903R90004
&EPA, Region III
RECORD OF DECISION
SLUDGE MANAGEMENT STUDY
FOR THE
BLUE PLAINS WASTE WATER TREATMENT FACILITY
WASHINGTON, D.C.
U.S. EPA Region III
TD Regional Center for Environmental
524 Information
. D5 1G50 Arch Street (3PM52)
R43 Philadelphia, PA 19103
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TO
^7
,0$
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
M1 Chestnut Building
Philadelphia, Pennsylvania 19107
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:
Enclosed is a copy of the public Record of Decision (ROD)
concluding the Environmental Impact Statement (EIS) process that
has been conducted on the sludge management study for the Blue
Plains Waste Water Treatment Facility in Washington, D.C.
The Record of Decision summarizes the Environmental Protection
Agency's (EPA) final evaluation of the sludge management
alternatives for the District of Columbia's Blue Plains Facility.
EPA has determined that land application is the most
environmentally sound method of disposing of the sludge from this
facility.
The District of Columbia has not filed a formal request for
funding for sludge management at this time. However, if a
construction grant is applied for in the future for implementation
of a sludge management alternative at this facility, EPA will
evaluate the request in terms of the findings concluded from the
EIS process.
I wish to thank the officials and citizens of the District of
Columbia and the States of Maryland and Virginia for the
participation and assistance provided to EPA's staff during this
EIS process.
Sincerely,
—Ct.-
Edwin B. Erickson
Regional Administrator
Enclosure
egion m
Regional Center tor Fmironmcntal Information
US EPA Region III
1650 Arch St
Philadelphia. PA 19101
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Record of Decision
In May 1990, the U.S. Environmental Protection Agency (EPA)
issued a Final Environmental Impact Statement (EIS) on the Sludge
Management Plan for the District of Columbia's (District) Blue
Plains Waste Water Treatment Facility. This Record of Decision
finalizes the EIS process by presenting the Agency's final decision
regarding an acceptable solution to the District's immediate and
future sludge management needs.
Background
For many years the District has investigated the proposal to
incinerate up to half of the sludge produced by the Blue Plains
Waste Water Treatment Plant as part of their Facility Plans. The
plans also call for recycling roughly half of the production
through composting both at the Plant and in Calverton, MD at a site
designated as Site-II. In 1983, EPA and the District signed an
agreement committing EPA to support the ultimate sludge disposal
decision, depending on the outcome of an environmental analysis.
In 1984, EPA issued a Finding of No Significant Impact
(FONSI) for the composting proposals and opereitions at the Blue
Plains Facility and Site-II. At the same time, EPA notified both
the Government of the District of Columbia and the user
jurisdictions that, as required by the National Environmental
Policy Act (NEPA), the EIS process would be applied to the
remaining half that was slated by the District for incineration.
Up to that time, the District had made no formal application
for funding support for incineration. However, NEPA guidelines
provide for the early application of NEPA. In 40 CFR 1501.2 it is
stated: "Agencies shall integrate the NEPA process with other
planning at the earliest possible time to insure that planning and
decisions reflect environmental values, to avoid delays later in
the process, and to head off potential conflicts."
In this case, the District had made known its preference for
incineration through its facility and feasibility plans. These
plans call for an engineered incineration capacity that would
exceed the plant's long term production, although the need is for
incineration for only 50% of the sludge produced. These plans were
submitted to EPA and triggered the NEPA process.
In August, 1984 EPA issued a Notice of Intent to prepare an
EIS on the incineration portion of the sludge management plan. A
Draft EIS was completed in March 1989, and was distributed for
public review to Federal and state agencies, elected officials,
local government agencies, environmental interest groups, area
residents, and numerous other individuals and organizations. The
Final EIS was issued in May 1990.
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A public participation program was initiated to ensure that
all interested citizens could become involved in the decision-
making process. Public meetings, a public hearing, numerous
meetings and telephone conversations with area residents, and
periodic newsletters were some of the methods utilized by EPA to
encourage citizen participation.
Alternatives Evaluated
A variety of sludge disposal methods were evaluated by the
EPA during this EIS process. Six action alternatives were
developed and reviewed. In addition a no-action alternative was
also considered. A brief description of each alternative is given
below:
* Incineration with Ash Landfilling
The District proposed to construct six fluidized
bed furnaces to process the eguivalent of 22 dry tons
per day (DTPD) of sludge. The incineration proposal
includes final ash disposal at the Lorton Landfill. In
preparing the EIS, both multiple hearth and fluidized
bed furnaces were considered. In addition, a scaled down
incineration alternative using only four fluidized bed
furnaces was considered.
* Ocean Disposal
Ocean disposal was evaluated because of the location
of Blue Plains on the shores of the Potomac River.
Barges departing from Blue Plains would have access to
the Atlantic Ocean via the Potomac River; thus making
ocean disposal a low cost alternative.
* Land Application
Historically, land application of Blue Plains sludge
has been a major part of the District's solids
management program. Approximately 600 to 700 wet tons
of dewatered sludge are presently transported off-site,
stored, and applied as required to support crop nutrient
requirements.
* Composting and Product Use
Composting of dewatered sludge is a major component
of the District's long term plan for the non-EIS sludge.
Under the FONSI, the present on-site aerated static pile
composting is due to be replaced with in-vessel
composting to provide increased capacity while using less
of the space constrained Blue Plains site.
* Drying and Product Use
Heat drying reduces the overall weight and volume
of the sludge to be removed from the site. The final
dry sludge pellets, which are stable and pathogen-free,
may be used for land application programs. Environmental
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concerns focus on the moist gas stream discharge to the
atmosphere and the liquid sidestream from the scrubber
unit.
* Landfilling
The Lorton Landfill in Fairfax County, Virginia is
currently the only site available to accept dewatered
sludge. However, the Commonwealth of Virginia prohibits
the disposal of dewatered sludge in the Occoquan
Watershed where the landfill is located. Therefore,
implementation of this alternative is not feasible.
* No-Action
The no-action alternative presumes the continuation
of the current sludge handling and disposal methods for
the EIS portion of the sludge. All sludge not subject
to the FONSI (composting) or the Montgomery County
Composting Facility (composting) would be dewatered and
land applied to the limit of the ability of the existing
facility.
Final Recommended Action
Of the alternatives evaluated during the EIS process, land
application coupled with composting is EPA's preferred choice as
a sludge management alternative for the portion of the facility's
sludge not covered by the FONSI. Land application includes the
following major elements:
* Improved sludge handling and dewatering at Blue Plains.
This includes the installation of centrifuge dewatering
at Blue Plains.
* Continuation and renewal of long-term contracts to haul
and dispose of sludge including:
Contracts that provide for disposal of an average
200 DTPD and for up to 384 DTPD during the maximum
two months of the year, and
- Contracts that provide for appropriate regulatory
management, environmental impacts mitigation, and
traffic control.
* Coordination with programmed development of the FONSI
composting and the expanded use of the Montgomery County
Composting Facility.
Costs
Land application is not the least cost alternative but it
compares favorably with other alternatives, including incineration.
Considering the variability in engineering estimates for planning
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purposes, the total annual equivalent costs (per year costs) and
annual equivalent costs on a per dry ton basis are nearly equal.
The following table summarizes the costs for land application.
The capital costs of $17,490,000 reflect the cost of installing a
centrifuge dewatering process at Blue Plains. The District plans
to complete this dewatering process regardless of the disposal
technology selected.
Annual operation and maintenance costs of $18,360,000 are
based on the District's estimates for operation and maintenance of
the centrifuge dewatering system and the cost of contract land
application. The cost for contract land application is the major
component of this cost ($12,988,000) and is based upon the
District's current contracts for land application of sludge.
Annual energy costs for land application are estimated to be
$979,000. These costs include approximately $310,000 for
electrical power for the centrifuge dewatering equipment and
$669,000 for fuel for the sludge transportation and application.
SUMMARY OF COSTS OF LAND APPLICATION
Capital Cost
1988 Estimated
Project Cost (1)
Operation & Maintenance Cost (2)
- Centrifuge Dewatering
- Land Application
- Administrative Cost
Total Annual Equivalent Costs
Estimated Annual Equivalent
Cost per Dry Ton (3)
$ 5,047,000
$ 12,988,000
$ 325,000
Totals
17,490,000
$ 18,360,000
$ 20,218,000
$ 277/dry ton
(1) Based on District Cost Data and Engineering Science Concept
Design Cost Information
(2) Based on District Cost Data and District Contracts for Land
Application §73,000 dry tons per year sludge solids
(3) Based on annual loading of 73,000 dry tons of sludge solids
Review Comments Submitted on the Final EIS
Following is a summary listing of individual comments EPA
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received on the Blue Plains Final EIS. Letters appear in Appendix
I.
Commentator:
Affiliation:
Comments:
Commentator:
Affiliation:
Comments:
Commentator:
Affiliation:
Comments:
Commentator:
Affiliation:
Comments:
Commentator:
Affiliation:
Comments:
Rosemary Roswell
Assistant Secretary, State of Maryland, Department
of Agriculture, Office of Resource Conservation
In calculating availability of useable cropland for
land application, competition with other existing
STPs and animal wastes has not been considered. The
seasonal unavailability of land indicates a need for
temporary covered sludge storage areas. This is
currently not considered as a requirement in the
EIS.
Reginald W. Griffith
Executive Director, National Capital Planning
Commission
The Commission's May 4, 1989 comments on the Draft
EIS were not included in the Final EIS. In these
comments the Commission supported land application,
based on the premise of continuing land availability
for the disposal of sludge.
Carol B. Thompson
City Administrator/Deputy Mayor for Operations,
Government of District of Columbia
The Final EIS format is not consistent with the
requirements of NEPA. Also, comments on the Draft
EIS were not adequately addressed.
John E. Touchstone
Director of Public Works, Government of the District
of Columbia
The Final EIS format is not consistent with the
requirements of NEPA. Also, comments on the Draft
EIS were not adequately addressed.
H. Bryan Mitchell
Deputy State Historic Preservation Officer,
Department of Historic Resources,, Commonwealth of
Virginia
We support EPA's preferred alternative of land
application.
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Funding Status
At this time EPA has not received an official request for
funding for this project. In the future, should the District
request funding for a sludge management alternative for the Blue
Plains facility, EPA intends to support the preferred alternative,
land application, as evaluated in the draft and final EIS and this
record of decision. Until such time as there exist significant
changes in sludge management technology or the legislation
affecting these technologies, EPA will continue to support land
application as the most environmentally sound sludge management
alternative for the Blue Plains Waste Water Treatment Facility.
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APPENDIX I
COMMENTS ON FINAL ENVIRONMENTAL IMPACT STATEMENT
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'Ptcdt crufManttanf! Dumber One /«&rtn/ -
' Jr-
Robert L We ike:
°*pof>'
STATE OF MARYLAND
DEPARTMENT OF AGRICULTURE
OFFICE OF RESOURCE CONSERVATION
April 17, 1990
§•} ST /"*'—• p 1 f rT\
R £ v.« !/*»' S ¥ e. U
APR 2 01990
1 %
Wetffei^cf^l. Sect,
LPA - L;cii 111
Ms. Phoebe C. Robb
EPA. Region III
841 Chestnut Building
Philadelphia. PA 19107
Dear Ms. Robb:
The following comments are in response to the Final Environmental Impact
Statement on the sludge disposal alternatives for the District of Columbia's Blue
Plains wastewater treatment facility.
I. Availability of Land for Land Application Alternative
In calculating availability of usable cropland, competition with other
existing STPs and animal wastes has not been considered.
a. There are approximately 300 MGD of wastewater treated in municipal
treatment plants in Maryland. This results in production of about 2000
wet tons/day.
b. Animal waste production in Maryland is estimated at about 9 million tons
per year, which is applied to the agricultural croplands.
II. Storage Costs for Sludge
Application times for sludge and animal wastes should be limited to spring
and fall months. December, January, and February applications are not
recommended due to the potential runoff problems caused by frozen ground and
the inability of dormant plants to uptake nutrients. In June, July and August
most agricultural land is covered by summer crops and wastes cannot be
applied.
50 HARRY S TRUMAN PARKWAY, ANNAPOLIS, MARYLAND 21401
(301)641-5700
Buttimori/Annipolit Ar»»
(301)261-8106
Wuhington Metro Area
WihPnfc
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The seasonal unavailability of land indicates a need for temporary covered
sludge storage areas. This is currently not considered as a requirement in
the EIS.
An alternative solution is to compost the sludge in summer and winter
months. However, the composted form of sludge would also need to be
stored in those months.
It is not clear whether this extra storage cost is included as an
operation and maintenance cost for land application (Item (16), page 57).
We appreciate the opportunity to comment. Since we are actively pursuing
a 40t nutrient reduction in the Chesapeake Bay region, it is important that
additional inputs be carefully considered.
Sincerely,
Rosemary Roswell
Assistant Secretary
RR:bab
cc: Louise Lawrence
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NATOMAL CAPITAL PL-ANNING COMMISSION
IK REPLY REFER TO:
HCPC File No. 2355
Appointed by the
President of the Unted Sales
GtenT Urquhart
CHAIRMAN
WHIiam E Baumgaerlner
W Don MacG*way
Appointed by the
Mayor of the District of Columbia
Robert J Nash
Patricia Elwood
Secretary of Defense
Honorable Richard B Cheney
Secretary of the Interior
Honorable Manuel Lutan. Jr
Administrator of General Servees
Richard G Austin (Acting)
Chairman Commitleeon
Governmental Affairs.
United States Senate
Honorable John Glenn
Chairman Committee on the
District of Columbia.
US House of Representatives
Honorable Ronald V DeHums
Mayor District of Columbia
Honorable Marion S Barry. Jr
Chairman Council of the
District of Columbia
Honorable David A Clarke
APR 211990 "tr:.
Ms. Phoebe C. Robb ''''
United States Environmental Protection Agency
Region III
841 Chestnut Building
Philadelphia, Pennsylvania 19107
Dear Ms. Robb:
We appreciate receiving a copy of the Final Environmental Impact
Statement (EIS) on the Blue Plains Wastewater Treatment Plant Sludge
Management Study. We concur with and encourage the land application
alternative recommended by the Environmental Protection Agency. We
note, however, that the Commission's May 4, 1989 comments are not
included in the Final EIS. In these comments the Commission
supported land application, based upon the premise of continuing
availability of land for the disposal of sludge. The incineration
alternative is less desirable because the stacks would have an
adverse visual impact on nearby Federal park properties and other
Federal interests along the shoreline of the Potomac River. Enclosed
is a copy of the Commission's May 1989 comments.
We appreciate your coordination with Federal, regional, and local
agencies and look forward to future cooperation with EPA. If you
have questions about our comments, please contact Maurice Foushee at
(202) 724-0174.
EXECUTIVE DIRECTOR
Reginald W QnlMh
Sincerely,
Reginald W. Griffith
Executive Director
Enclosure
1325 G STREET M W
WASHINGTON. D C 2O576
C2O2) "72.4-0174
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N.VliON'AL CAPITAL PLANNING COMMISSION
KCPC rile Ko. 2355
BLUE PLAINS VASTCVATEK TREATMENT PLANT,
SLUDGE KUULGnZNT STUDY -
DRAFT ENVIRONMENTAL IMPACT STATEMENT
to tht U.S. Environmental Protection Agency. Recrion III
May 4, 1989
Tht Commission comments to the U.S. Environmental Protection Agency, Region
III, on tbe Blue Plains Vastewater Treatment Plant Sludge Manage»ent Study,
Draft Environmental Impact Statement (CIS), as follows:
1. Assuming the continuing availability of land for the disposal of
sludge, the Commission endorses IPA's preferred alternative of Land
Application, which provides for spreading dewatered sludge on permitted land
disposal sites in Maryland and Virginia, as having, at this time, the least
adverse impact on Federal interests; and
2. The Incineration alternative, if it requires stacks 225 feet high to
burn dewatered sludge at Blue Plains, would result in adverse visual impacts on
nearby Federal park properties, the Anacostia Freeway gateway, and other
Federal interests along the shoreline of the Potomac River. Therefore, it is
recommended that other means of addressing this problem be explored.
BACKGROUND AMD STAFF EVALUATION
Description of Proposal
The U.S. Environmental Protection Agency (EPA) has requested the Commission's
comments on a Draft EIS it has prepared for the Blue Plains Wastewater
Treatment Plant, Sludge Management Study. The purpose of the study is to
examine options for disposing of a portion of the sludge generated at tbe plant
over the next 20 years.
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Pa.r *
The Blue Plaint Vaatevater Treatment Plant complex is located on approximately
159 acres in the southwest portion of the District of Columbia. It is bounded
iy tae Stanr»i Reswaveb Laboratory oa the north, Interstate 23b on the east, Oxon
Core on the south, and the Potomac River on the west. The facility is designed
to treat an aaaoal average of 309 million gallons per day («gd) of wastewater
flow. It genres the District, parts of Fairfax and Loudoun Counties in
Virginia, and portions of Montgomery and Prince George's Counties in Maryland.
The residuals from the wastewater treatment process is called sludge. These
•olids undergo further processing prior to disposal, including thickening,
anaerobic digestion, blending, dewatering, and on-site aerated static pile
composting. Dewatered sludge, which is not processed further on-site, is
stored until it can be transported off-site to processing facilities.
Currently, about 250 dry tons per day of sludge are generated at the plant.
loughly 70 tons are composted on-site. Another 40 tons are composted at the
Montgomery County Composting Facility (MCCF) in Calverton near the
Montgomery/Prince George's County border. The remaining 140 tons are taken by
private contractors to permitted land application sites in Maryland and
Virginia.
Several alternative sludge disposal plans are discussed in the EIS. All of the
disposal solutions, however, assume that capacity for approximately 410 dry
tons per day (dtpd) of sludge will be required at the plant by the year 2010.
Under the 1985 Blue Plains Intermunicipal Agreement (IMA), approximately 88
dtpd will be bandied by the MCCF, Site II. An additional 123 dtpd will be
composted by an in-vessel system planned for Blue Plains. The remaining 200
dtpd could be disposed of in a variety of ways, and it is this 200 dtpd that is
the subject of the EIS.
The four alternatives tbat are identified as most viable include: No Action,
Land Application, Incineration, and a combination of Incineration and Land
Application. Landfilling, ocean disposal, composting, and drying and product
use were eliminated through the screening process.
The Mo Action alternative involves a continuation of current practices. The
MCCF would process 88 dtpd of sludge. One hundred and twenty-three dtpd would
be handled by the District on-site in an in-vessel composting system. The
remaining 200 dtpd of sludge would be land applied (dewatered sludge either
spread on the surface of the land or injected into the soil).
Land application, which is IPA's preferred alternative, is similar to the No
Action option. The MCCF would continue to process 88 dtpd. On-site composting
at Blue Plains would remain at 123 dtpd. Under the Land Application scenario,
however, available land application eites would not only accommodate the 200
dtpd of sludge generated at the plant on an average daily basis but would also
provide for the disposal of up to 384 dtpd to handle peak rates of sludge
production. According to the document, there are approximately 70,000 acres of
land in Virginia and Maryland that are permitted to accept sludge. While all
of this land is not set aside for use solely by Blue Plains, EPA believes
sufficient land is available to handle the sludge from the plant that would
require land application.
Incineration involves burning the sludge that would not be composted under the
IMA. This would include both the 200 dtpd produced on an average daily basis
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KCPC flic he-. :.:;5
Pajfe 3
as- veil as the 384 dtpd generated at peak rates. Four fluidized bed furnaces
mtuIS ae iastailed is the existing Solids Processing Building. Piens are to
install four furnaces in case one or more of the furnaces is not operational at
as? point. Each furnace would be designed to incinerate 133 dtpd. Ash is
expected to be landfilled at the Lorton Landfill in Virginia, furnace exhaust
gases would pass through air pollution control equipment prior to reaching the
•tacks to remove harmful pollutants. The stacks would be 225 feet high with
three 3.25-foot diueter flues in each stack.
The Combination Incineration/Land Application option involves disposing of the
sludge using both incineration and land application. This option would also
accommodate average daily and peak rates of sludge production. Half of the 200
dtpd of sludge produced on an average daily basis would be incinerated and the
other half would be land applied. The combination alternative would also
accommodate peak rates of sludge production.
According to the document, the total annual cost of the Incineration
alternative is $261 million, while the Land Application option is $277 million.
Although the total costs are comparable, Incineration has a higher capital cost
while Land Application's operating and maintenance costs are greater. The
overall operability (the ability of a given solids management system to
continuously provide the intended disposal service) are judged to be equal for
Incineration and Land Application. Both options are considered to have good
prospects for being implemented.
The environmental implications of the respective disposal approaches vary.
Incineration results in the emission of air pollutants that would not be
produced with Land Application. The document does indicate, however, that
incinerator emissions are expected to be within allowable air quality standards
and that adverse health impacts are not expected from the emissions. Both
methods would require the use of leachate collection and treatment systems and
surface water controls. Additional truck traffic on 1-295 would result from
either of the two primary build options. The Land Application alternative
would require a minimum of 37 to 44 truck trips per day to transport the
projected 200 dtpd. Fewer truck trips would result from the Incineration
option than the Land Application alternative. Scheduling truck movements for
non-peak periods would lessen the effect of either alternative.
According to the document, the visual impact of the stacks will affect the
aesthetic quality of parks along the Potomac River, including the Shepherd
Parkway Park to the north, the Bald lagle Bill Park located to the east, and
Qxon Bill Children's Farm located southeast of Blue Plains. Viewpoints from
Old Town Alexandria, the Vhite Bouse, and Daingerfield Island would also be
impacted. The close of the public comment period on the document is May 22.
BPA also indicates that a public hearing will be scheduled toward the end of
the comment period.
Conformance With Comprehensive Plan
The two primary alternatives offered by EPA for the disposal of sludge at Blue
Plains may affect air and water quality, Federal parklands, and the scenic view
afforded by a major gateway to the Nation's Capital. The following policy
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KK * i.e Ho. 1, , ,
Pace 4
contained in the Federal Environment element relating to air quality is
applicable to the Incineration alternative:
Stationary source concentrations of air pollutants should be reduced
by:
Using and/if or demonstrating test available existing and new
technology, feasible;
An additional policy contained in this element relating to the protection of
ground and surface water applies to both the Incineration alternative and the
Land Application alternative:
Spoil, sludge, and other waste materials should be disposed of in a
manner which does not contaminate ground or surface water resources.
There is concern that the construction of emission stacks 225 feet high, as
would be required under the Incineration alternative, could adversely impact
the views from nearby Federal parklands, namely, Oxon Hill Children's Farm/Oxon
Cove Regional Park, Daingerfield Island, and Shepherd Parkway. Policies
contained in the Parks, Open Space and Natural Features element require that
the natural qualities of these parklands and their views be protected.
The emission stacks would also be visible from the Anacostia Freeway, which
serves as a major gateway to the Nation's Capital. The following policy
contained in the Visitors to the National Capital element relating to scenic
views along gateways is applicable:
Maintain the gateways in the National Capital Region in a manner
which protects their landscape character and quality, promotes scenic
views, and enhances the Visitors experience of the Nation's Capital.
It would appear that emission stacks at the proposed elevation would detract
from the scenic views accorded visitors to the Nation's Capital along this
gateway.
The Committee received an information presentation on the Draft CIS at its
April 12, 1989 meeting. Agencies represented on the Committee will forward
their individual comments to the EPA on the document. Attending the meeting
were representatives of NCPC, the District of Columbia Office of Planning,
General Services Administration, and the Washington Metropolitan Area Transit
Authority.
Previous Commission Action
At its meeting on August S, 1971, the Commission approved the final building
plan for the Solids Processing Facility, Blue Plains Water Pollution Control
Plant, as shown on NCPC Nap File No. M.40(52.10)-26315. The final plans
included provisions for three "stub" stacks (and a possible fourth stack).
According to the staff report, the three stacks would reach an elevation of 110
feet or approximately 20 feet above the planned high point on the building.
Incinerator furnaces were never installed in the building.
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Federal Interest Evaluation
A long-term solution to the sludge disposal problem at Blue Plains is critical.
Expansion of the plant to accommodate more wastewater flows and the application
of more stringent water quality controls on plant operations will produce in
the future additional quantities of sludge requiring disposal. According to
EPA, failure to find environmentally acceptable and dependable means of
disposing of the Region's sludge could result in limitations on future growth
and development in areas served by the plant.
Assuming the continuing availability of land for the disposal of sludge, the
staff recommends that the Commission endorse EPA's preferred alternative of
Land Application. EPA indicates that this option is most consistent with the
National Environmental Policy Act and EPA's national policy which encourages
recycling resources. Further, indications are that it can be accomplished
without severe operational problems. While incineration would provide the
District with greater autonomy in meeting its long-term sludge disposal
requirements, staff believes that if incinerator stacks with top elevations of
225 feet are required, adverse visual impacts will be created from viewpoints
up and down the river and would detract from the beauty and image of the
Nation's Capital. The proposed stacks would be clearly visible from nearby
Federal parks located along the shores of the river, such as Daingerfield
Island and Oxon Cove Park. The 1-295 gateway into the city would also be
negatively affected by the presence of tall stacks. Views from across the
river along the Alexandria waterfront would be impaired as well. All of these
riverfront sites would have a clear vision of the proposed stacks since no
intervening trees or structures would filter views.
The staff has contacted the Department of the Navy and the National Park
Service {NFS) to elicit their comments on the Draft EIS. The Navy had not
reviewed the document at the time of the staff's inquiry. Their preliminary
indication, however, was that based on the staff's description of the EIS
neither of the two principal options in the EIS would adversely affect their
activities at the Naval Research Laboratory or the Naval District Washington,
Anacostia. Representatives of the UPS also advised the staff that they had not
received a copy of the document. Based on their understanding of the options,
however, they believe 225 feet high incinerator stacks would have adverse
visual impacts on nearby park properties and views along the river. On
November 2, 1987, the Federal Aviation Administration issued its determination
that the stacks would not pose a problem for air navigation. It did ask,
however, that since the structures would exceed obstruction standards that they
be Barked and lighted.
Since the preferred alternative (Land Application) appears to be a reasonable
option with costs, operational requirements, potential for implementation, and
environmental impacts comparable to the Incineration option, the staff
recommends that the Commission endorse Land Application as the option to be
selected. It would have less impacts on Federal interests than the
Incineration alternative. Although the Commission previously approved plans
for the Solids Processing Building, which required incinerator stacks, the
previously proposed stacks were much lower in height and would not have
resulted in a major change in the skyline as would the current proposal.
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NCPC File No 2?55>
Page 6
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FIGURE 11-12
BLUE PLAINS SITE
EXISTING CONDITIONS
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NCPC File No. 2355
Page 7
F ,
EXCESS FLOW
CHLORINE CONTACT TANKS
RAW WASTEWATER
PUMP STATION NO. 2
MAW WASTEWATER
STATION NO. 1
WIST PRIMARY
SEDIMENTATION
TANKS
ANAEROBIC
MOESTION
TANKS
\
EAST PRIMARY
SEDIMENTATION
TANKS
SECONDARY
BLOWER BUILDING
CAST
SECONDARY
REACTORS
^NITRIFICATION
\\BLOWER
VBUILDING
GRAVITY
THICKENING
TANKS
L^~ SOLIDS
L PROCESSING
BUILDING
MULTI-MEDIA
FILTRATION
FACILITY AND
DftlNFECTION
TANKS
OUTFALL
OUTFALL O02
PRIMARY SEDIMENTATION TANKS
ARRANGED FOR EXCESS FLOW
TREATMENT
BLUE PLAINS WASTEWATER TREATMENT PLANT '
EXISTING PLANT FACILITIES
6REELEY AND HANSEN
BLUE PLAINS FEASIBILITY STUDY
FINAL REPORT
EPA NO. C110040
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NCPC File No. 2355
Page 8
I WHITE HOUSE AND TOAL §AS»N AREA
2 SHEPARO PARKWAY PARK
3 OKON HILL CHILDREN'S FARM
4 DAINGERFlELO ISLAND PARK
9 OLD TOWN ALEXANDRIA
6 PORTAMERICA DEVELOPMENT
SITES VISUALLY IMPACTED
BY INCINERATOR STACKS
FIGURE 4-
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GOVERNMENT Oe T^E C'CTC;CT OF CCLUMf'A
EXLCUTT . Or ICE
OFFICE OF THE CITY ADMINISTRATOR
DEPUTY MAYOR FOR OPERATIONS K^jSfi-irJ) 1350 PENNSYLVANIA AVE., N.W. - ROOM 507
WASHINGTON. D.C. 2COCM
***
Mr. Edwin B. Erickson
Regional Administrator
U.S. Environmental Protection Agency
Region III
841 Chestnut Building
Philadelphia, Pa. 19107
Dear Mr. Erickson:
I have reviewed the Final Environmental Impact Statement (EIS) for
sludge disposal at the Blue Plains Wastewater Treatment Plant. I
am extremely concerned with the final recommendation of the study,
and deeply troubled by the substantial sludge management burden
your recommendation places on the Washington Metropolitan Area.
As I have stated in previous conversations and correspondence,
the District of Columbia cannot provide reliable sludge disposal
through a combination of land application and composting. The
District expects that sludge volumes will increase in the future.
I believe it would be irresponsible to place the District in the
position of being completely dependent upon private contractors
and surrounding state and local governments to provide such a
vital municipal service.
I am also concerned that your decision does not appear to be based
upon technical or environmental considerations, or on the cost
effectiveness to the local governments. Instead, the decision
appears to be based upon EPA's national policy that: "whenever
economically feasible, . recycling and reuse are to be considered
options of choice. " I believe that our sludge management plan,
which calls for composting half of the sludge produced at Blue
Plains and incinerating the remaining half of the sludge meets this
test.
I also believe your recommendation fails to recognize that the
District has virtually no control in implementing a land
application program. We have no land suitable for sludge disposal
within the District of Columbia, the suburban user jurisdictions
are running out of land for sludge disposal within their counties,
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the State of Maryland has imposed limits on sludge storage
facilities which severely limit land application within that
state, . and draft Federal regulations also limit the viability of
land application nation-wide. The combined affect of these
constraints render the land disposal of up to 200 dry tons (1,000
wet tons) of slodge per day an unacceptably risky operation over
the next twenty years.
We do not agree that "there does not appear to be a trend opposing
the continued practice of land application of sludge" (page 30,
response). Local government efforts to prevent siting of sludge
storage facilities (Carroll County, . MD..) and to prevent
importation of sludge (Talbot County and Queen Anne's County,. MD. _
and Carolina County and Culpepper County, , VA. ) are indicative of a
continuing trend to inhibit land applicaton of sludge from any
"outside" county. We believe this trend will accelerate as more
municipalities adopt land application programs in lieu of ocean
disposal.
The anticipated beneficial affects of land application which you
cite in the Final EIS are not universally recognized. As recently
as January 3, 1990, the U.S. Department of Interior, . Bureau of
Land Management stated that they would prohibit the disposal of
sludge on public lands based upon the risks and problems
associated with sewage sludge. Even though the Bureau of Land
Management may have erred in its finding, this kind of position
has a damaging affect on the acceptability of land application by
landowners and local governments.
Enclosed for your review are the District's comments on the Final
Environmental Impact Statement. I hope you will give our comments
serious consideration and revise your recommendation to support
our sludge disposal plan. I would appreciate an opportunity to meet
with you or your staff at your convenience to discuss our concerns
and negotiate a mutually acceptable solution to this problem.
Sincerely,
Carol B. Thompson
City Administrator/ /
Deputy Maypr fojt Operations
Enclosure
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FIRAT, EFVISONK^NTAL IMPACT £T?-.Tr"-'T':'!V
SLUDGE MANAGEMENT STUDY, . BLUE PLAINS WASTEWATER TREATMENT PLAINT
- Detailed Comments -
1. We question whether the final EIS format is consistent with
the requirements of NEPA. The final EIS document includes
the executive summary from the draft EIS, plus the testimony
and comments received by the U.S. EPA and your agency's
response to the testimony. We believe this material should
have been included in an Appendix to the Final EIS. We
believe that the final EIS should be a "stand alone" document
which would include all of the analysis which led EPA to its
conclusions and recommendation. We recommend that EPA republish
the full EIS with the corrections and comments resulting from
the public testimony incorporated into the report and append
the hearing transcript and written testimony.
2. The final EIS recommendation is based upon the U.S. EPA
•beneficial use policy". However,.the final EIS imposes a
disposal system on the District of Columbia designed to benefit
the surrounding states. We believe this application of the
beneficial use policy is unfair and exceeds the authority of
the U.S. EPA.
3. We believe that the Final EIS did not adequately respond to
the region's comments as presented in the following
cor respondence:
- Regulatory Review and Impact Assessment prepared by
Engineering Science for the District of Columbia
dated May, 1989, (M-89-1)
- Review and Evaluation of Draft Environmental Impact
Statement, prepared by CH2M Hill for the WSSC,.dated
June,.1989, (J-89-1)
- Regional Comments from the Blue Plains User
Jurisdictions,.dated June 9,.1989,. (J-89-28)
- Comments from the Metropolitan Washington Council of
Governments,.dated June 21,.1989,.(J-89-39)
- Annotated Detailed Comments from the Metropolitan
Washington Council of Governments,.dated June 21, 1989,
(J-89-40)
- Letter from Carol B. Thompson,.City Administrator/Deputy
Mayor for Operations, dated June 30,.1989,.(JL 89-1)
We specifically believe that the Final EIS did not adequately
respond to the following comments and concerns presented by
the Blue Plains users.
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-2-
o Uncertainty regarding the impact of future sludge TTianjaneTrerr
Tegu-ations on'the long-term viabij.lt:y of ic^c c.pc L j cat .: n.
We do not question ZPA's technical calculation of sludge
loadings under the proposed sludge land application
regulations, but we do believe that the overall effect of the
proposed regulations will be to limit public acceptance of
land application. We also believe that the EIS recommendation
reflects EPA's willingness to "gamble" that sludge land
application will remain an acceptable solution in the future.
We do not believe it would be prudent to risk future sludge
disposal problems given the uncertainty regarding future land
application regulations.
o The significant difference between the availability of
permitted land and actual availability of land for sludge
disposal.
EPA failed to respond to the District's request dated
June 30, 1989 for a copy of the data used by EPA to support
the Final EIS assertion that sufficient land is available
for land application of sludge. We believe there is
considerable difference between land permitted for sludge
disposal and land actually available for sludge disposal on
any given day. Land owners often agree to sign a contract to
accept sludge and then later decide to plant crops,.making
that land unavailable for sludge disposal. We do not believe
the Final EIS adequately analyzed this problem.
o The affect of prior loadings on permitted land's ability to
accept additional sludge loadings.
We also do not believe that the Final EIS adequately analyzed
difficulties which will arise from land permitted for the
disposal of sludge from more than one wastewater treatment
plant. We believe this "double counting" of land makes land
application appear unreasonably attractive.
o The impact of weather on land application.
The Final EIS does not give adequate consideration to the
vulnerability of land application to wet or cold weather.
Several times in the past year the District has had to
stockpile sludge due to contractor's inability to haul sludge
due to bad weather. The potential for a sludge disposal crisis
increases as sludge volumes increase and on-site storage
capacity decreases in the future.
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The impact of limited storage capacity on the viability of land
application.
While the State of Maryland professes to support land
application,. their sludge storage facility siting practices
limit the success of the District's land application program.
Maryland has requested that wastewater treatment plants
provide on-site storage of sludge. This is an obvious
problem for the District which lacks adequate storage
capacity. Several Maryland and Virginia counties have taken
independent action to limit sludge storage or land
application. We believe this practice will increase in the
future and severely impact the District's ability to manage
a land application program.
The impact of competition with other East Coast local
governments for land application sites.
We believe that as other East Coast municipalities move from
ocean disposal to other forms of sludge disposal,.land
application will increase in this region. We believe that
competition for land will significantly drive up the cost of
land application and make the securing of sites more difficult.
The cited errors in the cost comparison between land
application and incineration.
We believe that the Final EIS did not adequately respond to
our comments that the cost comparison between land
application and incineration was inaccurate. Specifically, we
believe that energy costs and administrative costs were not
calculated correctly in the Final EIS, and that these errors
favored land application.
EPA's rejection of the region's assertion that land
application will be subject to inflationary cost increases in
the future.
We believe that EPA's statement that land application costs
will not escalate in the future is wrong. We believe that
costs will escalate due to increased transportation costs,.
increased labor costs and increased competition for land for
sludge disposal. If this region continues to develop as it
has in the past decade,.and as projected in the Chesapeake
Bay Program 2020 Report,. land for sludge disposal will become
increasingly difficult to find. We believe this will have a
significant affect on the future cost of land application.
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-4-
0 EPA's lack of concern about the long-term reliability of land
av-pl: cation elver, the fact tnat the tistrict controls r:_o -£.:.J
suitable for land application,. and that the District would be
dependent upon annual contracts with private firms for
providing this vital municipal service.
Sludge disposal is a basic municipal service which must be
provided every day. The Final EIS recommends a sludge
disposal process which makes the District completely
dependent upon other governments, private contractors and
private landowners for providing this service. We believe
this presents an unacceptable risk given the quantity of
sludge involved. The Final BIS fails to give this concern
adequate consideration.
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C>~ •"*-,'.". 7 S~R,C~ Cr
EK- CF PUBLIC WCR •
2OOO 14TM STREET N W
6-H FLOOR
WASHINGTON DC 20OO9
OFFICE CF THE Dt»ECTO«*
APR 8 0 iggr.
Mr. Greene A. Jones, Director
Environmental Services Division
U. S. Environmental Protection Agency
Region III
841 Chestnut Building
Philadelphia, Pennsylvania 19107
Dear Mr. Jones:
The D. C. Department of Public Works respectfully
submits these comments in opposition to the Final
Environmental Impact Statement ("FEIS") dated March 30,
1990, for the Blue Plains sludge management plan. I believe
the FEIS does not comply with the procedural requirements of
the National Environmental Policy Act ("NEPA"). It
completely omits discussion of an important viable
alternative; and in several respects, as discussed below, it
does not comply with the substantive requirements of NEPA.
Moreover, the executive summary and Environmental Protection
Agency ("EPA") responses to comments on the Draft
Environmental Impact Statement ("DEIS") betray an
unwarranted bias in favor of the land application
alternative and against the incineration alternative.
The significant changes in the various draft EIS
documents over the past four years, from initially
supporting incineration, then composting and finally land
application were not based on any new technical or
environmental information. I believe EPA's reasons for
rejecting sludge incineration in favor of land application
are political and economic rather than environmental or
technical considerations. Our opposition to the EIS
document are provided below.
A. NEPA Procedural Requirements
The FEIS violates the procedural requirements of NEPA
and the Council on Environmental Quality ("CEQ")
regulations. The FEIS does not contain a required section
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discussing tne alternatives, including the proposed action,
as required by NEPA Sections 102(2)(C) and (E), and the CEQ
regulations at 40 C.F.R. Part 1502.14. Nor does the FEIS
includ* required sections on the affected environment, nor
on the environmental consequences of the proposed action.
Failure to address these issues, including discussion of
direct and indirect effects, land use conflicts,
environmental effects of the alternatives, energy
requirements and conservation potential of the alternatives,
or mitigation of adverse environmental impacts, as required
by 40 C.F.R. Part 1502.16 leaves the final EIS an incomplete
document. The omitted sections of the FEIS go to the very
heart of NEPA's purpose. An EIS with no discussion of
alternatives or the environmental consequences of the
proposed action is clearly insufficient to provide
decisionmakers and the public with a full and fair
discussion of the environmental impacts of the proposed
action.
The nine-page executive summary in the FEIS, which the
CEQ regulations contemplate as a separate section in
addition to the omitted sections, (40 C.F.R. Part
1502.10(b)), cannot take the place of a true environmental
impact statement. In lieu of the required omitted sections
listed above, the FEIS explains how comments on the DEIS
were handled (with comments and EPA responses attached), and
then indicates only that, n[t]here have been comments made
that will be incorporated into the Draft EIS. The Draft EIS
will be amended to reflect these comments and will then be
adopted as amended."
EPA's confusing and novel procedure of indicating the
manner in which The DEIS will be amended in the future does
not satisfy the NEPA requirements for an FEIS. It also
raises a number of questions about compliance with the
procedural requirements of NEPA. Will the Record of
Decision ("ROD") be based on the FEIS; the DEIS as amended,
or a combination of the FEIS and the DEIS (as amended or
unamended)? When will the amended DEIS be available, and
will it be subject to public comment? Is the FEIS merely a
supplemental DEIS? If so, will a true FEIS be prepared in
the future?
These questions indicate that the FEIS, as written,
impedes public review of the document. If EPA's intent is
to incorporate parts of the DEIS into the FEIS by reference,
the District questions whether incorporating the very heart
of the FEIS by reference complies with NEPA. In any event,
EPA made no indication that the DEIS, or any parts of the
DEIS, should be incorporated by reference into the FEIS.
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B. Failure to Discuss Alternatives
The FEIS is seriously inadequate in its failure to
discuss important, appropriate, and clearly reasonable
alternatives for sludge treatment at Blue Plains. The CEQ
regulations require that the preparer of an EIS
"[rjigorously explore and objectively evaluate all
reasonable alternatives, and for alternatives which were
eliminated from detailed study, briefly discuss the reasons
for their having been eliminated." (40 C.F.R. Part
5012.14(a)). The FEIS does not consider, even briefly, the
alternative of a combination of incineration and land
application. This unaddressed alternative goes far beyond
evaluating the incineration alternative both with six
fluidized bed furnaces and with four fluidized bed furnaces.
An incineration/land application alternative would
require both a separate energy cost analysis and a separate
capitalization cost analysis. Moreover, the combination
alternative would require a separate aesthetic impact
analysis because an incinerator built under such an
alternative would likely have only one stack.
In this case, the alternative of a combination of
incineration and land application was clearly a reasonable
alternative that should have been discussed in detail in the
FEIS. The FEIS is therefore insufficient as a full
disclosure document to fully inform decisionmakers and the
public about reasonable alternatives for the project.
The FEIS also does not consider anaerobic digestion as
a sludge management option. EPA notes, without discussion
or explanation, that anaerobic digestion was beyond the
scope of the DEIS. (FEIS at 139).
C. Specific Objections to the FEIS
In addition to the procedural errors noted above, the
District has the following specific objections to the FEIS.
1. Energy Cost Analysis
EPA's responses to comments do not adequately
address the value of energy produced by the incinerator
which will be captured for electrical production. EPA
summarily dismissed comments on this weakness by alleging
that fertilizer displacement costs and the energy saved from
the displacement outweigh the incinerator's energy output
without any data to back up its allegations.
2. Resource Recovery
EPA does not recognize sludge burning as resource
recovery in the FEIS, yet recognizes hazardous waste
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incineration as- recycling under Subtitle c of RCRA. Sludge
incineration and use of the recovered energy is resource
recovery. This factor should be weighted in the discussion
of the incineration alternative in the same way that
resource recovery is considered to be a benefit of land
application. EPA states that "while the incineration
alternative has certain management advantages, and it
appears from the air emissions modeling (see FEIS at 111-
113) that it will not violate existing regulations, it does
not meet NEPA's purpose as effectively as does land
application.11 (FEIS at 65). As noted, however, in this
section and in section C.l, incineration is more likely to
meet "EPA's goals for maximum reuse of resources and
minimization of energy use." (FEIS at ES-7).
3. Long—term Harm of Land Application
EPA does not recognize or incorporate into the
FEIS the long-term impacts of land application sludge
disposal, which causes long-term irrecoverable metals
contamination of agricultural areas. The state and federal
sludge disposal rules, both existing and proposed,
acknowledge this contamination by limiting sludge
application.
In addition, land application does not preclude
commercial fertilizer application in the long term.
Although land application temporarily forestalls chemical
fertilizer application, it leaves metal contaminated soils
caused by sludge disposal to erode into adjacent surface and
ground water bodies over the course of time.
4. Metals Concentration: Benefits of Incineration
EPA's comments and analysis in the FEIS do not
acknowledge that incineration of sludge concentrates metals
which are then disposed of in the finite area of a protected
landfill. In contrast, land application spreads the metals
over wide, unprotected areas, thus contributing to the long-
term pollution of surface and ground water.
5. No Benefit to Chesapeake Bay
EPA's runoff study on nutrient transport in
agricultural runoff is a single, small, flawed research
study that should not be applied to a large scale land
application situation like the one envisaged by the FEIS.
Fertilizer and sludge have similar characteristics in terms
of runoff and their impact on water quality in the
Chesapeake Bay. There is, therefore, no benefit to the
Chesapeake Bay by designating land application as the
preferred alternative. EPA did not evaluate current
practices within the study area to determine whether sludge
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is replacing commercial fertilizer or adding a new source of
nutrients to the basin.
EFA adsiits in the FEIS that «[t]here is not
sufficient information available to estimate the possible
benefit in reducing nutrient runoff from use of sludge."
(FEIS at 59 - emphasis added). Yet in the Executive
Summary, on the list of major benefits of the land
application alternative, EPA states that the land
application alternative "has a secondary benefit in that it
reduces nutrient runoff to the Chesapeake Bay.11 (FEIS at
ES-7). The preferred alternative should not be chosen, even
indirectly or secondarily, on the basis of erroneous
information. EPA, in another response in the FEIS, lists
chemical fertilizer runoff reduction as "information . . .
that has given significant support to the selection of land
application as the preferred alterative." (FEIS at 123).
6. Adverse Effects
EPA states in the Executive Summary that one of
the major factors behind EPA's selection of land application
is that "[ajdverse environmental impacts are known to be
minor and controllable." (FEIS at ES-7). As noted above in
sections C.3 and C.4, this statement is incorrect. EPA
based its erroneous conclusion on the fact that in
discussions with county and state agencies, no significant
adverse environmental impacts were identified. (FEIS at
59). If this were true, counties, states and the U. S.
Department of Interior, Bureau of Land Management would not
be limiting or banning land application, nor would EPA
itself be in the process of promulgating regulations
limiting land application. Moreover, lack of evidence
elicited in conversations with certain local agencies is not
positive proof that there are no significant adverse
environmental impacts associated with land application.
EPA's "major factor" of lack of adverse environmental
impacts is, therefore, highly suspect.
7. Clear Trend Against Land Application
Contrary to EPA's wishful thinking, there is a
clear and unmistakable trend in Maryland and Virginia toward
increased regulation of land application. As noted in the
FEIS, five legislative initiatives were introduced in the
Maryland Legislature in 1988 to further regulate land
application. In 1989, the number of initiatives rose to
eight, three of which passed. (FEIS at 46-47) . Talbot
County, Maryland requires deed recordation when sludge is
applied to the land, effectively halting land application of
sludge. In addition, Carolina and Culpeper Counties in
Virginia have prohibited land application of sludge. (FEIS
at 124 and 369). Statements of support for land application
from certain groups do not outweigh the plain facts
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indicating a clear trend in local opinion and laws in
opposition to spreading sludge on farmland. Nor does
stating that additional land has been permitted for land
applicative* in the past five years somehow counterbalance or
eliminate increasingly negative public opinion toward land
application.
8. EPA Part 503 Technical Regulations
EPA's Part 503 Technical Regulations have an
enormous potential impact on the land application
alternative, substantially increasing costs, increasing land
requirements up to 3-5 times, and creating a negative public
perception of land application because of the risk
assessment methodology used in the proposed regulations that
may affect land availability. EPA cannot dismiss any
discussion whatsoever of the Part 503 regulations simply
because they have not been promulgated in final form. The
regulations were proposed and subjected to public comment
months ago. EPA should certainly have the capacity to find
out from within the agency whether there will be substantial
modification of the Part 503 regulations. If there are to
be substantial modifications to the Part 503 regulations,
those modifications must certainly be well under way, since
EPA itself plans to promulgate the regulations in final form
this year. Under the circumstances, it is clearly
reasonable to expect some discussion of the effect of the
Part 503 regulations in the FEIS. In addition, EPA should
publish a Supplemental EIS when the Part 503 regulations are
promulgated in final form.
9. Cumulative Impacts
EPA fails to disclose the cumulative impacts of
other facilities in the area that are also using land
application and the potential impact of these facilities as
land area decreases and permitted sites reach their
capacities.
EPA ignores previous loadings of sludge and
fertilizers on the land application areas. Without
explanation, EPA says that it was beyond the scope of the
DEIS to evaluate the previous loadings of sludge or other
fertilizers on the land application areas. (FEIS at 55).
In order to establish the true environmental impact of the
land application alternative, past action must be considered
together with future plans. Otherwise, the adverse
environmental impact could be disastrous.
EPA's recommendation ignores its own requirements
for long-term sludge disposal contracts with landowners.
The state of Maryland and the State of Virginia do not issue
long-term permits, but only single application permits. As
a result, the uncertainty of the long-term reliability of
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the land application alternatives creates unreasonable
risks. Moreover, the entire land application program will
have to be restructured annually. Contractors are subject
to the same annual permitting requirements.
10. Land Application Storage
The FEIS, and in particular the cost analysis,
ignores expensive storage requirements and associated costs,
and ignores both the negative aesthetic impacts of sludge
storage, and vector control requirements. Moreover, limited
seasonal availability of land for land application requires
substantial storage capacity, which would not be required
with a sludge incineration facility.
EPA received storage information from interested,
and therefore potentially biased, land application
contractors. Yet EPA made no effort to verify the
information received from the contractors, other than to say
that information agrees with information received from "the
states." (FEIS at 86). However, EPA made no effort to
verify the information received from the states, either.
That information could also have originally come from land
application contractors.
11. Urban Growth
EPA ignores the inevitable growth in this urban
area that will result in increased travel distances, and
less acreage for land application.
12. Cost Analysis
Accurate cost analysis shows that EPA's preferred
alternative is $11.1 million dollars more per year than EPA
estimates. (See CH2M Hill comments dated June, 1989 (J-39-
1) page 1-10). Present worth cost estimates are $68 million
higher for land application than for incineration over the
life of the project.
13. Implementability
EPA fails to consider in the FEIS that the
financial burden of implementing the land application
alternative will fall on local ratepayers, with no federal
sharing of costs. This certainly affects the
implementability of the land application alternative.
Although this issue was raised in a comment on the DEIS,
(FEIS at 119-120), it was ignored by EPA.
14. Bias
The preparer of an EIS must show a good faith
objectivity in the environmental effects analysis. (Isle of
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Hope Hist-orical Ass'n, inc. v. United States Army Corps of
Engineers, 646 F.2d 215 (5th Cir. 1981)). The CEQ
regulations require that "environmental impact statements
shall serve as the means of assessing the environmental
impact of proposed agency actions, rather than justifying
decisions already made." (40 C.F.R. Part 1502.2(g)).
It was apparent in the DEIS that EPA had already
made up its mind to prefer land application over the
incineration alternative. Comments made on the DEIS during
the public comment period appear not to have been given
serious consideration. To the extent that the District must
implement the program as outlined by EPA, the District is
forced into an extremely difficult situation because of the
practical problems with the preferred alternative. EPA has
recommended a sludge disposal method over which the District
of Columbia has no control over the disposal sites nor their
availability. Because EPA did not objectively consider the
incineration alternative, as discussed above, I believe its
choice of land application as the preferred alternative was
predetermined.
The Department of Public Works is keenly interested in
developing a workable sludge disposal program which combines
EPA's desire for maximum reuse of the sludge produced at
Blue Plains, with the District's need for a permanent
disposal facility under our direct control. I am troubled
that EPA has ignored previous requests for arriving at a
mutually agreeable solution. I am available to meet with
you at your convenience to work towards this goal.
incerely,
John E. Touchstone
Director of Public Works
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COMMONWEALTH of VIRGINIA
Hugh c Miller. Director Department of Historic Resources TDD 786-3143
R,chmond V.rg.ma 23219
Mr. Edwin B. Erickson
Regional Administrator
United States Environmental J[JN 20 1990
Protection Agency, Region III
841 Chestnut Building
Philadelphia, PA 19107 EPA, RF/I10N III
tfFICE OF KGUMl ttiMfilUIN
RE: Blue Plains Wastewater Treatment Plant, Washington, D.C.
DHR file t 5 4 54 -AX
Dear Mr. Erickson:
Thank you for providing the Virginia Department of Historic
Resources with a copy of the Final Environmental Impact Statement
for the Blue Plains Wastewater Treatment Plant. We support EPA's
preferred alternative of Land Application. This alternative will
not require the construction of a multi-story building to handle
the disposal of sludge.
We are concerned about visual impacts to the Alexandria Historic
District for a proposed alternative that would involve
construction of a tall building or incinerator stacks. The
Alexandria Historic District is listed on the National Register
of Historic Places and has been designated a National Historic
Landmark by the Secretary of the Interior. Therefore, we have no
objection to any alternatives that would not visually impact the
Alexandria Historic District.
Please contact Elizabeth Hoge if we can be of further assistance.
Sinceft/ely,
H. Bryari/Miteftell
Deputy gcate pistoric Preservation Officer
cc: Advisory Council on Historic Preservation
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