S-10-0164 Attachment 2 Eagle Lake Sewer Ponds_Identified Alternatives with Maps.pdf

Alternatives _____________________________________ Alternative 1 -The proposed Action

The Proposed Action is divided into four phases as described below. Each phase outlines the work to be completed before the next phase can begin. It should be noted that during Phases II and III, material in the existing ponds would be transferred to other ponds as necessary, to allow for removal and relining of each pond1. Liner selection and design would occur during the EL Facility design process and under consultation with Lahontan. All replaced liners would be removed off National Forest System land and disposed of according to existing regulations2 Figure 3. displays the location of the newly constructed site, the site where soil material would be used to build the new pond (borrow site), and the area where tree thinning would occur to reduce hazardous fuels to protect this site.

Heritage Site Evaluation

Heritage Site FS05-06-58-499, adjacent to what is currently Pond 3 cannot be avoided or protected by the application of standard protection measures. The site has not been previously evaluated for inclusion in the National Register of Historic Places (NHRP), therefore an evaluation would occur. If the site is determined to be ineligible for inclusion in the NHRP, no further management of the site would be required and the project may proceed. If the site is determined to be eligible for the inclusion in the NHRP, then additional consultation with the State Historic Preservation Office (SHPO) and Indian tribes would be needed before a National Environmental Policy Act (NEPA) decision would be made.

Phase I – Site Preparation

• Remove existing barbed wire and above ground sprinkler heads from the old spray field area.

• Remove 3,100 feet of existing barbed wire fence from the perimeter of the sewage treatment facility site, and construct a temporary fence around the entire project area. Construct a cattle guard at the entrance gate to the project area. Unused fence material would be removed off National Forest System land.

• Clear the 12-acre3

• Thin from below approximately 14-acres borrow site and pond expansion areas; leave stumps in place.

• Prior to commencing and thinning and or clearing operations the Lassen NF would obtain a 2009(or subsequent year) Timber Waiver Permit for Lahontan. (Where thinning and clearing operations are mentioned in the remainder of this document this statements shall apply) of forested land, as described in the thinning prescription.

1 Per Hydrogeologic Investigation Draft Report, Cascade Earth Sciences, December 8, 2009, Page 5: “The lean clay soil found at the site, which appears to be at least 10 feet thick throughout, had permeability of about 10-7 cm/sec.

This clay present should greatly limit infiltration of any wastewater from the ponds, as 10-7 cm/sec is often the design specification for clay pond liners”.

2 Federal Acquisition Regulations that would be included in the contract involving replacement of liners include standard language that contracted work is to be in conformance with all local, State and Federal requirements.

3 In the scoping document the acreage was incorrectly listed as 16 acres.

4 In the scoping document the acreage was incorrectly listed as 10 acres.

Figure 1: Alternative 1- Relining Layout of EL Facility

Phase II – Pond Expansion

• The construction contractor would remove stumps and, if necessary, slash piles and any remaining vegetation. Stumps could be temporarily stored on site.

• Develop the 7-acre5

• The area west of Evaporation Pond 3 would be leveled to the same depth of the existing pond and an earthen berm would be created to form the new perimeter. Most of the leveling would be done by adding fill material obtained from the borrow site, although some excavation is possible.

About 28,000 cubic yards of borrow material would be excavated from the borrow site. This would expand the surface area of Evaporation Pond 3 from approximately two acres to five acres, and expand its capacity to approximately 13 million gallons.

borrow site by retaining and storing the topsoil to be used during Phase IV.

• Evaporation Pond 3 would then be expanded from approximately two acres to five acres, and relined. . At a minimum the subgrade preparation, compaction and final inspection prior to installing of the synthetic liner would at a minimum meet the liner's manufacturer’s specifications.

• Lysimeters would be installed for early detection of leaks and to sample water quality in the unsaturated soils surrounding the ponds. At a minimum the lysimeters would be capable of collecting and storing enough groundwater/fluid for analysis to assure that groundwater

5 In the scoping document the acreage was incorrectly listed as 8 acres.

contamination is not occurring and must support the requirements of the Monitoring and Reporting Program attached to the Lassen NF Permit from Lahontan to operate the EL Facility.

Location, quantity and design of the lysimeters would be determined by a Professional Engineer with expertise in wastewater facility design. (Where lysimeter installation is mentioned in the remainder of this document the above statements about what the lysimeters would be used for and how they would be designed and installed shall apply).6

Phase III – Pond Reconstruction

• Remove the 12,000-cubic-yard dike between Evaporation Ponds 1 and 2, creating a single rebuilt pond to be called Evaporation Pond 1, approximately four acres in size.

• Place the 12,000 cubic yards of material from the dike in the borrow site.

• Lysimeters would be installed for early detection of leaks and to sample water quality in the unsaturated soils surrounding the ponds.

• Remove stumps from National Forest System lands.

Phase IV – Reclamation

• Remove cattleguard and temporary fencing from perimeter of project area.

• Construct approximately 4,250 feet of 8-foot-high chain-link fence around the sewage treatment facility perimeter.

• Re-spread retained topsoil in the borrow site.

• Revegetate approximately 16 acres, including the borrow site and any areas disturbed during construction.

• Construct a temporary fence around the borrow pit to exclude cattle from the re-vegetated area post-project, until such time as reclamation is complete and grazing can resume.

Thinning Prescriptions

Prescription 1 applies to the larger-diameter trees on 80 percent of the thinning area; Prescription 2 applies to the smaller-diameter trees on 20 percent of the thinning area. In both prescription areas, the largest, healthiest conifer trees would be designated as leave trees. All conifers that are 30 inches diameter at breast height (dbh) and greater would be marked as leave trees regardless of tree health, vigor, or species. All snags greater than 15 inches dbh would be retained regardless of species, unless they pose a safety or operational concern. All conifer stumps greater than 14 inches in diameter would be treated with SPORAX® (Sporax). Activity-generated fuels would be mechanically and/or hand piled and burned, removed, or chipped to provide organic matter.

Prescription 1 would thin from below to 100-110 square feet of basal area per acre. All pine 30 inches dbh and greater would be leave trees unless they have Hawksworth mistletoe rating greater than 3. The Hawksworth 6-Class Dwarf Mistletoe Rating System rates the severity of dwarf mistletoe infection on a scale from 0 (no visible infection) to 6 (highest possible infection).

Prescription 2 would thin from below to 50-70 square feet of basal area per acre. All pine of 14 inches dbh and greater would be leave trees unless they have a Hawksworth rating greater than 3.

Wetlands Mitigation

6 In the scoping document the number of Lysimeters required was inadvertency stated.

An area of the existing Merrill wetlands (0.774 acres7

Papoose Meadows is a large, 270-acre meadow located south of Eagle Lake in T. 31 N., R. 11 E., Sections 20 and 29, MDM. At present, approximately 160 acres are a seasonally flooded wet meadow and marsh system. Historically, this wetland complex was ditched to dry it out to improve hay production for livestock. The ditches would be filled or successively plugged. Cursory analysis indicates that between 30 and 110 acres could be restored.

) would be eliminated when Evaporation Pond 3 is expanded. The eliminated wetlands would be mitigated by creating at least 1.34 acres of other wetlands;

the PMWR Project would be used as mitigation for this project. Papoose Meadows is located approximately 4.5 miles east of the Eagle Lake sewage ponds and is in the same 5th-field watershed. The Decision Notice and Finding of No Significant Impact for the PMWR Project were signed in 2008, under the South Eagle Lake Grazing Allotment decision.

Alternative 2 - No Action

Under the No Action alternative no proposed replacement of the liners, associated improvements to the facility, or thinning would be implemented. Figure 4 displays the layout of the EL Facility for the No Action Alternative.

Alternative 3

Alternative 3 was developed to address the issue to not eliminate a portion of the Merrill wetlands. In this alternative existing Primary Pond 2 would be expanded and converted into Evaporation Pond 4. A new Primary Pond 2 would be relocated to the north of its existing location. The bank between Evaporation Pond 1 and 2 would be raised so that the ponds function as two separate ponds. Evaporation Ponds 1, 2 and 3 and Primary Pond 1 would be relined. A sludge drying bed would constructed north on the new Primary Pond 2. Additionally, one water well would be developed east of Primary Pond 1. This alternative is divided into five phases as described below. Each phase outlines the work to be completed during that phase. Work from multiple phases may occur concurrently. During Phase I through IV material in the existing ponds may be transferred to other ponds as necessary, to allow for removal and relining of each pond. All replaced liners would be removed off NFS land. Figure 5 displays the location of the newly constructed sludge drying bed, primary and evaporation ponds, the site where soil material would be spread from newly constructed features, the boulder stockpile area, approximate location of the new water well and the area where tree thinning would occur to reduce the risk of a wildfire damaging the EL Facility.

7 0.89 acres of the Little Merrill Flats wetlands within the EL Facility Project.

Figure 2: Alternative 2 - Sewage Ponds for Eagle Lake

Phase I – Site Preparation

• Remove the existing barbed wire fences on the interior of the 40 acres and the above ground sprinkler heads from the old spray field area.

• Remove 3,100 feet of existing barbed wire fence from the perimeter of the sewage treatment facility site.

• Construct approximately 4,500 feet of 8-foot-high chain-link fence around the sewage treatment facility perimeter.

• Repair and or construct a barbed wire fence around the perimeter of the property where the 8-foot chain-link fence does not exist.

• Construct a cattle guard where the access road enters the property.

• Develop a water well for dust abatement East of Primary Pond 1.

• Unused fence material would be removed off National Forest System land.

• Clear the approximately 8 acres for the stockpile area, sludge drying area, pond expansion areas and primary pond area; leave stumps in place.

• Thin approximately 13 acres of forested land.

Phase II – Construct Sludge Drying Bed and Reline Evaporation Pond 3

• Remove stumps and, if necessary, slash piles and any remaining vegetation.

• Remove and stockpile boulders that are suitable for other uses on the forest in random areas within the boulder stockpile area.

• Stockpile the topsoil.

• Construct the road to the sludge drying area (300 feet by 18 feet wide).

• Excavate the sludge drying bed (0.8 acres, 1,500 CY) to a depth of approximately 5 feet. .

Excavated topsoil would be stockpiled for later distribution. All other excavated material would be stockpiled for possible use in future phases.

• Construct the walls, floor and handrail for the sludge drying bed

• Haul and Spread topsoil in disturbed area outside the sludge drying bed.

• Revegetate the disturbed area outside the sludge drying bed.

• Transfer the sludge from Evaporation Pond 3 to the sludge drying bed.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Pump all liquids from Evaporation Pond 3 into Evaporation Ponds 1 and 2.

• Remove the existing lining from Evaporation Pond 3.

• Haul the removed lining to a landfill in accordance with existing regulations.

• Install functionality features for Evaporation Pond 3.

• Prepare the surface for a new lining and reline Evaporation Pond 3.

Figure 3: Alternative 3 – Layout for the Expansion of the EL Facility to the North

Phase III – Construct Primary Pond 2 and Evaporation Pond 4

• Excavated Evaporation Pond 4 and Primary Pond 2 to the appropriate depths and stockpile the excess material 15 feet high in the stockpile area for use on future Lassen NF projects (3.5 acres, 66,000 CY). All topsoil would be stockpiled for later distribution.

• Remove and stockpile boulders that are suitable for other uses on the forest in random areas within the boulder stockpile area.

• Transfer the sludge from existing Primary Pond 2, Evaporation Ponds 1 and 2 to the sludge drying bed.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Pump all liquids from Primary 2 to the Evaporation Ponds.

• Remove the existing lining from Primary Pond 2.

• Haul the removed lining to a landfill in accordance with existing regulations.

• Install functionality features for Evaporation Pond 4 and Primary Pond 2.

• Prepare the surface for new lining and line Evaporation Pond 4 and Primary Pond 2.

• Install lysimeters

• Install aerators

• Haul and Spread topsoil in disturbed area outside the sludge drying bed.

• Revegetate the disturbed area outside Evaporation Pond 4 and Primary Pond 2.

Phase IV – Reline Primary Pond 1, Evaporation Ponds 1 and 2

• Transfer the sludge from Primary 1 to the sludge drying bed.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Pump all water from Primary Pond 1, Evaporation Ponds 1 and 2 into Evaporation Ponds 3 and 4.

• Remove the existing lining from Primary Pond 1, Evaporation Ponds 1 and 2.

• Raise the berm between Evaporation Ponds 1 and 2 obtaining approximately 3,110 CY of material from the stockpile area.

• Haul the removed lining to a landfill in accordance with existing regulations.

• Install functionality features for Primary Pond 1, Evaporation Ponds 1 and 2.

• Prepare the surface for new lining and reline Primary Pond 1, Evaporation Ponds 1 and 2.

• Install lysimeters

• Install aerators

Phase V – Reclamation

• Haul and Spread topsoil in remaining disturbed area.

• Revegetate the remaining disturbed areas.

• Remove cattleguard and temporary fencing from perimeter of project area.

Alternative 4

Alternative 4 was developed to address the issue to not eliminate a portion of the Merrill Flats. The bank between Evaporation Pond 1 and 2 would be raise so that they ponds function as two separate ponds.

Additionally, the depth of Evaporation Ponds 1, 2 and 3 would be increased by approximately two (2) feet. Evaporation Ponds 1, 2 and 3 and Primary Pond 1 and 2 would be relined. A sludge drying bed would constructed north on the Primary Pond 2. Additionally, one water well would be developed east of Primary Pond 1. This alternative is divided into six phases as described below. Each phase outlines the work to be completed during that phase. Work from multiple phases may occur concurrently. During Phase I through V material in the existing ponds may be transferred to other ponds as necessary, to allow for removal and relining of each pond. All replaced liners would be removed off NFS land and disposed of according to existing regulations. Figure 6 displays the location of the newly constructed sludge drying bed, the sites where soil materials would be removed and spread as need for the newly constructed features and the lowering of the evaporation ponds, the boulder stockpile area, approximate location of the new well and the area where tree thinning would occur to reduce hazardous fuels to protect this site.

Phase I – Site Preparation

• Remove the existing barbed wire fences on the interior of the 40 acres and the above ground sprinkler heads from the old spray field area.

• Remove 3,100 feet of existing barbed wire fence from the perimeter of the sewage treatment facility site.

• Construct approximately 3,700 feet of 8-foot-high chain-link fence around the sewage treatment facility perimeter.

• Repair and or construct a barbed wire fence around the perimeter of the property where the 8-foot chain-link fence does not exist.

• Construct a cattle guard where the access road enters the property.

• Develop a water well for dust abatement east of Primary Pond 1.

• Unused fence material would be removed off National Forest System land.

• Clear the approximately 3 acres for the stockpile area borrow area and sludge drying area; leave stumps in place.

• Thin approximately 20 acres of forested land.

Phase II – Construct Sludge Drying Bed and Lower Evaporation Pond 3

• Remove stumps and, if necessary, slash piles and any remaining vegetation. Stumps could be temporarily stored on site

• Remove and stockpile boulders that are suitable for other uses on the forest in random areas within the boulder stockpile area.

• Stockpile the topsoil.

• Construct the road to the sludge drying area (300 feet by 18 feet wide).

• Excavate the sludge drying bed (0.8 acres, 1,500 CY) to a depth of approximately 5 feet. .

Excavated topsoil would be stockpiled for later distribution. All other excavated material would be stockpiled for possible use in future phases.

• Construct the walls, floor and handrail for the sludge drying bed.

• Haul and Spread topsoil in disturbed area outside the sludge drying bed.

• Revegetate the disturbed area outside the sludge drying bed.

• Transfer the sludge from Evaporation Pond 3 to the sludge drying bed.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Pump all liquids form Evaporation Pond 3 into Evaporation Ponds 1 and 2.

• Remove the existing lining from Evaporation Pond 3.

• Haul the removed lining to a landfill in accordance with existing regulations.

• Excavate and stockpile approximately 4,700 CY from the bottom of Evaporation Pond 3. The excavate material would be stockpiled for possible use in future phases.

• Install functionality features for Evaporation Pond 3.

• Prepare the surface for new lining and reline Evaporation Pond 3.

• Install aerators.

Phase III – Reline Primary Pond 2

• Transfer the sludge from Primary Pond 2 to the sludge drying bed.

• Pump all liquids from Primary Pond 2 into Evaporation Pond 3.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Remove the existing lining from Primary Pond 2.

• Haul the removed lining to a landfill in accordance with existing regulations.

• Install functionality features for Primary Pond 2

• Prepare the surface for new lining and reline Primary Pond 2.

• Install aerators.

Figure 4: Alternative 4 – Layout for the Deeping of Evaporation Ponds

Phase IV – Reline Primary Pond 1, Evaporation Ponds 1

• Transfer the sludge from Primary 1 and Evaporation Ponds 1 to the sludge drying bed.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Pump as much water as possible from Evaporation Ponds 1 and 2 into Evaporation Pond 3.

• Construct coffer dams and plug the 18 inch culvert between Evaporation ponds 1 and 2. If the

Coffer dam does not work pump and haul all remaining liquids in Evaporation Ponds 1 and 2 to a sewage treatment facility (approximately 2.6 million gallons).

• Pump all liquid from Primary Pond 1 and Evaporation Pond 1 into Evaporation Ponds 2 and 3.

• Remove the existing lining from Primary Pond 1 and Evaporation Pond 1.

• Haul the removed lining to a landfill in accordance with existing regulations.

• Install functionality features for Primary Pond 1 and Evaporation Pond 1.

• Excavate and stockpile approximately 6,400 CY from the bottom of Evaporation Pond 1. The excavate material would be stockpiled for possible use in future phases.

• Raise the ½ of berm between Evaporation Ponds 1 and 2 obtaining approximately 1,555 CY of material from the stockpile area.

• Prepare the surface for new lining and reline Primary Pond 1 and Evaporation Pond 1.

• Install lysimeters

• Install aerators

Phase V – Reline Evaporation Pond 2

• Transfer the sludge from Evaporation Pond 2 to the sludge drying bed.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Pump all liquid from Primary Pond 2 into Evaporation Ponds 1 and 3.

• Remove the existing lining Evaporation Pond 2.

• Haul the removed lining to a landfill in accordance with existing regulations.

• Install functionality features for Evaporation Pond 2.

• Excavate and stockpile approximately 6,400 CY from the bottom of Evaporation Pond 2.

• Raise the ½ of berm between Evaporation Ponds 1 and 2 obtaining approximately 1,555 CY of material from the stockpile area.

• Prepare the surface for new lining and reline Evaporation Pond 2.

• Install aerators

Phase VI – Reclamation

• Haul and Spread topsoil in remaining disturbed area.

• Revegetate the remaining disturbed areas.

• Remove cattleguard and temporary fencing from perimeter of project area.

Alternative 5 Alternative 5 was developed to address the issue to not eliminate a portion of the Merrill wetlands. The bank between Evaporation Pond 1 and 2 would be raise so that they ponds function as two separate ponds. Evaporation Ponds 1, 2 and 3 and Primary Pond 1 and 2 would be relined. A sludge drying bed would constructed north on the Primary Pond 2. Additionally, one water well would be developed east of Primary Pond 1. This alternative is divided into six phases as described below. Each phase outlines the work to be completed during that phase. Work from multiple phases may occur concurrently. During Phase I through V material in the existing ponds may be transferred to other ponds as necessary, to allow for removal and relining of each pond. All replaced liners would be removed off NFS land and disposed of according to existing regulations. Figure 7 displays the location of the newly constructed sludge drying bed, the sites where soil materials would be removed for the newly constructed features, the boulder stockpile area, approximate location of the new well and the area where tree thinning would occur to reduce hazardous fuels to protect this site.

Phase I – Site Preparation

• Remove the existing barbed wire fences on the interior of the 40 acres and the above ground sprinkler heads from the old spray field area.

• Remove 3,100 feet of existing barbed wire fence from the perimeter of the sewage treatment facility site.

• Construct approximately 3,700 feet of 8-foot-high chain-link fence around the sewage treatment facility perimeter.

• Repair and or construct a barbed wire fence around the perimeter of the property where the 8-foot chain-link fence does not exist.

• Construct a cattle guard where the access road enters the property.

• Develop a water well for dust abatement east of Primary Pond 1.

• Unused fence material would be removed off National Forest System land.

• Clear the approximately 1.5 acres for a borrow area and sludge drying area; leave stumps in place.

• Thin approximately 21 acres of forested land.

Figure 5: Alternative 5 – Layout for Relining All Ponds

Phase II – Construct Sludge Drying Bed and Reline Evaporation Pond 3

• Remove stumps and, if necessary, slash piles and any remaining vegetation. Stumps could be temporarily stored on site.

• Remove and stockpile boulders that are suitable for other uses on the forest in random areas within the boulder stockpile area.

• Stockpile the topsoil.

• Construct the road to the sludge drying area (300 feet by 18 feet wide).

• Excavate the sludge drying bed (0.8 acres, 1,500 CY) to a depth of approximately 5 feet.

• Construct the walls, floor and handrail for the sludge drying bed. Excavated topsoil would be stockpiled for later distribution. All other exacted material would be stockpiled for possible use in future phases.

• Haul and Spread topsoil in disturbed area outside the sludge drying bed.

• Revegetate the disturbed area outside the sludge drying bed.

• Transfer the sludge from Evaporation Pond 3 to the sludge drying bed.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Pump all liquids from Evaporation Pond 3 into Evaporation Ponds 1 and 2.

• Remove the existing lining from Evaporation Pond 3.

• Haul the removed lining to a landfill in accordance with existing regulations.

• Install functionality features for Evaporation Pond 3.

• Prepare the surface for new lining and reline Evaporation Pond 3.

Phase III – Reline Primary Pond 2

• Transfer the sludge from Primary Pond 2 to the sludge drying bed.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Pump all liquids from Primary Pond 2 into Evaporation Pond 3.

• Remove the existing lining from Primary Pond 2.

• Haul the removed lining to a landfill in accordance with existing regulations.

• Install functionality features for Primary Pond 2

• Prepare the surface for new lining and reline Primary Pond 2.

• Install aerators.

Phase IV – Reline Primary Pond 1, Evaporation Pond 1

• Transfer the sludge from Primary 1 and Evaporation Pond 1 to the sludge drying bed.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Pump as much water as possible from form Evaporation Ponds 1 and 2 into Evaporation Pond 3.

• Construct coffer dams and plug the 18 inch culvert between Evaporation ponds 1 and 2. If the

Coffer dam does not work pump and haul all remaining liquids in Evaporation Ponds 1 and 2 to a sewage treatment facility (approximately 2.6 million gallons).

• Pump all liquid from Primary Pond 1 and Evaporation Pond 1 into Evaporation Ponds 2 and 3.

• Remove the existing lining from Primary Pond 1 and Evaporation Pond 1.

• Haul the removed lining to a landfill in accordance with existing regulations.

• Install functionality features for Primary Pond 1 and Evaporation Pond 1.

• Raise the ½ of berm between Evaporation Ponds 1 and 2 obtaining approximately 1,555 CY of material from the stockpile area.

• Prepare the surface for new lining and reline Primary Pond 1 and Evaporation Pond 1.

• Install lysimeters

• Install aerators

Phase V – Reline Evaporation Pond 2

• Transfer the sludge from Evaporation Pond 2 to the sludge drying bed.

• Remove the dried sludge from the sludge drying bed and haul it to a landfill in accordance with existing regulations.

• Pump all liquid from Primary Pond 2 into Evaporation Ponds 1 and 3.

• Remove the existing lining Evaporation Pond 2.

• Haul the removed lining to a landfill.

• Install functionality features for Evaporation Ponds 2.

• Raise the ½ of berm between Evaporation Ponds 1 and 2 obtaining approximately 1,555 CY of material from the stockpile area.

• Prepare the surface for new lining and reline Evaporation Pond 2.

• Install lysimeters

Phase VI – Reclamation

• Haul and Spread topsoil in remaining disturbed area.

• Revegetate the remaining disturbed areas.

• Remove cattleguard and temporary fencing from perimeter of project area.