR is of the opinion that the preferred alternative can be designed and constructed to meet state environmental standards.”

BENEFITS:
FACT: This project will provide the City of Hot Springs additional revenue in sewer user fees while only taking up 2% of the City’s underutilized plant which users are paying to operate and maintain anyway. If Wind Cave National Park constructs its own treatment plant, taxpayers will pay to operate and maintain two treatment plants within 15 miles of each other, when the existing municipal plant would suffice. This project will allow property owners along the Highway 385 corridor the opportunity to hook into the system, protecting our water source from potential contamination from septic systems, while encouraging growth that will add to the County tax base. We firmly believe that the sewer line is the best for the NPS, for Custer and Fall River Counties, the City of Hot Springs, and South Dakota, as well as being the best long-term investment. This alternative also takes the best care of the park and your world-class cave.