4>EPA
United States
Environmental Protection
Agency
Region 3
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
May 1983
Final Environmental
Impact Statement
West Ocean City
Wastewater Treatment
Facilities
Worcester County, MD
Supplement to North Central Ocean Basin EIS dated December 1978
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APR -5
UNITED STATES ENVIRONMENTAL PROTECTION AGF.NC'
REGION II!
6rn A\D WALNUT STREETS
PHILADELPHIA. PENNSYLVANIA !9;06
,983
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS AND CITIZENS:
Enclosed is a copy of the Final Environmental Impact Statement (BIS) prepared
by the U.S. Environmental Protection Agency (EPA) in conjunction with the
Worcester County Sanitary Commission's wastewater management Facilites Plan
for West Ocean City, Worcester County, Maryland.
This Final EIS was prepared pursuant to the National Environmental Policy
Act of 1969, the Clean Water Act of 1977, and regulations promulgated by
this Agency (40 CFR Part 6, November 6, 1979 and 40 CFR Part 35, September
27, 1978 and May 12, 1982). CoiFJients o~ que-.-ions concerning this Final EIS
should be submitted to Mr. Thomas A. Slenkamp a. -"h" above address by
no later than June 20, 1983.
EPA recommends as part of this Final EIS that the wastewater treatment
alternative selected in the Facilities Plan be implemented as soon as
possible, along with a mitigation plan to protect environmentally sensitive
resources which is outlined in Chapter IV. This recommendation does not
necessarily constitute approval of the WCSC's full Facilities Plan, which
is still subject to State and EPA administrative review.
I wish to thank all of you who participated in the EIS process for your
time and effort, especially members of the EIS Coordination Committee
which provided a cross-section of opinions and ideas on all of the major
issues. I encourage all of the West Ocean City area's residents and
landowners to work cooperatively with local and State officials to ensure
that the recommended project and mitigation plan are fully implemented.
A public meeting on the Final EIS will be held on June 9, 1983 at the
Ocean City Elementary School beginning at 7:30 p.m. All are encouraged to
attend.
Sincerely yours,
Peter N. Bibko
Regional Administrator
Enclosure
U.S. Eavironnant*! Protection Agency
Library. Room 2404 FX-2U-A
401 M Street, S.W.
"feshington, DC 30460
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FINAL ENVIRONMENTAL IMPACT STATEMENT
ON
WEST OCEAN CITY
WASTEWATER TREATMENT FACILITIES,
WORCESTER COUNTY, MARYLAND
Prepared by:
U.S. Environmental Protection Agency
Region III
Philadelphia, Pennsylvania
Evelyn Gchulz, Project Monitor
With Assistance from:
ESEI, inc.
Rockaway, New Jersey
Lanny Katz, Project Manager
Type of Action.
Legislative ( )
Administrative ( x )
Supplement to
North Central Ocean Basin EIS
dated December 1978
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TABLE OF CONTENTS
LIST OF TABLES
LIST OF FIGURES
EXECUTIVE SUMMARY
CHAPTER I. INTRODUCTION AND PURPOSE
CHAPTER II. PROJECT ALTERNATIVES
Introduction
No-Action Alternatives
Service Area
Collection and Conveyance Alternatives
Treatment and Disposal Alternatives
Cost Comparison
CHAPTER III. COMMENTS AND RESPONSES
Key Issues
Comment and Response Format
Synopsis of Written Comments
Summary of Public Hearing Testimony
Responses
Environmentally-Sensitive Lands
Regulatory Basis for Mitigation
The West Ocean City Mitigation Process
Key Draft EIS Mitigation Comments
Wetlands Identification
Wetlands Impacts
Erosion/Sedimentation
Septic System Failures
On-Site Alternatives
Collection System
Land Application
Conveyance Route/Force Main
Ocean City Treatment Plant Expansion
Dredge/Fill Request for Ocean City
Carter-Regier Study
Population Projections
Developable Land
Proposed Seafood Processing Plant
Public Water Supply
Water Conservation
Threatened and Endangered Species
Air Quality
Transportation Impacts
Community Services
Solid Waste Disposal
Project Costs
Financial Capability
Af fordability
Public Opinion
111
iv
v
4
4
5
6
12
17
20
20
20
21
26
30
30
30
36
38
41
41
43
43
44
44
45
45
47
48
48
49
51
51
54
54
55
55
55
56
56
56
59
59
62
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r
CHAPTER IV. F.ECOMMENDED ACTIONS
Recoranended '/Js.stewater Alternative
Collection/Conveyance
Treatment and Disposal
Project Costs
Financing Schemes
Service Area and Population
Growth Effects on Sensitive Areas
Mitigation Measures
Implementation Plan
Timing
Monitoring and Enforcement
REFERENCES
LIST OF PREPARERS
FINAL EIS DISTRIBUTION LIST
APPENDICES
A. Draft EIS Summary
B. Draft EIS Comment Letters
C. Public Hearing Transcript (Incorporated by
Reference;
D. Additional Correspondence - WCSC Put lie
Opinion Letter, etc.
Page
64
64
64
66
66
68
70
72
74
77
78
78
80
81
82
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.1ST OF TABLES
t.t-1.
111-1.
111-2.
III-3.
III-4.
III-5.
IV-1.
IV-2 .
TV-3.
IV-4 .
Present Horth Cost of Alternatives
Existing and Projected (Year 2000) Dwelling
Units by Facilities Planning Subarca
Page
19
50
Annual User Charges Under Scheme 1 58
Annual User Charges Under Scheme 2 58
Annual User Charges Under Scheme 3 60
Median Household Incomes 61
Present Worth Cost of Recommended Alternative 67
Annual Operation and Maintenance Costs 68
Annual User Charges Under Scheme 3 70
Year 2000 Growth Projections 71
ill
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LIST OF FIGURES
1-1.
II-l.
II-2.
II-3.
II-4.
II-5.
II-6.
III-l.
III-2.
III-3.
III-4.
III-5.
IV-1.
Iv-2.
West Ocean City Study Area
Facilities Planninq Service Areas
Gravity Sewer System
Pressure Sewer System
Vacuum Sewer System
Locally Funded Gravity Collection System
Treatment and Disposal Ootions
Flood Hazard Areas
Wetlands (Federal Classifications)
Gravity Collection System Showinq Seqments
Being Considered for Elimination
Property Lines - 1976
Existing Land Use
Recommended Conveyance and Treatment
Combined Floodplain/Wetland Areas
Page
3
7
8
9
10
13
14
31
42
46
52
53
65
76
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Executive Summary
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IECOTIVE SUMMARY
Purpose and
Background
Draft BIS
Findings
Public Comments
This Final Environmental Impact Statement (PEIS) has been
prepared by the Reqion III (Philadelphia) Office of the U.S.
Environmental Protection Aqency (EPA). It concerns wastewater
treatment facilities for the area of West Ocean City, in
Worcester County, Maryland. It was prepared in accordance with
the National Environmental Policy Act (NEPA), which requires all
Federal agencies to prepare EIS's when major Federal actions
(e.q. fundinq of wastewater treatment facilities) could
siqnificantly affect the quality of the environment.
The primary purpose of the Final EIS is to address salient
comments received on the Draft EIS, which was issued in
September, 1982 and to present EPA's conclusions reqarding
wastewater treatment service for West Ocean City. (For a
complete summary of the Draft EIS, please refer to Appendix A.)
This EIS was prepared as a Supplement to an earlier full EIS
prepared by this office on the Worcester County Sanitary
Commission's (WCSC) North Central Ocean Basin Facilities Plan.
The West Ocean City Sanitary District represents a small portion
(2,300 acres) of the total area (63,712 acres) covered by the
North Central Ocean Basin Facilities Plan and EIS. The specific
needs of West Ocean City were examined throuqh a Facilities Plan
Amendment prepared for the WCSC by George, Miles, and Buhr,
Incorporated. A report coverinq this Amendment was issued in
March, 1982 with minor revisions involvinq collector sewers and
cost estimates occurring in Aquust, 1982.
In the West Ocean City Draft EIS, EPA evaluated several
wastewater collection and treatment alternatives developed in
the Facilities Plan Amendment. The Draft EIS tentatively aqreed
with the Amendment's recommendation of a gravity collection
system with pumpover to Ocean City for treatment (Figure IV-1)
as the most cost-effective solution, provided that connection
restrictions to properties in environmentally sensitive areas
were implemented, and provided that the cost of the system to
individual users was shown to be acceptable to area residents.
EPA received many written and verbal comments on the Draft EIS
durinq a formal public comment period from September 17, 1982 to
November 1, 1982. In addition, oral testimony on the Draft EIS
and Draft Facilities Plan Amendment was recorded at a Public
Hearinq held at the Ocean City Elementary School on October 27,
1982. Comments on the Draft EIS were in the form of questions,
new information, suqgestions for improving the document, and
opinions as to which wastewater treatment alternative should be
selected and how sensitive environmental resources should be
protected. From EPA's perspective, all comments made were
beneficial in assisting the Agency to refine the Draft EIS
analyses and in formulating solid and thorough recommendations
in the Final EIS. The full set of written comments received is
reprinted in Appendix B.
From all the comments received, the following issues were most
frequently raised and/or considered of qreatest importance to
future proiect decisions:
o methods to be used to ensure that sewer service to flood
prone and wetlands areas will be controlled
o the need to protect wetlands and coastal bays from
sedimentation impacts
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Final EIS
Recommendat ions
Recommended
Alternative
Project Cost
o the potential impact of constructing a force main across
Sinepuxent Bay
o tlje effect of the West Ocean City project on the need to
expand the Ocean City STP
o the feasibility of continued on-site system use
o the financial impact of the project on local residents
EPA's responses to all of the substantive comments received are
presented in Chapter III of this document.
In preparing the Final EIS, EPA carefully reviewed all letters
and comments received on the Draft EIS and reconsidered the
alternatives and preliminary conclusions reached in the Draft
EIS. With respect to wastewater treatment alternatives, the
great majority of commentors expressed support for the system
recommended in the Draft EIS arid Facilities Plan Amendment. No
new information or analyses have shown that there is any more
suitable technical alternative which will eliminate the hazards
to groundwater and public health associated with the area's
numerous failing septic tanks.
Therefore, subject to the restrictions on sewer serice described
below, EPA continues to support the system of gravity sewer
collection, force main conveyance* and Ocean City treatment and
discharge recommended in the Draft£ EIS and Facilities Plan
Amendment. (see Figure IV-1). This alternative consists of a
gravity collection system for West Ocean City, with laterals and
t 8 _to 10" gravity sewer lines, six li*ft stations, and a pump
sta'tion (Figure II-2); a 16" diameter force main connecting the
west Ocean City collection system into the Ocean City collection
system at* 15th Street, including a 2500 foot segment which will
cross Sin^puxent Bay near the Route 50 bridge; a'hd treatment at
the Ocean City treatment olant with discharge through the Ocean
City outfall.
•
The total esfbimated cost of the recommended alternative is
t broken down below: ,
Present Worth Cost of the Recommended Alternative
Component
Collection
Const.
Year 'Capital
Salvage
Value
O & M
Total
Present
Worth
Gravity
sewer
system
(Includes
six lift
stations
and one
pump
station)
1983 $7,545,300 - SR42,000 + 5505,900 = $7,209,000
(continued on next page)
L
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Component
Const.
Year Caoital
Salvaqe
Value
0 & M
Total
Present
Worth
Cost to Users
Treatment
and Disposal
16" Force
Main
19B3 51,907,300
1
1
1
Ocean City
Treatment
Plant
Expansion 19R5 SI ,732, 5002-S427,000 + 51,190,400= 54,110,100
1 The Salvaqe Value, Operations and Maintenance costs, and
total present worth for the force main are included in the
cost fiaures for the Ocean Citv Treatment Plant Expansion.
2 Assumes that West Ocean City will oay 10.5% of the
513,200,000 cost to expand the Ocean City plant by 9.5 mqd,
plus 5346,500 to cover enqineerinq and administration fees.
The above fiaures reflect a reduction in the caoital cost for
collection baSed on WCSC's elimination of approximately 5280
feet of Federal qrant-ineliqible sewer lines in order to reduce
the local share'of costs.
In addition to eliminating certain sewer lines, WCSC examined
several other ways to reduce overall costs and the local share
thereby reducing the costs to system users. These included
assuminq 25 percent, rather than 30 percent of proiect con-
struction costs/, for enqineerinq, leqal, and administrative
fees; assuminq an 8 percent rather than 12 percent inflation
rate; installing laterals only to existing lots of record at the
time «-f construction; and obtaininq additional sources of
funding from the state of Maryland. Additional State financial
assistance* being sought includes an 5800,000 grant for
constructing the collection system under the State's Failing
Septic Tank Program; and securing a total of 51,000,000 in State
loans at an 8 percent interest rate to reduce annual debt
service gayments.
The combined effect of all of the above cost reduction measures
would be a reduction in the local share from 53,739,200 to
$1,988,000; and a corresponding reduction in user charges.
Using these reduced cost figures and potential additional
sources of fundinq the WCSC prepared and distributed a letter in
late" October, 1982 to all property owners describing the most
probable financing scheme and costs to individual sewer system
users (see Appendix D) . These cost figures were based on the
WCSC's previously developed financing scheme 3, simply using the
revised cost assumptions. These costs are presented in the
following table. The figures assume no State or Federal funding
for the cost of the Ocean City treatment plant expansion. They
also do not include a collection system hookup charge of $600-
$800 for new lots, the $500-51500 cost for service line
installation, or a $150 plumbing permit fee, all of which must
be borne by individual users.
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Affordability
Mitigation Plan
for Sensitive
Areas
Front Foot
Rate
Multiolied by
Lot width
50 ft.
100 ft.
200 ft.
300 ft.
Plus
Operation and
Maintenance
(0 & M)
Costs for one
residence
Equals
Total Cost by
Lot Width
50 ft.
100 ft.
200 ft.
300 ft.
ftnnual_JJser Charges Under Recommended Alternative
1983 1985 1990 2000
S 2.91/ft
S 1.41/ft $ 2.91/ft S 2.91/ft
S 71
$141
$282
$423
$80/yr
$146
$291
$582
$873
$80/yr
$146
$291
$582
$873
$69/yr
$146
$291
$582
$873
$68/yr
$151
$221
$362
$503
$226
$371
$662
$953
$215
$360
$651
$942
$214
$359
$650
$941
Depending on lot widths and the cost assumptions utilized, the
estimates of user charges in some cases may represent a cost
burden to individual home or property owners, especially for
those whose lots are wider than 100 feet. However, it is
difficult to establish how much the average resident/property
owner can afford to pay. Results of WCSC's October 29, 1982
letter to all property owners soliciting public opinion showed
that a slight majority were in favor of the project. EPA is of
the opinion that if after public review of this BIS the project
as described is approved by local officials, and then the state,
that the issue of user costs above will not prevent a construc-
tion grant award.
Any Federally-funded sewer system and the area it serves must
comply with Federal and State regulations and policies to
protect environmental resources from direct damage and indirect
loss through development. EPA and the State provided the
following guidance on limitations which must be placed on West
Ocean City's sewer service areas if Federal funding is to be
sought.
Vlll
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Flood-prone areas - sewer service can be extended only to lots
platted as of May 1977. The sewage capacity per lot would also
be limited to one equivalent dwelling unit (i.e. no future sub-
divisions ).
Wetlands - no sewer service could be planned for these areas.
Prime agricultural lands - sewer service could be planned for
residentially-zoned areas (most of West Ocean) even if they were
classified as prime farmland but not for agriculturally-zoned
areas. This is consistent with Worcester County's Comprehensive
Plan.
Non-sensitive areas - sewer service could be provided in a
manner consistent with local zoning and population projections.
Sensitive areas which were excluded from sewer service - these
areas could be developed with the use of on-site/alternative
systems, but not connect to the Federally-funded sewer system.
While the EIS clearly described the expected environmental
impacts of the selected alternative, and outlined the above
constraints necessary to protect environmentally sensitive
areas, it did not specify the institutional framework and
procedures by which the protective measures would be carried
out. As part of the Final EIS, EPA, in conjuntion with the
Maryland Department of Health and Mental Hygiene and the EIS
Coordination Committee, developed a specific implementation plan
for the necessary mitigation measures (see Chapter IV).
The implementation plan calls for actions at the Federal, State
and local (County) levels of government. It consists of two
primary institutional mechanisms, a local-State Consent Order,
and a condition to the EPA Construction Grant award, each of
which in turn requires a number of individual actions. Although
the final language has yet to be specified, the Consent Order
and grant condition together will contain the following basic
elements:
1. Require the Worcester County Sanitary Commission to
provide the State and EPA with a set of maps which clearly
delineate within the study area all wetland areas as defined by
the U.S. Fish and Wildlife Service, and all lands within the 100
year floodplain as defined by the Federal Emergency Management
Agency (FEMA). The maps will also delineate all specific vacant
parcels of land which lie partially or wholly within the above
floodplain or wetland boundaries, and will indicate which
parcels within the floodplain boundaries were platted as
building lots prior to June 1, 1977 and which had been developed
prior to the issuance of the Final EIS.
2. Require the WCSC to prohibit any connections to the
sewerage system from structures located on any parcel of land
subject to development restrictions based on the above maps,
i.e. any parcel of land not platted as a building lot prior to
June 1, 1977 which lies oartially or wholly within a floodplain
area, or any parcel of land which regardless of when platted
lies wholly or partially within a wetland area.
3. Require WCSC to incorporate the maos and connection
restrictions in floodplains and wetland into the County
Comprehensive Water and Sewerage Plan.
IX
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Next Steps
4. Designate the County Environmental Health Officer as
the responsible party for deciding whether or not a lot is
allowed sewer service.
5. Require WCSC to establish a new permitting process, or
modify its existing plumbing permit process, to require an
undeveloped lot owner to obtain a permit for connection to the
sewer system prior to or concurrently with his application for a
construction permit. An owner of: a developed lot would only be
required to obtain the connection and/or plumbing permit(s).
6. Require WCSC to amend its administrative procedures,
and obtain additional resources, if necessary, to assure
compliance with the above provisions.
When executed, these actions will provide a protective framework
which, combined with the existing controls, will adequately
mitigate any potentially adverse environmental impacts from West
Ocean City's proposed wastewater facilities.
Following the close of a 30-day public comment period after
issuance of the Final EIS, and a detailed review and aporoval of
the Final Facilities Plan Amendment, the State and EPA will be
in a position to consider a construction grant award. The
Worcester County Sanitary Commission and County commissioners
must decide whether they will agree to the EIS recommended
alternative and mitigation plan, and if so, work with the State
and EPA to finalize the Consent Order and grant condition
agreements. The WCSC must also work with the State to ensure
that all construction grant requirements have been satisfied,
and work with the Corps of Engineers to satisfy any Federal
dredge/fill activity requirements prior to the affected
construction.
Later this year, EPA will issue a Record of Decision, formallv
closing the NEPA review process. The Record will summarize th<;
conclusions of the EIS, report any modifications made to th<;
Final EIS based on comments received, and disclose any funding
decisions made by the State and EPA.
A final public meeting to discuss the Final EIS recommendations
will be held in June as specified in the cover letter of thii
document.
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Chapter I.
Introduction and Purpose
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CHAPTER I. INTRODUCTION
NEPA
Statutory
Authority
Construction
Grants Program
EIS Issues
The National Environmental Policy Act of I""!? (NEPA) requires that
Federal agencies evaluate the ootential environmental impacts of
any Federally funded or permitted oroject. When the potential for
adverse impacts on the natural, hu-nan, and/or economic environment
is significant, an Environmental Impact Statement (EIS) is
prepared. The intent of the EIS process is to identify all
possible impacts and to recommend a plan which minimizes adverse
impacts and provides mitiqative measures for those which are
unavoidable.
Draft and Final EISs on the North Central Ocean Basin (NCOB)
Facilities Plan were issued by KPA in 1977 and 1978, resoectively.
A Draft EIS on West Ocean City was issued in Seotember 1982, as a
supplement to the NCOB EISs in order to reflect the larqe reduction
in scope of the project, major changes in alternatives, and
environmental concerns which have arisen since 1978. This Final
EIS on wastewater treatment facilities for West Ocean City was
prepared to address the public hearing testimony and written
comments received following distribution of the Draft EIS.
The proposed action involves Federal financial assistance under the
statutory authority of Title II, Section 201(g)(l) of the Clean
Water Act. This authority enables the U. S. Environmental
Protection Agency's (EPA) Administrator to make grants to any
state, municipality, or intermunicipal or interstate agency for the
planning, design and construction of publicly owned water pollution
control facilities. EPA regulations for administering the program
appear in 40 CFR 35, Subpart I, Grants for Construction of
Treatment Works, which were published on May 12, 1982 as Interim
Final rules to replace 40 CFR 35, Subpart E.
Under the Construction Grants Program, EPA has and will through
October 1, 1984 provide up to 75% of the cost of conventional
wastewater treatment systems (sewage treatment plants and gravity
sewers, for example). After October 1, 1984, several major changes
to the program enacted by Congress in December 1981 become
effective. First, sewage collection systems such as that proposed
for West Ocean City will become ineligible for Federal funding.
Grants for sewage treatment plants will be based on the needs of
the existing population. Treatment plant expansion to serve future
growth will no longer be grant eligible. In addition, the Federal
share of the cost of constructing treatment plants will be reduced
to 55%. Construction Grants for individual projects have and will
continue to be awarded from State allocations according to an
EPA-approved State priority system. This State priority system
ranks projects according to the severity of pollution problems, the
need to preserve water guality, and other factors. In Maryland,
the lead State agency is the Maryland Department of Health and
Mental Hygiene. The availability of a grant for the West Ocean
City project will be contingent upon the amount of money allocated
to the State of Maryland as part of the Federal budget process and
the project's relative position on the State's priority list.
The West Ocean City Sanitary District has a lengthy history of
problems with failing septic systems due to unsuitable soils and a
high groundwater table. At the same time, the area has been under
strong pressure for development due to its proximity to Ocean City.
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General Setting
Much of Wsst Ocean City is covered by environmentally sensitive
lands including flood-crone areas, wetlands, and prime agricultural
lands. Issues on which the West Ocean City EIS has focused
include:
1. The population growth and development that would be caused by
availability of a sewer system;
2. The effects of increased develooinent on flood-prone areas,
wetlands, and prime agricultural lands;
3. The effects of increasing urbanization on the water quality cf
surrounding bays;
4. Methods to minimize adverse impacts on the area's environmental
resources; and
5. The financial impacts of constructing and operating a sewer
system on area residents.
The West Ocean City Sanitary District is located in southeastern
Maryland, approximately 110 miles southeast of Baltimore and 10
miles south of the Maryland-Delaware border. West Ocean City is
located on the mainland adjacent to the resort community of Occ;an
City. The Assateague Island National Seashore is southeast of W«st
Ocean City. As an unincorporated area of Worcester County,
wastewater management planning efforts are under the jurisdiction
of the Worcester County Sanitary Commission (WCSC). West Ocean
City encompasses 2,300 acres (3.6 square miles) of the 63,712 acres
(99.5 square miles)
management Facilities
(Figure 1-1).
covered by WCSC's original wastewater
Plan for the North Central Ocean Ba:3in
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OCEAN
CITY
WEST OCEAN CITY
STUDY AREA
WEST OCEAN CITY STUDY
AREA IN RELATION TO
NORTH CENTRAL OCEAN
BASIN
FIGURE 1-1
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Chapter II.
Project Alternatives
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No-Action
CHAPTER II. PROJECT ALTERNATIVES
The Facilities Plan Amendment considers various alternatives to
meet West Ocean City's wastewater treatment needs throuqh the year
2000. George, Miles and Buhr, Inc., engineering consultant to
WSCS, examined the alternatives on the basis of engineerinq
feasibility and cost. These alternatives included several which
were environmentally acceptable and eligible for Federal funding
and one which could not receive Federal funding but would also not
be as limited by Federal environmental regulations. EPA, through
the EIS process, has reviewed the alternatives and examined their
environmental, social and economic impacts. The alternatives
prooosed by WCSC addressed four basic questions:
o Where will sewer service be provided and how will environ-
mentally sensitive areas be protected from construction-
related damage and loss through future development?
o How will the wastewater be treated?
1. Pumped to the existing Ocean City plant with effluent
discharge through Ocean City's existing outfall.
2. At a new treatment plant to be constructed on the
mainland and then pumped to Ocean City for effluent
discharge through Ocean City's existing outfall.
3. At a new treatment plant to be constructed on the
mainland with disposal of effluent by land application
at a site on the mainland within five miles of West
Ocean City.
o How will the wastewater be collected?
1. By a conventional gravity sewer system.
2. By a pressure sewer system.
3. By a vacuum sewer system.
o How will the proiect be funded?
1. With a 75% Federal grant under EPA's Construction Grants
Program and the remaining portion paid for by the State and
local residents.
2. Totally by local residents with a potentially substantial
direct assessment against property owners benefiting from
the system.
Of the alternatives, wastewater collection by gravity sewers and
treatment and disposal at the Ocean City plant offered the least
expensive alternative on a 20-year basis. This alternative, given
as the Selected Plan in the Facilities Plan, is discussed in
greater detail in Chapter IV. Chapter II contains an overview of
each alternative and its environmental impacts. Environmental
impacts considered include direct impacts (those resulting from
construction and operation) and secondary impacts (those caused by
the availability of sewer service, such as increased development).
The EIS process must consider the effects of taking no Federal
action, in this case the effects of EPA providing no financial
assistance for construction of wastewater facilities in West Ocean
City. Under the no-action alternative, the Worcester County
Sanitary Commission (WCSC) could elect to (1) construct a system
which would be paid for totally by local residents or (2) take no
action to provide sewer service to the West Ocean City area.
A locally funded alternative was considered in the Facilities Plan
for implementation by the WCSC; this alternative is described below.
Under the locally funded alternative, sewer service would not be
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No Federal
Action-Locally
Funded
Alternative
No Federal
Action-No
Additional
Service
Service Area
limited by certain Federal policies and regulations, described in
Chapter III, which require environmentally sensitive areas to be
protected whenever Federal dollars are used. The service area
could expand from 1,287 to 2,087 acres and the year 2000 populatr.on
from 13,920 to 17,700 persons. However, even if no Federal grant
is used to construct a centralized system, a number of Federal and
State policies and regulations, such as the Coastal Zone Management
Act, the Section 404/10 Dredge/Fill Permit Program, and :he
Maryland Wetlands Act of 1970, wouLd still discourage development
of environmentally sensitive areas..
The imparts from a locally funded alternative would include at
least these which will be reviewed for the grant funded alterna-
tives ar^sented later in this chapter. The most significant
additional impacts would occur in the 800 additional acres served,
including primarily floodplains, agriculturally-zoned property and
some wetlands. As with the other alternatives, groundwater quality
would no longer be affected by seepage from septic tank drain-
fields, a beneficial effect which would reduce potential public
health problems. As growth proceeded, the local tax base would
increase; since growth exceeding that forecast for the selected
alternative is forecast in the Facilities Plan to occur in the
period from 1990 to 2000, the additional tax advantages of ~he
locally funded alternative would occur in that period. Public
service costs would also increase, and could easily exceed rhe
increases in tax revenue. A one-time payment of $4,400 per acre
would be required of all property owners to finance capital costs.
An assessment of this level could exceed the financial caoability
of many cirea property owners.
If the WCSC chose to provide no additional wastewater service to
the area,, growth would be severely curtailed. Year 2000 dwelling
units are estimated at 1,467 and population at 5,868 under this
course of action, versus 3,480 units and 13,920 persons with the
selected alternative. Under this option, the amount of growth in
wetlands, prime agricultural lands and floodplains would be
governed by State and local controls. Little additional wetland
development would occur; limited floodplain development would
continue, mainly in existing subdivisions. Since most prime
agricultural soils in West Ocean City are not protected locally,
and most of these soils are also suited to septic tank drtiin-
fields, :nuch of the residential growth in the service area would
center on these areas. Water pollution problems caused by failing
septic tank drainfields would continue. Special tax reductions are
available for parcels which have been denied septic tank perm.-ts;
the number of these reductions would increase, lowering the local
tax base somewhat. No significant increases in public service
costs would occur. If no solution to septic tank problems appeared
likely in the foreseeable future, the value of undeveloped
properties in the area would begin to stabilize and could decline.
If seotie system malfunctions increase, a building moratorium might
be imposed on West Ocean City. Homes and businesses with a severe
public health hazard might be forced to install expensive on-:=ite
systems or face condemnation. While no user charges for wastew.jter
treatment would be levied, costs to individual residents for seotic
tank maintenance and repair wou!3 remain.
Concern over sewer-induced growth .and it impact on environmentally
sensitive areas has been the central issue of the West Ocean ;:ity
EIS. To be eligible for Federal and State financial assistance,
waatewater projects must conform with Federal and State policies
regarding wetlands, floodplains, and prime agricultural land. The
regulatory basis which requires EPA to take positive action to
I
-------
Wastewater
Collection and
Conveyance
Alternative
prevent damage to environmentally sensitive areas is described in
Chapter III. Early in the Facilities Planning/EIS process, EPA and
the State of Maryland issued guidance to the Worcester County
Sanitary Commission (WCSC) on how the Federal Executive Orders,
Policies and regulations would apply to the West Ocean City
project. WCSC incorporated this guidance into the sewer service
area used to plan alternatives which could be eligible for Federal
funding. The shaded areas in Figure II-l represent areas which
could not receive sewer service (wetlands, agriculturally-zoned
lands, and flood-prone areas not platted prior to May 1977). The
numbered subareas (Areas 1 through 15) were identified as potential
sewer service areas. WCSC planned sewer service for Areas 1
through 7 in a manner consistent with local zoning requirements and
acceptable population projections. Areas 8 through 15 are located
in the 100-year floodplains; sewer service in these areas was
planned in accordance with EPA/State guidance on the extent of
development in flood-prone areas which could be supported by a
Federally-funded sewer system. Estimates of the existing and
future population in the 15 subareas are presented in Chapter IV of
the Final EIS.
Sewage collection systems are used to transfer wastewater from
homes, commercial buildings and other structures to a central
pumping station; conveyance systems transfer wastewater to
treatment and disposal sites. Three types of collection systems
were evaluated in the West Ocean City Facilities Plan: gravity,
pressure and vacuum sewers (Figures II-2 through II-4). The
proposed alignments are nearly the same for all three systems; most
sewers are planned to follow existing roadways and railroad
rights-of-way. Because the alignments would be in areas which have
already been disturbed by construction, no significant adverse
impacts are anticipated on wetlands, floodplains, prime agricul-
tural lands or potential archeological sites. Each proposed system
would require six lift stations and one pumping station. None of
the six required lift stations would involve significant adverse
impacts during construction. Lift stations *H and #4 are located
in residential areas; additional landscaping and shrubbery may be
appropriate to make them more harmonious with their surroundings.
The proposed location for lift station #5 is adjacent to wetlands.
Careful site planning, design and construction practices must be
used to prevent wetlands damage. Because the collection system
would be constructed along State and local roads, WCSC should
maintain continued coordination during design and construction with
State and local highway officials. Disruption of traffic and
business access along Route 50 and near the marina could be mini-
mized by scheduling construction during the off-tourist season.
Principal differences between the three systems are caused by
construction and excavation requirements and overall costs for
operation and maintenance. The gravity system would require
deeoer trenches and hence longer and more costly construction. The
gravity system would also be the most likely of the three systems
to develop cracks or ruptures which would permit groundwater to
enter the sewer system to be unnecessarily treated as sewage. The
pressure and vacuum systems utilize shallow trenches which are less
costly and time-consuming to excavate. Construction related
erosion and sedimentation would be qreater for a gravity system
because of the need for extensive dewatering during trench
construction. However, long-term energy costs and operation and
maintenance requirements and expenditures would also be lowest for
a gravity system. The Facilities Plan recommends that a qravitv
system be installed in West Ocean City because it is the least
costly of the three systems over a 20-year period and also because
-------
SIHEPUXENT
BAY
SANITARY DISTRICT BOUNDARY
LEGEND
6 SERVICE AREAS
H AREAS EXCLUDED DUE TO
ENVIRONMENTAL SENSITIVITY
Facilities Planning Service Areas
FIGURE 11-1
-------
SINEPUXENT
BAY
- SANITARY DISTRICT BOUNDARY
LEGEND
GRAVTTY SEWER
FORCE MAM
* PUMP STATION (PS)
• LIFT STATION 0.3)
Gravity Sewer System
FIGURE 11-2
-------
SINEPUXENT
— SANITARY DISTRICT BOUNDARY
LEGEND
— PRESSURE SEWER
FORCE MAIN
• POMP STATION (PS)
• LIFT STATION
Pressure Sewer System
FIGURE 11-3
-------
SWEPUXEHT
BAY
SANITARY DISTRICT BOUNDARY
LEGEND
VACUUM SEWER
FORCE MAIN
• PUMP STATION (PS)
• LIFT STATION (LS)
A VACUUM STATION (VS)
Vacuum Sewer System
FIGURE 11-4
10
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Gravity Sewer
System
Pressure Sewer
System
Vacuum Sewer
System
the Sanitary Commission already operates two such system;;.
Additional details on the three systems evaluated are presented :.n
the followinq sections.
Gravity sewer systems transport wastewater from buildinqs to
convenient low points utilizing differences in elevation to achieve
flows. Because the area is relatively flat, a minimum of seven low
points would be required. At six of these seven points, wastewater
would be collected in lift stations. These stations would thijn
pump wastewater uphill by way of force mains, discharging to the
upper elevations of gravity interceptors, or directly to a finsl
pumping station. Eventually, the wastewater would be pumped to tie
location(s) chosen for treatment and disposal. Federal funding is
available for installing collection sewers to serve areas which
were substantially developed by 1972. Consequently, not all col-
lection sewers in the area can qualify for Federal funding. A
potential alignment for a Federally-funded gravity collection
system to serve the study area is illustrated in Figure II-2.
Because of the need to maintain a minimum grade for gravity flow,
and the requirement of a manhole every 200 to 300 feet of seiner
lenqth, both the depth of required trenches and the duration of
construction would be greater under this approach than for either
the pressure or vacuum sewer alternatives. Trenches would rarge
from approximately 3 feet to 15 feet in depth. Erosion e.nd
sedimentation controls would be necessary in areas of high grour.d-
water? dewatering of trenches would occur during construction,
increasinq sedimentation somewhat.
The pressure sewer system evaluated for the West Ocean City Study
area would use on-site grinder pumps to pump wastewater from
buildinqs into a network of small diameter, shallow force mains.
In using a pressure sewer system, the small diameter pressurised
sewers are buried just beneath the frost penetration depth; this
can reduce sewer line construction costs and potential infiltration
of qroundwater. It is assumed that, whenever possible, one on-s:.te
grinder pump unit will serve two single family residences. ?or
multi-family residences, one pump unit could serve up to eiqht
dwelling units. Wastewater flows in the pressure sewer system are
conveyed to six lift stations and a final pumping station,
identical to those utilized in the gravity sewer system. The final
pumping station would convey the wastewater to the location(s)
chosen for treatment and disposal. A potential alignment for a
pressure sewer system to serve the study area is illustrated in
Figure II-3.
Pressure sewers would be installed in shallow, narrow trenches at a
uniform depth of approximately 3 feet to prevent freezing of pipes
during winter. The shallow trenches would require less excavation
and shorter construction time than necessary for conventional
gravity sewers, thereby exposing less soil to erosion. The shallow
trenches and reduced excavation would also minimize the need for
dewatering of trenches in areas of high groundwater, thus reducing
sedimentation impacts on surface waters.
Vacuum sewer systems depend on a central vaccum source which
constantly maintains partial vacuum on small diameter collection
mains. Household wastes flow by gravity to an on-site hole ing
tank. Adjacent to the tank is a gravity/vacuum interface vclve
which opens when a sufficient volume of sewage has accumulated,
thus allowing a volume of sewage to enter the main and move to a
central vacuum station. From this point the sewage is pumped via a
force main to a primary transmission line. Wastewater flows in
11
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Locally Financed
Sewer System
Wastewater
Treatment and
Disposal
Alternatives
Treatment and
Disposal at
Ocean City
the vacuum sewer system would be conveyed by six central vacuum
stations with locations identical to the six lift stations in the
gravity and pressure sewer systems. In addition to the six vacuum
stations, six lift stations and a final pumpinq station identical
to those utilized in the qravity and pressure sewer systems would
be needed. A potential alignment for a vacuum sewer system to
serve the study area is illustrated in Fiqure II-4.
Because the aliqnments and construction methods for the vacuum
sewer system would be similar to those for the pressure system,
potential impacts would be common to those described for the
pressure sewer alternative. The shallow trenches required for the
vacuum sewers would result in minimal impacts from erosion and
sedimentation. The combination vacuum and lift stations would be
constructed at the same six sites common to the pressure sewer
alternative.
If local funds were used to construct a sewer system in West Ocean
City, the project would not be considered a Federal action. Con-
sequently, the environmental constraints on sewer-induced qrowth
needed to comply with the Executive Orders on Floodplains and
Wetlands and the National Environmental Policy Act would not apply.
The locally funded alternative developed by WCSC would also use
gravity sewers and six pumping/lift stations. However, the extent
and capacity of sewer service would be expanded. The sewer service
area would be expanded from 1,287 acres to 2,087 acres. The waste-
water flow would be increased from 974,400 qallons per day to
1,239,000 qallons per day. The projected year 2000 population
would increase from 13,920 persons to 17,700 persons. A potential
alignment for the locally-funded system is shown in Fiqure II-5.
Alternatives for treating and disposing of wastewater collected
from the West Ocean City study area included conveyance to the
existing wastewater treatment facility at Ocean City, or treatment
at a new facility in the planning area with subsequent disposal
either through the existing outfall at Ocean City or land applica-
tion to a site southwest of West Ocean City. Direct discharge of
treated effluent to one of the surrounding bays is not a viable
alternative for West Ocean City. The limited capacity of the sur-
rounding bays to accommodate existinq wastewater discharqes has
caused the State to prohibit consideration of any new discharqes.
Raw sewage collected in the West Ocean City area would be pumped
via a 16-inch force main to the Ocean City collection system at
15th Street. From this point the existing Ocean City collection
system would convey the wastewater to the Ocean City facility for
treatment and disposal. A force main would be installed under
Sinepuxent Bay? this alternative is illustrated in Figure II-6.
The existing Ocean City secondary treatment plant has a capacity of
12.0 million qallons per day (mgd). Current peak summer day flows
at this facility are about 9.5 mgd. The remaining capacity
available for growth in Ocean City and service to West Ocean City
is therefore 2.5 mgd. The existing 12.0 mgd treatment facility
could accommodate the projected combined 1985 flows of 11.5 mgd
for Ocean City and 0.49 mgd from West Ocean City. At that time,
however, it would become necessary to expand the existing Ocean
City treatment facility by 9.5 mgd to accommodate 1.0 mgd of
projected year 2000 flow from West Ocean City and a projected 8.5
mgd flow increase from Ocean City by the year 2000. It is assumed
that West Ocean City will bear a proportional share, 1.0/9.5 or
10.5 percent, of the capital cost of the 9.5 mgd expansion. In
12
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SINEPUXfNT
BAY
SANITARY DISTRICT BOUNDARY
LEGEND
— GRAVITY SEWER
—— FORCE MAIN
• PUMP STATION
• LIFT STATION
Locally Funded Gravity
Collection System
FIGURE 11-6
13
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LEGEND
WEST OCEAN CITY TREATMENT
TREATMENT PLANT
——FORCE MAIN TO EXISTING
OCEAN OUTFALL
OCEAN CITY TREATMENT
• PUMP STATION
FORCE MAIN TO OCEAN CITY
COLLECTION SYSTEM
TREATMENT AND
DISPOSAL OPTIONS
FIGURE 11-6
14
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Direct Impacts
from Treatment
and Disposal at
Ocean City
Treatment near
West Ocean City
with Disposal
through Ocean
City Plant
Outfall
addition to capital costs West Ocean City would, immediately upon
connection, assume a proportionate share of operation and
maintenance costs at the Ocean City facility.
The existing Ocean City outfall has a diffuser capacity of 12.0 mgd
(the outfall pipe has an approximate capacity of 25 mgd). As
discussed above, combined flows from Ocean City and West Ocean City
would reach this level in 1985; an expansion of the outfall pipe
diffuser may be necessary at that time.
One important beneficial impact of this option is that groundwater
quality would no longer be affected by seepage from septic tank
drainfields, reducing potential public health problems.
Constructior of approximately 3,500 feet of 16 inch force main
across the Sinepuxent Bay would result in temporary suspension of
bottom sediments. This action would require a Section 404 anc
Section 10 permits from the U. S. Army Corps of Engineers. Most of
the suspended sediments would be chemically inert, inorganic
particles including clay, silt, sand and gravel derived from soil
and bedrock. Organic materials and toxic substances (heavy metals
and pesticides) included in the sediment would also be released
during construction. However, these would tend to be adsorbed onto
aggregate particles and returned to the sediment without signifi-
cant effect on the overlying water column. The ability of the
water column to transport sediments is dependent upon the wet.
density of the material and on water currents and turbulence.
Larger particles are quickly redeposited, while finer particles and
low density organic material may remain in suspension for longer
periods. Flow patterns in the bay are influenced by strong tidal
currents which enter through the Ocean City Inlet and through a 20
to 30 foot dredged channel along the eastern shore of the bay.
Tidal currents in the bay near the Route 50 bridge are approxi-
mately 1.5 feet per second. Given this relatively low velocity of
current, and the shallow water depth at the force main crossing,
transport of sediment would not be significant. Nonetheless, a
detailed evaluation will be necessary as part of the project
evaluation by the U. S. Army Corps of Engineers. Construction of.
the force main to the Ocean City sewage collection system from th<;
point of crossing the bay will result in adverse impacts fron
disruption of traffic and business access. The proposed alignment
was selected so as to minimize these impacts by avoiding narrow
roadways. Impacts can be further mitigated by scheduling - con-
struction during the non-tourist season.
Carter and Regier (1978) reported no detectable impacts attribut-
able to the Ocean City outfall on any aspect of the marine
environment in the vicinity of existing discharge. Based on th?
fact that the outfall will be diffusing secondary treated efflueni
rather than the primary treated effluent being discharged at the
time of the 1978 study, it is anticipated that the ultimate
disposal of West Ocean City wastewater flows via the Ocean City
outfall will have no significant impact on water quality. However,
it may be necessary to reevaluate the impact of Ocean Cit*'
wastewater discharges when plant expansion is again considered.
The collected raw sewage would be treated at a new plant in West
Ocean City, with the effluent pumped via force main to the existing
Ocean City ocean outfall. The treatment plant would be sized for a
flow of 1.0 mgd and would provide secondary treatment and disin-
fection. The effluent force main would cross Sinepuxent Bay to
Ocean City; construction of the force main would require Section
404 and Section 10 permits from the U. S. Army Corps of Engineers.
15
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Direct Impacts
from Treatment
near West Ocean
City with Dis-
posal through
Ocean City
Plant Outfall
Treatment with
Disposal by Land
Application near
West Ocean City
Once in Ocean City the force main would follow a route along St.
Louis Avenue and Philadelphia Avenue to the existing 64th Street
outfall. A potential treatment site and effluent conveyance system
to the existing Ocean City plant outfall is illustrated in Figure
II-6.
One important beneficial impact of this option is that qroundwater
quality will no longer be affected by seepage from septic tank
drainfields, reducing potential public health problems.
The proposed 3.5 acre site for a 1.0 mgd wastewater treatment plant
in the West Ocean City planning area is situated in a swampy wooded
area near the juncture of Route 611 and the railroad tracks at the
south boundary of the Sanitary District. Although not identified
as a wetland on the State map, the area is identified as swamp land
on the USGS topographic quadrangle map and probably considered
wetland under Federal jurisdiction. Construction would require
careful siting and mitigative measures to reduce erosion and
sedimentation impacts. The site would receive a detailed review in
accord with the 404 permit program administered by the U. S. Army
Corps of Engineers.
Construction of the force main in Ocean City from the bay crossing
to the existing 64th Street outfall would result in disruption of
traffic and business access on St. Louis Avenue and Philadelphia
Avenue. The alignment was chosen to avoid narrow streets. Impacts
can be acceptably mitigated by scheduling construction during the
non-tourist season when traffic and business activity are
substantially reduced.
Carter and Regier (1978) reported no detectable impacts attribut-
able to the Ocean City outfall on any aspect of the marine
environment in the vicinity of existing discharge. Based on the
fact that the outfall will be diffusing secondary-treated effluent
rather than the primary-treated effluent which was being discharged
at the time of the 1978 study, it is anticipated that the ultimate
disposal of West Ocean City wastewater flows via the Ocean City
outfall will have no significant impact on water quality. However,
it may be necessary to reevaluate the impact of Ocean City waste-
water flows when plant expansion is again being considered.
This alternative would treat the collected raw sewage at a new
plant in West Ocean City and use spray irrigation near West Ocean
City as an ultimate disposal method for treated effluent. The
collected raw sewage would be treated usinq aerated lagoons before
spray irrigation; storage ponds which provide system backup and
flow equalization would be sized to provide 60 days holding
capacity.
During project planning a distance of five miles was estimated as
the maximum distance over which effluent could be transmitted at a
reasonable project cost. Land within this radius was, therefore,
considered during facilities planning. The land area required for
spary irrigation was estimated using 39 weeks of application per
year at a rate of 1.5 inches per week. A total of 510 acres would
be required for spray irrigation, buffer areas, storage and treat-
ment .
The primary site selection procedure was to establish soil
suitability on remaining land areas after deleting all areas of
high or moderate density habitation. In reviewing suitable land
areas, it was evident that the more acceptable soils for spray
irrigation were located near the outer perimeter of the five mile
-------
Direct Impacts
from Land
Application
Alternative
Locally Financed
Treatment and
Disposal
Alternative
Cost Comparison
evaluation area. Also, after considering the length of pipel_ne,
parcel ownership, geoloqic location and the criteria of avoidance
of pipelines crossing environmentally sensitive areas, parcels
north of Ocean Pines were excluded in favor of those south and vest
of West Ocean City.
The analysis focused on locating large parcels in close proximity,
which would total at least 500 acres. A group of parcels between
the confluence of Ayer and Trappe Creek on Route 376 were selected
as the most likely spray irrigation site. However, on-site evalua-
tion by the Division of Residential Sanitation, of the Maryland
Department of Health and Mental Hygiene concluded that this site
was unacceptable due to the high seasonal groundwater table.
Because this site was typical of better soils in the area, spray
irrigation was no longer considered feasible. Nevertheless, a cost
analysis, was prepared utilizing ths unsuitable site. The high cost
of land application at the unsuitable site indicated that examining
more suitable sites farther from West Ocean City would not be
economically feasible.
The land application alternative, if feasible, would have commr.tted
approximately 500 acres of agricultural land to restricted use for
the principal purpose of effluer.t disposal. The use of the land
for this purpose would limit the type of crop and the ultimate use
of the ^orp which would be planted and harvested in the area. For
public health reasons, certain food crops are not recommended -:o be
grown i:i conjunction with land application of wastewater.
Because the closest feasible sites to the planning area were
determined to have seasonally high groundwater conditions, :.heir
use for land application of effluent could result in contamination
of groundwater. The land application alternative would also re-
quire a conveyance system with a pipeline approximately five niles
in length, resulting in adverse impacts from soil erosion and
sedimentation during construciton,, and possible impacts on environ-
mentally sensitive areas depending upon the alignment selected.
In the event that the WSCS decides against Federal funding the
costs incurred for sewage collection, conveyance, treatment, and
ultimate disposal would be borne solely by the residents o:: the
study ara. In that case, collected wastewater would be conveyed to
the existing Ocean City facility for treatment and disposal. Under
this approach, the force main beneath sinepuxent Bav would De 20
inches in diameter, traversing the same route as the one which is
under consideration for Federal funding (Figure II-6). Treatment
and disposal at the Ocean City plant was shown to be the least
costly approach independent of how the system was financed.
EPA requires that the costs of all alternatives be calculated on a
basis which allows fair comparisons of those that are expensive to
construct but inexpensive to maintain with those that havs low
construction costs but high operating expenses. The present worth
analyses is used to compare the total capital, salvage, oneration
and maintenance cost of the alternatives. Present worth can be
defined as the amount of money that must be invested, at a specific
interest rate, at the start of the oroiect to provide enough funds
to meet construction costs anH annual expenditures for the design
life of the facilities.
The cost analvsis of alternatives in the Facility Plan was ba:3ed on
the present worth conceot. Table II-l summarizes the present worth
of collection systems and treatment/disposal alternatives. Nine
different combinations of the three collection and three
17
-------
treatment/disposal options are oossible. In deriving the present
worth, the Facilities Plan made the following assumptions:
o All costs shown were in 1982 dollars.
o Discount rate used was 6 3/8%.
o Twenty years was used as the planning oeriod.
o Salvage values of collection systems and treatment/disposal
facilities were based on their anticipated life.
o No land purchase costs were included.
The alternative descriptions given earlier in this chanter note the
absence of a cost for the project area's share of expanding the
Ocean City outfall diffuser. The cost for expanding the Ocean City
outfall diffuser was estimated in the original 1977 NCOB Facilities
Plan at $1,800,000. Updating this cost using a construction
inflation index for the area yields an estimated 1982 cost of
$2,448,000. Applying the 15% inflation factor used in the
facilities plan for shifting costs from 1982 to 1983, this estimate
increases to $2,815,000. Assuming the 10.5 percent West Ocean City
share used for plant expansion in the facilities plan, the
additional 1985 costs not enumerated in the plan are estimated at
$295,575. Using an amortization over 30 years at 10% interest
(also from the plan), an additional annual cost of $31,500 can be
computed for the period 1985-2000.
For the locally-funded alternative, the Facilities Plan estimated
the initial capital cost to be $11,162,400 with an additional
capital expense in 1985 of $2,135,400. Annual operation and
maintenance costs were estimated to be $132,100 in 1985 and
$217,400 in 1995.
18
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Table II-1. Present Worth (in 1982 Dollars) of Wastewater Collection, Treatment and
Disposal 1
Alternatives
Gravity sewer system
Pressure sewer system
Vacuum sewer system
Treatment and disposal at
Ocean City
Treatment in West Ocean
City/Disposal at Ocean
City
Treatment and disposal by
land anolication near West
Ocean City
Capital
3,346,700
9,378,000
8,107,500
Operation Total
Capital and Present
Improvement Salvage Maintenance Worth
7,543,300 842,200 505,900 7,20C',000
6,882,900 1,603,9002 528,200 1,186,200 9,144,800
6,395,000 663,7033 397,700 1,878,300 8,544,300
427,000 1,190,400 4,1H],100
741,000 2,096,500 9,37?,000
757,600 1,678,100 9,023,000
are presented in the West Ocean City Facilities prepared by Georqe, Miles, and
Buhr issued in March 1982, revised in August 1982.
Cost of annual capital improvement for purchase of additional grinder pumps for new
development.
Cost of annual capital improvement for future interface valve and holding tank
construction for new development.
19
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Chapter III.
Comments and Responses
-------
-------
Draft BIS
Comments
Key Issues
Comments and
Resoonses Format
CHAPTER III. COMMENTS RECEIVEDONTHE DRAFT EIS AND EPA'S
RESPONSES
Throughout the preparation of the Environmental Impact Statement
(EIS), EPA has continuously sought participation from local,
reqional. State and Federal agencies; citizens; and interested
environmental groups. EPA has considered suggestions, criticisms,
and opinions from the public in documenting the need for wastewater
treatment facilities, in developing wastewater management
strategies, and in assessing potential impacts. EIS newsletters,
advertisements, and meetings with the public have been used to
ensure that all concerned parties were involved in the EIS
decision-making process.
In accordance with the National Environmental Policy Act and EPA
procedures for the preparation of Environmental Impact Statements,
the public as well as Federal, State and local agencies were
requested to comment on the Draft EIS from September 8, 1982
through November 10, 1982. In addition, oral testimony on the
Draft EIS was received at a Public Hearing held in West Ocean City
on October 27, 1982.
In total, EPA received written responses from 9 Federal agencies,
2 State agencies, 2 environmental groups, and 3 citizens. Oral
testimony at the Public Hearing was presented by representatives of
1 State agency, 13 environmental groups, and 4 citizens.
From EPA's perspective, all comments are helpful in formulating a
decision which has a sound basis. From all the comments received,
the following concerns are considered by EPA to be among the most
important:
o mechanisms to be used to ensure that development in
flood-prone areas and wetlands will actually be limited
if a sewer system is constructed
o the need to protect wetlands and the coastal bays from
sedimentation
o the potential impact of constructing a force main across
Sinepuxent Bay
o the feasibility of continued use of on-site systems
o the financial impact of the project on local residents.
The remainder of this chapter presents a summary of the comments
received on the Draft EIS and EPA's responses. The summary of
comments is presented first, and includes both a synopsis of
written comments, in the order in which they were received, and a
summary of the public hearing testimony. The full set of written
comment letters is Presented in Appendix B, while the full tran-
script of the public hearinq proceedings is available for inspec-
tion at the offices of the Worcester County Sanitary Commission.
Following the summary of comments, EPA's responses are provided to
the most prominent issues raised in the various comment letters.
20
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Synopsis of Written
Comments
Letter Number: 1
Organi zat ion/Individual; Frank Harrington
o Is in favor of the gravity sewer system.
o Notes that his property will be useless if sewer
service is not provided.
Response/
Addressed
on Page
Comment Noted
Letter Number; 2
Org a n i 2 a t i >yn/ Individual;
F. Bryan Gatch
Maryland State Clearing-
house
o Clearinghouse review of the Draft EIS has
begun.
Letter Number; 3
Organ izati3n"7lndividuali Risque w. Plummer
o Is in favor of the Facilities Plan's selected
alternative.
Comment Noteid
Comment Noted
Letter Number: 4
Organizatiqn7lndividual; Donald E. Einolf
o Is strongly in favor of sewer service for
Cape Isle of Wight.
Letter Number; 5
Organization/Individual:
George D. Bond
U.S. Department of
Transportation
Comment Notod
o No comments on the Draft EIS.
o Final EIS should mention continued coordination
during design and construction with State and
local highway officials.
Comment Not<=d
Page 55
Letter Number; 6.
Orgarii zatidri/Ind ividual;
Frank S. Lisella, Ph.D.
U.S. Department of Health
and Human Services,
Public Health Service
o The Final EIS should address the use of water-
saving devices to reduce per capi.a water
consumption.
Page 86
Letter Number; 7
Organization/Individual;
William E. Trieschman, Jr
U.S. Department of the
Army, Corps of Engineers
o The Draft EIS provides sufficient and adequate
information concerning floodplain related
matters..
o Permits; will be required pursuant to Section 10
of the Harbor and River Act of 1899 and Section
404 of the Clean Water Act.
o The Corps presently maintains a navigation
channel and a ietty project in the area; the
proposed West Ocean City project would not
adversely i"ioact these projects.
Comment Noted
Comment Noted
Comment Noted
21
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Response/
Addressed
on Page
Letter Number; 8
Orqanization/Individual:
Walter P. Pierson
Federal Emergency Manage-
ment Agency
The floodplain policies developed as part of
the EIS orocess represent a reasonable balance
between the mandates of the Construction Grants
Proaram and the Executive Order.
Essentially in agreement with the decision to
serve lots that were individually olatted Prior
to May 1977.
Relieve that the date of Directive GS-6 (January
1976) would be more reasonable as the date of
"existing need". RO 11988 should not he con-
strued to have a "grandfathering" provision.
The Final EIS should orovide specific details
on how the limitations on sewer service should
be implemented.
A funding agreement between EPA and the Sanitary
District should spell out implementation pro-
cedures to be performed by the Sanitary District.
Letter Number: 9
Organization/Individual:
Jane Benesch, Chairman
The Maryland Wetlands
Committee
o Concerned about the proposal to dredge/fill
wetlands ad-jacent to the Ocean City treatment
plant and also the impacts of nutrient loading
and sedimentation on aquatic vegetation.
o Question the need to expand the Ocean City
Treatment Plant.
Letter Number; 10
Organization/Individual:
Joyce N. Wood/Ruth O.
Rehfus, U.S. Department
of Commerce National
Oceanic and Atmospheric
Administration/National
Marine Fisheries Service
The selected plan would not result in signifi-
cant adverse impacts on marine resources or
habitat in the short-term.
The Final EIS should discuss the Sanitary
Commission's proposal to dredge and fill wet-
lands adjacent to the Ocean City sewage treat-
ment plant.
The relationship between the request to expand
the Ocean City plant and the connection with
the West Ocean City project should be clarified.
The Ocean City plant's current and potential
operating capacities should be defined. The
Final EIS should identify whether the West Ocean
City project is directly responsible for the
proposed expansion of the Ocean City plant and
its associated adverse environmental impacts.
Comnent Noted
Corment Noted
Page 37
Paae 77
Page 77
Page 41, 48
Pare 47
Comment noted
Page 48
Page 47
22
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o The Final EIS should address the biological
impacts of crossing Sinepuxent Bay with a sub-
merged sewaqe pipeline.
o Alternative attachment of the proposed pipeline
to the Route 50 bridqe should be considered.
Letter Number; 11
Organization/Individual:
Ilia Fehrer, Co-chairman
Worcester Environmental
Trust
o Concerned that West Ocean City residents will
have to pay 10.5% of the cost of expanding the
Ocean City plant.
o Questioned the need for the capacity proposed
for the Ocean City plant.
o Request clarification on the septic tank fail-
ure statistics which appeared in the Draft EIS.
o Question the statement that fLoodplains have
been historically attractive population centers.
o The potential for salt water intrusion and the
costs of providing a potable water supply for
West Ocean City should be examined.
o Figure III-:, of the Draft EIS showing property
lines as of 1976 could be misinterpreted to
illustrate developable property.
o The effects of rising sea levels encroaching
on low "upland areas" should be considered.
o Construction techniques should minimize runoff.
o A detailed study of the proposed route of the
force main LO transport West Ocean City's sewage
to Ocean Ci~y should be performed.
o The Carter-:*egier study of 1978 should be
clarified.
o The lack of major sources of air pollution in
Worcester County, specifically Berlin, should
be verified.
o Less costly alternatives to alleviate failing
septic tanks should be examined.
o The acreage requirements and potential impacts
of land application should be justified.
o The proposed seafood industrial park should not
be used to justify an increased demand for low
income housing. The water and sewer needs for
the proposed facility should be substantiated.
o Tidal as well as non-tidal wetlands should he
protected.
o Development of flood-prone areas platted orior
to 1977 should be limited.
o Construction in flood-nrone areas should adhere
to the Federal Flood Insurance Act adopted by
Worcester County in 1979. A larger county
enforcement staff may be required.
o Worcester County has no building code.
o The coastal bays should be protected from run-
off and secimentation. Sediment control
facilities should be required.
o Thft diameter of the proposed force main under
Sinepuxent Bay seems oversized.
Response/
Addressed
on Page
Page 45
Page 45
Comment Noted
Page 47
Page 43
Page 30
Page 54
Page 51
Page 30
Page 43
Pace 45
Page 48
Page 55
Page 36
Page 45
Page 51
Page 75
Page 75
Comment Noted
Comment Noted
Page 64
Page 45
23
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The Worcester County should revise its Compre-
hensive Plan to reflect the intent of Executive
Orders 11988 and 11990.
EPA. and Maryland's Environmental Health Admini-
stration should review the "referendum ballot"
sent to West Ocean City property owners by the
Worcester County Sanitary Commission.
Response/
Addressed
on Page
Page 77
Paoe 62
Letter Number; 1 2
Organization/Individual:
William P. Patterson
U.S. Department of the
Interior Office of
Environmental Project
Review
The Draft EIS provides a good discussion of
Federal floodplain and wetland policies and the
need for Corps of Engineers permits.
The restriction of sewer service to lots platted
prior to 1977 and the selection of treatment and
disposal at the Ocean City facility are environ-
mentally acceptable and consistent with EO 11988
and EO 11990.
The Final EIS should depict the Assateague
National Park System.
The fish processing plant proposed for the area
should be examined with regard to potential
impact on treatment facility plans and the
Assategue National Park.
Potential impacts on threatened and endangered
species should be discussed. If no impacts are
anticipated, a statement to that effect with
supporting evidence should be made.
Federal policies and regulations which would
influence development even if no Federal funds
were used to construct a sewage collection
system should be clarified.
The impacts of stormwater runoff and associated
toxic materials should be examined with regard
to wetland-dependent fish and wildlife resources,
The Final EIS should determine if additional
action is warranted.
The Department commends the efforts of the EIS
Coordination Committee to minimize development
in floodplains and wetlands while still address-
ing the need for sewer service in the West Ocean
area.
Comment Noted
Comment Noted
Page 3
Page 53
Pa^c 55
Page 51
Page 41
Comment Noted
24
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Letter Number: 13
Organization/IndivLdual:
o
o
Thomas J. Gola
U.S. Department of Hous-
inq and Urban Development
Provide more information on the Federal and
State quidance on development in flood-prone
areas, including the documentation and legal
basis. Define the term "buildinq lots which had
a sellinq capability prior to May 1977." Define
how the oolicv of limited development would be
implemented and its permanence assured.
Present, if possible, 1980 population and dwell-
inq unit estimates for individual subareas as
delineated by the Facilities Plan for the year
2000 estimates.
Substantiate the adequacy of fire protection,
police, ambulance service, and education to meet
the needs of the projected population.
Discuss the impact of population growth on solid
waste disposal facilities.
Discuss the adequacy of roads serving the sub-
divisions north of Route 50.
Response/
Addressed
On Page
Pages 30-54
and.
Page 77
Page 49
Page 56
Page 56
Paae 55
Letter Number: '..4
Organization/Individual;
Don L. Klima
Advisory Council on
Historic Preservation
o
Noted that the Maryland State Historic Preserva-
tion Officer [SHPO) has been consulted and that
EPA will comply with the National Historic
Preservation Act and the Advisory Council's
Regulations (36 CFR Part 800).
Have no substantive comments at this time.
Letter Number: 15
Organization/Individual:
F. Bryan Gatch
Maryland State Clearing-
house
The Maryland Department of Agriculture, Depart-
ment of Economic and Community Development,
Office of Environmental Programs, Department
of Transportation, University of Maryland Center
for Environmental and Estuarine Studies, and
Ocean City noted that the Draft EIS appears to
adequately cover their concerns.
The Maryland Department of State Planning sug-
gests West Ocean City's purchase of existing
capacity at the Ocean City treatment plant with
Ocean City taking the responsibility for the
cost of any future expansions.
State Planning also notes that certain State
Development Policies, coastal zone policies, and
Federal requirements would apply to development
in West Ocean City, regardless of the source of
funding for & sewer system.
Comment Noted
Comment Noted
Comment Noted
Pace 48
Comment Noted
L
25
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I Summary of
Public Hearing
I Testimony
Letter Number; 16
Organization/Individual;
Response/
Addressed
on Page
Earl S. Quancef Program
Administrator Construc-
tion Grants and Permits
Program Office of Environ-
mental Programs Maryland
Department of Health and
Mental Hygiene
The financial capability analysis contained in
the Draft EIS does not incorporate the use of
$800,000 of Failing Septic Tank Grant Funds now
being considered. However, the resulting change
in user charges would not significantly alter
the outcome of the analysis. The project would
still have a small margin of safety relative to
affordability and local officials should proceed
with caution. Public opinion should play a
maior role in the decision-making process on
affordability.
The EIS proposes various measures to mitigate
short and long-term adverse impacts associated
with this project. There are existing provisions
within the statutory framework of the Sanitary
District which would ensure implementation of
many of the proposed measures; however, there is
currently no active institutional mechanism by
which to enforce the guidance for limiting
sewer service in the 100-year flood plain and
for avoiding the sewering of wetland areas.
The Worcester County Sanitary Commission should
be required, as a condition of any future grant
action, to develop and institute adequate
measures to ensure that Federal and State guid-
ance on floodplain and wetlands be put into
practice. The Commission should be required,
as a minimum, to incorporate the guidance into
the County's 10-year Water and Sewer Plan and
to implement this guidance, and any other
measures necessary for the desired assurance,
prior to the date the proiect is advertized for
bidding.
Organization/Individual:
Anqelo Bianca
Construction Grants and
Permits Program, Maryland
Office of Environmental
Programs
The Facilities Plan for West Ocean City is
essentially complete with the exception of
sections dealing with environmental issues and
public participation.
Upon completion of the EIS process and accept-
ance by the Sanitary Commission and the public,
the Facilities Plan must oass a final detailed
review before the Sanitary Commission can apply
for a construction qrant.
Comment Noted
Page 77
Corjnent Noted
Comment Noted
26
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o Although the project is now slightly outside of
the Eundable range on the State's priority list,
the project may become eligible for funding
prior to September 30, 1983.
o The Draft BIS presents a fair analysis of the
primary and secondary environmental impacts
associated with constructing the project.
Organization/Indi vi du al; Tim Lindon
Arnold and Porter on
behalf of the Natural
Resources Defense Council,
Committee to Preserve
Assateague Island,
Federated Garden Clubs
of Maryland, Maryland
Wetlands Committee,
Audubon Naturalist Society,
Worcester Environmental
Trust, Maryland Conserva-
tion Council, Maryland
Wildlife Federation,
Sierra Club, Defenders of
wildlife, Environmental
Defense Fund, Environmental
Policy Center, and
Chesapeake Audubon Society.
o Support the proposals in the Draft EIS to solve
sewage problems while protecting environmentally
sensitive areas; hope that the proposals can be
implemented immediately without placing undue
financial burdens on local residents.
o Concur with the environmental constraints on
near service described in the Draft EIS; request
that the Final EIS contain specific plans to
implement these restrictions; note that actions
are required at the Federal, County, and local
levels to assure proper implementation.
o EPA should expressly condition its grant on
compliance with the restrictions contained in
the Draft EIS. The Sanitary Commission should
be required to file lot maps identifying all
lots which will be eligible for sewerage. Noted
the EPA has iir.posed similar conditions on Cape
May, New Jersey.
o Prior to receipt of an EPA grant, Worcester
County should amend its Comprehensive Plan, Sub-
division Regulations, and other County ordin-
ance to assure compliance with the grant condi-
tions. The Worcester County Sanitary Commission
(WCSC) should develop procedures and regulations
to assure day-to-day compliance with the grant
restrictions. WCSC should also revise its
plumbing code accordingly and require plumbing
permit applicants to secure affadavits
demonstrating that their property is eligible
for hookup under the grant restrictions.
o The Draft EIS does not address the need to ex-
pand the Ocean City treatment plant. The
Sanitary Commission has applied for a license to
fill 8.4 acres of wetlands adjacent to the
existing alant. This application is
Response
Addressed
on Page
Comment Noted
Comment Noted
Comment Noted
Page 77
Page 77
Page 77
Page 48
27
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o
inconsistent with the Coastal Zone Management
Plan. There is an alternative site immediately
to the north of the proposed site. The Final EIS
should assure that any expansion of the Ocean
City plant to treat West Ocean City sewage would
not cause destruction of highly productive
wetlands or filling of Assawoman Bay.
West Ocean City residents should not he required
to pay for more than their fair share for sewage
treatment at the Ocean City plant.
Response/
Addressed
g_n__P_a_ge__
Comment Noted
Organization/Individual:
Ilia Fehrer
Worcester Environmental
Trust
o Question statistics in the Draft EIS on septic
tank failures.
o Periodic septic tank maintenance as a cheaper
alternative should be explored.
o Question the statement that floodolains have
been historically attractive for population
centers.
o Question the need for almost doubling Ocean
City's wastewater treatment capacity.
o The cost of providing a potable public water
supply to West Ocean City should be examined.
o Figure 3-1 of the Draft EIS showing property
lines as of 1976 unrealistically reflects
developable properties.
o Concerned about the impact of runoff during
construction of sewer system and during
preparation of ground to build new homes and
streets.
o A detailed study of the route of the proposed
force main in Assawoman Bay is necessary.
o Conditions should be made part of the West Ocean
City wastewater treatment system.
o NoB-tidal as well as tidal wetlands should be
protected.
o Present agricultural zones should be perpetually
used as open space.
o Flood-prone areas platted prior to 1977 should
be allowed minimal developments and adhere to
conditions set forth in the Federal Flood
Insurance Act adopted by Worcester County in
1977.
o Coastal bays should be protected from runoff and
sedimentation.
o The diameter of the force main should be sized
to reflect the anticipated 1 mgd capacity.
o A supply of potable water should be guaranteed
to West Ocean City.
Page 43
Page 36
Page 30
Page 47
Page 54
Page 51
Page 43
Page 45
Page 77
Page 76
Comment Noted
Page 77
Page 43
Page 45
P age 5 4
Organization/Individual;
Boss Harrington
West Ocean City homeowner
o Has spent $10,000 in the past five years in an
effort to repair his failing septic system. The
system still overflows regularly.
Comment Noted
28
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Organization/Individual;
Vernon McCabe
West Ocean City resident
Response/
Addressed
on Page
o
Replacement of septic tank drainfields arid other
corrective measures should be considered as a
less costly option.
The seasonal test code for septic tank oermits
should be revised.
Revise population densities and future develop-
ment to accomnodate private system.
Page 36, 43
Comment Noted
Page 36
Organization/Individual:
Allen Sklar
West Ocean City resident
o The project will degrade the quality of life of
the area.
o On-site systems should be improved with the help
of the Health department.
o The Sanitary Commission letter to poll property
owners on whether they wish to proceed with the
project should be revised to reflect accurate
costs.
Page 64
Comment Noted
Page 62
Organization/Individual:
Bill.Metz
West Ocean City property
owner
o
Has owned property in West Ocean City for 10
years on which he has been unable to build.
o Believes that there are no simple solutions to
the area's problems and that a sewer system is
necessary.
Coinment Noted
Comment Hoted
29
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RESPONSES TO COMMENTS
Environmentally
Sensitive Lands
Regulatory Basis
for Mitigation
Much of the West Ocean City oroiect area is covered by environ-
mentally sensitive lands including floodolains, wetlands, and prime
agricultural lands. The area has a lenqthy history of failing
septic systems. At the same time, development pressures are strong
due to nearby Ocean City. The Ocean City area's main attractions
are the ocean and associated recreational facilities. Ocean City's
population has increased by 230 percent over the past decade.
Waterfront locations, although flood-prone, have been among the
most desirable in this resort community. Figure III-l depicts the
boundary of the 100-year floodplains in West Ocean City as defined
by the Federal Emergency Management Agency. Aoproximately 60
percent of West Ocean City's existing population resides in the
100-year floodplain. Consequently, much of the proposed collection
system must be located in the floodplain. One commentor suggested
that the effects of rising sea levels and the bay's encroachment on
present lowlands be considered. Although this larger issue is not
within the scope of the West Ocean City EIS, EPA has considered the
potential imoacts of flooding. Present and prospective property
owners should, however, maintain an awareness that our nation's
coastlines are dynamic and subject to change through time.
Protection of environmentally sensitive lands clearly falls within
the scope of the National Environmental Policy Act (NEPA), and the
regulations on NEPA implementation issued by the Council on
Environmental Quality (CEQ) and EPA. The NEPA regulations require
EPA to minimize adverse environmental impacts in these areas and to
issue a Record of Decision which describes methods of implementing
mitigation requirements, including grant conditions if appropriate.
However, specific details on the extent of "minimize" and the exact
mechanism for implementation are not described in the regulations.
These decisions are to be made on a case by case basis, with
consideration of pertinent factors such as environmental values,
community welfare, cost and available technology. The mitigation
measures proposed for the West Ocean City area outline detailed
guidance on the extent of development in floodplains and wetlands
which may be supported by a Federally funded sewer system.
Approximately 3000 persons or 60 percent of West Ocean City's
population now reside in the 100-year floodplain. If the flood-
plain were developed to its saturation potential in accordance with
allowed residential densities, the floodplain could ultimately
contain 36,800 persons. This 1000 percent increase could only
occur with the benefit of a centralized wastewater treatment
system. WCSC has requested EPA to provide Federal financial
assistance for such a system. In order to consider Federal
funding, EPA must also examine methods to minimize the loss of
environmental values through dramatic sewer-induced growth. The
Federal regulations, Executive Orders, and guidelines which
demonstrate EPA's mandate to do so are described below.
EPA's mandate to protect environmentally sensitive areas stems from
a number of sources, icluding;
I. The National Environmental Policy Act of 1969 (NEPA; 42 USC
4321) addresses the need to preserve environmentalfeatures from a
general, but far-reaching standpoint.
"it is the continuing responsibility of the Federal government
to use all practical means (to):
1. fulfill the responsibilities of each generation as trustee
of the environment for succeeding generations;
2. assure for all Americans safe, healthful, productive, and
30
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-SANITARY DISTRICT BOUNDARY
LEGEND
100-YEAR FLOOOPLAIN
Flood Hazard Areas
FIGURE III-
31
-------
5.
esthetically and culturally pleasing surroundings;
attain the widest ranqe of beneficial uses of the environ-
ment without degradation, risk to health or safety, or
other undesirable and unintended consequences;
preserve important historic, cultural, and natural aspects
of our national heritage, and maintain, wherever possible,
an environment which supoorts diversity, and variety of
individual choice;
achieve a balance between copulation and resource use
which will permit high standards of living and a wide
sharing of life's amenities; and..."
Consistent with our environmental mediation efforts on the West
Ocean City project, NEPA authorizes Federal agencies to prepare
Environmental Impact Statements and also to "...study, develop, and
describe appropriate alternatives to recommended courses of action
in any proposal which involves unresolved conflicts concerning
alternative uses of available resources...."
II. The Council on Environmental Quality (CEQ) Regulations
Implementing "the^Procedural Provisions" ofNEPA~ (40 CPRParts
1500-1508) were issued on November 29, 1978. The CEQ regulations
outline the Agency's procedural and decision-making requirements
for the EIS process. When an agency has prepared an EIS, the CEQ
Regulations require that a public Record of Decision be issued
which outlines effective and appropriate mitigation measures for
anticipated environmental imoacts.
"§ 1505.2 Record of decision in cases requiring environmental
impact statements.
At the time of its decision ($ 1506.10) or, if appropriate, its
recommendation to Congress, each agency shall prepare a concise
public record of decision. The record, which may be integrated
into any other record prepared by the agency, including that
required by OMB Circular A-95 (Revised), part I, sections 6 (c) and
(d), and part II, section 5(b)(4), shall:
(a) State what the decision was.
(b) Identify all alternatives considered by the agency in
reaching its decision, specifying the alternative or
alternatives which were considered to be environmentally
preferable. An agency may discuss preferences among
alternatives based on relevant factors including economic
and technical considerations and agency statutory mis-
sions. An agency shall identify and discuss all such
factors including any essential considerations of nation-
al policy which were balanced by the agency in making its
decision and state how those considerations entered into
its decision.
(c) State whether all practicable means to avoid or minimize
environmental harm from the alternative selected have
been adopted, and if not, why they were not. A monitor-
ing and enforcement program shall be adopted and
summarized where applicable for any mitigation.
§ 1505.3 Implementing the decision
32
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VII. EPA's Regulations _qn Jj.RP_A _Jmplementation {40 CFR Part 6)
issued on November 6, 1979. These regulations are heinq updated to
reflect the changes in the Construction Grants Program. A proposed
rule was recently published in the Fereral Reqister (January 7,
1983). Onlv minar substantive revisions have been made to the 1979
version. Part 6 clearly outlines the requirement to evaluate
imoacts and develop mitiqation measures concerninq floodplains,
wetlands, and orine aqricultural lands. Like CEQ's requlations on
NEPA implementation, EPA'S requlations require that a Record of
Decision be prepared following completion of a Final EIS and that
appropriate stecs be taken to ensure that the EIS recommendation be
carried out. Wcrdinq of the newly proposed rule is as follows.
"§ 6.510 Record of decision and identification of mitiqatinq
measures.
(a) Record of decision. When a final F)IS has been issued, the
responsible official shall prepare a record of decision in
accordance with 40 CFR 1505.2 prior: to the submission of an
application for qrant assistance. The record of decision
shall include identification of mitiqation measures derived
from the EIS process which are necessary to make the recom-
mended alternative environmentally acceptable.
(b) Specific mitigation measures. Prior to the approval of
qrant assistance, the responsible official must ensure that
effective mitigation measures identified in the PNSI, final
EIS, or record of decision are implemented by the qrantee.
This should be done by revising the facilities plan, initiat-
inq other steps to mitiqate adverse effects, or aqreeinq to
conditions in grants requiring actions to minimize effects.
Care should be exercised'if a condition is to be imnosed in
a grant document to assure that the applicant possesses the
authority to fulfill the conditions.
§ 6.511 Monitoring for compliance
(a) General. The responsible official shall ensure there is
adequate monitoring of mitigation measures and other qrant
conditions; which are identified in the FNSI, final RSEI, and
record of decision.
(b) Enforcement. The responsible official may consider taking the
following actions consistent with 40 CFR 35.965 and 30.430 if
the qrantee fails to comply with qrant conditions:
1. Terminating or annulling the grant;
2. Disallowing project costs related to noncompliance;
3. Withholdinq project payments;
4. Finding the qrantee to be nonresponsible or ineliqible
for future Federal assistance or for approval for future
contract awards under EPA qrants;
5. Seeking an injunction against the grantee; or
6. Instituting such other administrative or judicial action
as may be legally available and appropriate."
VIII. EPA's Interim Final regulations for the Construction Grants
Program (40 CFR part 35, Subpart I) issued on May 12, 1982 contain
35
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The West Ocean
City Mitigation
Process
sliqhtlv different lanquaqe on protection of environmentally
sensitive areas than that of the 1978 version (Subpart E) . With
regard to flood-nrone areas, Subpart I lists "The cost of treatment
works that would provide capacity for new habitations or other
establishments to be located on environmentally sensitive land such
as wetlands or floodplains" as an unallowable cost. The regula-
tions state that the proiect must comply with EPA's Implementation
of Procedures on the National Environmental Policy Act (40 CFR Part
61. The 1978 Construction Grant Regulations (Subpart E) stated
that:
"The collection system conforms with an approved WQM plan,
other environmental laws in accordance with § 35.925-14,
Executive Orders on Wetlands and Floodplains and Agency
policy in wetlands and agricultural land? and
(e) The system would not provide capacity for new
habitations or other establishments to be locat-
ed on environmentally sensitive land such as
wetlands, floodplains, or prime agricultural
lands. Appropriate and effective grant condi-
tions (e.g. restricting sewer hook-up) should
be used where necessary to protect these resources
from new development."
The main task of the RIS process was to develop a method of
wastewater service for West Ocean City which was environmentally
sound and economically viable. Efforts to develop a system which
was consistent with environmental goals began in 1979 when EPA and
the State of Maryland first agreed to take a second look at the
West Ocean City proiect area. As stated earlier, most of the
existing need to replace failing septic systems with sewer service
and centralized treatment is already located within the 100-year
floodplain. Unfortunately, many other landowners have also
purchased lots in the floodolain; waterfront locations are very
attractive locations in this resort community. Most landowners who
attempted to build on their lots after 1976 were unable to do so,
even though their neighbors had. This was principally because
their lots would no longer pass percolation tests required for
septic tank permits. In 1976, the State's Directive Policy GS-6
became effective in Worcester County, requiring seasonal testing in
high groundwater areas; groundwater levels in West Ocean City reach
within ten inches of the surface. The Cape Isle of Wight
development in the northwestern corner of West Ocean City provides
a good example of the problem. Cape Isle of Wight was initiated in
the mid 1950's. Platted lots within this subdivision were pur-
chased rapidly. This development contains approximately 650 lots.
Approximately 210 are currently occupied. From 1976 to 1979,
approximately 150 individuals requested building permits on
remaining lots. Only 2 permits were granted; the remaining lots
failed to pass the seasonal percolation testing required to obtain
a septic tank permit. In response to a public meeting held in May
1982, EPA received 41 letters from property owners in Cape Isle of
Wight who expressed their preference for the centralized wastewater
treatment system required to make their properties developable.
Because lot sizes in Cape Isle of Wight range only from 0.25 to 0.5
acres, acceptable alternative technologies to either replace
failing systems or support new residences are very limited.
Provision of sewer service and centralized treatment to existing
homes which create water quality problems due to failing septic
systems is consistent with the goals of the Clean Water Act and
Construction Grants Program, even though those homes may be located
36
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in the floodplain. However, the existing problems cannot be solved
at the expense of long-term environmental values. EPA is required
to minimize adverse impacts on environmentally sensitive areas to
the extent possible, using all practicable means. Approximately
3000 persons or 60 oercent of West Ocean City's existing population
reside in the floodplain. If the floodplain were developed to its
saturation potential in accordance with planned residential
densities, the floodplain could contain 36,800 persons. This 1000
percent increase could only occur with the benefit of centralized
wastewater treatment. EPA cannot, within the spirit and intent of
Executive Order (3O) 11988, provide Federal funds to support such
large-scale sewer-induced growth in the floodplain. WCSC recog-
nized that EPA would require limitations on floodplain development
if Federal funds were used to construct e. sewer system. AS a
result, the Facilities Plan prepared by WCSC examined two
scenarios: (1) a Federally funded system which incorporated
limitations on development in floodplains and wetlands in order to
comply with executive Orders 11988 and 11990; and (2) a locally
funded system in which development would not be limited to comply
with the Executive Orders.
In December 1979, EPA in consultation with the State of Maryland
issued guidance on how EO 11988 would be interpreted for the West
Ocean City project. The guidance incorporated EO 11988*s intent to
minimize economic: and safety risks, as well as to preserve the
natural benefits of environmentally sensitive areas. The guidance
stated that EPA would evaluate lands platted in West Ocean City
prior to the May 1977 date of issuance of EO 11988 for conformance
with other EPA construction grant regulations and Executive Orders.
If it were not otherwise inconsistent, centralized treatment could
be Planned for these lands, even though they were contained in the
100-year floodplain. A platted lot was defined as a recorded
parcel of land "hat has been subdivided into lots that have a
sellina capability. The subdivision was restricted by local zoning
and required conformity with the Maryland directive Policy GS-6 to
acquire a buildira permit. This meant that sewer service could not
be Planned for individual lots which had been created by sub-
division after Mav 1977.
This was based on the fair and reasonable assumption that proper-
ties platted prior to that date were purchased bv individuals who
could have obtained building permits prior to January 1976, but
were now restricted by more stringent septic system regulations.
Properties platted after January 1976 were created in a more
speculative nature since the likelihood of obtaining septic system
and building permits was small. Development of these properties
would most likely only occur with the benefit of centralized
wastewater treatment; no potential to build existed at the time of
platting. EPA chose to use May 1977 as the limit for eligibility
of sewer service rather than January 1976. EPA does not intend to
imply the EO 11988 contains a "grandfather clause." The May 1977
date was chosen to reflect the time when both EO 11988 required EPA
to limit support of floodplain development and development in West
Ocean City was limited by septic system requirements.
In March 19R1, the State, with direction from EPA, issued addition-
al guidance on how environmentally sensitive areas in West Ocean
City would have to be protected from sewer-induced development if
Federal funding was desired. The guidance affirmed that sewer
service could only be extended to undeveloped lots in the flood-
plain if they were platted prior to Mav 1977. In addition, the
sewage capacity for each undeveloped lot would be limited to that
required for one dwelling unit. This would allow the individual
37
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Key Draft BIS
(Mitigation
I Comments
property owner to build, but would prevent the large-scale develop-
ment that future subdivisions and multiple connections would allow.
This ensured that EPA had taken all practicable steps to minimize
floodplain development to the extent possible, as required by
E011988, without penalizing the individual property owner and the
welfare of the community.
The March 1981 guidance also addressed the issue of wetlands
protection, as required by Executive Order 11990. The guidance
stated that no wastewater service could be planned for West Ocean
City's wetlands. There is no existing need for wastewater service
in wetland areas to alleviate water quality problems. Any sewer
service to these areas would be solely to promote new development.
To promote new development in these areas would be totally
inconsistent with the spirit and intent of Executive Order 11990,
as well as other Federal and State policies concerning wetlands.
The March 1981 guidance also considered EPA's Policy to Preserve
Prime Agricultural Lands, The guidance stated that no sewer
service should be planned for such lands zoned for agricultural
use. This is consistent with Worcester County's policy to
discourage development of agricultural lands and supported by the
County zoning Ordinance.
Several comments received on the West Ocean City Draft EIS
addressed the floodplains/wetlands issue bv:
1. Noting that our position was consistent with the intent of
Executive Orders 11988 and 11990;
2. Requesting that detailed mitigation measures and mechanisms
for their implementation appear in the Final EIS; and/or
3. Requesting that EPA condition the grant or take other
measures to ensure mitigation of environmental impacts.
Relevant quotations from the comment letters are cited below.
Earl S. Quance, Construction Grants Program Administrator
Office of Environmental Programs
Maryland Department of Health and Mental Hygiene
"The EIS Proposes various measures to mitigate short and long-term
adverse impacts associated with this project. There are existing
provisions within the statutory framework of the Sanitary District
which would ensure implementation of many of the Proposed measures;
however, there is currently no active institutional mechanise by
which to enforce the guidance for limiting sewer service in the
100-year floodplain and for avoiding the sewering of wetland areas.
Consequently, we recommend the Worcester County Sanitary Commission
be required, as a condition of any future grant action, to develop
and institute adequate measures to ensure that Federal and State
guidance on floodplain and wetlands be put into practice. We
further recommend the Commission be required, as a minimum, to
incorooorate the quidance into the County's 10-vear Water and Sewer
Plan and to implement this guidance, and any other measures
necessary for the desired assurance, prior to the date the oroiect
is advertized fir bidding."
Walter P. Pierson, Chief
Natural and Technoloqical Hazards Division
Federal Emergency Management Agency - Region III
38
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"FEMA has always recognized that EPA in implementing the Executive
Order is not released from its obliqation to address water
pollution problems in floodplain areas. The policies developed
over the last several years appear to us; to constitute a very
reasonable approach to balancing the mandate of the Construction
Grants Program anc the Executive Order.
In previous correspndence (December 28, 1979) we indicated that we
were essentially in agreement with the decision to limit service to
those lots that were individually Platted prior to May 1977. While
we believe the 3ate of Directive GS-f (Janaury 1976) would have
been a more appropriate date, since it can reasonably be argued
that as of that date "existing need" was recognized, the actual
difference in the number of lots to which service would be avail-
able is probably inconsequential. Again, however, we wish to point
out that there is no "grandfathering: provision in the Executive
Order as could be inferred from EPA's use of May 1977, the date of
the Order's issuance, as a cut-off date for sewer service.
We believe it essential that the Final EIS detail how the
limitations on service will be implemented. We believe the
limitations should be spelled out in the funding agreement between
EPA and the Sanitary District and the agreement should specify that
the Sanitary District, based on the agreement, will deny permits
except on the designated lots."
William P. Patterson
U.S. Department of the Interior
Office of Environmental Project Review
"This DEIS was written to concentrate on the issues of user
affordability and primary and secondary impacts on floodplains,
wetlands, and prime agricultural lands. The statement also
provides a qocd discussion of federal floodplain and wetland
policies and the need for required Corns of Engineers Permits for
this project.
This Department oelieves that the restriction of sewer service to
lots platted prior to 1977 and the selection of treatment and
disposal at the Ocean City facility are environmentally acceptable
and consistent with Executive Orders 11988 and 11990...
this Department commends the efforts of the EIS Coordination
Committee to minimize development in floodplains and wetlands while
still addressing the need for sewer service in the West Ocean City
area."
39
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Timothy J. Lindon of Arnold and Porter, representinq;
The Committee to Preserve Assateaque Island
Natural Resources Defense Council
Chesapeake Bay Foundation
The Federated Garden Clubs of Maryland
Maryland Wetlands Committee
National Parks and Conservation Association
Maryland wi.ldlands Committee
Audubon Naturalists Society
Worcester Environmental Protection Fund
Worcester Environmental Trust
Maryland Conservation Council
Maryland Wildlife Federation
Sierra Club
Defenders of Wildlife
Environmental Defense Fund
Environmental Policy Center
Chesapeake Audubon Society
"Therefore, as proposed in the DEIS, sewer service will be limited
to existinq structures, and to those undeveloped lots which were
platted as buildinq lots prior to May 1977. Sewer service capacity
for undeveloped lots Platted prior to May 1977 will be limited to
th?.^ required for one equivalent dwelling unit. No hookups will be
permitted in wetlands or in prime aqricultural zones.
While we support each of these restrictions, which are mandated by
Federal and State law, we are concerned that the DEIS does not in-
clude anv ulans for assuring that development will be limited to
the areas noted above. If the final EIS does not contain specific
plans to implement these restrictions, it will be clearly deficient
and the proiect will be ineliqible for Federal and State fundinq.
Actions at the Federal, County, and local levels are required to
assure proper implementation of the provisions necessary to
protect environmentally sensitive areas.
thirst, it is essential that the Environmental Protection Aqency
(EPA) expressly condition it qrant on compliance with the
restrictions contained in the DEIS. We Propose that the Worcester
County Sanitary Commission (WCSC) be required to file lot maps
identifyinq all lots which will be eliqible for seweraqe and the
EPA condition its qrant on restricting hookups to those areas so
that the extent and location of development will be effectively
fixed in advance. EPA has imposed similar qrant conditions
restricting hookups in environmentally sensitive floodplain areas
in Cape May, New Jersey.
Second, prior to receipt of the EPA qrant, Worcester County should
amend its Comprehensive Plan, Subdivision Regulations, and, if
necessary, other County ordinances to assure compliance with the
grant conditions. Amendment of the sections of these plans and
regulations which effect development in environmentally sensitive
areas is essential if property owners are to receive adequate
notice of environmental restrictions on development of their
property.
Third, the WCSC will need to develop procedures and regulations for
assurinq day-to-day compliance with the grant restrictions. As
stated above, the WCSC should prepare and file with EPA lot maps
identifying West Ocean City properties which will be eligible for
sewerage. These maps will serve as a basis for grantinq or denying
plumbing permits. In order to provide better notice to property
owners, the Sanitary Commission 'should consider amending its
40
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Wetlands
Identification
Wetland Impacts
plumbinq code to include these restrictions. In additioi,
applicants; for plumbing permits should be required to execute ai
affidavit stating that their property is eliqible for hookup undsr
the grant restrictions.
while we cecognize that all of the measures necessary to iroplemerr.
the restrictions to protect environmentally sensitive areas canno :
be implemented immediately, it is essential that implementation
plans, including the imposition of EPA grant conditions, b:
discussed in the Final EIS. Otherwise, the proposals contained i i
the DEIS, which we strongly support, may be transformed into empt/
and unenforceable promises."
Ilia Fehrer, Co-chairman
Worcester Environmental Trust
"We request that certain conditions be made part of the grant for
the West Ocean City Wastewater Treatment Facilities in order to
protect environmentally sensitive areas:
1. Non-tidal as well as tidal wetlands must be preserved.
2. Preseit agriculturally zoned lands should not be allowed
greater density (no zoning changes unless to downgrade).
3. Flood prone areas platted prior to 1977 should be allowed
only minimal development and structures should adhere to
conditions set forth in the Federal Flood Insurance Act
adopted by Worcester County in 1979. This may require a
larger county enforcement staff. The county has no buildinq
code.
4. Protection of the coastal bays from runoff and sedimentation
should be incorporated as a grant condition. Water quality of
our coastal bays was a ma-jor reason for justifying the sewer Lnq
of the West Ocean City area. Installation and maintenance o:
sediment control facilities should be made a condition of thi?
project.
The Fish and wildlife Service of the U.S. Department of :.he
Interior is in the process of rnaopinq wetlands throughout the
United States as part of the National Wetlands Inventory (Ntfl)
Program. Since the West Ocean City Draft EIS was issued, EPA nas
obtained preliminary NWI maps for the West Ocean City area. Fiqjre
III-2 deoicts tidal (estuarine) wetlands and non-tidal swamas,
boqs, and fresh water marshes (palustrine) as classified by the
U.S. Pish and Wildlife Service.
In the management of water resources, increasing attention is being
paid to the effects of non-point sources of pollution. As opposed
to direct discharges from municipal and industrial facilities,
non-point sources can originate through an entire watershed and
enter a waterway along its entire shoreline. The quantity and
quality of non-point source pollutant loads are highly variable.
Controlling factors include the land use of the watershed, the
lenqth and intensity of individual storms, weather conditions
preceding storm events, and other factors. Non-point pollution was
examined for the -Jest Ocean City project because it is known that
changes :.n land use (such as those caused by sewer-induced growth)
can produce chano^s in the quantity and quality of storm runoff.
General knowledge available on non-ooint source pollution indicates
that agricultural land contributes greater quantities of nutrients
due to fertilizer use, while urban areas and highways contribute
oil and chemicals deposited by traffic. The West Ocean City Draft
41
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SHBPUXENT
SAMTARY DISTRICT BOUNDARY
LEGEND
^] ESTUARINE
Fvl PALUSTHINE
Wetlands
FIGURE 111-2
42
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Erosion/
Sedimentation
Septic System
Failures
EIS contained a detailed comparison of non-point source pollutant
loads from estimates of the existing land use and that projected
for the year 2000. Published data which could be reasonably
applied to ~he West Ocean City area ware collected by Cerco et al
(1978) during 1976 and 1977 from EI series of small watersheds
occupied by single land uses typical of Assawoman Bay, Isle of
Wight Bay, and Sinepuxent Bay. The Cerco study provided
accumulation rate factors for three pollutant types (total
phosphorus, total nitrogen, and biochemical oxygen demand). One
comment received on the Draft EIS requested that the analysis of
non-point source pollutants be*carried further to include estimates
of oil and chemicals in runoff. Unfortunately, no accumulation
rate factors which could reasonably apply to the West Ocean Cit\
area are available. Therefore, it is not possible to calculate the
existing and future projected quantities of chemicals contained ir
runoff or "heir probable affects on wetlands. However, it if
unlikely that increased residential development in West Ocean City
will cause major changes in the existing conditions. Route 50,
which bisects West Ocean City, is a major highway carrying seasona?
visitors to Ocean City. Route 50 probably comprises the greatest.
source of traffic related non-point source pollution in West Ocean
City. Given the projected increase in Ocean City's population over
the next 20 years, it is Ikely that this will continue, independent;
of whether the West Ocean City sewage collection system if;
constructed.
Worcester County adopted an ordinance to control erosion and
sedimentation in March 1971 which would apply to any sewer system
constructed in West Ocean City due to the large amount o":
excavation required. The County requires a sediment and erosion
control plan to be submitted to the Worcester Soil Conservation
district for any construction project that disturbs at least 300
cubic yards of material. The plan must comply with State
specifications on sediment and erosion control and be approved bv
the County Sediment and Erosion Control Officer. A one-year permi:
is issued after the Sediment Control Officer reports the
acceptability of the plan to the Soil Conservation Distric:
supervisors. The permit is issued under a fee system providing
funds to administer the program. The County performs on-sit?
inspections as needed and forwards reports to the Soil Conservation
District to insure that all work Is being performed according to
the approved plan (Bruce Nichols, USDA-Soil Conservation Service,
1982).
As stated in the Draft EIS, 73% of the land in West Ocean City is
unsuitable for conventional on-lot systems due to the presence of a
high or seasonally high water table; 11% of the land has slight
limitations and could accommodate only low-density housing
(USDA-Soil Conservation Service 1973). Approximately 15% of the
land in West Ocean City consists of Made Land for which septic
system use is severely limited due to both soil composition and the
depth to qroundwater. Most of the area's existing housing is
located on soils that are unsuitable for on-site systems.
In 1976, the Worcester County Health Department adopted the State's
Directive Policy GS-6 which required seasonal percolation testing
in areas krown to have a high groundwater table. CS-6 has severely
limited new construction in West Ocean City. Two observation wells
monitored Dy the County Health Department during the first six
months of 1979 showed groundwater depths to be shallower than 10
inches and not more than 30 inches. The Health Department
concluded that under these conditions it is unlikely that a
conventional septic tank system could function properly throughout
the year. The impact of a seasonally high water table has
43
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Dn-Site
Liter-natives
>llection
lystem
increased as more homes in West Ocean City have been occupied on a
year-round basis.
Unfortunately, most of the existing homes were constructed prior to
the adoption of GS-6. Existinq housing densities in some areas
greatly exceed current requirements for adequate renovation of
septic tank effluent. Many of the lots in the area were surveyed
and recorded prior to the existence of Health Department Sub-
division Regulations. Health Department records have noted that
as of December 1980, 732 or 54% out of a total of 1348 on-site
systems in West Ocean City has failed. Since then, 16 new failures
were recorded and 16 new homes were built. (See Maugans 1979,
1980, and 1982 in Appendix D).
EPA has encouraged the use of on-site systems with improved
maintenance as an alternative to sewer systems in rural areas.
Construction Grants have been awarded for on-site rehabilitation
through EPA's Program Requirements Memorandum 79-8 on Small Waste-
water Systems. The Facilities Plan and the Draft EIS evaluated the
status of on-site systems in West Ocean City to determine whether
their long-term use was a feasible alternative. However, the
combined lack of suitable soils, high water table and high density
of existing housing raise serious doubts as to the potential
long-term success of on-site systems in West Ocean City. The
options available to repair already known failures are severely
limited by the fact that many lots on which homes are built are
smaller than 0.25 acres. The presence of a seasonally high water
table increases the potential public health hazard posed by
surfacing of poorly treated septic tank effluent or contamination
of the private wells used for water supply. EPA concurs with the
Worcester County Health Department's conclusion that conventional
septic systems are not feasible for use in West Ocean City on a
year-round basis. However, greater efforts should be made to
ensure that the area's on-site systems receive appropriate
maintenance and repair.
WCSC has chosen gravity sewers over pressure and vacuum sewers as
the preferred method of sewage collection for West Ocean City. The
deeper excavation required for gravity sewers (3 to 15 feet) and
the shallow level of groundwater (less than 1 to 3 feet) will
necessitate extensive dewatering during construction. Prior to
construction, WCSC must prepare an erosion/sedimentation control
plan for submission to and approval by the County Sediment Control
Officer and the Soil Conservation district supervisors. Sediment
control measures should be tailored to minimize the transport of
sediment to wetlands and surface waters. Sedimentation basins
should be constructed and maintained until a cover is fully
reestablished on the area disturbed during construction.
Figure II-2 illustrates the proposed alignment for the gravity
sewer system as presented in the Draft EIS. In an effort to reduce
the local share of costs, WCSC has examined the financial benefit
of eliminating approximately 5000 feet of sewer line from the
proposed alignment for the gravity sewer system. The segments of
sewer line under consideration are ineligible for Federal funding
since they would not serve areas in which two-thirds of the
wastewater flow would be contributed by residences in place as of
1972. The segments being considered for elimination include
portions of the following streets:
44
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r
Land Application
Conveyance
Route/Force
Main
Bonita Drive
Center Drive
Kent Road
Keyser Point Road
Lake Avenue
Marlowe Road
North Harbor Road
Ridge Avenue
Tudor Road
Unnamed Street
between Bay Shore Drive
and Riggins Road
Waltham Road
Windsor
Fiqure III-.3 illustrates the exact location of sewer segments under
consideration. WCSC estimates that eliminating the 5000 feet of
line would reduce the local share of costs by $165,500 and wou_d
reduce the front foot assessment by $.14/ft or our annual savings
of S14 for a 100 foot lot. WCSC Plans to delay its final decision
on whether to eliminate these lines until actual construction bi^s
are received.
The Facilities Planners examined potential land application sitas
within a Eive mile radius of West Ocean City. This distance was
estimated as the maximum distance over which effluent could be
transmitted at a reasonable cost. The land area required for
effluent explication was estimated to be 280 acres, based on spray
irrigation over 39 weeks at a rate of 1.5 inches per week. This
did not include the land required for buffer zones. Buffer zone
requirements were calculated to separate the spray irrigation site
by 500 feet from habitation and by 200 feet from property lines,
waterways and roads. A group of parcels near the confluence of
Aver and Trappe Creeks was selected as the most likely spray
irrigation site. These parcels were not contiguous and also
adjoined streams. The total acreage requirement for applicaticn,
buffer, storage, and treatment was calculated to be 510 acres. An
on-site evaluation by the Division of Residential Sanitation of the
Maryland Department of Health and Mental Hygiene showed that the
sites were not usable. Hydrogeological testing showed that
groundwater level was between 8 and 22 inches of the surface. 'j'he
State's land application guidelines recommend at least 2 feet to
seasonally high water table in that portion of the State to ensure
adequate wastewater renovation. The height of the qroundwater
table at the proposed sites could have caused groundwater
contamination if land application were performed.
The Draft BIS stated that for public health reasons, certain food
crops are not recommended to be grown in conjunction with land
application of wastewater. The Process Design Manual for L;ind
Treatment of Municipal Wastewater (SPA 1981) notes that wastewa:er
should not be used to irrigate crops that are eaten raw because of
potential transmission of parasites and other pathogens. Land
application systems in the United States are usually used for
fiber, feed, fodder, and processed grain crops. Note that separate
criteria apply to the land application of sewage sludge as a metnod
of disposal and soil conditioning.
Sewage collected in West Ocean City would be transported to Ocean
City for treatment and disposal by means of a pumping station near
the intersection of Golf Course Road and Route 50 and a 16 inch
force main under Sinepaxent Bay. The fact that the Route 50 bridge
to Ocean City is a drawbridge under frequent use eliminates
possible attachment of the force main to the bridge as an
alternative. Concern was expressed of the size of the force rrain
to be used. Upon leaving the pumping station in West Ocean City,
sewage would have to traverse 16,200 linear feet of force n.ain
before reaching the Ocean City collection system at 15th Street.
On the basis of professional engineering judgement, the Facilities
45
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LEGEND
GRAVITY SEWER
-• FORCE MAIN
• FVKff> STATION CPS)
4 LIFT STATION (LS)
®®«x» ELIMINATED SEGMENT
GRAVITY SEWER SYSTEM
SHOWING SEGMENTS
BEING CONSIDERED FOR ELIMINATION
FIGURE IH-3
46
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Ocean City
Treatment Plant
Expansion
Planners calculated that a 16 inch diameter was required in order
to ensure adequate transport since no intermediate pumpinq stations
would provide an additional surge. Once detailed designs for the
project are proposed, the size and location of the force main,
alonq with other project components, will receive a thorough
evaluation. In order for construction of the force main tc
proceed, permits must be received from the U.S. Army Corps of
Engineers as required under Section 10 of the River and Harbor Act
of 1899 and also under Section 404 of the Clean Water Act. At thai.
time, the force main will be reviewed for less environmentally
damaging construction and design and its overall potential to
adversely affect aquatic resources. Any permits subsequent!''
issued would require mitigation measures to reduce or eliminate
impacts on aquatic biota. Some of the possible mitigation measures
include th2 use of special construction techniques to minimize
sediment transport and relocation of any shellfish beds identifier!
alonq the force main route.
Several commentors questioned WCSC's plans to expand the Ocean City
treatment plant and the relationship of the proposed expansion to
the West Ocean City project. The Ocean City treatment plant was
recently expanded to a design capacity of 12 mgd with peak flow
capability of 18 mgd. Average flows through the plant during the
peak months of July and August 1982 were 8.59 mgd and 8.39 mgd,
respectively (Connell 1982). The presence of at least 3 mgd cf
unused capacity during peak summer months indicates that plart
expansion is not an immediate need as would be the case if tre
Ocean City plant were hydraulically overloaded. The West Oces.n
City Sanitary District is expected to contribute a wastewater flow
of 1 mgd by the year 2000. initial flows are expected to be in the
range of 350,000 gallons per day. West Ocean city's initial
contribution would clearly not cciuse the Ocean City plant to
require expansion. If the year 200C projected flow of 1 mgd from
West Ocean City were sent to the Ocean City plant at the system's
startup in 1983, almost 2 mgd of reserve capacity would remain for
growth in Ocean City. The Sanitary Commission's plans to expand
the Ocean city plant stem from the strong committment of Ocean Ci:y
and Worcester County to develop Ocean City to its full economic
potential. The North Central Ocean Basin Facilities Plan (1977)
assumed that Ocean City's population would increase at approxi-
mately 3.5% oer year, producing a maximum wastewater flow of 20.5
mgd in the year 2000 from a peak seasonal population of 205,000.
This projection was based on a 1973 study by Morton and Hoffman and
Company, Inc. on projected year-round and seasonal population in
Worcester County under alternative development patterns over the
period 19"'2-1990. Population projections for the Ocean City plant
were not revised as part of the West Ocean City EIS. No Federal
funds are under consideration for the Ocean City treatment plant at
this time.,
As stated earlier, EPA decided ir 1979 not to endorse the NCOB
Facilities Plan in its original form because of serious environ-
mental concerns. Federal financial assistance for expansion of t.he
Ocean City treatment plant is not under consideration at this time,
either as a separate grant action or as part of the West Ocean City
collection and conveyance system. Considering the recent changes
in the Construction Grants Program regulations (40 CFR part ;!5,
Subpart I), it is unlikely that expansion of the Ocean C:.ty
treatment plant will be eligible for funding in 1985. Subpart I
requires that grants for sewage treatment plants be based on :he
capacity necessary to serve the existing population? any additional
costs to provide reserve capacity for future growth must be borne
by the grant applicant. In addition, Subpart I cites the cost of
L
47
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Dredqe/Fill
Request for
|Ocean City
Expansion
Carter-Reqier
Study
treatment works that would provide capacity for new development on
environmentally sensitive lands (such as wetlands or floodplains)
as unallowable for Construction Grants funding.
WCSC's Facilities Plan for West Ocean City assumes that the 20.5
mgd of year 2000 treatment capacity will still be required for
Ocean City. West Ocean City wastewater flows were not contained in
the NCOS Facilities Plan's flow projections for the Ocean City
treatment plant. Therefore, WCSC increased the year 2000
wastewater flow to the Ocean City plant by 1.0 mgd, yielding a
total treatment capacity requirement of 21.5 mgd. WCSC projected
that the existing 12.0 mgd treatment plant could accommodate the
combined 1985 flows of 11.5 mgd from Ocean City and 0.49 mgd from
West Ocean City. At that time, however, it would become necessary
to expand the Ocean City treatment plant by 9.5 mgd. The
Facilities Plan assumed that West Ocean City would pay a percentage
equal to 1.0 mgd/9.5 mgd or 10.5% of the capital cost of the 9.5
mqd expansion. West Ocean City would also assume a proportionate
share of operation and maintenance costs for the Ocean City plant.
It was suggested that West Ocean City purchase existing capacity at
the Ocean City plant and that Ocean Citv bear the entire cost of
any future expansion. Such an arrangement would be at the dis-
cretion of the Worcester County Sanitary Commission, as owner and
operator of the Ocean City treatment facilities. The purchase of
existing capacity would not be eligible for funding through EPA's
Construction Grants Program since no new construction would be
involved. EPA grant funds have already been used to expand the
Ocean Citv plant to its present capacity of 11 mgd.
The Worcester County Sanitary District had submitted a permit
application to create land by filling existing wetlands to
accommodate expansion of the Ocean City sewage treatment Plant at
some time in the future (reference Public Notice NABOP-F/S
83-0102). Federal financial assistance to promote expansion of the
Ocean City plant is not under consideration hy EPA at this time,
either as a separate grant action or as part of the West Ocean City
collection and conveyance system. The oroposed action in Ocean
City involves the dredqing of 7.4 acres of shallow water hatitat to
enable filling of an adjacent 8.5-acre vegetated area adjacent to
the existing treatment plant.
The performance of any dredqe/fill activity requires the applicant
to secure a Section 404/10 permit from the U.S. Army Corps of
Enqineers. The permit request is evaluated by the Army Corps of
Engineers and other cooperating aqencies. In this case, EPA, the
U.S. Fish and Wildlife Service, the National Marine Fisheries, as
well as the Maryland Department of Natural Resources comprised the
commenting 'board'. Permit authorization is continqent on the
aqencies' consideration of the project justification, the potential
to adversely impact environmental resources, and the need for the
activity. The Worcester County Sanitary District permit
application has been subjected to this review, and, due to the
unanimous recommendation of permit denial bv EPA, F&WS and NMFS,
their application was withdrawn on February 26, 1983.
The Carter-Reqier Studv war. a special study released by the
Chesapeake Bay Institute of Johns Hopkins University as a physical
assessment of the Maryland coastal waters to receive wastewater.
The purpose of the studv was to identify and rank potential ocean
outfall corridors alonq the Maryland seacoast for the disposal of
approximately 30 mqd of sewaqe effluent. Pour possible outfall
routes were compared with respect to potential impact on the
area's recreational and aquatic life resources. Criteria for
comparison of the four routes included:
-------
Pooulation
Projections
1. The potential for effluent trapping in Isle of Wight and
Sinepuxent Bays via the Ocean City inlet;
2. The potential for interaction with the Ocean City treatment
plant's existing outfall/diffuser at 64th Street; and
3. The availability of near-field currents, deep water, etc. to
dilute sewage effluent.
Field studies were performed during July and August 1977 at thre<;
offshore locations. Currents, temperatures, and salinities wer-j
measured to compare the uniformity of nearshore waters north an;3
south of the Ocean City inlet. Far-field dilutions were measured
by pumping tracer dye through Ocean City's existing outfall for IT
days. Turbulent diffusion data were obtained by releasing single
slugs of tracer dye through the existing outfall and at two
locations south of Ocean City Inlet.
In 1976, the Chesapeake Bay Institute released results of a fielrl
study which focused on the effects of the Ocean City outfall
(Carter 1976). At that time, the Ocean City outfall was being useS
to discharge a peak summertime flow of 7 mgd of primary-treated
sewage. Since that time, the Ocean City plant has been upgraded t:>
secondary treatment capability; peak summertime flows during 1982
averaged 9 mgd. Carter (1976) presents the results of a field
program to collect baseline data on nutrients, suspended sediments,
heavy metals, and other water quality parameters. The effective-
ness of the diffuser was measured in terms of near-field dilutions
of effluent. The study concluded that the diffuser was performing
effectively. Baseline water quality parameters were within a range
typical of coastal waters and no sludge buildup was occurring on
the bottom anywhere along the outfall.
In order to estimate future population and wastewater flows, the
Facilities Planners divided the land in West Ocean City into 15
subareas. (Figure II-l). The subarea boundaries were drawn
according Hio local zoning districts, presence in the floodplain,
subdivision and stream locations, and subjective judgement. The
subarea boundaries do not correspond to census tracts, political
units, or other categories for which population data are compiled.
The Facilities Plan's population projections for the year 2000
assumed that:
1. Flood-prone areas (Subareas 8 through 15) would be fully
developed by the year 2000 to the limits imposed by
environmental constraints.
2. The remaining year 2000 population would be uniformly dis-
tributed among service areas 1 through 7.
3. Population densities and corresponding wastewater flows
would be estimated at 4 persons per structure and a waste-
water flow of 70 gallons per person per day.
It was suggested that the Final EIS contain data on the existing
population in the subareas for comparison with future projections.
Table III-l lists dwelling unit counts by Facilities Planning
subarea for 1980 and 2000. The 1980 figures were derived by
counting tine number of structures in each subarea and adding an
estimate of known multi-family structures. As stated earlier,
census data on the exact population existing within each subarea
are unavailable.
49
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Table III-1 - Comoarison of Existinq and Future Projections
of Dwelling Units by Facilities Plan Subarea.
Facilities Plan Subarea
Number of Dwellinq Units
1980
2000
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
TOTAL
69
10
83
106
148
R
52
164
201
50
105
162
48
19
94
1319
428
341
237
82
316
104
19
322
629
158
179
17R
97
121
269
3480
50
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nevelooable
Land
Proposed Seafood
Processinq Plant
Fiaure II1-4 (which appeared on P. 50 of the Draft EIS as Figure
III-I1 illustrates orooerty lines in West Ocean City as of 1976,
This information was compiled by the Facilities Planners front
available subdivision olats and 1977 tax mans. Some existinr
structures in the area are known to occupy more than one lot. Some
multiole lots under single ownership may appear as sinqle lots,
Fiaure III-4 should not be interpreted as an exact map of lot:;
platted prior to Mav 31, 1977. The individual lots depicted in
Fiqure III-4 should not be interpreted as developable accordinq to
local zoniig criteria or environmental considerations. Fiqure
III-5 (which appeared as figure II-7 on p. 33 of the Draft BIS i
illustrates that many Properties have already been developed. Th=
availability of water and sewer service, compliance with local
zoninq cri':ria, and other factors. If a Federally-funded sewer
system is constructed in West Ocean City, future development must
comply witt" limitations on sewer service to flood-prone areas, wet-
lands, and aaricultural zones described in the Final EIS. Even
without a Federally-funded sewer system, development in West Ocean
City must comply with State, Federal, and Coastal Zone policies
which limit; or discouraqe development in environmentally sensitive
areas.
Associated Enterprise Development, Inc. has prepared conceptual
plans for a thirty million dollar seafood processing port and
industrial park in West Ocean City to be funded by private and
public interests. The project would aim to provide centralized
facilities for approximately 40 independent businesses on an 8C-
acre property north of the existinq West Ocean City harbor. The
project's promoters cite the potential to process 100 million
pounds of seafood annually and to accommodate currently under-
utilized soecies as benefits. Opponents of the project arque thc.t
the existinq fishery is insufficient to support such large-sea]e
processinq facilities, citinq the decline in recent years in loce.l
catches as evidence of diminished resources.
The seafood park would require extensive dredge/fill activities to
create a second harbor and also to permit access of large commer-
cial trawlers via the Ocean City Inlet. Because these activities
would affecrt wetlands and navigable waters, detailed project review
and permit authorization will be required before any construction
can take place. Both State and Federal agencies have issued
regulations designed to protect wetlands from unnecessary degrada-
tion. These regulations apply to all activities which may affect
wetlands, including those which receive no Federal funding, such .as
construction of bulkheads, boat ramps and buildings by individual
property owners. The State of Maryland (Wetlands Act of 197iJ)
controls the alteration of wetlands for development through a
system of licenses and permits. Under Section 404 of the Clean
Water Act, the U.S. Army Corps of Engineers administers a permit
program which regulates dredging and filling of wetlands. Und=r
the program, each project is evaluated for its compliance with
EPA's Section 404{b) guidelines published in the Federal Register
in December 1980 (45 PR 249). The need for the activity, tie
availability of less environmentally damaging construction design
and practical alternatives, and its overall potential to adversely
impact aquatic resources are considered during project review. All
activities which may affect wetlands -in West Ocean city has and
will continue to be controlled by Federal and State regulations,
whether or not a sewer system is constructed. Because the Federal
jurisdiction over dredge/fill activities is more extensive than
that of the State, Federal regulations will be the limiting factor
51
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Property Lines - 1976
FIGURE lil-4
52
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*-?.
SMEPUJltHl
BAY
DIS1RICT BOUfJUARr
LEGEND
LOW DENSITY RESIDENTIAL
HIGH DENSITY RESIDENTIAL
COMMERCIAL
MARINE / INDUSTRIAL
PUBLIC SERVICE
AGRICULTURAL
WOODLANDS
WETLANDS
OPEN FIELD
Existing Land Use
FIGURE in- s
53
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kblic Water
Ipply
ter
Inservation
on whether permits to construct the seafood port are issued.
Because of the seafood park's proximity to the Assateaque Island
National Seashore, the U.S. Department of the Interior has noted
that additional studies to assess potential impacts on Assateague
should be instituted if the project develops further.
One commentor on the Draft BIS questioned the statement on paqe 74
of the Draft EIS that "public water and sewer were not essential to
this type of industrial development." Water and wastewater
facilities would be required for this type of operation, but not
necessarily under public ownership. It is not uncommon for
industrial water and wastewater facilities in large-scale
operations to be privately owned and operated. Associated Enter-
prise Development, Inc. is considering various alternatives, but no
final Plans have been selected.
On October 26, 1982, the Worcester County Commissioners passed a
resolution supporting the establishment of a seafood agency with
the Purpose of studying the compatibility of a seafood industrial
park in West Ocean City with Ocean City's tourism industry and
developing further plans • for the facility. In order for the
seafood park to proceed to construction, numerous environmental,
enconomic, and engineering issues must be resolved.
Private wells which tap the Pleistocene aquifer supply domestic
water to West Ocean City. The transmissivity of this aquifer
ranges from less than 2500 to more than 10000 square feet per day.
The Pleistocene acquifer is capable of producing moderate to very
large supplies of water (500 to 2000 gpm). It is one of the most
productive acquifers in Maryland and could accommodate extensive
development. Although not currently utilized, deep wells which
penetrate the Ocean Citv and Manokin aquifers could provide
additional supplies if needed. No incidences of salt water
intrusion have been reported in West Ocean City {Morris 1982 and
Mauqans 1982).
The Worcester County Sanitary Commission has considered providing
the area with a centralized water supply system at an estimated
cost of three million dollars (Connell, 1982). Due to limitations
on borrowinq capability and the prelected high cost to users, it is
unlikely that construction of both water and sewer systems can be
considered at this time.
The State of Maryland has demonstrated recognition of the value of
water and waste reduction measures. The Maryland Water Conserva-
tion Plumbing Fixture Act was enacted by the State Legislature in
1978 and recodified into Article 56 as section 445 in 1982. The
Act requires water-conserving fixtures to be installed in all
buildings constructed or remodeled after January 1, 1979. The Act
also prohibits the sale of any plumbinq fixtures which are not
water-conserving. The responsibilities of enforcement are placed
upon local plumbing inspectors. Given the constraints on
wastewater treatment at the Ocean City plant and *he hiqh cost of
expansion, it is in the best interest of the Worcester County
Sanitary Commission to ensure that the Act is enforced. The
Construction Grant regulations under which the West Ocean City
Facilities Plan was prepared require a detailed analysis of flow
and waste reduction measures when the existing sewaqe flow is
greater than 70 gallons per capita per day (gpcd) or the existinq
population is qreater than 10,000. The West Ocean City Facilities
Plan assumes a per capita sewage flow of 70 gpcd; approximately
5000 persons currently inhabit the area.
54
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Threatened and
Endangered
Soecies
Air Quality
Transportation
Impacts
Three Federally-listed endanqered soecies have been reoorted in th<>
vicinity of the study area. Two subspecies of Pereqrine falcons,
the Arctid oereqrine (Falco peragrinus tundrius) and the American
pereqrine (F. p ana t urn) utilize Assateaque Island for resting an'}
feedinq durTnq annual migrations and, therefore, may pass throug.i
or near We-it Ocean City. However, 10 significant impact to th J
falcons are exoecte^ as a result of the West Ocean City project.
West Ocean City's collection systen will be placed under existing
streets ami railroad riqhts-of-wav. No portion of a Federally
funded sewer system in West Ocean Citv will traverse or orovid-
wastewater service to the area's wetlands and thereby adversely
impact shore birds upon which the falcons feed. The elimination cf
effluent seepage from failing septic tanks into canals should
imorove the shorefront aquatic habitat. The Maryland Wildlife
Administration (Taylor 1978) has reported a bald eagle (Haliaeetus
leucocepha]us) nesting area souih of Berlin, approximately fTve
mTTesfrom the project area. No adverse impacts to the bald eagle
are anticipated, either directly or indirectly through changes in
the food chain. No new surface discharges of wastewater which
could impact; fish communities are olanned. The elimination of
septic tank seepage should have a positive impact on surface wat*;r
quality.
No major point sources of air pollution exist in West Ocean Cit".
The followlnq are known sources that exist in Worcester County.
Berlin Town Power Plant
*Chesapeake Foods
*Lance T. Eller
Ocean City Sewaqe Treatment Plant
*Tri-State Oil
*Worchester County Sanitation
Berlin, MD
Berlin, MD
Pocamoke City, MD
Ocean City, MD
Snow Hill, MD
Snow Hill, MD
* Major point source whose emissions exceed 100 tons per year of
any criterial pollutant including particulates, sulfur dioxides
(562), hydrocarbons (HC), nitrous oxides (NOX), and carbon
monoxides (CO).
Construction of a sewer system in West Ocean City will affect bcth
State and County roads. WCSC should continue to coordinate with
State and local highway officials during design and construction of
the project. The adverse impact of traffic disruption could be
minimized by construction during the off-tourist season. One
commentor on the Draft EIS questioned the adequacy of principal
roads north of Route 50 to serve the population increase projected
for the area's subdivisions. The Principal roads in question would
be Golf Course Road and Keyser Point Road. The Facilities Planning
areas that would rely on these roads include Area |1 (the central
portion north of Route 50). Area #8 (Captain's Hill) and Area #9
(Cape Isle of Wight). Facilities Planning areas are depicted on
Figure II-I in this Final EIS. The Maryland State Highway
Administration, Traffic Forecasting Section, performed an analysis
of the capacity of Keyser Point and Golf Course Roads (See
Appendix D). The State concluded that these roads were adequate to
handle current and projected traffic, based on the number of
existing dwelling units and the number of dwelling units
anticipated in the year 2000 if a Federally funded sewer system is
constructed.
55
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THir. i ty
Services
Solid Waste
Disoosal
Facilities
Project Costs
Population growth inevitably places burdens on the community's
ability to nrovide municipal services, such as fire protection,
ambulance/emernencv service and education. In West Ocean City,
inolementat ion of the centralized wastewater management program
will allow significant growth in the area. During the preparation
of this EISr contact was made with, the agencies involved in pro-
viding the above services to determine the impact of population
growth .
Fire protection and a-nbulance service are considered adequate to
meet the growing need in West Ocean City, The volunteer fire
department and ambulance service which serves both Ocean City and
West Ocean City, ha-3 approximately 125 members, 75 of whom reside
in West Ocean City. Current response time is under five minutes.
The large force, bolstered by a permenantly manned station in Ocean
City, is considered rullv capable of handling the increased
population since the program is designed for accommodating the huge
summer populations in the area.
Students from West Ocean City attend Worcester County Schools.
Facilities of this system are new or recently renovated. Total
enrollment as of 19°2 was approximately 5000 reflecting a decrease
in enrollment over the past 5 years from a high of about 6500 in
the mid 1970 's. The system has been losing about 250 students per
year. West Ocean City children attend the Ocean City Elementary
School, the Berlin. Middle School, and the Steven Decatur High
School in Berlin. Because of previously decreasing enrollments,
and the nature nf pro-jected development in West Ocean City
(including a continuation of second home and retirement residences)
th:e projected increase of population should not exert significant
on educational facilities.
Solid wafite generated in Worcester County will be disposed in three
sanitarv landfills located in Berlin, Pocomoke, and Snow Hill.
According to the 1981 update of the Worcester County Solid Waste
Management Plan, the County's landfills have a combined capacity of
20 to 25 years. West Ocean City's projected population increase of
9,000 represents less than 25 percent of the County's total
population by the year 2000. This projected increase would
certainly have an imoact on the life expectancy of the County's
sanitarv landfills, but apparently not a major one. As is common
in rural areas, the Worcester County government does not provide
for solid waste collection. Generators either haul their wastes to
a disposal facility or arrange with a private contractor to haul
the wastes. Article 43 of the Maryland Code does contain pro-
visions to allow the County Sanitary Commission to set UD a solid
waste collection system if desired.
In August 1982, WCSC examined a variety of ways to reduce project
costs and the resulting costs to local residents. These included;
1. Assuming that the engineering, legal, and administration
fees would add 25 percent to the project's construction
cost, rather than 30 percent.
2. Changing the assumption for cost increases due to inflation
from 12 percent to 8 percent.
3. Installing laterals to only existing lots of record at the
time of construction.
56
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Financing
Schemes
Scheme 1
Scheme 2
4. Eliminating 5,280 feet of gravity sewer line which would
be ineligible for Federal funding in order to directly
reduce the local share of costs.
These measures reduced the total oroject cost from 510,280,200 to
$8,675,300. The local share of project costs, which would not be
covered bv EPA;s grant of 75 percent of eligible costs and the
State's 12.5 percent of eligible costs, was reduced from $3,739,200
to $2,788,000.
In an effort to further reduce the local share of costs, fcCSC
sought additional sources of funding from the State of Maryland.
Potential sources included:
1, An $800,000 grant to be awarded to WCSC through the Failing
Septic Tank Program to cover the cost of constructing West
Ocean City's collection and conveyance system in 1983.
2. Assuming that WCSC could also receive $500,000 loans from
the State at the current interest rate of 8 percent {comparsd
to 10 percent for general deligation bonds) for a 30-year
term in both 1983 to cover the cost of constructing West Ocean
City's collection system and in 1985 to cover West Ocean City's
share of the cost of expanding the Ocean City Treatment Plant.
If WCSC were to receive the $800,000 grant, the local share of
costs to be paid in 1983 would be reduced from $2,788,000 to
$1,988.000. The principal benefit gained by $1,000,000 in E.tate
loan fuids would be the reduction in annual payments to cover debt
service caused by the lower interest rate.
Using the revised project cost figures described in the previous
section and potential sources of funding, WCSC's Facilities Plan
described three funding schemes and the potential resulting user
charges. All three schemes assume that EPA will provide a qrant
for 75 percent of eligible costs and the State will provide a
matching grant for 12.5 percent of eligible costs. The following
sections describe the three scenarios.
Under Scheme 1, the local share of costs to construct the systems
in 1983 would be paid totally by local residents through issuance
of general obligation bonds. No EPA/State grant funding or State
loans would be available to cover the cost of expanding the Ocean
City treatment plant in 1985. Scheme 1 would yield the user
charges estimated in Table IV-2. Note that these estimates do not
include the collection system hookup charge of $600-800 for new
lots or the $500-1,500 cost to install a service line froii the
house to the property line.
Under Scheme 2, the local share of costs to construct the system in
1983 would also be paid totally by local residents through the
issuance of general obligation bonds. Scheme 2 assumes thcit EPA
will crovide a 75 percent grant to cover the cost of expanding the
Ocean City treatment plant in 1985; this is inconsistent with the
Construction Grant regulations published on May 12, 1982 which
disallow funding of treatment works that would serv« new
habitations in wetlands or flood-prone areas and also eliminate EPA
funding of treatment Plant expansion to serve future growth after
October 1, 1984. Scheme 2 would vield the user charges estimated
in Table IV-3. Note that these estimates do not include the
collection system hookup charge of $600-800 for new lots Dr the
$500-:. ,500 cost for service line installation to be Pcdd by
individual users.
57
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TABLE III-2 - Annual
Front Foot Rate
Multiplied by
Lot Width
50 ft.
100 ft.
200 ft.
300 ft.
User Charges Under Scheme
1983
$2.06/ft
$103
$206
$412
$618
1985
S3.56/ft
$ 178
$ 356
$ 712
$1,068
1
1990
$3.45/ft
$ 178
$ 356
$ 71 2
$1,068
2000
$3.56/ft
$ 178
$ 356
$ 712
$1,068
Plus Operation and
Maintenance (0 & M)
Costs for One Residence S80/yr $80/yr $69/yr S68/yr
Equals
Total Cost by
Lot Width.
50 ft. = $183 $ 258 $ 247 $ 246
100 ft. = $286 $ 436 $ 425 $ 424
?nO ft. = $492 $ 792 $ 781 S 780
300 ft. = $698 $1,148 $1,137 $1,136
TABLE III-3 - Annual User Charges Under Scheme 2
1983 1985 1990
2000
$2.43/ft
$
$
S
$
122
243
486
729
$
$
$
$
122
243
486
729
$
$
$
$
122
243
486
729
Front Foot Rate $2.06/ft $2.43/ft $2.43/ft
Multiplied by
Lot Width
50 ft. ~ $103
100 ft. = $206
200 ft. = $412
300 ft. = $618
Plus Operation and
Maintenance (0 & M)
Costs for One Residence S80/yr $80/yr $69/vr $68/yr
Equals
Total Cost bv
Lot Width.
50 ft. = $183 $ 202 $ 191 $ 190
100 ft. = $286 $ 323 $ 312 $ 311
200 ft. = $492 S 566 $ 555 $ 554
300 ft. = $698 $ 809 $ 798 $ 797
58
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•Tie 3
Financial
Capability
Affordability
Scheme 3, was the financing scheme usnr to describe usor chines in
WCSC' s letter to all nrooertv owners ssolicitinq nublic ooinion on
the oroiect. "Tnder Schotie 3, '\TC?0 sisssumr-G that in l^m the state
will award an $300,000 qrar.t throuoh the Pailim Seotic Tank
Proqram and also a $r>00,000 loan at 8 oerc«nt interest for a
30-vear ter"> to cover the local share of costs to construct West
Ocean Citv's sewaqe collection system, WCSC also assumes that the
State will rrovide a ?C00,000 loan at C| oercent interest in l^ss to
cover West Ocean Citv'r, share of the cost of exoandinq the Ocean
City sc;waqe treatment nlant. WCSC assumes that no EPA/State qrant
fundinq will be available to cover the cost of the expansion Scheme
3 would vield the user charoes esti-nated in Table IV-4. Note that
these "Stineites do not include the collection system hookcn charqe
of S60H-ROO for new lots or the SSOO--1,500 cost for service line
installation to be oaid bv individual jsers.
The West Ocean City Draft CIS contained detailed analvses of the
financial impacts of constructinq and operatinq a seweraqe svsteir
in West Ocean city. EPA assessed the financial capability of West
Ocean Citv as a community to support the construction, operation,
and maintenance costs of such a system as well as the system's:
affordability by individual users. The financial capability
analysis concluded that WCSC, Worcester County, and the West Ocean
City Sanitary District could support the costs of constructinq and
maintaining a centralized wastewater treatment system, but the
marqin of safety was very small. The analysis contained in thn
Draft EIS was based on project costs and the anticipated loca".
share of costs as contained in WCSC's Facilities Plan. A revised
version of the Facilities Plan, completed bv WCSC on Auaust 20,
19B2, noted that the State of Maryland may qualify for an $800,00>
qrant under the Failinq Septic Tank Proqram maintained hv the Stat'i?
of Maryland. A comment on the Draft EIS forwarded by the Maryland
Department of Health and Mental Hvqier.e noted that:
"The financial capability analysis was prepared prior to a
decision bv this office to favorably consider the use of:
SBOO,000 of Failinq Septic Tank Grant Funds to reduce 1983
user fees to what we consider to be a fair and reasonable
level of approximately S220 per year (for a 100' wide lot),
which is seemingly affordable for the community as a whole.
In 19Fi5, or whenever the Ocean City plant is expanded, the
yearly user fees are expected to escalate to $371 (1001 lot).
Althouqh this revised cost fiqure is $17 less than the one
presented in the EIS, we feel it does not chanqe the outcome
of the financial capability analysis, i.e. the project still
has a small marqin of safety relative to affordability and, as
such, the local officials should take a cautious approach in
deciding this project's fate. However, we feel this con-
clusion has limited applicability because its development
failecl to consider the element of public input. Regardless of
the accuracy of the assumptions and the input data used in the
analysis, the ultimate decision on affordability lies in tY e
collective decisions of the potential users of the system.
Should the affected public decide to reject this project.,
knowing full well the economics involved, then we would be
inclined to conclude that the project is not affordable, ev
-------
TAB_LF^_I!_!_-£ - Annual nser Charqes Under Scheme 3
1983 1985 199JJ 2000
Front Foot Rate Sl.41/ft S2.91/ft S2.91/ft $2.91/ft
Multiolied by
Lot Width
50 ft. = S 71 S146 S146 $146
100 ft. = $141 $291 $291 $291
200 ft. = $282 $582 $582 $582
300 ft. = $423 $873 $873 $873
Plus Ooeration and
Maintenance (O & M)
Costs for One Residence $80/yr S80/yr $69/yr S68/yr
Equals
Total Cost bv
Lot width.
50 ft. = $151 $226 $215 $214
100 ft. = $221 $371 $360 $359
200 ft. = $362 $662 $651 $650
300 ft. = $503 $953 $942 $941
60
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guidelines utilize a comparison of annual charqes to customers with
median household income. User charges include debt service and
operation and maintenance costs. Additional one-time costs to the
consumer include the cost of constructing a service line which
connects the house plumbing with the sewer line in the street and
new unit connection fees. When total annual charges to customers
exceed the following percentage of median annual household income,
a project is considered expensive:
o 1.0% when median income is under $10,000.
o 1.5% when median income is between $10,000 and $17,000.
o 1.75% when median income is over $17,000.
Since no income surveys are available for the study area, the
median household income must be estimated fron U.S. Census data for
Worcester County in 1979 {1980 Census). Income is then inflated
from 1979 to 1983 (the year for which user costs are estimated)
using known and forecast changes in the consumer price index.
Known and estimated incomes are shown in Table III-5. Based on the
median income comparison described above, EPA considers any user
charge greater than $371 per year expensive for the average
Worcester County resident. However, only 58 percent of the
residences in West Ocean City are occupied year-round. It is
likely that the manority of the remaining property owners do not
live in West Ocean City. Hence, their ability to afford the
anticipated user charges cannot be evaluated on the basis of
Worcester County income data. It is not possible within the scope
of this EIS to determine the median household income of non-
resident property owners. However, the project may be expensive
for property owners who do reside in Worcester County, particularly
for those whose lots are wider than 100 feet.
Table III-5. Estimates and U.S. Census Measurements of Annual
Median Household Income.
Area
United States
Maryland
Worcester County
1_9_69
8,389
10,092
6,249
1979
16,553
20,070
14,149
198 3*
24,830
30,105
21,224
* Estimated using known and forecast changes in the consumer price
index from 1979 throuqh 1983.
As can be seen on Table III-5, Worcester County has a median
household income below that of the United States and Maryland. In
addition, some of tie families in the study area depend on forms of
income which miaht make it difficult for those families to pay the
required user charaes and connection fees. These include the
following:
o families livina on fixed income (retirement.)
o families whose income fluctuates (seasonal)
o families with low disposable income (farmers).
L
61
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?ublic Opinion
Because the estimated user charges indicate that financing the
proposed alternative could have an adverse impact on the local
community, special attention should be paid to the means of
assessing and collecting the required fees, since these can provide
the potential of either mitigating or heightening cost impacts.
The Facilities Plan combines two different methods of assessing and
collecting sewer fees. The first involves user charges to cover
the costs of operation and maintenance (0 & M) only and the second
involves front-foot assessments to cover local bond costs (a small
portion of the capital construction costs). Both of these methods
conform with State and Federal policies. If the system were
constructed totally with local funds, property tax assessments
based on acreage would be levied to cover capital construction
costs not included in the local bond. As mentioned above,
additional costs to be financed by the consumer include private
costs (plumbing and service line costs) and new unit connection
fees.
The user charge system for 0 s. M costs assumes a uniform charqe per
dwelling unit while the front-foot and property tax assessments
depend on the size of the lot and vary significantly from one
service area to another. In 1983, the annual 0 & M user charge for
the selected system is $80. Tables III-2, III-3, and III-4 listed
estimated user charges according to lot width for the three
financing schemes presented in WCSC's Facilities Plan.
Additional private costs and new unit connection fees must be added
to these cost estimates in order to obtain the total costs per
customer. Estimates of private costs range from S500 to $1,500 and
new unit connection fees from $600 to $800. If, for the purposes
of analysis, financing of the private costs and new unit connection
fees is assumed to occur throuqh a five-year loan, the private
costs paid by an existing unit would range from $149-448 oer year;
the private cost and new unit connection fees paid annually by new
customers would range from S328 to $687. However, in the case of
new customers it is probable that these costs will be included in
the cost of financing the new unit.
The ultimate decision to apply for a Federal grant to construct a
sewer system in West Ocean City rests with the Worcester County
Sanitary commission (WCSC). Because the project's substantial cost
must be borne by the area's property owners, WCSC has solicited
public opinion on the project. A letter (see Appendix D) was sent
to all property owners on October 29, 1982, with a request for
reply by December 1st. The letter included a table showina
projected user charges under the followinq assumptions:
1. The total project cost would be $8.6 million.
2. The State of Maryland would contribute $300,000 throuqh the
State Failing Septic Tank Program, in addition to the 12 1/2
percent qrant of elidible costs normally contributed in con-
junction in the 75 percent grant of eligible cost awarded by
EPA throuqh the Construction Grants Program.
3. The local share of project costs, equivalent to $1.99 million,
would be bonded over a 30-year period.
4. The front-foot rate levied against each property owner to cover
capital costs would he $1.41 per front-foot per vear in 1983
and increase to $2.91 per front-foot per year through 1985 to
2000. The letter does note that these rates would increase bv
62
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5.
S.14 per front-foot per year if WCSC choos.es to include 5000
feet of ineligible sewer line which were removed in an effort
to reduce costs.
A collection syscem hookup fee of $600-$800 would be charged
for all properties connected to the system after initial
construction.
6. Each property cwner would nay approximately $500 to $1,500 for
installation of a service line from the house to the property
line. The cost would vary accordinq to the lot size and the
house location.
7. A Dlumbinq pern-it would be required at a.i approximate cost of
$150. The actual cost would vary with tie structure.
As of December 21st, 64 percent of West Ocean City's 1,045 property
owners had responded to the letter; 341 were; for the proiect and
328 were aqainst.
63
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Chapter IV.
Recommended Actions
i PRIVATE
BEACH
-------
-------
Recommended
klternative
lastewater
lollection and
jnvevance
CHAPTER IV. RECOMMENDED ACTIONS
The Facilities Plan Amendment prepared by George, Miles, and Buhr,
Inc. for the Worcester County Sanitary Commission considered
various alternatives to collect, convey, and treat West Ocean
City's wastewater over the next 20 years. Following a detailed
analysis of the alternatives according to engineering feasibility
and cost., the Facilities Plan Amendment recommended an alternative
employing a combination of wastewater collection by gravity sewers
and conveyance by force main to the exisitng sewage treatment plant
and ocean outfall in Ocean City for treatment and disposal. The
Facilities Plan Amendment further analyzed this alternative under
two funding scenarios: one which would be locally funded and
designed to produce the maximum growth and development that
centralized sewer service would permit; and a second which would be
partially Federally funded and would incorporate special measures
to limit the loss of environmentally-sensitive lands.
Following a detailed analysis of all of the Facilities Plan's
alternatives according to environmental impacts, costs, and
implementability, EPA has concluded that the Facilities Plan's
recommended combination of gravity sewer collection, force main
conveyance,, and Ocean City treatment and disposal is an accept-
able solution to West Ocean City's wastewater treatment problems,
provided that special measures are taken to mitigate potential
sewer-induced loss of environmental values. These mitigation
measures are necessary in order to qualify the alternative for
Federal funding through EPA's Construction Grants Program. This
system would provide wastewater to West Ocean City's anticipated
year 2000 population of 13,920 persons and accommodate a wastewater
flow of 974,400 gallons per dav. The primary beneficial imoact of
this alternative would be elimination of the hazards to groundwater
and oublic health associated with the area's numerous failing
septic tanks.
Gravity sewer systems transport wastewater from buildinqs to
convenient low points utilizing differences in elevation to achieve
flows. Because West Ocean City is relatively flat, a minimum of
seven low points will be required. At six of these seven points
wastewater would be collected in lift stations. These stations
would pump wastewater uphill by way of force mains, discharging to
the upper elevations of gravity interceptors or to a final pumpinq
station. The proposed alignment for the gravity sewer system,
including the 8 inch to 10 inch gravity sewer lines, six lift
stations and one pumping station is shown in Figure II-2. Federal
funding is available to cover the cost for installing collection
sewers only to serve areas which were substantially developed by
1972. Consequently, not all of the sewers in the area can qualify
for Federal funding. In an effort to reduce the overall cost of
the system to its users, WCSC has identified approximately 5,000
feet of grant-ineligible sewer line which mav be eliminated from
the project in order to reduce the local share of costs. Figure
III-3 depicts these segments. WCSC's final decision on whether to
construct these segments as part of the original proiect will be
contingent upon construction bid costs. Raw wastewater collected
by gravity sewers in West Ocean City would be Dumped via a 16-inch
diamter force main to the Ocean City collection system at 15th
Street (Figure Vl-l). From this point, the existing Ocean City
collection system would convev the wastewater to the Ocean Citv
facility for treatment and disposal. A 2500 foot seqment of the
force main will cross Sineouxent Bav near the Route 50 bridge.
64
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ASSAWOMAN
BAY
ISLE OF WIGHT
BAY
OCEAN CITY
WEST OCEAN CITY
TREATMENT PLANT
— OCEAN CITY
COLLECTION SYSTEM
OUTFALL
PUMP STATION
FORCE MAIN TO OCEAN CITY
COLLECTION SYSTEM
RECOMMENDED PLAN
FIGURE IV-1
SCALE IN MILES
65
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•Treatment and
•Disposal
•Project Costs
Construction of the force main must receive permits from the U.S.
Army Corps of Engineers as required under Section 10 of the River
and Harbor Act of 1899 and also under Section 404 of the Federal
Water Pollution Control Act. The detailed review which will occur
as oart of the oermittinq process may identify mitigation measures
necessary to minimize impacts due to the force main's location,
desiqn, or construction. It is anticipated that the force main
will cause short-term adverse impacts on water quality and aquatic
organisms due to suspension of sediments. Because of the slow
currents in the vicinitv of the alignment, sedimentation impacts
are not expected to he significantly adverse. Construction of the
force main in Ocean City will result in short term adverse impacts
on traffic and business disruption. These impacts can be reduced
bv scheduling construction during the non-tourist season.
Otherwise, these imoacts could be severe.
After West Ocean City's sewaqe flow enters the Ocean Citv
collection system, the combined flows would be transported to the
Ocean City plant at 64th Street for treatment and disposal through
the Ocean City outfall (Figure IV-1). The Ocean City sewage
treatment plant provides secondary treatment capabiliy. The plant
was recently expanded to a desiqn capacity of 12 mqd, with peak
flow capability of 1R mgd. Averaqe flows through the plant durinq
the peak months of July and August 1982 were 8.59 mgd and 8.39,
respectively (Connell 1982). The presence of at least 3 mqd of
unused capacity during the peak summer months indicates that plant
expansion is not an immediate need as would be the case if the
Ocean City plant were hydraulically overloaded. No new local
treatment facilities would be required solely as a result of the
additional flow from West Ocean City. The marginal increase in
effluent flow through the Ocean City outfall as a result of West
Ocean Citv sewaqe is not expected to noticeably effect water
quality.
The Facilities Plan divided the costs for the West Ocean City
project into two manor components: (1) sewaqe collection and (2)
the cost to treat and dispose West Ocean City's sewaqe at the
existing sewage treatment plant in Ocean City. The project for
which WCSC seeks Federal funding at this time includes a gravity
sewer system in West Ocean City and a 16 inch force main under
Sinepuxent Bay to convey raw sewaqe from West Ocean City to the
Ocean City collection system. WCSC also assumes that if and when
the Ocean City treatment plant is expanded in the future, West
Ocean City residents will pay for their share of the expansion
cost, or 10.5 percent based on the 1.0 mqd of wastewater capacity
that West Ocean City residents will ultimately use. Additional
details on the Ocean City treatment plant and its proposed
expansion are presented in Chapter III in response to comments
received on the Draft EIS. The following table shows projected
costs as they appeared in the August 20, 1982 version of WCSC's
Facilities Plan.
66
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Table IV-1 - Present Worth Cost of the Recommended Alternative
Component
Collection
Const,.
Year Capital
Salvage
Value
0
& M
Total
Present
Worth
Gravity
sewer system
(Includes six
lift stations
and one pump
station)
Treatment
and Disposal
16" Force
Main
Ocean City
Treatment
Plant
Expansion
1983 S7,545,300-8842,000+5505,900 = 37,209,000
1983 $1,907,300
1985 $1,732,5002-S427,000+$1,190,400=$4,110,100
1 The Salvaqe Value, Operations and Maintenance costs, and
total present worth for the force main are included in the
cost fiqures for the Ocean City Treatment Plant Expansion.
2 Assumes that West Ocean City will pay 10.5 percent of the
$13,200,000 cost to expand the Ocean City plant by 9.5 mgd
plus 5346,500 to cover engineering and administrative fees.
Annual costs for operation and maintenance are not eligible for
Federal funding. These costs for collection, transmission, and
treatment must be paid for by those persons actually using the
system, in proportion to their wastewater flow. The Facilities
Plan assumes that as these costs increase, population qrowth and
development in West Ocean City will create more users to share
the cost of operating the system, as well as repayinq the debt
incurred for construction. The following table shows estimated
annual operation and maintenance costs and the anticipated
number of equivalent dwelling units as they appear in the
Facilities Plan.
67
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Table IV-2 - JVmuialOperation & Maintenance Costs
financing
Schemes
Category
Force Mains
Year
1983
$ 5,900
Pump Stations 16,900
Treatment
Gravity
Collectors
Total Cost
55,600
$98,100
Estimated Number
of Equivalent
Dwelling Units
(EDU's) 1240
1981
$ 5,900
26.900
87,700
19,700
$140,200
1760
1990
$ 5,900
36,'700
2000
$ 5,900
54,300
119,600
19,700
$181,900
2660
156,600
19,700
$236,500
3480
The first step in determining the cost of constructing the project
to local residents involves calculating the local share of costs
which will not be eligible for Federal or State funding. WCSC has
assumed that the Commission will initially install one sewer
lateral to each lot of record containing an acceptable structure.
Future lateral installation to accommodate new construction will be
done on an as-needed basis by the Sanitary Commission and paid for
by the property owner through a service charge or new hookup
connection fee in the range of $600-$800, depending on the line
size and street width. In addition, all lateral cleanouts and
service lines from the residence of the property line will be paid
for by the property owner. This cost will range from $500 to
$1500, depending on lot size. This cost applies to all connections
independent of whether they are to serve new development or
existing homes. Placing the cost burden of all lateral cleanouts
and future lateral installation directlv on the property owner
reduces the cost of the project to be constructed by WCSC to
$8,675,300. The cost includes the gravity sewer svstem with six
lift stations and one pump station and the 16 inch force main to
Ocean City. Through October, 1984 EPA may grant UP to 75 percent
of the eligible cost of constructing publicly owned sewaqe
treatment Plants; the State of Maryland may provide an additional
12.5 Percent of the eligible cost. WCSC must contribute the re-
maining 12 1/2 percent of the eligible cost. EPA Construction
Grant Program Regulations place limitations on the eliaibility of
sewers for Federal funding. Collector sewers are only grant-
eligible if they will serve areas which were substantially
inhabited prior to 1972. For this reason, WCSC has estimated that
$1,947,000 of the project cost will be ineligible for funding. The
total local share of costs, therefore, becomes $2,788,000. This
cost is within the legal bonding capability of the Sanitary
District.
In an effort to further reduce the local share of costs, WCSC
sought additional sources of funding from the state of Marvland.
Potential sources included:
>?AT41. Receipt of an $800,000 arant bv WCSC throuah the State's
Failing Septic Tank Program to cover the cost of constructing West
Ocean City's collection and conveyance system in 1983.
£AT4_2. Assumina that WCSC could also receive 5500,000 loans from
the State at the current interest rate of 8 percent (co-r\oarerl to 10
68
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percent for general obligation bonds) for a 30-year term in both
1983 to cover the cost of constructinq West Ocean City's collection
system and in 1985 to cover West Ocean City's share of the cost of
exoandinq the Ocean City treatment plant.
If WCSC were to receive the 5800,000 qrant, the local share of
costs to be oaid :n 1983 would be reduced from $2,788,000 to
31,988,000. The princioal benefit qained by 51,000,000 in State
loan funds would b2 the reduction in annual nayments to cover debt
service caused by the lower interest rate. Usinq the revised
project cost fiqjres described in the orevious section and
potential sources of fundinq, WCSC Facilities Plan described three
funding schemes and the potential resultinq user charqes. (See
Chapter III). The followinq describes the recommended fundinq
scheme.
So he *).:•> 3 wa?; the f inane inq scheme used to describe user
;::;ar
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Service Area
md Population
Table
IV-3 Annual User
Charges
1983
Front
Foot Rate SI.
41/ft
Under
1985
Scheme
$2.91/ft
3
1
S2
990
.91/ft
2000
$2.
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Sewer-promoted
Growth
Table IV-4,,
Year 2000 Rstimates of Equivalent
Population Levels
and Wastewater
Dwell inq Units,
Flows Obtained from
Georqe, Miles & Buhr (Friedel, 1982).
Service
Area*
1
2
3
4
5
6
7
8
9
1.0
11
12
13
14
15
Total
* Areas 1 t
Equivalent
Dwelling Units
428
341
237
82
316
104
19
322
629
158
179
178
97
121
26_9
3,480
•.hrouah 1 are not cc
Population
1,714
1,363
948
32:6
1,264
415
•'8
1,288
2,5'.6
S3 2
716
712
338
434
1,076
13,920
insidered extrem
Wastewater Plow
(gallons/day)
120,000
95,400
66,400
22,800
88,500
29,000
5,500
90,200
176,100
44,200
50,100
49,800
27,200
33,900
75,300
974,400
elv environmentally-
sensitive. Population qrowth and development in these areas fan
proceed in a manner consistent with local zoning and land use
plans. Areas 8 through 15 are environmentally-sensitive.
Population qrowth and development in these areas must comply
with Federal and State environmental regulations if a Federal!.y-
funded sewer system is constructed.
A lack of centralized sewerage and severe limitations on the use of
septic systems have virtually halted development in the West Ocean
City area in the last decade. Providing central sewer service to
the area will accommodate housing demand built UP during tills
period. Initial qrowth will be the strongest in existing sub-
divisions north of Route 50 (Cape Isle of wiqht and Captain's
Hill). Subsequent growth will occur on tracts of farmland north of
Route 50 since those areas are large enough to make subdivision and
development profitable. Because the land adjacent to and south of
Route 50 is divided into lots with separate ownership and because
the area mixes commercial, residential and industrial uses, develop
ment in this area is more dependent on economic considerations than
a lack of public services. Sewer service will encourage the
economic development of this area, but without a strong demand for
additional motel/hotel rooms, restaurants, amusements or marine-
related industries, development of this area will be slower than
growth to the north.
The Worcester County Comprehensive Plan designates the west Ocean
City area as a high growth area with an average density of 10
units per net acre. The Worcester County Health Department's
septic permit code limits building densities in the area north of
Route 50 to 2 units per acre, while local zoning allows 5 units per
acre. In the area south of Route 50 the Health Department pernits
7 units per acre, while the zoning averages 21 units per acre. The
Health Department's septic permi- restrictions no longer apply once
sewer service is provided, therefore providing sewer service to the
area will increase the allowable dwelling unit densities. This
will allow the area to develop at the densities suggested in the
comprehensive plan. Providing sewer service to the area will
71
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3wth Effects
Sensitive
?as
promote another goal of the plan. By allowing West Ocean City to
grow to its full potential, the pressure for development in the
rural and agricultural parts of the county will decrease. There-
fore, providing sewer service to West Ocean City will postpone or
eliminate the development of valuable farmlands and other water-
front areas in the county.
Most of the waterfront property in West Ocean City has been sub-
divided into lots of 1/4 acre or less. EPA and State guidance
permits one sewer connection for each lot within the floodplain
Platted before 1977. The highest demand for housing is in the
waterfront areas. When sewer service is provided, initial develop-
ment will tend to occur within the floodplain. Most of this
development will be single family homes in existing subdivisions
north of Route 50. A large portion of the waterfront property
south of Route 50 is already developed. The one large tract of
vacant developable land south of Route 50 is being considered for a
seafood industrial park. If this park is developed additional
commercial support facilities will be drawn to the area. Although
public water and sewer are not essential to this type of industrial
development, these public services will make West Ocean City more
attractive to developers.
Placing interceptor lines on both sides of Route 50 and along Route
707 will increase the value of adjacent property. Since much of
the property located along Route 50 is owned by speculators devel-
opment companies or -joint ventures, increasing property values will
also increase carrying costs to these interests. This will prompt
property owners to reassess their investments, possibly leading to
sale or development of speculative property. Therefore providing
sewer service to the area may facilitate the high density com-
mercial development of Route 50. Large single family homes and
cottages are located south of Route 50 along Old Ocean City Road
{Route 707). The area has large tracts of vacant land divided into
small lots owned by local residents. Tncreasina property values
will encourage these residents to develop this land. Combining
lots will lead to the most efficient use of the land. With proper
planning this area could provide the community with attractive
low-cost permanent housing. Once building levels increase with the
provision of sewerage, a slow expansion of the cottages and motels
located in the area is expected. Construction of new motels and
hotels will depend upon future demand and will follow commercial
and residential development.
As described previously, growth inducement in environmentally
sensitive areas in West Ocean City (wetland, floodplains, and prime
agricultural lands) has been the central issue in this EIS. The
Draft EIS described these areas in detail and discussed possible
Federal, State and local controls on their use and development. A
specific plan to minimize sewer-induced loss or damage of these
areas is described later in this chapter.
The Federal Coastal Zone Management Act of 1972 requires that
Federal activities occurring in coastal areas be consistent with
approved state coastal management programs, to the maximum extent
practicable. The recommended federally-funded wastewater treat-
ment facilities and service restrictions to environmentally
sensitive areas have been reviewed with respect to this
requirement, and found to be consistent with the approved 1978
Maryland Coastal Zone Management Program. Communication with the
Maryland Department of Natural Resources, Tidewater Administration
(March 17, 1983 telephone call with Elder Ghiqiarelli) confirmed
72
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Wetlands
Growth Effects
on Floodplatns
this consistency determination, provided that the federally-funde3
system is implemented.
The following sections summarize the qrowth effects on these areas
which will occur as a result of implementation of the recommended
seweraqe system.
No Federally funded sewer service is projected for any of the
area's wetlands, thereby avoiding any direct adverse effects. l.n
updated map of Federally designated wetlands is West Ocean City, as
defined by. preliminary data collected for -the National Wetland
Inventory beinq conducted by the U.S. Fish and Wildlife Service
appears in Chapter III as Figure 111-2. This map will serve as the
guide for restricting Federally funded sewer service to wetlands.
Very limited future qrowth, if any, is anticipated in the area's
wetlands through non-federally funded wastewater systems. Federal
and State policies act to limit destruction of wetlands, even whsn
private funding is used to provide sewage treatment. The avail-
ability of sewer service in adjacent upland areas will act as a
deterrent on future wetlands development.
Growth under the selected plan will cause changes in the volume and
pollutant loads in runoff. In West Ocean City, runoff is carried
primarily through drainage ditches and deposited into small ditches
or streams which drain the wetlands. Wetlands act to mechanically
remove sediment, store nutrients and adsorb or chemically remove
toxic materials which are contained in runoff. The assimilative
capacity of the wetlands is, however, limited.
Development forecast for the study area by the year 2000 involves
conversion of approximately 17 percent of the land area {excluding
the wetlands) from forest and agriculture to low, medium and high
density urban uses. Increases in nutrient and biochemical oxygen
demanding material loadings have been estimated at about 13 psr-
cent. Urbanization will also increase toxic materials in run:>ff
such as hydrocarbons and heavy metals (from vehicular spills and
leakage of oils, gasoline and grease).
The selected wastewater plan allows sewer service to portions of
the floodplain which were subdivided into platted building lots as
of 1977. Portions of the floodplain not included in the service
area may not connect to a Federally funded sewer system; develop-
ment in these areas would therefore require separate approaches to
wastewater management such as septic tanks or innovative on-?;ite
systems. Initial growth in floodplains within the project service
area will occur as infill to existing developments north of Route
50 (Cape Isle of Wight and Captain's Hill, for example). Sub-
sequent qrowth north of Route 50 will then center on the large
undeveloped area between Route 50, Golf Course Road and Keyser
Point Road. Commercial development in floodolain areas along Route
50 will be dependent on economic trends. Floodplain areas
potentially affected occur north of Route 50 at the western edgs of
the study area and south of Route 50 at the eastern edge. As was
the case with wetlands, the provision of sewer service in parts of
West Ocean City will act to discourage development in floodplain
areas outside the service area both in West Ocean City and
Worcester County generally.
In 1979, the Worcester County Commissioners adopted a floodclain
management ordinance as required in order to participate in the
National. Flood Insurance Program. As a result, all new or sub-
stantially-improved structures would have to be floodproofe^ or
73
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Growth Effects
On Prime
Agricultural
Lands
Mitigation
Measures for
Environmentally
Sensitive Areas
elevated to the level of the 100-year flood. Almost all of the
existinq structures in the area were constructed orior to 1979.
New develooment and substantial rehabilitation in West Ocean City,
therefore, would have a lower ootential for flood damaqe than
structures already in existence. Limitations of the sewer service
capacity to that required for one dwellinq unit for lots in the
100-year floodplain would also limit the ootential for substantial
economic losses and potential loss of lives if major development
were permitted.
The recommended alternative provides wastewater service to
siqnificant areas of West Ocean City on soil desiqnated as crime
aqricultural land by the U.S. Department of Agricultural, Soil
Conservation Service. Much of the prime aqricultural land in West
Ocean City has already been subdivided into buildinq lots and/or
developed.
Worcester County's Comprehensive Plan allocates a siqnificant
proportion of the county's land area to aqriculture (250,000 acres
of a total 310,000 acres). In 1978 the Worcester County Commis-
sioners revised the aqricultural cateqory of the zoninq ordinance
to discouraqe conversion of cropland to other uses; new roads and
subdivisions of more than five lots are prohibited. The plan calls
for concentratinq develooment around existinq towns and bay front
lands adjacent to Ocean City, includinq the project service area.
It is for the above reasons that the selected plan projects service
for larqe areas of prime aqricultural soils in West Ocean City.
The County feels that concentratinq development in limited areas
offers the best approach to discouraqinq haphazard conversion of
other aqricultural areas of the County. Accordinqly, a larqe
parcel of aqriculturally zoned land in the southwest portion of the
study area is not projected to receive sewer service. This oarcel
contains some areas of prime aqricultural soils. Development of
prime aqricultural soils outside of the service area is possible if
local zoninq permits; any such development would require approaches
to wastewater manaqement separate from the centralized system in
the selected plan. As with wetlands and floodplains, sewer service
in parts of West Ocean City will discouraqe development on prime
aqricultural soils outside the service area both in West Ocean City
and Worcester County qenerally. This effect will be somewhat
limited, however, because many of the characteristics that make
soils hiqhly suitable for aqriculture, also make them suitable for
conventional septic systems. Therefore, in areas where development
pressure remains and county zoninq permits, growth served by
conventional septic systems will continue to occur.
The recommended wastewater alternative decribed earlier has been
desiqned so as to minimize potentially adverse impacts on environ-
mentally sensitive areas (floodplains, wetlands, prime aqricultural
lands). Direct construction in these areas has been avoided by
aliqninq the collection and conveyance system alonq existinq
roadways and raillines. Sitinqs of lift and pump stations have
similarly avoided sensitive areas to the extent possible. Pipe
diameters have also been reduced to the minimum size necessary to
adequately transport the sewaqe flow.
In spite of the attention qiven to minimizing environmental impact
throuqh desiqn of the system, because of the "pent-up" demand for
housinq which has accumulated durinq the past decade, induced
growth and its accompanying impacts will inevitably occur as a
result of a centralized seweraqe system in West Ocean City.
Existinq State and local government plans and procedures, such as
74
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the Worcester County Comprehensive Plan, Zoninq Ordinance, and
Floodplain Management Ordinance, and the Maryland Coastal Zone
Management Plan, already provide some measure of protection from
potentially adverse impacts which often accompany a rapid influx of
new growth. In addition, the Draft EIS outlined specific restric-
tions on sewer service in West Ocean City's environmentally
sensitive areas which must be imposed if the sewerage system is to
receive Federal funding. Figure IV-2 roughly indicates the
combined floodplain/wetland area which will"be subject to the sewer
service restrictions. These restrictions are summarized as
follows:
Flood-prone Areas—Because most of the area's existing septic tank
problems are located in the floodplain, sewer service will be per-
mitted for all existing structures where required. However, new
development must be limited. Sewer service will be permitted for
only those undeveloped lots which were platted as building lots
prior to May 1977. This date corresponds roughly to the issuance
of EO 11988 and the stringent septic system requirements which have
restricted development. The sewer service capacity must also be
limited to that required for one equivalent dwelling unit (i.e. 280
gallons per day). This will permit individual homeowners, and in
some cases small businesses, to develop their land. New sub-
divisions and major development in flood-prone areas cannot be
served by a Federally-funded system.
Wetlands—There is no need for central sewer service to wetland
areasto alleviate existing water quality problems. Any sewer
service to these areas would be solely to promote new development
and would be inconsistent with the intent of Federal Executive
Order 11990, as well as other Federal and State wetland protection
policies. Therefore, sewer service will not be permitted within
any of the area's wetlands, as designated by the U.S, Fish and
Wildlife Service. These include both tidal and non-tidal
wetlands.
Prime Agricultural Lands—Worcester County has a program to pre-
serve the County's; 250,000 acres of agricultural land throuqh
provisions in the County's Comprehensive Plan and Zoning Ordinance.
The plan states that West Ocean City should oe developed in order
to protect farmland in the rest of the County. Much of the land in
West Ocean City containing Prime Agricultural soils has already
been developed or subdivided into small lots of individual owner-
ship. Sewer service can be permitted here: on residentially zoned
lands, but should be discouraged in agricultural zones.
Combination Areas—The land area north of the east-west portion of
Golf Course Road is composed entirely of wetlands, floodplain and
prime agricultural land. No sewer service will be permitted here;
there is no existing need to alleviate water quality problems. No
interceptor will be permitted to extend across the east-west
portion of Golf Course Road. EPA regulations prohibit extension of
interceptors throuqh environmentally sensitive lands when there is
no existing need for service. Undeveloped industrially-zoned lots
south of Route SO and east of Golf Course Road which are composed
of wetlands and floodplain areas which were not platted prior to
1977 are also not eligible for service.
Non-sensitive Areas—Sewer service can be olanned in these areas in
a mannerwhichTsconsistent with local planning and zoning regu-
lations and population projections.
75
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LEGEND
H FLOODPLAIN
§ WETLANDS
76
Floodplain/Wetlands
FIGURE IV-2
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Implementation
Plan
Sensitive Areas Which Cannot Rece i ve Federally-funded Sewer
Service^-—Any development" "must be supported by the use of on-site
wastewater treatment systems where permitted in accordance with
State and local requirements.
While the Draft EIS clearly described the exoected environmental
impacts of the selected alternative, and outlined the constraints
necessarv to protect environmentally sensitive areas, it did not
specify the institutional framework and procedures by which the
protective Treasures would be carried out. As several commenters
noted, the absence of a plan for ensuring that these measures are
carried out releqates the measures t'nemselves into nothinq more
than good intentions.
To address this shortcoming, EPA, in con-junction with the Maryland
Department of Health and Mental Hygiene and the EIS Coordination
Committee, has further researched and discussed the possible
mechanisms which could be employed to achieve implementation of the
necessarv mitigation measures. The following recommended imple-
mentation Plan has resulted. When executed, it will provide a set
of measures which, together with existing controls, will satisfac-
torally mitigate potentially adverse impacts in environmentally
sensitive areas.
The implementation Plan calls for actions at the Federal, State and
local (County) levels of government. It consists of two primary
institutional mechanisms, a local-State Consent Order, and a
condition to the EPA Construction Grant award, each of which in
turn requires a number of individual actions. The Consent Order
and grant condition will serve as the legally binding instrument:?
for ensuring implementation of the individual mitigative measures
specified therein.
The grant condition, as currently envisioned, will contain two main
provisions:
1. It will require the Worcester County Sanitary Commission
to provide the State Department of Health and Mental Hygiene and
EPA, Region III with a set of maps prior to construction which
clearly delineate within the study area all wetland areas as
defined by the U.S. Fish and Wildlife Service and all lands with
the 100 year floodplain as defined by the Federal Emergency
Management Agency (FEMA). The naps will also delineate all
specific vacant parcels of land which lie partially or wholly
within the above floodplain or wetland boundaries, and will
indicate which parcels were platted as building lots prior to June
1, 1977 and which had been developed prior to the issuance of the
Final EIS.
2. It will require the WCSC to prohibit for a period of 30
years from the date of grant award any connections to the sewerage
system from structures located on any parcel of land subject to
development restrictions based on the above maps, i.e. any parcel
of land not platted as a building lot prior to June 1, 1977 which
lies partially or wholly within a wetland or floodplain area.
The Consent Order will be negotiated between WCSC and the State
Department of Health and Mental Hygiene, and is expected to contain
the following provisions:
77
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Timing
Monitoring and
Enforcement
1. It will require maps similar to those required by the
grant conditions, delineating floodplains, wetlands, and vacant
parcels therein.
2. It will require WCSC to incorporate the maps and connec-
tion restrictions in floodplains and wetlands into the County
Comprehensive Water and Sewerage Plan.
3. It will designate the County Environmental Health Director
as the responsible party for deciding whether or not a lot is
allowed sewer service.
4. It will require WCSC to establish a new permitting pro-
cess, or modify its existing plumbing permit process, to require an
undeveloped lot owner to obtain a permit for connection to the
sewer system prior to or concurrently with his application for a
construction permit. An owner of a developed lot would only be
required to obtain the connection and/or plumbing permit(s).
5. It will require WCSC to amend its administrative
procedures, and obtain additional resources, if necessary, to
assure compliance with the above provisions.
It is anticipated that the proposed Consent Order will be agreed to
and siqned prior to a Construction Grant award for West Ocean City.
If this occurs, then a grant condition as outlined above will be
included as part of the grant award. Should the Consent Order not
be negotiated and signed p.rior to a Construction Grant award, then
the grant condition may need to be modified to reflect the in-
complete status of this component of the mitigation plan.
Most of the provisions contained in the grant condition and Consent
Order will be required to be accomplished prior to local award of
any construction contracts. Certain of the provisions, however,
may not have to be implemented until prior to initial system
operation.
The primary monitoring and enforcement tool for the provisions of
the Consent Order is the Worcester County Water and Sewer Plan.
This Plan is a State Approved document that delineates those areas
in the County that are in need of water and/or sewer service and
when, within a period of ten years, such service is to be provided.
Each County Plan is required to be updated biennially and an
approval must be received for each update. A County Plan is also
the document against which a project is checked for conformance
before a State construction permit is issued. In light of this, by
withholding approval of Worcester County's next update until there
are adequate provisions contained therein to control development in
environmentally sensitive areas, the State Department of Health and
Mental Hygiene will be able to ensure compliance with its Consent
Order.
The reponsibility for monitoring compliance with the grant
condition provisions rests initially with the State DHMH as part of
the Construction Grant delegation agreement with EPA, and
ultimately with EPA itself. EPA may consider taking the following
actions if the qrantee (WCSC) fails to comply with the grant
conditions:
1. Terminating or annulling the qrant;
2. Disallowing project costs related to noncompliance;
3. Withholdinq project payments;
78
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4. Suspending work:
5. Finding the grantee to be nonresponsible or
ineligible for future Federal assistance or for
approval for future contract awards under EPA grants;
6. Seeking an injunction against the grantee; or
7. Instituting such other administrative or -judicial
action as may oe legally available and appropriate.
79
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REFERENCES
Carter, H. H. and R. J. Reqier, 1976. An Evaluation of the
Performance of the Ocean City, Maryland Diffuser. Chesapeake
Bay Institute. The Johns Hopkins University. Special Report
48. 45 PD.
Carter, H. H. and R. J. Reqier, 1978. A Physical Assessment of the
Maryland Coastal Waters to Receive wastewaters. Chesaoeake ^ay
Institute. The Johns Hookins University. Special Renort 62.
92 DP.
Connell, N. 1982. Letter to "velyn Schulz, EPA, re: Ocean City
treatment plant. District Engineer, Worcester County Sanitary
District. November 24, Snow Hill, Maryland. 2 np.
Mauqans, E. p. 1971. Letter to Dr. Max Eisenberq, Maryland
Environmental Health Administration re: observation wells in
West Ocean Citv. Worcester County Environmental Health
Director. September 7. Snow Hill, Maryland. 4 PP.
Mauqans, E. P. 1980. Letter to Norman Connel, Worcester Countv
Sanitary Commission re: septic tank drainfield failures in West
Ocean City. Worcester County Environmental Health Director.
December 12. Snow Hill, Maryland. 1 pp.
Mauqans, E. P. 1981. Personal communication with Andris Laoins,
ESEI re: qroundwater contamination. Worcester County
Environmental Health Director. November 24. Snow Hill,
Maryland.
Mauqans, E. P. 1982. Letter to Evelyn Schulz, EPA, re: septic
system failures. Worcester County Environmental Health
Director. December 8, Snow Hill, Maryland. 1 P.
Mauqans, E. p. 1982. Personal communication with Evelyn Schulz,
EPA re: saltwater intrusion. Worcester County Environmental
Health Director. Snow Hill, Maryland.
Morris, H. 1982. Personal communication with Evelyn Schulz, EPA,
re: saltwater intrusion. Director of Planninq and 2oninq,
Worcester County, Snow Hill, Maryland.
Nichols, B. 1982. Letter to Evelyn Schulz, EPA, Re: Erosion and
sedimentation control requirements in Worcester County.
District Conservationist, U. S. Department of Aqriculture, Soil
Conservation Service. November 23. Snow Hill, Maryland. 1 p.
U. S. Soil Conservation Service. 1973. Soil Survey of Worcester
County, Maryland. Maryland Aqricultural Experiment Station.
U. S. Government Printinq Office, May. Washinqton, D.C. 77 pp.
80
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LIST OF
PREPARERS
This Final Environmental Impact Statement was prepared by the U.S.
Environmental Protection Agency, Reaion III (Philadelphia) with
assistance from ESEI, inc.
Kev personnel from EPA included:
Evelyn Schulz Project Monitor
Thomas Slenkamn Project Administration
Karen Riscli .Secretary
Terrv Leo Secretary
Key personnel from ESEI, inc. included:
Lanny Rat;;, Ph.O Project Administrator
Lois Sheplak .... Secretary
81
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ilest Ocean City BIS
PisttTbution ~LTst
Federal Aqencies
Maryland State
Agencies
Reqional Agencies
Local Agencies
Advisory Council on Historic Preservation
Council on Environmental Quality
Federal Emergency Management Agency
National Agricultural Lands Study
US Bureau of Prisons
US Department of Agriculture
Soil Conservation Service
Farmers Home Administration
US Deoart-nent of the Army
Corps of Engineers, Baltimore District
US Department of Commerce
Office of Environmental Affairs
National Marine Fisheries Service
US Deoartment of Defense
US Department of Energy
Office of the Secretary for the Environment
US Department of Health and Human Services
US Department of Housing and Urban Development
US Department of Interior
Bureau of Outdoor Recreation
Fish and Wildlife Service
National Water Resource Analyses Group
Eastern Energy Land Use Team
National Park Service
Assateague Island National Seashore
US Department of Transportation
Marine Environmental Protection Division
US Department of the Treasury
US General Services Administration
Water Resources Council
Department of Agriculture
Department of Health and Mental Hygiene
Air Pollution Control Commission
Bureau of Air Quality and Noise Control
Office of Environmental Programs
Environmental Health Administration
Department of Natural Resources
Water Resources Administration
Department of Parks and Recreation
Assateague State Park
Department of State Planning
State Clearinghouse
Department of Transportation
State Highway Administration
State Clearinghouse
Water Quality Advisory Council
Regional Planning Council, Baltimore
Berlin
Council
Mayor
Ocean City
Mayor
Council
City Manager
Worcester County
Health Department
Planning Director
82
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Elected Officials
Citizens Groups
Media--Newspapers
Media—TV
Media--Radio
Libraries
Citizens
Governor Harry R. Hughes
Honorable Charles Mac Mathias, Jr., U.S. Senate
Honorable Paul Sarbanes, U.S. Senate
Honorable Dyson, U.S. Representative
Honorable Barbara Ann Mikulski, U.S. Representative
Honorable Clarence Dickinson Long, U.S. Representative
Honorable Marjorie Holt, U.S. Representative
Honorable Joseph J. Long, MD Representative
Honorable Robert C. Biggy Long, MD Representative
Committee to Preserve Assateague Island
Maryland Conservation Council
Maryland Environmental Trust
Sierra Club-BSA of Potomac Chapter
Environmental Defense Fund
Sierra Club-Delaware Group
Natural Resources Defense Council
The CNAC Committee
Baltimore Environmental Center, Inc.
Chesapeake Bay Foundatin
Chesapeake Environmental Protection Association
Environmental Concern, Inc.
Sierra CLab-Washington, D.C.
Maryland Wildlife Federation
Environmental Impact Reporter
Daily and Sunday Times, Salisbury., MD
Worcester County Messenger
Maryland Coast Press
Sun
Eastern Shore Times
Resort Publications
WBOC-TV
WCPB-TV
WETT-AM
WBOC-AM
WDMV-AM
WJDY-AM
WICO-AM
Berline Branch Library
Ocean City Branch Library
Worcester County Library
Rodney, Thomas L.
Fehrer, Ilia J.
Collins, Thomas H.
Burnett, K. King, Esq.
Polliuir., Ronald
Johnson, Albert
Woods, John J.
Stachurski, Joseph
Beard, William S., Esq.
Bouchared, Ernest M., Dr.
Chavoor, Arthur G., Dr.
Taylor, Robert, Dr.
Weisbeirg, Alan S., Dr.
Whitlock, Larry
Cherrix, Janet Holland
Kinqling, John
Megre, Beatrice
Hager, Harold
Gray, Bill and Sue
Hromadha, Eugene
Johnson, Albert F.
Fairman, Harold, Sr.
Harrington, William
Gillis, Lee
Kutch, Gordon, Jr.
Albright, Mildred
Brueckmann, Frances
Livingston, William C.
Cooper, Clifford M. Jr.
Hallman, R. W.
Pull, Ruth
Boyer, Bruce
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Fisher, Mr. and Mrs.
Stachurski, Stephen
Tyler, William
Cullum, Richard
Connolly, Harry J.
Lynch, William H.
Ilugosz, Stanley
Venable, William W.
Hazard, Shirley M.
DeAngelo, Dominick
Harrington, William F.
Curtis, Robert
Hartman, William
Caldwell, Louis
Crussey, Earl Sr.
Wandelt, Edward
Green, William S.
Bailey, Halcolm S.
Ayres, Guy R, III
Cannell, Norman
Spain, Michele
Schutz, Pam
Mason, P.E., Jr.
Dieke, Sally H.
Peterson, Ellen L.
Duquette, Herbert E.
Leggett, William
Putney, Helen
Cluman, Robert J.
Hickman, Cashar J.
Snillis, C.
Gordon, Mr.
Winter, Ruth
Mackuga, Joseph
Pull, Sherry
Hasting, Irma
Lynch, W. H.
Bankert, Helen
Evans, Charles
Booze, Louise and William
Lappe, George
Mariaer, Marleae
Winter, Ronald
Kremselt, Dr. and Mrs. Huqh
Dlubola, Ed
Faultnet, Murry D.
Vellucci, Rocco
Neal, J.
Brown, Paul F.
Seymour Doris
Cuddy, Mary
Harrington, Paul
Crompton, John E.
Hyrley, Gary R. Sr.
Leonard, Pam
Hensler, Pat
Withbugson, Erskin
Linz, Skilma
Hollenbaugh, Howard
Hopkins, Ed
Harrignton, Frank
Green, William S. Esq.
Leatherman, Stephen P., Dr.
Linaweaver, Pierce, Dr.
Phillips, E.
MacGee, Carlton
Clark, Jeff
McCabe, Vernon W. Jr.
Hickman, Louis J.
Harper, Ben
Pulhan, Ronald C.
Grabanck, R. Doyle
Smith, William E.
Clark, Bruce
Homerghausen, Mrs.
Floydmoore, Mr. and Mrs,
Albright, Jeff
Clark, Robert
Brittingham, Wilson
French, Wallace
Garniloff, Nick
Heran, Michael
Evans, George H.
Mauren, Mr. and Mrs.
Slechta, Mr. and Mrs.
Benston, Mr. and Mrs.
Urick, John J.
Sleckta, Joseph V.
Todd, Dan
Varuolo, Thomas T.
Adams, Gary Esq.
Scout, Francis
Rice, Cathy
Murray, Mary
Metro, Joseph M.
Jruger, James
Scanlon, Frank X.
Winter, Frank
Clarke, Wm. A. Lee III
Morgan, Helen G.
Jester, Bob
Anderson, Aloma H.
Heemann, Ann
Smith, Becky
Zabriskie, Everett L.
Willis, William
Bill, William C.
Lease, Kenneth
Kittel, Charles L.
Krabbe, Frank T.
Tomlinson, Peter E.
Llewellyn, D. David
Kruntick, Paul J.
Schultz, Lawrence A.
York, Floyd C.
Tyler, William
Harrington, Paul
Blaskes, John
Moriarty, Theresa A.
Schutz, Charles J.
Van winkle, Leroy
Stoecker, Karl
Elwell, Joseph G.
Whitlock, Lawrence T.
Jester, Robert L.
Clark, Bruce H.
Suluke, John P.
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Dauqherty, John C.
Moleski, Frederick 55., Dr.
Selway, Roger W.
Keefer, Scott D.
Cook, Harry
Koons, Elouise
Dyer, James E.
Met?, William T.
Elwell, Joseph
O'Connor, Thomas
Willis, Mr. and Mrs. W.
Wallnoter, Anthony P.
Slechta, John
Overby, Archie
Columbia, Mildred C.
Roberts, Thomas J,, Dr.
Chamberlain, H.S.
2aut'^, Marie T.
Brent, M.r. and Mrs.
N'eifert, Euqenia
Scheu, Mr. and Mrs.
Sutphin, Patricia
Gutenko, Theresa
Stein, Aileen
Ross, Arthur
Miller, L. T.
Heaps, Henry 0.
Einoff, Ronald E.
Carette, L.
Rush, Barbara
Higgs, Joseph W.
Heaney, James E.
Carlson, Vincent A.
Emler, John D.
Porter, Saundra G.
Irvin, Thomas D.
Chulick, Sylvia
Tiqani, Mr. and Mrs,
Reed, Mrs.
Palermo, Mary R.
Smith, B. G.
Price, Earl P. Jr.
Peist, Ernest L.
Millin, Crest Jr.
Gull, Janet
Hrioson, Richard J.
Dewey, Iris
Palter, Charles
Street, Pauly L
Adkins, Richard
Parker, Mehuin
Deviti, Michael
Eshara, Pauline J.
Thompson, Amelia
Scheu, Arthur J.
Heavel, Shirley
Lynch, William H.
Root, Fred M.
Gione, Ralph
Quienti, Albert
Caldwell, P. P.
Oliver, George
Money, Robert L.
Borles, Robert H.
Hudson, Edward L.
Advocat, Fred
Albert, Russell A.
NJE-,€ , John
Sapping, Robert E.
Steiner, Jean Marie
Brown, Paul F.
Urlck, John J.
McCormack, Barney
Richardson, Peter E.
Deputy, J. Christian
Gilliss, R. Lee Jr.
Sheoherd, Peter
Bloecker, John C. Jr.
Steen, Marvin
Conner, Thomas
Ingersall, B. S.
Serejim, Earl
Redden, Clintopn
Baker, William K.
Watson, A. Wayne
Phillies, Jeff
Stoecker, Karl
Sleckta, J. V.
Kelley, Albert S.
MacLeod, Bruce A.
RLqgis, William A.
Wellnof, G.
Hall, Dorothy A.
Marqaret, Barny
Sklar, Allen
Baker, Richard
Phillips, Edward A.
Van Fossen, John
Phillips, Ronald
Nartman, Warren
Palermo, Thomas
Birch, Clifford
Warren, H.
Kines, Bill
Kruger, James
Seller, Leonard
Elliott, Charles
Sklar, Ellen
Diubala, Ed
Wehage, Louis A.
Murphy, Edward
Maurew, R. D.
Winter, Mr. and Mrs.
Fulkres, Murry D.
Bush, Sterling
Eren, Toni
Timmons, Leon W.
uteal, Violet F. Helen
Harrison, Joseph G. Jr.
Katthews, Sewell
Christopher, Frank H.
Simpson, Helen
Jimme, Suzanne
Richardson, Pete
Welley, Mr. and Mrs.
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:her
Kraus, John C.
Davis, Robert Lee
Kirk, Douglas
Cathell, Norman H.
Connell, George B.
Blonawag, Ruby A.
Schafer, Dorothy
Chamberlin, Susan
Massey, Edward
.Einolf, Donald
Wy, George
Hazard, Shirley
Melvin, Lucy
Marshall, Leontine
Brown, Paul
Gulberry, Len
Weber, Fred
Buating, Jack
Conner, J. T.
Hire, Dot
Vernairi, Mae
Sconlon
Scrivener, Ralph
Bomb, William
Parker, Mitch
Bailey, Halcolm
Hanin, Hale
Armstrong, W. L.
Parks, Patrick S.
Gullen, John C.
Guntin, John F., Jr.
Gaitan, Paul
Selfmour, Delores
Cooke, Ruth U.
Jackson, Peter A.
Warren, James C.
Parker, Gene
Day, David
Day, Mr. and Mrs.
Kolarik, Stephen
Frenick, Wallace
Stonie, Tim
Paguette, Bob
Slesher, Joseph H.
McCabe, Vernon W. Jr
Cuggins, William A.
Purnel, H. S.
Payer, Albert
Grafe, LeRoy
Maugans, Peter
Booze, W. C.
Simpson, Uliebian Lee
Zimmons, Dale, Jr.
White, Jack A.
Cullum, Richard L.
White, Edward H.
Cropper, LeRoy
Hammond, Louise
Tyler, Ken
Seibeld, John
Witherspoon, Erskine
Varmil, Thomas F.
Harrington, Marie & Anna
Belnte, Evelyn
Anderson
Crompton, John
Zullin, John H.
Ailkins, Howard
Urumeford, John U.
Brittingham, William
Cook, Harry
Boonraan, Carol
Barry, Edna
Harper, Fran
Lovalvo, Joseph
Chesapeake Bay Center for Environmental Studies
University of Delaware
Edward H. Richardson Asso., Inc.
George, Miles, and Buhr
Gene Parker Real Estate
West Ocean City Limited Partnership
Baker Realty
S&M Construction Co.
The Bautz Realty Co.
Ken Tyler Real Estate
John Hopkins University
Roy F. Weston, Inc.
Kamber, Inc.
ESEI, inc.
VA Insitute of Marine Science
Chesapeake Foods, Inc.
Union Trust Co. of Maryland
Biohydronics, Inc.
International Environmental Engineers, Inc.
Associate Enterprises Development, Inc.
International Research and Evaluation
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Appendices
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APPENDIX A: EXECUTIVE SUMMARY OF DRAFT EIS
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IECDTIVE SUMMARY
jickground
le Facilities
The National Environmental Policy Act (NEPA) of 1969 requires all
Federal agencies to evaluate the potential consequences of provid-
ing Federal financial assistance. When the potential for adverse
impacts on the natural, human, and/or economic environment is sig-
nificant, an Environmental Impact Statement (EIS) is prepared. The
EIS process identifies all possible environmental and economic
impacts and recommends a plan which minimizes adverse impacts by
providing mitiqative measures for those which are unavoidable.
Federal funding through EPA's Construction Grants Program is one of
the Federal actions subject to the requirements of NEPA.
The West Ocean City Sanitary District has a lengthy history of
problems with failing septic systems due to unsuitable soils and a
high groundwater table. At the same time, the area has been under
pressure to develop due to its proximity to Ocean City. The
Worcester County Sanitary Commission (WCSC) first designed a sewage
collection system for West Ocean City in 1974. At that time, EPA
and the State of Maryland directed WCSC to prepare a Facilities
Plan for a larger region which included Ocean City, West Ocean City
and surrounding parts of the North Central Ocean Basin. EPA pre-
pared Draft and Final EISs ton the Facilities Plan in 1977 and 1978,
respectively, which recommended large-scale regional wastewater
treatment facilities and a new ocean outfall. Because of signifi-
cant unfavorable comments by Federal and State agencies as well as
environmental groups, EPA decided in 1978 not to endorse WCSC's
original project. EPA did provide funds to WCSC to upgrade the
Ocean City plant to secondary treatment and to expand the plant to
a capacity of 12.0 mgd. EPA and the State also agreed to take a
second look at the West Ocean City area.
The West Ocean City Sanitary District represents a very small por-
tion (2,300 acres) of the area covered by the original North
Central Ocean Basin (63,712 acres). Because of the continuing need
for a solution to failing septic systems, EPA decided to issue a
Facilities Plan grant amendment to WCSC which would focus solely on
the needs of West Ocean City. The amendment was to cover specific
Facilities Planning requirements, including:
1. Methods of sewage collection and treatment
2. Preparation of population projections
3. Identification of wastewater treatment needs
4. Consideration of environmentally sensitive features, including
wetlands, floodplains and prime agricultural lands
At the same time, EPA prepared this Supplement to the original
North Central Ocean Basin EIS which focuses on the following issues
related to West Ocean City:
1. Population growth and development induced by the availability
of sewer service
2. The effects of increased development on flood-prone areas,
wetlands and prime agricultural lands
3. The effects of increasing urbanization on the water quality of
the surrounding bays
4. The financial impacts on area residents of constructing and
operating a sewer system
This Draft EIS contains an analysis of wastewater collection and
treatment alternatives proposed in WCSC's Facilities Plan
Amendment. George, Miles and Buhr, Inc., the engineering
consultants to WCSC, evaluated the alternatives for engineering
A-l
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Existing
Environment
feasibility and cost. EPA has examined the alternatives from an
environmental standpoint. The Facilities Plan and EIS have b
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the Alternatives
;wer Service Area
Future Population—Construction has been severely curtailed since
1976 due to the implementation of strict septic tank permit regula-
tions. If sewer service and centralized treatment are not pro-
vided, the peak seasonal population is expected to increase by only
560 persons to 5,868 in the year 2000. If a sewer system were in
place, the restrictions on housing construction would be lifted.
West Ocean City's population would probably grow at a rate similar
to that which occurs now in the neighboring communities of Ocean
Pines/Berlin where sewer service is already available. The year
2000 population with a Federally-funded sewer system is estimated
to be 13,920 persons. If a sewer system were constructed with
local funds only and not constrained by State and Federal environ-
mental requirements, the year 2000 population is estimated to be
17,700 persons.
WCSC's Facilities Plan Amendment describes various alternatives to
meet West Ocean City's wastewater treatment needs through the year
2000. The alternatives cover four basic areas:
0 Where will sewer service be provided? How will environmentally-
sensitive areas be protected from construction-related damage
and loss through future development?
° How will the wastewater be collected?
" How will the wastewater be treated and disposed?
* How will the project be funded?
Any Federally-funded sewer system and the area it serves must
comply with Federal regulations and policies to protect environ-
mental resources from direct damage and indirect loss through
development. The entire system must be environmentally acceptable;
this includes that portion of the sewerage system which is for new
development and therefore cannot receive Federal funding. At the
start of the alternatives development process, EPA and the State
provided guidance on limitations which must be placed on West Ocean
City's sewer service area if Federal funding is to be sought. Each
resource was given careful consideration. The intent was to mini-
mize the damage and loss of environmental values, but at the same
time minimize the economic impact on local residents and land-
owners. The following paragraphs describe the Federal policies and
appropriate limitations:
Flood-prone Areas—Executive Order (EO) 11988 on Floodplain Manage-
mentwas issued on May 24, 1977. All Federal agencies must now
avoid taking part in any actions which cause the occupancy, modifi-
cation and development of flood-prone areas. This includes
financing for public services such as sewers which would promote
floodplain development. Because most of the area's existing septic
tank problems are located in the floodplain, sewer service will be
permitted for all existing structures where required. However, new
development must be limited. Sewer service will be permitted for
only those undeveloped lots which were platted as building lots
prior to May 1977. This date corresponds roughly to the issuance
of EO 11988 and the stringent septic system requirements which have
restricted development. The sewer service capacity must also be
limited to that required for one equivalent dwelling unit (i.e. 280
gallons per day). This will permit individual homeowners, and in
some cases small businesses, to develop their land. New sub-
divisions and major development in flood-prone areas cannot be
served by a Federally-funded system.
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Wastewater
Collection
Treatment and
Disposal
Wetlands—EO 11990 on the Protection of Wetlands was also issued en
May 24, 1977. The objectives of EO 11990 were to avoid the
destruction or loss of wetlands, avoid Federally-funded
construction in wetlands, and preserve and enhance their values as
wildlife nurseries and sources of water purification and
groundwater recharge. Like EO L1988, EO 11990 applies to a1.!
Federally-funded projects, including the Construction Grants
Program.
No sewer service will be permitted within the area's wetlands. T'ie
wetlands which surround West Ocean City are a valuable resource in
their present undisturbed state.
Prime Agricultural Lands—Prime farmlands are those which have the
best combinationoTsoil characteristics, growing season and
moisture supply for producing crops. In September 1978, EPA issued
a Policy Statement to Protect Environmentally Significant Agri-
cultural Lands in recognition of their value and the need to
preserve farmlands wherever potentially affected by agency action.
Worcester County has a program to preserve the County's 250,000
acres of agricultural land through provisions in the County's
Comprehensive Plan and Zoning Ordinance. The plan states that West
Ocean City should be developed in order to protect farmland in the
rest of the county. Sewer service will be permitted here on
residentially zoned lands, but not in agricultural zones. No
interceptor will be permitted across the east-west portion of Golf
Course Read. EPA regulations prohibit extension of interceptors
through environmentally sensitive lands when there is no existing
need for sewer service.
Non-sensitive Areas—Sewer service can be provided in a manner
consistent withlocal comprehensive plans, zoning regulations and
population projections.
Sensitive Areas Which Cannot Receive Federally-funded Sewer Ser-
vice—Any development In these areas must be supported by the use
ofon-si';e wastewater treatment systems where permitted under the
requirements of State policies.
Three sewage collection systems were evaluated for use in West
Ocean Ci^y: gravity, pressure and vacuum systems. Proposed sower
routes are nearly the same for each system. For the most part, the
sewer alignments follow existing roads and railroad rights-of-way.
Because these areas have already been disturbed, no significant
damage to the environment is anticipated. Traffic disruption could
be minimized by scheduling construction during the off-tourist
season. Principal differences between the three systems are caased
by construction requirements and costs for operation and
maintenance. The gravity system is the most expensive system to
construct as deep trenches (3 to 15 feet) and extensive dewatering
would be required. This system would have the lowest long-term
costs for operation and maintenance. Pressure and vacuum systems
have lower construction costs and would require much shallower
trenches. However, these systems are more expensive to operate and
maintain because of power requirements and additional equipment
which must be purchased annually. The Facilities Plan recommends
that a gravity system be installed on the basis of lowest t.otal
cost over 20 years.
Several options were examined for treatment and ultimate disposal
of raw sewage collected. The wastewater flow is projected to be
974,000 gallons per day based on a year 2000 population of 13.920.
Discharge of treated effluent to surrounding surface waters cannot
A-4
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it Comparison
be considered because of the sensitivity and limited capacity of
these bays to accept existing discharges. Land application is an
attractive alternative, but not viable because of the lack of
suitable soils. For West Ocean City, the only remaining disposal
option is use of the existing ocean outfall in Ocean City.
Two treatment options were considered. In the first, raw sewage
collected in West Ocean City would be pumped through a 16-inch
force main under Sinepuxent Bay to the Ocean City sewage collection
system at 15th street. From this point, the combined flow would be
transported to the Ocean City plant at 64th Street for treatment
and disposal. The Ocean City plant has a capacity of 12.0 million
gallons per day (mgd); this should be adequate for the 11.5 mgd
Ocean City flow and 0.5 mgd West Ocean City flow through 1985. In
1985, WCSC plans to expand the Ocean City plant to a capacity of
20.5 mgd. West Ocean City would then have to contribute its share
(10.5% based on eventual use of 1.0 mgd of capacity) of the cost
for expansion. In the second alternative, a new 1.0 mgd secondary
treatment plant would be constructed in West Ocean City. Treated
effluent from the West Ocean City plant would be pumped across the
Bay to Ocean City. Because the treated effluent and Ocean City's
raw sewage could not be mixed, the force main would be extended to
the Ocean City treatment plant outfall for discharge. Of the two
options, treatment and disposal using Ocean City's existing plant
and outfall has the lower cost.
Wastewater treatment and disposal costs are composed of capital
(construction) costs and the long-term costs of operation and
maintenance (O&M). To compare the cost-effectiveness of each
alternative, the total present worth ic used. The total present
worth is based on the sum of the capital and O&M costs over the
20-year planning period less the value of any equipment which can
be salvaged after 20 years. This sum is then amortized to reach to
current value of each expenditure. This permits a more accurate
comparison of alternatives which are inexpensive to build but
expensive to maintain. The following table shows costs for the
treatment and collection alternatives as presented in WCSC's
Facilities Plan.
Treatment/Disposal
Alternative
Ocean City treatment
and disposal
West Ocean City
Treatment and Ocean
City disposal
West Ocean City
treatment and land
application
Capital
O&M
Total
Present Worth
$3,480,400 $1,190,400 $4,223,900
8,343,000 2,096,500 9,698,900
8,431,800 1,678,100 9,352,300
A-5
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The Selected Plan
Collection
Alternative
Gravity Sewers
Pressure Sewers
Vacuum Sewers
Capital
8,057,000
7,219,400
6,723,900
O&M
517,000
2,790,000*
2,638,600*
Total
Present Worth
7,706,000
9,252,600
8,884,400
*Includes costs for purchasing additional equipment for new
development.
Land application costs are illustrated for comparison, but this
treatment method is not feasible due to the lack of suitable so;.Is
in the area.
The Facilities Plan recommends wajstewater collection by gravity
sewers and treatment/disposal using the Ocean City treatment plant
and ocean outfall as the lowest cost combination. In addition to
alleviating seepage by the area's failing septic systems, t-jis
alternative would allow population growth and development to
resume. There is a high unsatisfied demand for housing in the
area. If the amount and location of development is implemented
according to EPA and State guidance, impacts on wetlands, flood—
prone areas and prime agricultural lands would be minimized. One
of the potential adverse impacts of implementing this plan would be
the financial impact on area residents. The user charges may be
high for persons on fixed or limited incomes. WCSC could establish
a user charge system which reduces charges somewhat to local resi-
dents, while increasing costs to commercial and industrial users.
Growth under the selected plan will cause changes in the volume and
pollutant loads of runoff. Additional public services will also be
required to accommodate the projected population increase.
Because of the limitations which must be placed on sewer service in
a Federally-funded system, the Facilities Plan also considers a
system which would be funded totally by local residents but wsuld
not be constrained by environmental regulations. The following is
a brief sketch of the differences.
Acres to be
developed
Year 2000
Populat ion
Wastewater
Flow (mgd)
Local share of
capital cost
Federally-funded
1287 with restrictions
on amount of development
13,920
.975
Locally-funded
2300 with development
per local zoning
17,700
1.239
$3,379,200 plus $1,801,800 $11,608,900 plus
for 1985 expansion $2,220,700 in 1985
User Charges
Because of State limitations on bond issuance, the locally-funded
alternative could only be financed with a direct assessment to
property owners benefiting from the system. An up-front assessment
of $4,400/acre would be charged in addition to the new unit hookup
charges, service line construction costs and annual front-footage
assessment and O&M fees.
Fees to be paid by local residents and land owners are estimated in
the Facilities Plan. These user charges have several components:
A-e
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1. A front-footage assessment based on lot width to be paid
annually by all property owners in the service area. This
assessment would cover local bonds issued to pay for
construction costs.
2. An annual operation and maintenance (O&M) charge to be paid by
all residents and businesses served by the system.
3. A one-time hookup fee of $600-800 to be paid by all new
development.
4. A one-time private cost of $500-1,500 to individual homeowners
to pay for plumbing and other costs to install a service line
between the house and the sewer lateral at the property line in
the street.
User charges will also be affected by the availability of Federal
funds. The Ocean City treatment plant may have to be expanded in
1985. Should this occur, West Ocean City will have to pay for its
share (10%) of the expansion. The Facilities Plan assumes that
Federal funds will be available in 1985 to cover part of the cost
of the expansion; West Ocean City's share of the local cost would
be $585,600. The potential Ocean City expansion may, however, be
Federally funded. In that case, West Ocean City's contribution
would be $1,801,900. The following tables show estimates of user
charges for West Ocean City, based on the draft Facilities Plan.
One-time costs for hookup of new units and installation of private
service lines are not included.
Annual User Charges
expansion in 1985:
Front Foot Rate
+
O&M Costs for
one residence
=
Total by lot width
50 ft.
100 ft.
200 ft.
300 ft.
Annual User Charges
expansion in 1985:
Front Foot Rate
+
O&M Cost for
one residence
Total Costs by
lot width
50 ft.
100 ft.
200 ft.
300 ft.
with no grant funding for the
1983
1985
1990
$2.62/ft $4.25/ft $4.25/ft
$ 86
$217
$348
$610
$872
$ 86
$ 299
$ 511
$ 936
74
$ 287
$ 499
$ 924
$1,349
Ocean City
2000
$4.25/ft
$ 73
$ 286
$ 498
$ 923
$1,348
with Federal funding for the Ocean City
1983
1985
1990
$2.62/ft $3.02/ft $3.02/ft
$ 86/yr
217
348
610
872
$ 86/yr
237
388
690
992
$ 74/yr
225
376
678
980
_20.°_0_
$3.02/ft
$ 73/yr
224
375
677
979
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Affordability
Preliminary
Recommendations
The Decision-
making Process
These charges assume that each user, residences and businesses,
will be charged the same rate. Charges could be reduced to hone-
owners sonewhat if rates for commercial and industrial users were
raised. WCSC has the responsibility to prepare user charge systems
within the County. In the two existing systems, WCSC does charge
higher rcites to commercial and industrial users; because WCSC's
rates are based on the number of fixtures, multiple dwelling units
also pay higher costs.
In an attempt to reduce the cost burden to system users, WCSC
recently made revisions to the draft Facilities Plan's proposed
project and financing assumptions. These changes yield :he
following figures:
Annual user Charges with no grant funding for the Ocean City
expansion in 1985 and assuming $800,000 from the Maryland Failing
Septic Tank Program:
1983
1985
1990
2000
Front Foot Rate
+
O&M Costs; for
one residence
$1.41/ft $2.91/ft $2.91/ft $2.91/ft
Total Costs
lot width
50 ft.
100 ft.
200 ft.
300 ft.
by
$ 80
150
221
362
503
$ 80
226
371
662
953
$ 69
215
360
651
942
$ 68
214
359
650
941
These changes will be presented by WCSC at the upcoming puolic
hearing specified in the front of this document.
Depending on lot widths and the cost assumptions utilized, the
estimates of user charges in many cases exceed EPA guidance' on
affordafcility. Based on median income, any cost greater than S371
per year may be expensive for the average Worcester County resi-
dent. It is impossible to determine how much the average West
Ocean City resident/property owner can afford to pay. Roughly 50%
of West Ocean City residents are seasonal visitors only. I:, is
unlikely that their incomes appear in Worcester County ecoromic
data. In addition, income data are also not available for the
large number of property owners who do not have residences in the
area. A detailed financial analysis was performed on the capa-
bility of WCSC, Worcester County and the West Ocean City Sanitary
District to construct and support the costs of the system. The
analysis indicated that the community as a whole can support the
project, but the margin of safety is very small (see Appendi*: D) .
EPA recognizes that the Facilities Plan's selected alternative has
the lowest cost of those examined. However, the proposed user
charges may place a financial burden on some residents. WCSC and
the Worcester County Commissioners will make the final decision to
apply for a construction grant. This should not be done without
full support by West Ocean City's residents. WCSC must also camply
with EPA and State limitations on sewer service in environmentally
sensitive areas.
Both the costs and environmental impact information should be
reviewed carefully by area residents and other interested parties
to determine which of the alternatives, if any, is preferable.
A-8
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Ample time will be made available to study the material contained
in the Draft EIS and raise questions. Following public distribu-
tion of the Draft BIS, there will be a 45-day review and comment
period during which time a public hearing will be held.
The Draft EIS will be distributed to government agencies, citizens
and other interested groups on the mailing list which appears in
Chapter VI. All concerned citizens, groups and agencies should
forward their opinions and comments to EPA. EPA will carefully
evaluate any comments received and make any necessary changes to
the alternatives analysis based on these comments. A response to
substantive comments will be provided in the Final EIS, which will
be completed following the end of the Draft EIS review period.
Also in the Final BIS, EPA will identify a recommended alternative
for implementation, with consideration given to public comments,
local government positions and the cost and impact evaluations
described in the Draft EIS. EPA will also indicate whether other
alternatives may also be acceptable and can be considered for
Federal funding.
A-9
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APPENCIS B: DRAFT EIS COMMENT LETTERS
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JOAN AV£
BALTIMORE HO Z1234
B-l
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HARRY HUGHES
GOVERNOR
MARYLAND
DEPARTMENT OF STATE PLANNING
3O 1 W. PRESTON STREET
BALTIMORE. MARYLAND 2 1 201
&
CONSTANCE LIEDER
SECRETARY
September 22, 198;
Mr. Peter N. Bibko
Regional Administrator
U.S. Environmental Protaction Agency
Region III
6th And Walnut Streets
Philadelphia, Pennsylvania 19106
RE: State Clearinghouse Project - DEIS _ West Qcean city
Facilities, Worcester Co. 82-9-940
Dear Mr. Bibko:
The State Clearinghouse has received the above project. The review of this
project has now been initiated and you may expect a reply from us by
November 5. 1982 _ • If you have any questions concerning this review,
please contact ^_ Samuel ._Saker , ( 3 §3 - 7 87 6 ) of this Clearinghouse.
We are interested in your project and will make every effort to ensure prompt
action. Thank you for your cooperation with the Clearinghouse program.
Sincerely,
F. Bryan Gatch
Acting Director, State Clearinghouse
cc: Francis Aluisi
SB:pm
TELEPHONE: 301-383- 7821.
OFFICE OF STATE CLEARINGHOUSE
B-2
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LAW OFFICES
RISQUE W. PL.UMMER
THE LAW BUILDING
•425 ST. PAUL. Pt_ACE
BALTIMORE. MARYLAND 212O2
TELEPHONE:
OFFICE 3Ol.68S.lsoo
RESIDENCE 301-689-2243
/? V? fi /
^
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B-4
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October 19, 1932
Ms. Evelyn Schultz
United States Environmental Protection Agency
Region 3
Sixth & Walnut Sts.
Phila., Pa. 19106
Dear Ms. Schultz:
I have received a copy of the Draft EIS for West Ocean
City Wastewater Treatment Facilities, and I would like to
re-affirm my support for sewer service.
I was in attendance at the May 1982 meeting, but I am
unable to attend the October 27th meeting.
I ara a property owner in Cape Isle of Wight and am strongly
in favor of sewer service in that area.
Please keep my name on your mailing list for this project.
Yours very truly,
DONALD E. EINOLF
906 Pine Heights Ave.
Baltimore, Md. 21229
B-5
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U.S. Department of
Transportation
Office of the Secretary
of Transportation
Regional Representative
of the Secretary
October 22, 1982
Region III
434 Walnut Street
Philadelphia, PA. 19106
Evelyn Schulz
EIS Preparation Section
EPA, Region III
Curtis Building
6th & Walnut Streets
Philadelphia, PA 19106
(3PM61)
Dear Ms. Schulz:
The following is the Department of Transportation consolidated
response for the West Ocean City Draft EIS. This document was
forwarded for review to the Fifth Coast Guard District, Maritime
Administration (Eastern Region), Federal Aviation Administration
(Eastern Region), and Federal Highway Administration (Region III).
There are no continents to be offered relative to this EIS with
the exception that comment might be made in the final EIS to the
effect that the design and construction of the facility will continue
to be coordinated with the appropriate state and local highway officials
The Department of Transportation appreciates this opportunity
to comment and appreciates the efforts which have adequately addressed
the probable impacts to the transportation modes.
George D. Bond, II
Lieutenant Commander, USCG
Senior Staff Officer
B-6
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Centers for Disease Control
Atlanta, Georgia 30333
(404) 452-4095
October 25, 1982
Ms. Evelyn B. Schulz
U.S. Environmental Protection Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Schulz:
We have reviewed the Draft Environmental Impact Statement (EIS) for West Ocean
City Wastewater Treatment Facilities, Worcester County, Maryland. We are respond-
ing on behalf of the Public Health Service.
We have reviewed this document for possible health effects and find that with
one exception the EIS adequately addresses our concerns. It was noted that the
EIS did not consider reducing per capita water use in conjunction with any of the
alternatives discussed. The City should encourage water saving devices in all
new construction and in the replacement of existing fixtures through review and
revision of local codes. The Final EIS should address this issue.
Thank you for the opportunity of reviewing this EIS. Please send us a copy of
the final statement when it becomes available. If you should have any questions
about our comments please contact Mr. Lee Tate of my staff at FTS 236-6649.
Sincerely yours,
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
B-7
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DEPARTMENT OF THE ARMY
8»L~IMORE DISTRICT. CORPS OF ENGINEEHS
P.O. BOX 1715
BALTIMORE. MARYLAND 212Q3
REPLV TO ATTENTION OF:
NABPL-E
26 October 1982
Ms. Evelyn B. Schulz
Project Manager
United States Environmental
Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Schulz:
This letter is in response to your Draft Environmental Impact Statement (DEIS),
West Ocean City Wastewater Treatment Facilities, located in Worcester County,
Maryland. Comments are directed toward the alternatives under consideration
for the proposed project as they relate to Corps of Engineers' areas of concern.
This agency's areas of concern are flood control hazard potentials, permit
requirements under Section 404 of the Clean Water Act, Sections 9, 10, and 13
of the River and Harbor Act of 1899, and other direct and indirect impacts on
Corps of Engineers' existing and/or proposed projects.
The Flood Plain Management Services Program is the Corps' means of using its
technical expertise in flood plain management matters to help those outside
the Corps, both Federal and non-Federal, to deal with floods and flood plain
related matters. The subject DEIS provides sufficient and adequate flood
plain related information concerning the project and potential adverse impacts
from encroachments on the area's flood plains.
The work described will require Department of the Army authorization pursuant
to Section 10 of the River and Harbor Act of 1899 and Section 404 of the Clean
Water Act. Any plans should be referred and application made to the Baltimore
District Office. For more specific information regarding permit needs, please
contact Mr. Woody Francis of the Regulatory Functions Branch of Operations
Division at (301) 962-4500.
The Corps presently maintains a navigation channel and a jetty project within
the immediate vicinity of the proposed project. It has been determined that
the proposed construction would not adversely impact these projects. Currentlj,
the Corps is studying beach and hurricane protection from the Ocean City Inlet
to the Delaware state line; however, the proposed wastewater treatment facilities
are not anticipated to have an adverse impact on this study.
B-8
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26 October 1982
Ms. Evelyn B. Schulz
The Baltimore District appreciates the opportunity to comment on your DEIS and
would appreciate a review of the Final Environmental Impact Statement following
its preparation. If you have any questions regarding that which has been pro-
vided or if we can be of further assistance, please do not hesitate to contact
either Mr. Rick Popino or Mr. Larry Lower of my staff at (301) 962-2558.
Sincerely,
ILLIAM E. TRIESCHMAN, Jr.
Chief, Planning Division
B-9
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Federal Emergency Management Agency
Region III 6th & Walnut Streets Philadelphia, Pennsylvania 19106
November 2, 1982
RE: Draft E.I.S. - West Ocean City
Wastewater Treatment Facilities
Ms. Evelyn B. Schulz
U. S, Environmental Protection Agency
Region III
6th & Walnut Streets
Philadelphia, PA 19106
Dear Ms. Shulz;
We have reviewed the West Ocean City Draft E.I.S., specifically those sections
concerned with the application of Executive Order 11988. As we have indicated
in our earlier correspondence and in meetings of the EIS Coordination Committee,
FEMA believes EPA policy for limiting sewer service in West Ocean City consistent
with the Executive Order.
In January, 1979 we commented on the Final E.I.S. for the North Central Ocean
Basin Facilities Plan. Ou:: comments concerning E.G. L1988 were prompted by
plans to provide sewer service, and thus facilitate development of, large
areas of the one hundred year floodplain in Worcester County.
FEMA has always recognized that EPA in implementing the Executive Order is not
released from its obligation to address water pollution problems in floodplain
areas. The policies developed over the last several years appear to us to
constitute a very reasonable approach to balancing the mandate of the Construction
Grants Program and the Executive Order.
In previous correspondence (December 28, 1979) we indicated that we were
essentially in agreement with the decision to limit service to those lots that
were individually platted prior to May 1977. While we believe the date of
Directive GS-6 (January, 1976) would have been a more appropriate date, since
it can reasonably be argueid that as of that date "existing need" was recognized,
the actual difference in the number of lots to which service would be available
is probably inconsequential. Again, however, we wish to point out that there is
no "grandfathering" provision in the Executive Order as could be inferred from
EPA's use of May 1977, th<> date of the Order's issuance, as a cut-off date for
sewer service.
We believe it essential that the Final E.I.S. detail how the limitations on
service will be implemented. We believe the limitations should be spelled out in the
funding agreement between EPA and the Sanitary District and the agreement should
specify that the Sanitary District, based on the agreement, will deny permits
except on the designated lots.
If any further clarifications of our comments are needed, please contact Joseph
Gavin at 597-1849.
Sincerely yours,
U
Walter P. Pierson
Chief
Natural and Technological
Hazards Division
B-10
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The..Maryland Wetlands .Committee: .-.-_
416 Edgemere Drive
Annapolis, Maryland 21403
Mr Peter Bibko, Regional Administrator October 28, 1982
U.S. Environmental Protection Agency
Region 111
6t" and Walnut Streets
Philadelphia. Pa. 19106
Dear Mr. Bibko:
I am writing to you on behalf of the Maryland Wetlands Committee,
a citizen's organization concerned with state water quality issues and the pre-
servation of wetland habitat. The following comments are in reference to the Draft
Environmental Impact Statement for the West Ocean City Wastewater Treatment Facil-
ities, Worcester County, Maryland.
Upon reviewing this permit, and after learning of the high productiv-
ity levels of the state wetlands in Assawoman Bay, I am concerned about the use of
federal funds for the filling of 8.4 acres of prime wetland habitat as proposed by
this p^rr.iu.
When we consider that the ocurrcnce of submerged aquatic vegetation,
such as wigeon grass, in the Chesapeake Bay has been affected by nutrient loading
and sedimentation, it becomes clear that, whenever possible, we should attempt to
balance these losses. The Coastal Wetlands of Maryland publication ranks wigeon
grass as,"...the most important food plant for waterfowl in the coastal zone of
Maryland." pg. 80 The diversity of shellfish and finfish species found in Assawoman
Bay is, no doubt, related to the variety of submerged and emergent vegetation that
have established themselves therein.
There are, at this time, no plans to mitigate the loss of wetlands
from this project. Thus, the Maryland Wetlands Committee is requesting that both
the city owned Playland Property and the canal just north of this property be
utilized for the sewage plant expansion project.
At nhis time only 10% of the land in Ocean City remains available
for development. Thus, we question the need for a sewage treatment plant that will
be expanded for a 25 ngd. capacity especially if this expansion will take place in
a highly flood prone area that is now a productive wetland.
B-ll
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UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
Washington. D.C. 30230
OFFICE OF THE ADMINISTRATOR
November 1, 1982
Mr. Peter N. Ribko
Regional Administrator
U.S. Environmental Protection Agency
6th ?< Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Bibko:
This is in reference ":o your draft envi ronnental impact statement
entitled "West Ocean City Hastewater Treatment Facilities, Worcester County,
Maryland." The enclosed comments from the National Oceanic and Atmospheric
Administration are forwarded for your consideration.
Thank you for giving js an opportunity to provide comments. We would
appreciate receiving two copies of the final environmental impact statement.
Sincerely,
Joyce T!. Wood
-------
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Services Division
Habitat Protection Branch
7 Pleasant Street
Gloucester, Massachusetts 01930-3799
OCT261982
Mr. Peter N. Bibko
Regional Administrator
U.S. Environmental Protection Agency
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Bibko:
The National Marine Fisheries Service has reviewed the Draft Environmental
Impact Statement (DEIS) entitled West Ocean City Wastewater Treatment Facilities,
Worcester County, Maryland.
The selected plan involving construction of a gravity feed collection system
with sewage treatment and disposal at the existing Ocean City facility should
not result in significant adverse impacts to living marine resources or habitat
in the short-term. However, implementation of the plan, as projected in the
DEIS, would cause the Ocean City facility to reach capacity by 1985. To accom-
modate anticipated demands in the area subsequent to 1985 would require expansion
of existing or construction of new treatment facilities.
Currently, the Worcester County Sewage Commission has submitted to the
Maryland Department of Natural Resources a proposal for expansion of the Ocean City
plant (enclosed). The expansion, as proposed, will entail extensive dredging
and filling of submergent and emergent wetlands. Additionally, the Maryland
Tidewater Fisheries Division has found this site to be an important nursery area *
for marine and estuarine species.
It is not clear whether or not the request to expand the Ocean City facility
is associated with the proposed link-up with West Ocean City, or is in response
to increased demand for development in Ocean City. If the request is in response
to the latter, the selected plan does not seem feasible to alleviate West Ocean
City's sewage problems because it implies that the Ocean City plantis presently
operating at full capacity. If the request is in response to the former, it
appears that the selected plan is directly responsible for the proposed expansion
and the associated adverse environmental impacts. In either case, the proposed
expansion should be discussed in the Final Environmental Impact Statement (FEIS)
relative to the selected or alternative plans.
The proposed expansion problem is further complicated by the fact that city-
owned uplands contiguous with the existing sewage treatment facility are available.
We recommend that the Environmental Protection Agency address and, if possible,
resolve these issues.
B-13
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The biological impacts of crossing Sinepuxent Bay with submerged sewage
pipelines are not addressed in the DEIS. The proposed pipeline could be attached
to the Route 50 Bridge to eliminate impacts to Sinepuxent Bay entirely. A
similar alternative was proposed in the FEIS for the North Central Ocean Basin,
Regional Wastewater Treatment Facility. This alternative should be discussed
in the FEIS.
Should you have any questions concerning our corrments, please do not hesitate
to call.
Sincerely,
Ruth 0. Rehfus
Branch Chief
Enclosure
B-14
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JAMES B. COULTER
SECRETARY
STATE OF MARYLAND
DEPARTMENT OF NATURAL RESOURCES
TIDEWATER ADMINISTflAYlON (3Q1 ) 269-2784
TAWES STATE OFFICE BUIL.DING
ANNAPOLIS 214O1
LOUIS N. PMIPPS. Jft.
DEPUTY SECRETARY
September 27, 1982
MEMORANDUM
TO:
TRCM:
SUBJ:
Harold Cassell, Chief
Wetlands Permit Division, WRA,
Sarah Taylor, Directo,
Coastal Resources Of
idewater Administration
Wetland Case 83-WL-0101, Worchester County
Sanitary Commission
The following comments, are submitted on the application for a wetlands
license by Worchester County Sanitary Commission to expand the wastewater
treitment plant at 64th St. in Ocean City. The applicant proposes to fill
cppvox'iiiflt'dly 8.5 acres of State wetlands to create the fastland needed
for t-h? expansion. The fill material will be obtained from the proposed
dredgin« of approximately 7.4 acres of open water area.
Tho major issues with the project are (1) the filling of shallow open
water And tidal marsh and the resultant loss of valuable fisheries habitat;
and (2} t!ie dredging of State wetlands for the purpose of obtaining fill
material to be used for the creation of fastland.
We recognize that there are public benefits to be derived from the
project. However, there is an alternative upland site available to carry
cut the objectives of the project. We recommend that this alternative be
fully explored prior to any consideration of approving the filling of State
wetlands to carry out the project. The following comments are submitted in
support of this recommendation.
r1ro j e c tD e s c rip t ip JT_
The applicant proposes to conduct the following activities (attachment 1):
- to construct a 1300 feet long by 12 feet high earthen dike within
a maximum of 750 feet channelward of the mean high water line;
TTV FOR OPAF - BALTIMORE ?H<»-2BO9 W* -T
B-15
-------
raroli Cassell
-2-
to fill approximately 8.5 acres of tide"! wetlands within the dike
consisting of approximately 7 acres of shallow open water bottom
1.5 acres of tidal marsh;
to obtain fill by dredging approximately 170,000 cubic yards of
material from a 7.4 acre open water area immediately channel ward of
the proposed dike.
Issues
The major issues associated with the project are the following:
(1) The filling of 8.5 acres of tidal wetlands and associated loss
-------
tarold Cassell
September 27, 1S3Z
addressed. These are: (1 ) the availability of an alternative upland site,
and (2) the proposed dredging for fill material. As noted in the following
section of this memorandum, the filling of State or private wetlands for
the purpose of creating fasti and is generally considered contrary to the
public interest, unless there is no feasible upland site available and there
is sufficient economic benefits (public benefits) to be derived. If these
conditions are satisfied and filling is approved for a particular project, it
is a policy to require that suitable quality fill material be obtained from
an appropriate land-based' source and not dredged from State or private
wetlands.
Based on discussions with Wetlands Permit Division personnel, the un-
developed land immediately north of the wastewater treatment plant is owned
by the town of Ocean City and appears to be of sufficient area to accomodate
the proposed expansion. Although not owned by Worchester County, the
possibility of an agreement between the County and the town of Ocean City
to use this land would appear to represent a viable alternative to the filling
of State wetlands. The possibility of using this land should be fully
explored prior to considering approval of wetlands license to create the
fastland necessary for the expansion.
Consistency with CZMP Objectives/Policies
The following objectives and policies of the CZMP relating to activities
occurring in tidal wetlands are applicable to this project. The objectives
and policies are found in Chapter III of the CZM Program Document.
(3) To protect coastal aquatic areas of significant resource value and
where possible, restore presently degraded areas of potentially signi-
ficant resource value, such as viable oyster bars and clam beds, important
fish.migratory pathways, spawning, jiursery and feeding areas, and
wintering and resting areas for migratory birds.
(4) To protect, maintain, and where feasible? restore the integrity of
the tidal wetlands of the State.
In carrying out these objectives it is the policy of the State to allow
dredging or filling of State or private wetlands only to the extent necessary
to provide reasonable riparian access, to provide necessary shore erosion
control, or to carry out necessary water-dependent activities. Approval to
dredge and fill private or State wetlands in undertaking a water-dependent
activity must be based on the following conditions being satisfied to the
extent possible:
- The project cannot feasibly be undertaken on adjacent or nearby
fastland;
- It is not feasible to provide the project's intended service by an
alternative means not involving the filling of wetlands;
- The creation of fastland should occur only in those areas adjoining
existing fastlands;
- No ecologically productive submerged wetlands, such as finfish and
shellfish spawning and habitat areas shall be destroyed;
B-17
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Harold Cassell
September 27, 19S2
- No areas important for feeding, nesting, or resting of waterfowl or
other valuable wildlife habitat shall be destroyed;
•• Fill utilized for the creation of fasti and shall be obtained from an
appropriate land-based source and not dredged from private or State
wetlands.
The filling of 1.5 ecres of marsh and the loss of shallow water habitat
are inconsistent with objectives (3) and (4). However, from a long-term
standpoint it appears that the wastewater treatment plant expansion is justi-
fied and there are public benefits to be realized. There is adequate fastland
for the project just north of the existing plant'; however, there is not
sufficient information available to determine if this is a feasible alternative
to the filling of State wetlands.
Additionally, the proposal to dredge eight acres of State wetlands to
obtain fill material is inconsistent with the above mentioned policy regarding
fill material. .
ST:EG:gvs
Attachments
cc: Pete Jensen, Director
Tidal Fisheries Division
B-18
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ASSAWGMAN-..BAV
DHC:DC;;;G TO
ELEV. -iJ.O
BORROW AREA
LIMIT Lliii
POINT "T" —
REA TO 3£ DREDGED
R£A TO S£ FJLLEJ3
ROGATION MAP
SCALE IN NAUTICAL MILES
oat 2
' PLAN
SCALE IN FEET
200 400
80O
rj -i'
jdW •-"^'^^/a.rd.
!. APPROXIMATELY 170,000 CY. TO 3E
OREOGSD AMD PLACED \H FILL AREA.
2. SOUKDINCS AND ELEVATIONS REFEH
TO WEAK LOW WATER IN ATLANTIC
OCEAN AT OCEAN CITY, MARYLAND.
3. BORROV.' AF:EA LIMIT LINE AND BULK-
. HEAD LINE AS ESTABLISHED BY
SENATE BILL NO. 465.
4. DREDGED MATERIAL TO BE SAND AKO
GRAVEL. -
83-WL-0101 _. . i • ..
Sheet 1 of 1
PROPOSED x DREDGING
IN
ASSAV/OMAN BAY
AT OCEAN CITY
WORCESTER
STATE
lOW C.8C.S. CHART NO. 1220
WORCESTER COUNT-
APPLICATION BY SANITARY DiSTRtC-
SNOW
DATE JULY, 1982
B-19
-------
JAMES B. COULTER
SECRETARY
LOUIS N.PHI =PS. JR.
DEPUTY SEC »ETA»Y
TO:
FROM:
SUBJECT:
STATE OF MARYLAND
DEPARTMENT OF NATURAL RESOURCES
TIDEWATER ADMINISTRATION
TAWES STATE OFFICE BUILDING
ANNAPOLIS 2I4OI
MEMORANDUM
September 15, 1982
Elder UJs^QhB. giar elli
Pete Jenser
Ocean City Sewage Treatment Plant expansion 83-WL-0101, Worcester Coun;y
Sanitary Con
sion
The applicant proposes to bulkhead and fill 8,5 acres of shallow water and
marsh in Assawoman Bay immediately west of the Ocean City Sewage Treatment Plant.
Fill material would be dredged from just outboard of the proposed bulkhead,
effectively doubling the disturbed area. The proposed project would result in the
destruction of aquatic habitat and dependent biota which we are mandated to protect
and conserve.
These comments were prepared by Bob Lunsford and Steve Early, Technical
'Assistance/Habitat Protection. "
The proposed fill area consists of seven (?) acres of shallow open water and
1.5 acres of State wetlands. This shallow water area has been sampled eight tiiies
since 1973 as a part of the regular Coastal Bays Seine Survey. Results are
presented in Table 1. A trawl survey was conducted on 8 September 1982; results
are presented in Table 2. Species assemblage from this area is considered to bn
among the most diverse of all survey sites in Maryland Coastal Bays.
Filling of the marsh and intertidal zone would destroy one of the most
productive zones of the coastal bays. Production from, this area serves as one of
the primary bases of all other production of aquatic life. Primary consumers
which benefit directly from marsh production serve as food base for recreationally
and commercially important fin and shellfish species. Dependent species include:
bluecrab, silver perch, hogchokers, anchovy, spot, croaker, and weakfish. Secondary
carnivores which in turn are dependent upon this production include: bluefish,
summer flounder, northern barracuda, sea bass and jack crevalle. These species as
well as many others have been captured at the project site. See Appendix A for
further explication.
Shallow water habitat is critically important to young of year fish.
fish are able to escape predation by larger species by retreating to shallow
water. Shoal areas not only offer a relatively protected resting areas but aro
B-20
TTY FOR OEAF — BALTIMORE 2O»-1«OB. WASHINGTON METWO
-------
Eider Ghigiarelli
September 15, 1982
Page 2
extremely important as feeding areas for the primary consumer level finfish.
During our 8 Sept. visit young of year fish of four species were collected (silver
perch, black seabass, spot, and summer flounder). Additional species have been
represented at the site by young of year which are ultimately the mainstay of
commercial and recreational fisheries. For undetermined reasons this shallow
water area is also particularly attractive to exotic species such as penaeid shrimp,
spotfin butterfly fish, pin fish, horse-eye jack, black drum and jack crevalle.
These species are currently on display at the National Park Service office at
Assateague.
Two species of submerged aquatic vegetation are found in the proposed dredge
.and fill site, widgeon grass and eel grass. Eel and widgeon grass are important
to fish as nursery areas and spawning medium (Stevenson & Confer, 1978). Widgeon
grass is considered important to fish as a ' source of shade as well as food
in that the epibiota and infauna, which include algae, protozoans, isopods,
anphipods polychaetes, bivalves and decapods; are utilized by fish. Grass beds are
particularly important to Juvenile fish which have higher growth efficiencies than
older fish. We also note that both widgeon and eel grass are utilized by
waterfowl.
Further investigations of the proposed dredge and fill sites have
demonstrated the existence of hard clams (M. mercenaria) (J. Casey, pers conm).
The hard clan population in the fill area is estimated to be over 9500. This
density is considered low average for commercial harvesting. We have no records
to indicate commercial use of this area, however, recreational clammers have been
observed in the proposed fill area. Recreational fishing in the coastal bays is
one attraction of Ocean City.
The borrow area for fill material is located just west of the proposed
bulkhead line and would be dredged to an elevation of minus 15 feet. Other deep
dredge holes in Assawoman Bay become anoxic below the surrounding bottom level
during at least part of each year (J. Casey, in file data). This effectively
removes the area as suitable habitat for fish and shellfish and in theory reduces
potential standing crop.
Aquatic species (fish and shellfish) which otherwise would utilize the proposed
dredge and fill areas cannot simply emigrate to other habitat if their own is
destroyed, because in general all habitat is filled to capacity. Destruction of a
unit of habitat is essentially equivalent to the destruction of the dependent
biota and therefore a reduction in standing crop upon which recreational and
commercial fishing industries are dependent.
PJ:jac
B-21
-------
Appendix A.
Marsh production serves as one of the primary bases of all other production
of life in the estuary. Along with green phytoplankton, and influx of green — -
plants form river floodplains, marsh grass combines radiant energy from sunlight
with carbon dioxide, water and inorganic elements to produce the basic foods
that all other life is dependent upon. Keefe and Boynton (1973) found an average ,
production of 2.25 tons per acre in Chincoteague Bay and cited eleven other studies
of marsh production which had reported a range of 1.39 to 13.38 tons per acre.
Heinle, et. al. (197*0 collected samples from the Patuxent River marshes which
averaged 7«^ tons per acre production.
Conversion of this primary production into animal flesh occurs primarily
vhen the dead material falls and is flushed into the water by the tides. Keefe
and Boynton (1973) discuss the importance of the lower zones of the marsh, which.
are flushed more regularly, and provide faster decomposition of dead material,
Massman (1971) notes that decay by bacterial and fungal action breaks down the
detritus into microscopic and larger particles. It has been shown that the
protein value of the detrital material increases for the primary consumer level
because of the aggregation of the decomposer species upon the detrital material;
Odum and de la Cruz (19^7) showed that this protein content quadrupled. Protein
content for recently dead material was 6% whereas that of decayed material was
2k%.
The primary consumers which directly benefit from this process of energy
fixation, decomposition and enrichment are amphipods, opposum shrimp, panaeid
shrimp, copepods, cladocerans, isopods, Crab larvae and bivalve shellfish.
Secondary consumers are the fish which feed directly upon the above listed
animals. Food studies (Vsjn Engel & Joseph 1968) on the most abundant of the
young fishes in shallow estuarine waters showed that either myscid shrimp,
amphipods or both were among the most important foods for White perch, hogchokers,
bay anchovy, spot, croaker, weakfish, sliver perch and southern kingfish.
Weakfish and striped bass preyed extensively on the larvae of anchovies and
naked gobies (Massman 1971). Massman cited other studies showing that striped
bass young feed directly on opposum shrimp and amphipods.
B-22
-------
LITERATURE CITED
Casey,. J.p. Tidal Fisheries Division, in file data.
Gosselin, J. G., E.P. odum, and R.M. Pope. 197^. The value of the tidal marsh.
Louisiana State University Sea Grant Pub. LSU-SG-7U-03.
Keefe, E. and W.R. Boynton. 1973. Standing crop of sale marshes surrounding
Chincoteague Bay, Maryland-Virginia. Chesapeake Science lM2):117-12l».
Massman, W.H. 1971- The significance of an estuary on the "biology of aquatic
organisms of the middle Atlantic region. Sport fishing Inst: A symposium
on the "biological significance for estuaries, 2/13/70.
Odum, E.P. and A.A. dela Cruz. 19^7. Particulate organic detritus in a Georgia
saltmarsh estuarine ecosystem, in Lauff, G. (ed.). 1967. Estuaries.
American Acad. Adv. Sci. Pub. Ho. 83.
Stevenson, J.C. and N.M. Confer. 1978. Summary of available information on
Chesapeake Bay submerged vegetation. USDI FWS/OBS-78/66.
Sweet, D.C. 1971« The economic and social importance of estuaries. E.P.A.
Water Quality Office, Washington, D.C.
Van Engel, W.A. and E.B. Joseph. 1968. Characterization of coastal and
estuarine fish nursery grounds as natural communities. Va. Inst. Mar.
Sci. P.L. 88-309 Va. 3-19-R-2 Final Report.
B-23
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Table 1
Species List for 8 September 82 Trawls At Proposed
SEWAGE TREATMENT PLANT EXPANSION AREA
Species Caught In Trawls
Travl
Reptiles
Diamondback Terrapins 1
Osteaththyes
Silver Perch
Bairdiella ohrysura
Spot
Leiostomus xanthurus
Pipefish
Syngnathus guscus
Cloridae
Black sea bass
Centrgpiristis striata.
Pin Fish
Langodon rhomboides
Spotfin butterflyfish
Chaetodon ocellatus
Simmer flounder
Parali_chthys_ dent at us.
Oyster toadfish
Opsanus tau
Anchovies
Anchoa mitchilli
hepsetus
Blue Crab
" ' " Callinectes; sapidus "
Horseshoe crab
Limulus, polyphemus '
Penaeid Shrimp
Penaeus spp
Grass Shrimp
Polomenetes spp
40
52
2
3
1
1
23
3
Trawl #2
1
8
86
9
2
29
3
k
308
1
10
1
3
82
B-24
-------
Species Dens icy As Je-: ermine a iy Seir.a IP rroposea Fill Area For
Ocean City Sewage Tr2a~~2n~ J" ••"":, .-ssawc.T.sn Say, 1973-1982 (S^.-.M^I
Species
1973 1974 'iJ75 ,9/7 1978
.•.'unbars/Hectare
i 979 1 981
962
American eel
Anchovy
Sluefisn
Conner
Croaker
Flounder,
winter
Flounder,
summer
Horseeye jack
"umniichog
Striped killifish
Sheeps head
minnow
Mullet
Atlantic
Needlefish
Northern
Barracuda
Menhaden
Naked Goby
Pipefish
Pinfish
Spot
3 spine
S-jrickleback
Atlantic
Silverside
Sea 3ass
Smooth Dogfish
Shark
Southern
Stingray
Sea Green Goby
Toad fish
Jack Crevalle
Blue Crab
Round Pompatao
Mud Crab
Spider Crab
Hermit Crab
Horseshoe Crab
Grass Shrimp
Pink Shrimp
Sand Shrimp
Penaeid Shrimp
363
1 6^66
206
10
27
14
30
14
20
6864
10
259
50
1705
41533
30
120 7
1-5 115
29 13
261
122
14 7
44 937 19
338
2450
44 7063 110
65 7
14 131
44 64
7
73
1349 316 1586
53 300G6 258
71
6
14 120 6
189 242 311
1 934
261
116
24
65
37
22
196
95
14
65
124
13734
37
771
3659
640
378
22
37
1659
7
14
1382
87
13
394
7
67
18
121
30
42
176
67
24
6
30
163
6
3027
60
784
1052
74
188
2111
20
14
536
14
4897
20
14
67
3578
382
744
->
25 }
< ^
p
2
27
8
7
724
32
Z
2
12
3
1331
3304
5
15
7
504
2
2
12
205
2
B-25
-------
Table 2 (continued)
Species Density As Determined By Seine In Proposed Fill Area For
Ocean City Sewage Treatment Plant, Assawoman Bay, 1973-1982 (summer;
Species
Year
1973 1974 1975 1977 1978
Numbers/Hectare
1979 1981 1982
Silver perch
Blue mussel
Mud Snail
Lady Crab
12
Z
12
2
B-26
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Worcester Enbironmental
A COUNTY COMMITTEE OF THE MARYLAND ENVIRONMENTAL TRUST
POST OFFICE BOX 38
SNOW HILL. MARYLAND 21863
632-2640
November 3, 1982
Ms, Evelyn Schulz
Project Monitor
West Ocean City Wastewater Treatment Facilities -
Worcester County, Maryland
United States Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Schulz:
These comments are in response to the Draft EIS on West Ocean City Waste-
water Treatment Facilities, Worcester County, Maryland.
The Worcester Environmental Trust is pleased that attention is focused on
the West Ocean City area> which is experiencing water quality problems.
These problems are due primarily to past poor land use decisions, i.e., the
creation of small lots in poorly drained soils.
We are concerned that residents of West Ocean City will be expected to under-
write more than their fair share of the proposed expansion of the Ocean City
Waste?rater Treatment Facilities by being asked to assume 10. ££ of the cost.
We question the need for almost doubling Ocean City's wastewater capacity
when Ocean City has been substantially developed and West Ocean City's input
will be limited to 1-mgd.
We question statistics on page 11 of the SIS which state that ^h% of a total
of I,3lj8 dwellings experienced septic tank failures. The number of repeat
failures is not made clear. One hundred homes could have had 7.32 failures
in the past 10 or 20 years to yield that same figure. To our knowledge,
periodic septic tank maintenance, a much cheaper alternative, has not been
adequately explored as a remedy.
We question the statement that flood plains have been historically attractive
for population centers. Conversely, flood plains have usually been lands
that speculators could buy cheaper and sell to those unaware of the problems
of flooding, high water tables, and poor drainage.
We feel that not enough attention has bee: ?;iven in the EIS to salt water
contamination of potable drinking water due to draw down of Ocean City's
aquifers. As the area grows and becomes more heavily used year around, salt
water intrusion will have to be dealt with. Presently Ocean City is consider-
ing mainland wells to augment its water supnly. Costs of providing a potable
water supply for West Ocean City also needs to be addressed.
B-27
En\ ironment. the I rust - Man. the Trustee
-------
The Worcester Environmental Trust opposes the filling; of -wetlands for expan-
sion of the present Ocean City sewage treatment plant and the siting of pump-
ing stations in West Ocean City. In addition, we feel the mati on page 50 of
the EIS, Figure III-l, shov/ing property lines as cf 1976, unrealistically
reflects developable property. Some of these lots were platted over 50 years
ago and are in wetlands. They cannot be develonec..
More attention should be addressed to the effect of rising sea level and the
bay's encroachment on ^resent low "upland areas." Many oldtimers remember
land bridges to •'what are now islands in Assawoman Bay.
We are concerned about secondary impacts of development. It is necessary to
clear and grade in preparation for building new homes and streets. The run-
off during the construction phase of development is a contributing factor to
loss of submerged aquatic vegetation, necessary for the health and productiv-
ity of the bay.
We feel that stringent requirements will be necessary regarding the burial of
pipes so as to minimize runoff during the construction phase.
Deep holes now exist in Assarroman Bay due to past dredging practices, when
bay bottom was used for fill in Ocean City. We feel that a detailed study of
the pipeline route under the bay will be necessary. Disruption and sedimenta-
tion of shallow, nea1" shore areas important to the marine eco-system can be
anticipated if care is not taken.
V»re feel growth of the West Ocean City area should not be comoared with Ocean
Pines. Ocean Pines has tight local environmental controls and a functioning
community ^overnnent infrastructure which makes it attractive to purchasers
•who seek a certain life style and protection of their investment.
Clarification is needed regarding the Carter-Regier study of 1978. This study
addressed diffusion of sewage effluent in the ocean, not its effect on benthic
organisms or marine ecology. See page 62 (in my copy of the EIS this page
should be numbered 63), also pages 6U and 72.
Vie take issue with comments that there are no major sources of air pollution
in the county (page U5). People in Berlin and elsewhere would take issue with
that.
We feel that there has not been sincere dedication to exploring less costly
alternatives to solving failing septic tank problems in West Ocean City. The
consulting eagineers are comfortable with traditional wastewater treatment
techniques.
Vfe take issue with the statement on page 65 of the SIS that land application
of wastewater effluent vrould result in contamination of ground water and should
be restricted to non-food crops. This need not be the casn if the waste-water
were properly treated. Ocean City sludge is now being land spread for use as a
nutrient for food crops. We also feel the amount of acreage required for land
treatment is overestimated.
B-28
-------
Regarding th = proposed seafood park, thsre are so many economic and environ-
mental constraints that :-?e foe], it should not be used to he3c justify an in-
creased demand for lo-v income housing. This oxnensivn -vistev/ater treatment
pro.iact may be financially out of reach to lo'.v income households. Also, vre
question th<- statement on p.-..^e lh v;hich nays that v/ator and se-ver arr> not;
essential for the seafood park. After all, th<= fi~h are to be cV?np.--st
Ocean Git" Y,'ast,-:-vrat.cr Treatment J^ilitir-s in ordrr t-o rror,ect p-nvirormr-ntally
s~ n 3 it ive are a E :
1. r.'on-tidal as -•(T>].I as tid-i" v.T-tlar.'i;; rr.ur;t be r>r~ served.
c. Pr^npnt n.^r' ci.7 t,ur--lly r.one-'i 1-n.rvir should not bn allo-.ved ftrn
3. }-"!mn -ronr- -ir^i." rlatte'i rrior to 1977 nnouVx be .'ill ov: -•=>;•• only mi ninal
df?vriorr.enb i.r-'i structure? s^ou'id adhere to cor.':-'.".ior:~ rrt :'ort.'-. in the
Fe'iern! Floo'i Insurance, Act adopted by '.'.'orccstcr County :.n 1979' Thir nay
require a l~r~-"r county enforcersnt staff, '^hc county hns no builairt code.
ii. Protection 01 the coastal bays from rr.noff r-nd 3ef'.i mentation should b-- in-
corno rated ?.r a ^rant condition. V.ratrr Duality o:' our coast'ii bays -.vas a
;.vi,jor reason for .justjfyin^ the sewering of the '"e-st Ocean City area. In-
stall'iiion and maintenance of sediment control facilities should bn made a
condition of tr.e project,
!~. Th*? diameter of the force main ur.drr the bay neens to be grossly evrrsif.ed.
Bec.?,u:.3e of inf iltration/inflo-.T nroblemn due to rrettlip.'-. tree roots, addi-
tional water •.: i-ct • ~.^ ; !-.-.<-. r.r. -if Kxr>eut,iv<- Ord^r^ 119flfi .in i 1T99O. Zones inc^nrat-ibl i?
, ••- • . .. ..„ ,-....-,, .. . .r,, .- w.. .,. ... .,, •-. ,. .. ._....,,.; ;;j.oul-J b*> d o;7n7 or..- .-1
••- .-'-:". <-ct, •..':••> c-r-nty' :i co.-mitraent to abide by the EIS rcccmendations.
-"" : -.' its -h-: ih ,irr> nn r?aner only should he revier.-pd for viability and at>-
ororriateness in todays "nvlronment.
7. The Jnite-i States 5nviron-r.er.tal i'rotcction A^e-'-cy and Maryland's Smdron-
rnental Health Administration should reviev: the referendum ballot sent to
-vest Ocean City nropr;rty ovrners by th^ ",Vorcester County Sanitary Co:rjnissi:>n,
to ensure thnt it adequately reflects the true cost of the proposed wante-
r/atf-r treatment facilities,
In surmary. v;e (jc^norally support the finding arid conclusions of thn DEIS if
economical ly ncceotablo to local resident:-. Hov'-vrr, the .-'inal L1S should in-
B-29
-------
elude means for guiranteeirr; the protection of environmentally sensitive
areas.
V/e appreciate the opportunity to corrjnent on the Draft EIS.
Sincerely yours,
Ilia J. Fehrer (Mrs. Joseph)
Co-Chairman
B-30
-------
IN REPLY REFER TO:
FWS/ES
ER 82/1558
United States Department of the Interior
OFFICE OF THE SECRETARY
Office of Environmental Project Review
15 State Street
Boston, Massachusetts 02109
November 1, 1982
L
Mr. Peter N. Bibko
Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Bibko:
This responds to your request for the Department of the Interior's conuncn1;.:
on the draft environmental impact statement for the West Ocean City Waste-
water Treatment Facilities, Worcester County, Maryland (ER 82/1558).
General Comments
This DEIS was written to concentrate on the issues of user affordability
and primary and secondary impacts on floodplains, wetlands, and prime
agricultural lands. The statement also provides a good discussion of
federal floodplain and wetland policies and the need for required Corps
of Engineers permits for this project.
This Department believes that the restriction of sewer service to lots
platted prior to 1977 and the selection of treatment and disposal at the
Ocean City facility are environmentally acceptable and consistent with
Executive Orders 11988 and 11990.
Specific Comments
The graphics in the final statement should depict the presence of Assateague
National Park System. In addition, it is our understanding that interest
has been expressed in the development of a fish processing plant within the
sewer service area. Should this proposal evolve further, we would anticipate
that additional studies should be instituted to assess project impacts on
Assateague. Further coordination with Superintendent Finley is appropriate
if such a project causes alteration of the treatment facility plans.
p. 43 Threatened and Endangered Species. This discussion constitutes little
more than a species list. No assessment of potential project impacts to
these species is presented. Conclusions regarding potential impacts (whether
NOV 081982
3PMOO
B-31
-------
direct or indirect, positive or negative) need to be discussed, including
tne rationale used in reaching those conclusions. If no impacts to threatened
tr endangered species are anticipated, a statement to that effect with the
supporting evidence should be included.
p. 47 No-action alteratnative. This section correctly explains that construc-
tion of a locally funded alternative would mean fewer restrictions by Federal
policies and regulations on future development in environmentally sensitive
areas. However, we feel that the statement incorrectly implies that this
would apply to all Federal policies and regulations, which is not true. Develop
tnent in wetlands and cor.struction in Sinepuxent. 3c.y would still require permits
from the Army Corps of Engineers, and are thus subject to Federal regulation.
This should be clarified in the final EIS.
p. 74 Growth Effects on Wetlands
Although well put toget ler overall, the analysis of project impacts on
wetlands is too limited in scope in this section as it fails to consider
impacts on aquatic organisms dependent on the wetlands. It states that
increased urbanization will elevate levels of nutrients and biochemical
oxygen demand (estimated at 13%) and will increase toxic materials such
as hydrocarbons and heavy metals by an unspecified amount.
As reviewed earlier in the statement, one of the benefits of wetlands is
the improvement of water quality through the removal of nutrients. But
it is shortsighted to assume that wetlands can filter and assimilate toxic
materials without subsequent harm to aquatic organisms. This Department
believes that it is within the intent and scope of this EIS to determine
if the existing stormwater management system is adequate to minimize
impacts on wetland fish and wildlife resources from nonpoint source toxic
materials generated due to increased development. The final EIS should
determine if additional concern and action are warranted in this regard,
Summary Comments
This Department commends the efforts of the EIS Coordination Committee to
minimize development in floodplains and wetlands while still addressing the
need for sewer service: in the West Ocean City area. We recommend that our
specific comments be Incorporated in the final statement to insure a complete
evaluation of project impacts.
Based on our evaluation of the project as presented in this draft statement,
the Fish and Wildlife Service would likely have no objection to the issuance
of the necessary permits from the Corps of Engineers. We do, however, reserve
the right to offer further comments on such permits when detailed project plans
are available.
Thank you for the opportunity to comment on this document.
Sincerely yours,
William P. Patterson
Regional Environmental Officer
B-32
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
PHILADELPHIA REGIONAL OFFICE
CURTIS BUILDING. SIXTH AND WALNUT STREETS
PHILADELPHIA, PENNSYLVANIA 19106
REGION III
I rsl REPLY REFER TO;
NOV 4 1982
Ms. Evelyn B, Schulz
Environmental Protection Agency
Region III
6th & Walnut Streets
Philadelphia, PA 19106
Dear Mr. Schulz:
We have completed our review of the DEIS for the West Ocean City
Wastewater Treatment Facilities in Worcester County, Maryland and offer
the following comments.
1. On P. 49, the DEIS indicates that Federal and State guidance
for the area stated that sewer service could be planned for
developed and undeveloped lots in the 100 year floodplain,
only if they were platted as building lots which had a selling
capability prior to May, 1977. What specific "Federal and State
Guidance" does the document refer to and on what is it based?
Also, how would the policy of limiting development, as described,
be implemented and its permanence assured? Finally, what is meant
by "building lots which had a selling capability prior to May,
1977"? This would appear to suggest that not all lots plotted
prior to May, 1977 could be built upon. Because these proposed
safeguards are so basic to the selected plan, we feel that there
should be some discussion of their legal basis in the Final EIS.
2. Table III-l on p. 53 shows Year 2000 estimates of equivalent dwelling
units and population by Service Area. We feel that the EIS
discussion of impacts would be enhanced if 1980 population and dwelling
units, by the same Service Areas, were added to this Table to show
where the greatest increase would occur.
3. In the discussion of growth effects on public services (p. 86),
fire protection, ambulance service and education are identified as
adequate to meet the needs of the projected population. While this
B-33
AREA OFFICES
Baltimore. Maryland - Philadelphia, Pennsylvania - Pittsburgh. Pennsylvania - Richmond. Virginia - Washington. D.C.
-------
may be the case, we could find no discussion or analysis in the
DEIS to support this assertion. We recommend, therefore, that
documentation and analysis in support of this conclusion be included
in the Final EIS. In addition, we note that although mentioned in
the introductory paragraph, there is no discussion of the impact of
population growth on tie solid waste disposal facilities of the
community. Nor is there any discussion of transportation impacts
beyond references to Routes 50, 707 and 611. Given the boost to
development that would occur in the subdivisions north of Route 50,
the adequacy of the principal roads serving these areas should be
examined and a discussion of impacts included in the discussion of
growth effects.
Thank you for the opportunity to comment on this "Draft EIS.
appreciate a copy of the final statement when it is completed.
We would
Sincerely,
thomas J. Gola
Regional Admin
inl4tra|jor, 3S
B-34
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Advisory
Council On
Historic
Preservation
1522 K Struct. NW
Washington. DC 20005
NOV 4 1982
Mr. Peter N. Bibko
Regional Administrator, Region III
U. S, Environmental Protection Agency
6th and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Bibko:
We have reviewed the Draft Environmental Impact Statement (DEIS) for
wastewater treatment facilities, West Ocean City, Worcester County,
Maryland. We understand that the Maryland State Historic Preservation
Officer (SHPO) has been consulted, and that EPA is prepared to ensure
that additional identification studies and other steps, as necessary,
are taken under the National Historic Preservation Act and the Council's
regulations, 36 CFR Part 800 (see pp. 43-44; 71). Therefore, we have no
substantive comments at this time. If you have questions or wish assistance,
please contact Staff Archeologist Ronald Anzalone at 202-254-3974 (an
FTS number).
5on L. Klima
Chief, Eastern Division of
Project Review
B-35
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MARYLAND
DEPARTMENT OF STATE PLANNING
30t W. PRESTON STREET
BALTIMORE. MARYLAND 212O1-2365
HARRY HUGHES
GOVERNOR
CONSTANCE LIEDER
SECRETARY
November 19, 1982
Mr. Peter N. Bibko
Regional Administrator
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Penna. 19106
SUBJECT: ENVIUCNMENTAL IMPACT STATEMENT (EIS) REVIEW
Applicant: Worcester County Sanitary Commission
Project: DEIS - West Ocean City WWT Faciltieis, Worcester Co.
State Clearinghouse Control Number: 82-9-940
Dear Mr. Bibko:
The State Clearinghouse has reviewed the above project. Acting under Article
88C of the Annotated Code of Maryland and Federal Executive Order 12372, the
State Clearinghouse received comments from the following:
Department of Agriculture, Department of Economic and Community Development
including their Historical Trust s-ection, Office of Environmental Programs,
Department of Transportation, University of Maryland Center for Environmenta.
and Estuarine Studies, and Ocean City noted that the draft EIS appears to
adequately cover those areas of interest to their agencies.
Department of Natural Resources indicated that the Department will forward
comments directly to EOA.
Worcester County advised that the County will respond directly to the applicant.
Our staff review comments (copy attached) recommended that the statement on
page iii under "Future Population" be modified.
We appreciate this opportunity to review the draft EIS and for your attention
to the review process.
Sincerely,
F. Bryan Gatch ^ ~t
Acting Director, State
cc: Lowell Frederick/Clyde Pyers/Herbert Sachs/Max Eisenberg/Praricis AluisL/'l
A. W, Barrett/Dennis Taylor/Wayne Cawley/John Yankus/Jeff 3Er@£ee -\
v;. "'" *J
FBG:SB:pm **
TELEPHONE: 301 383-7700
TTY for Deaf: 301 -383-7555
OFFICE OF SECRETARY
B-36
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1CTS REPORT
Maryland Department of State Planning
State Office Building
301 West Preston Street ^, /
Baltimore, Maryland 21201 Date: 772.7/ P*-
SUBJECT: ENVIRONMENTAL IMPACT STATEMENT OR ENVIRONMENTAL El
Applicant: Worcester Co. Sanitary Commission
Project: DEIS - West Ocean City WWT Facilities, Worcester Co
State Clearinghouse Control Number: 82-9-940
We have reviewed the above draft environmental impact statement and our
comments as to the adequacy of treatment of physical, ecological, and
socioxugical effects of concern are shown below:
Check (X) for each item
^ None
1. Additional specific effects which
should be assessed: X
2. Additional alternatives which should
be considered:
3. Better or more appropriate measures and
standards which should be used to ^
evaluate environmental effects: ^
4. Additional control measures which
should be applied to reduce adverse
environmental effects or to avoid
or minimize the irreversible of
irretrievable commitment of resources:
5. Assessment- of seriousness of the
environmental damage from this
project, using the best alternative X
and control meausres:
6. Activities which appear to be inconsistent
with the State approved Coastal Zone
Management Program.
7. Issues which require further dis-
| cussion of resolution as shown: %
Comment enclosed
y
*
^^L
Signature
Title_ Ci
Agency.
Address
B-37
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West Ocean City - Draft EIS
Department of State Planning Staff Comments
2. The alternative of West Ocean City buying current capacity in the
existing O.C. STP, and letting O.C. pa/ fc- any future necessary
expansion.
4 & 6. While the locally funded alternatives to serve the area indicate
that additional development will be possible through lack of
constraints in prime agricultural and flood plain lands, certain
State development policies, and Coastal Zone policies would
discourage development in such sensitive or valuable areas.
While the assumption is that this increment of development may
be possible under current local zoning, an evaluation of State
policy and legal constraints was not made in the EIS. Therefor,
the Statement on P. iii of the EIS under the "Future Population"
paragraph stating tjat tje state sewer system would not be
constrained by State and Federal environmental requirements
under the local funding option should be modified. Certain of
these requirements at both State and Federal levels of government
may still apply regardless of funding source.
B-33
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OFFICE OF ENVIRONMENTAL PROGRAMS
DEPARTMENT OF HEALTH AND MENTAL HYGIENE
BALTIMORE. MARYLAND 21201 * Area Code 301 • 383-2761
201 WEST PRESTON STREET
Harry Hucjhes, Governor
Charles R. Buck, Jr., Sc.D. Secretary
November 26, 1982
Ms. Evelyn Schulz, Project Monitor
EIS Preparation Section
U.S. Environmental Protection Agency
Sixth and Walnut streets
Philadelphia, Pennsylvania 19106
Dear Ms, Schulz:
Re: C-240407-OK.24) , Step 1
Worcester County
Sanitary Commission
West Ocean City Facility Plan
Draft EIS
This office has reviewed the draft of the referenced Environmental
Impact Statement (EIS) and, overall, we find the document to be a chorough
analysis of the probable primary and secondary environmental impacts associated
with constructing the proposed sewerage facilities. There are, however, two
issues in the EIS,project affordability and implementation of the recommended
mitigating measures, which we feel need to be examined in greater detail. A
discussion of our concerns follows:
1. The financial capability analysis was prepared prior to a decision by
this office to favorably consider the use of $800,000 of Failing
Septic Tank Grant Funds to reduce.1983 user fees to what we consider
to be a fair and reasonable level of approximately $220 per year
(for a 100' wide lot), which is seemingly affordable for the
community as a whole. In 1985, or whenever the Ocean City plant is
expanded, the yearly user fees are expected to escalate to $371
(1001 lot). Although this revised cost figure is $17 less than the
one presented in the EIS, we feel it does not change the outcome of
the financial capability analysis, i.e. the project still has a small
margin of safety relative to affordability and, as such, the local
officials should take a cautious approach in deciding this project's
fate. However, we feel this conclusion has limited applicability
because its development failed to consider the element of public
input. Regardless of the accuracy of the assumptions and the input
data used in the analysis, the ultimate decision on affordability •
lies in the collective decisions of the potential users of the system.
B-39
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Ms. Evelyn Schulz
Page Two
Should the affected public decide to reject this project, knowing
full well the economics involved, then we would be inclined to
conclude that the project is not affordable, even though the economic
indicators indicate otherwise. In summary, we feel public opinion
should play a major role in the decision making process on afford-
ability.
2. The EIS proposes various measures to mitigate short and long-term
adverse impacts associated with this project. There are existing
provisions within the statutory framework of the Sanitary District
which would ensure implementation of many o:: the proposed measures;
however, there is currently no active institutional mechanism by
which to enforce the guidance for limiting sewer service in the 100-
year flood plain and for avoiding the sewering of wetland areas.
Consequently, we recommend the Worcester County Sanitary Commission
be required, as a condition of any future grant action, to develop
and institute adequate measures to ensure that Federal and State
guidance on floodplain and wetlands be put into practice. We further
recommend the Commission be required, as a minimum, to incorporate
the guidance into the County's 10-year Wa^er and Sewer Plan and to
implement this guidance, and any other measures necessary for the
desired assurance, prior to the date the project is advertized
for bidding.
Should you have any questions concerning these comments, pleasr contact
Mr. Angelo Bianca, of my staff, at (301) 383-6346.
Sincerely,
Earl S. Quance, P.E.
Program Administrator
Construction Grants and Permits Program
ESQ:sl
B-40
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APPENDIX C: PUBLIC HEARING TRANSCRIPT
(Incorporated by Reference)
A copy of the October 27, 1982 Public Hearing transcript
is available for review upon request at the offices of the
Worcester County Sanitary Commission
-------
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APPENDIX D: ADDITIONAL CORRESPONDENCE
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(Cnuirtn
Santinrti -Bisirid
COMMISSIONERS
W,L_:AM A STEGLF,. Sn - cmifi
NORMAN F DENNIS - SECT TBEAS
JOSEPHS 8YRD. SR. - MEM8EP
COURT HOUSE ANNEX
1V-A \. VvASHiNGTON ST
SNOW HILL, MD. 21863
TE:i°«ONE DU1-63: '63P
STEPHEN1.' HALES- ADM ASSIST
NORV.ANR CC'-NELL - DiS' ENC
JACK DUNLAP - ATTOSN'l*
Evelyn Schultz
United Spates Environments-
Ac; e r. cy Reg i or. 3
6th &. Walnut St.
Philadelphia, Fa. 19106
Subject: Sewer for West Ocean
City Sanitary Dist-
rict
Sanitary Comr. i s s i on has been working since 1974
sewer for the West Ocean City Sanitary District. It appears
meeting and satisfying many obstacles, the probability of
Dear Property Owner,
The Worcester County
to provide
that after
providing public sewer is close to reality.
The Sewer District, established in 1975, is comprised of 2300 acres.
However, based on limitations imposed by the Floodplain Law of 1975, les's
then 1500 acres -will receive service initially. 613 acres of the service
area is within the 100 year Floodplain area. It is planned that all lots
platted within the Floodplain will be allowed one (1) connection for a
dwelling unit within that property. Prior to receipt of a Plumbing Permit
to hook-up' proof is to be presented that the property was platted and
recorded prior to 1 May 1977.
Of course, your major concern is what it will cost you as a property
owner. After the major revision was accomplished on the Facilities Plan
Amendment of 19S2, the State of Maryland, Environmental Health Administra-
tion informed Environmental Protection Agency that this project has the
highest priority for funding and has planned to financing up to $800,000.
with State Failing Septic Tank funds. This was in addition to the State
share of 12'} % of the total eligible cost. Consequently, the local share
cost of this estimated 8.6 million dcllar project will be 1.99 million
dollars. Since the Worcester County Sanitary Commission would plan on
bonding this amount for a thirty (30) year period your initial costs for
1983 and subsequent years are shown on the attached sheet, Scheme 3.The
costs within the box would be the annual charges. The costs identified
below the box are an estimated as one time cost. Item 1, Collection
System hook-up charge would only be paid by property owners of undevel-
oped properties when development occurs after initial construction of
the Collection System. Item 2, Local Residence Service Line from house
to the property line, is a cost estimate of what a plumber may charge to
D-l
-------
hook-up your property to public facilities. Item 3, Plumbing Permit cost.
is an estimate of octainin;
public facilities. This is
ing and inspection c f the :
a permit to HOOK-up 'your proye:"r/—nfi_u clTe
an a c n i n i s t r a t i v t? ccst to cover record keep-
e-in work and or.-site inspection, if required
tR'.
Regarding the estimated annual local costs as shown in the box,
following p c i ~ t r are made:
1
The front foot capital ccst estimate of Si. 41 per year
per front foot is shown for 1983 cost. If, when bids are
taker, for construction, bids are favorable cost wise, the
Worcester Courty Sanitary Commission may desire to add
5,OCC feet of sewer that would serve 96 additional platted
properties in the 100 year Fl oodpl a in . The 5,000 feet of
sewer is not r.ow eligible for Grant Funds. However, if
this amount is included in the project planning now, it
would add 14 cents to the $1.41 now shown. The cost range
then fror. Si. 41 tc SI. 5 5 is considered a reasonable cost.
planning equation is the
The unknown factor in the cos. , _ _ .. _. ,, . t__
cost West Ocean City property owners would be required to
pay for treatment by the Wastewater Treatment Plant of
Sanitary District No.1 (Ocean City). The costs as shown
are what we consider as the maximum cost to be anticipated
(worse case). The parameters used to develop these costs
are :
a. The Ccean City Plan:; would be expanded eventually
from i: MGD to 20,5 MGD. Since the West Ocean
City District, planned to require 1 MGD capacity
and reserved for this use would pay their proport-
unate share of 1/8.5 or 11.
o *
cost
For
planning, this cost is high for the West Ocean
City to pay. Final decision would not be made
on a fair share until expansion becomes necessary.
Expansion is forecasted in
indicate that a later date
would be more correct.
19S5, but present flows
possibly 1989 or 1990
c. No grant funds would be available for plant expan-
sion. The present Federal Grant Law does not pre-
clude grant award or eligibility for award. How-
ever, the reduction in per cent of eligible pay-
ment is evident in the law and recent appropria-
tions signal a reduction in available funds. It
is believed that this pessimistic forecast is best
for planning, but in the long run is reasonable to
take a calculated risk that some grant funds will
continue for this type of construction, necessary
to maintain water quality standards and to preserve
public health standards.
r e a s
note
then
men t
19S2
pro i
off ,
The W
o n a b 1 e
that
a re s
Sin
, we w
ect pr
and r
o r c e s
tot
this
idcn t
c e yo
ou 1 J
ece ed
c t u r r.
ter County Sanitary Commission considers the costs presente
he property owners of the District. It is interesting to
annual cost computed on a month})' basis is less costly
owner is paying for Cable TV or even private water treat-
u w e r c unable to attend the Public Hearing on 27 October
like your response as to whether you are in favor of this
ing as planned. Please fill out the section below, tar
to this Commission by 1 December 1982. If you have arv
D-2
-------
Questions, please correspond with us or contact the District Engineer's
Office in Ocean City, Maryland at 524-6760.
Thank you.
S i n c e r &i y ,
William A. Steger, Sr.
Chairman
WAS/NRC/vk
Encl .
Date
TO: \'l o r c e s t e r C o u n t y S a n i t a r y C o in IT, i s s i o n
Response to West Ocean City Sewer please place X by your choice
Opposed to project
In favor of project
Rema r k s :
Signature :
Please cut on the dashlines and return in self addressed envelope
to the:Worcester County Sanitary Commission
111 A North Washington Street
Snow Hill, Maryland 21863
by 1 December 1982.
D-3
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SCHEME
STATE & LC
LuC.-.-u C(JS .S , .so G."--•-..»- i* ^.'iMJIN1-^ C- THL,
OCIAK CITY TREATMENT PLANT EXPANSION
AKD $800,000 FAILING SEPTIC TANK GRAN^
1983
YEAR
1SS5 1990
2000
Capital Costs
1) Front Foot
Rate S1.41/YR $2.91/YR $2.91/YR S2.91/YR
2) Charge for
IOC Front
Foot Lot $1--1/YR S291/Y?. $S£1/YR S291/YR
3.
Operation
and Mainte-
nance Costs
oer EDU
$ 80/YR S 80/YR $ 59/YR S 68/YR
Total for
100* Front
Foot Lot
with Resi-
dence
$221/YR S371/YR 5360/YR $359/YR
*Other Costs
1} Collection System Hookup Charge - $600 to $800
(properties hooked up after initial construction)
2) Local Residence Service Line from House to
Property Line - $500 to $1,500. Cost will
vary with structure location and lot size.
3) PluiTibinc Permit Cost - approximately $150.
Cost will vary with structure.
D-4
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OFFICE OF ENVIRONMENTAL PROGRAMS
DEPARTMENT OF HEALTH AND MENTAL HYGIENE
201 WEST PRESTON STREET • BALTIMORE. MARYLAND 21201 • Area Code 301 • 383- 5 7 4 Q
Harry Hughes. Governor Charles R Buck, Jr., Sc.D. Secretary
January 13, 1983
Ms . Evelyn Schu Iz
EIS Preparation Section
United States Environmental
Protection Agency, Region III
3PM6 1
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Schulz:
I am writing in r-esponse to your recent inquiry concerning
ttie impact which a projected population increase (between 1982 -
2000) in West Ocean City, Maryland, would have on the solid
waste management system of Worcester County, Maryland.
According to the 1981 update of the Worcester County Solid
Waste Management Plan, the County's three sanitary landfills
have a combined capacity of 20 to 25 years. West Ocean City's
projected population increase of 9,000 represents less than one-
quarter of the County's total population by the year 2000. This
projected increase would certainly have an impact on the life
expectancy of Worcester County's sanitary landfills but,
apparently, not a major one. As is true in many rural counties,
the Worcester County government does not provide for solid waste
collection. Generators either haul their wastes to a disposal
facility, or arrange with a contractor to haul the wastes.
I trust that we have provided the information which you have
requested. If we can be of further assistance, please do not
hesitate to call Mr. Lawrence Leasner of my
Sincerely yours,
staff at (301) 383-5740
Douglas H. John, Chief
Program Development Division
DHJ:tk
cc: Mr. Ronald Nelson
Mr. Lawrence Leasner
D-5
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United States
Department of
Agriculture
Soil
Conservation
Service
301 Bank Street, Snow Hill, Md. 21863
Nov. 23, 1982
Svej_yn Schulz -2-'- Cj-
U.S. Bnvironmental Protection Agenry
Curtis Building
6th and "walnut Sts.
Phi lad el p-d a, Pa. 19106
Worcester County requires that any construction project that
disturbs 300 cubic yards of material submit a sediment and
erosion control plan to Worcester Soil Conservation District.
This plar. must comply with state specifications of sediment and
erosion control and be acceptable to the re-view of William Fritz.,
Sediment and Erosion Control Officer. Mr. Fritz then reports the
acceptability of the plan to the Scil Conservation District super-
visors who will then request the municipality to issue a one year
permit. The perrrat is issued under a fee system providing funds
tc administer the program. The review of site application is
under the county's supervision.
, ..
*
Eru.c2 E. Nichols
District Conservationist
Enc. Ordinance
D-6
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fflmmiu
DONALD HALTING MO.
COUNTY HIALTM O"ICf
1TATI MCALTH Orr
SNOW HILL. MARYLAND'
21883
7, 1979
r r*~ +•£
\
Dr. Max Eisenberg,
Program Administrator
Toxic Substance Control Programs
Environmental Health Administration
201 West Preston Street
>:..?itimcre, Maryland 21201
SEP
!S79
\
RE: West Ocean City Failing Septic
Tank Area
Dear Dr. Eisenberg:
During the joint meeting in Ocean City on August 23, 1979,
it was suggested by the EPA that additional justification of a
failing septic tank area at the above captioned would be helpful
if it were included in the Environmental Impact Statement. It is
within this context that the following information is being forwarded
to you.
Many of the lots in this area were surveyed and recorded before
there were any Health Department Subdivision Regulations. When perco- ;
lation tests were run, they were done during the summer months when
the water table was down and the percolation was good. However, more
and more of these homes are being occupied throughout the year, and
during the periods of high water table it is unlikely that a standard
septic tank system will properly function. In 1976 the department
adopted Directive Policy GS-6 which is their policy dealing with existing
lots of record. This policy requires seasonal testing in areas that have
a high water table.
During the recent seasonal test period there were approximately
102 requests for percolation tests'in this area. There were two
approvals and 100 disapprovals primarily due to the high water table.
Enclosed for your information are copies of our observation well
readings in the above captioned area. It is obvious that this is a
high water table area and that a standard sewage disposal system can't
be expected to function throughout the year.
D-7
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DC. M, Eisenberci
Page 2
September 7, 1979
I hope this information will be helpful to you and if
additional information is needed, please call our office.
Very trulv.yours,
E.P. MAUGANS, DIRECTOR
Environmental Heaitn
EPM/aw
cc: Rick Sellers
Norman Connell
Enc:
D-8
-------
. V
to .>
en en a>
3 C «J
(0 -<
O f -O
c *~<
41 •-< a,
D-9
-------
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01
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to
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o
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i
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January
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O* O* ftf
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re -(^
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D-10
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it, ';o i f.; 2
-;';V; ;S
C£PT. or PUQLJC HEAU7H
P. O. bCJ^ ^«'*
Si\0',v H:_L. f/AHV_.-xr;D
21S63
COr^ALE. HARTJN3. K.D. MPH
COUNTY HtALTM OfFlC.LR
OLP-'TY 5TATL HEALTH Of.^Cft
Norman Conneli
Distrirt Engineer
64G5 Seabay Drive
Ocean City, Maryland 21642
2, 1951
Ri: Sf.var^e Systems.; Failures
'.',c:st Ccean City Sanitary
Dear Mr. Conneli:
The enclosed plan contains a total of 1346 structures requiring
the use of a sewage disposal system. Those structures for the most
part are single family residences along with n few trailer parks,
motels, and small commercial businesses.
Out of tne 1348 structures the health cepartment records indicate
there are a total of 732 structures or 3-^ that have experianced
failures.
The regaining 616 homes cr 46^c, tr,e wealth department has no
knowledge of any failures occunncj.
Sincerely-,,-
--/ V
L.P. KAUGANS, D-TRQpTDR
[nvironmental Health
R/.'/lg
D-ll
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TEL. (301)632-1100
Department of Pgblic Health
(Uonrd
DONALD HART1NG, M.D. MPH
County Health Officer
Deputy State Health Office'
P.O. BOX 249
SNOW HILL, MARYLAND
21863
December E, 1932
Ms. Evelyn B. Schulz
CIS Preparation Section
U.S. Environmental Protection Agency, Region III
6th & rial nut Streets
Philadelphia, Penns\lvani3 19106
Dear Mrs. Schulz:
In reference to your letter to me of NovemDer 3C, 1982. I have obtained the
requested information.
Since preparation of the information contained in m\ December 12, 19BG letter,
there have been. 17 new systems installed for homes, businesses or trailer parks
that have oeen built since that time. This brings the number of existiny structures
to 1365. Of that number., since Decemoer of 1960, we have hac! 18 failures. That
addition brings the number of homes experiencing failures to 750 or 55* of the total.
The number of structures not experiencing any known failures are 615 or 4>?0.
With regard to your question about percolation tests in the West Ocean City
Sanitary District, this office has conducted 32 seasonal percolation tests since
January of 1980. Of that number, 27 of the standard tests failed and 5 passed.
In reference to your request concerning the feasibility of long term use of
on-site systems, I wish to offer the following comments. There are many homes on
small lots that are existing in this area that dispose of their wastewater .by dis-
charqino. into the underground water bearing sands. Our concern is that wastewater
may contaminate the nearby wells or find its way into adjacent shellfish growing
water.
It was indicated a1: the hearing on October 27, 1982, that approximately
$250,000 has been expended to explore the alternatives and come up with the most
cost effective method of waste disposal for West Ocean City. It is my opinion
that the proposed method with State and Federal funding serving existiny homes
plus existing lots of record is the most cost effective and to continue to ex-
plore other alternatives at this late date is not productive.
.vours,
iorman Connell
E.P. MAUGANS, DIRECTOR
Environmental Health
D-12
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Coimtg
Bisirict
COMMISSIONERS
WLLIAMA SIEGER. SR -CHAIRMAN
NORMAN F DENNIS - sec- -RFAS
JOSEPHM BYRD.SR -MEMBER
COURTHOUSE ANNEX
11--A N.WASHINGTON ST.
SNOW HILL, MD. 21863
STEPHEN V HALES - ADM ASSIS
NORMAN R CON'N'fLL - Dis:
JACK DUNlAc - ATT
Environmental Protection Agency
Region 111
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Attention: Evelyn Schultz
Dear Eve Iyn,
November 24, 1982
Subject: Expansion of the
Kastewater Treat-
ment PI ant , Ocean
City, Maryland
C-240407-01
November 1982, concerning the
In response to your question on
expansion requirement of the Kastewater Treatment Plant, Ocean City,
Maryland, the following data is provided:
1. Average flows through the plant during the peak months
of July and August, 1982 were 8.59 MGD and 8.39 MGD
respectively. The new plant design is 12 MGD with peak
flows capability of 18 MGD. With excellent response
with the oxygen activated plant, I would anticipate
could possibly treat adequately flows of up to 15-
MGD without difficulty and still meet our permit
requi rement s.
Planning to date, projects 'ultimate Ocean City flows to
up to 20 to 20.5 MGD-. To fulfill this requirement, it
is anticipated that approximately 7-8 acres of additional
land would be required to site the maximum size plant
ant icipated.
The acceptance of flows from the West Ocean City District
anticipated initially at 350,000 GPD would ultimately be
less then one (1) MGD, but for reservation of capacity,
I believe a one (1) MGD capacity should be projected as
the ultimate. The requirement for ultimate flows is not
anticipated for less then twenty (20) years.
D-13
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In suir.ir.ar>', bringing th
rict Nc.l, Ocean City, is ne
wetland filling has been sub
obtain perr.it approval and t
such new fill settle well, p
I would hope that the V.'
Impact Statement not get dec
Maryland Environmental Heal':,
most cost effective solution
City, It is further anticip
approval of the Environmenta
agencies will work toward ar
documents without argument.
Ocean City District flows into Dist-
reason why the present request for
With the leactime required to
that it would t e desirable to have
rior to construction, is the basic reason.
e W e s t
t the
IT. i 11 e d
he fac-
e • s t 0 c
ayed b
h Ad mi
to so
ated t
l Imp a
compli
ean City Amendment
e c a u s e of the .site
nistratior. c o n c u r r
Iving the sewerage
and the Environmental
fill request. The
that this is the
need? for West Ocean
hat with Environmental Protection Agency
ct Statement, that both State and Federal
shing the goals .set by those planning
Sincerely,
,onne 1 1
strict Engineer
c c : K . C . S . C .
NRC/vk
D-14
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UNITED STATES
DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
DIVISION OF ECOLOGICAL SERVICES
18253 Virginia Street
Annacolis. Maryland 2140"
January 7, 1983
Ms. Evelyn 3. Schulz
EIS Preparation Section
Environmental Protection Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Schulz:
In reference to your letter of December 3, 1982, and subsequent conversations
between yourself, Shelly Suflas, and Martha Tacha of my staff, we concur that
the proposed West Ocean City Wastewater Treatment Facilities will have no
significant adverse impact on federally listed endangered species under our
jurisdiction. We understand that the enclosed assessment (which we have
revised further) will be incorporated into the Final Enivronmental Impact
Statement for the project. We believe this revised assessment adequately
discusses the primary sources of potential impact to endangered species in
this case.
Three federally listed endangered species have been reported in the vicinity
of the study area. Two subspecies of peregrine falcons, the Arctic peregrine
(Falco peregrinus tundrius) and the American peregrine (P_. p. ana turn) use
Assageague Island for resting and feeding during annual migrations and,
therefore, may pass through or near West Ocean City. However, no significant
impacts to the falcons is expected as a result of the West Ocean City project.
West Ocean City's collection system will be placed under existing streets and
railroad rights-of-way. No portion of a federally-funded sewer system in West
Ocean City will traverse through or provide wastewater service to the area's
wetlands and thereby adversely impact shore birds upon which the falcons feed.
The elimination of effluent seepage from failing septic tanks into canals
should improve the shorefront aquatic habitat. The Maryland Wildlife Adminis-
tration (Taylor 1978) has reported a bald eagle (Haliaeetus leucocephalus)
nesting area south of Berlin, approximately five miles from the project area.
No adverse impacts to the bald eagle is anticipated, either directly or
indirectly through changes in the foo:; chain. No new surface discharges of
wastewater which could impact fish supplies are planned. The elimination of
septic tank seepage should have a positive impact on surface water quality.
D-15
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This response relates only to endangered species under our jurisdiction. It
does not address other Fish and Wildlife Service cor.cerns under the Fish and
Wildlife Coordination Act or other legislation.
Thank you for your interest in endangered species. If you have any questions
or need further assistance, please contact Martha Tacha at (301) 269-6324.
Sincerely yours,
''Glenn Kinser
Supervisor
Annapolis Field Office
D-16
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Maryland Department ofTfensportat/on
State Highway Administration
Lowell K. Brldwell
S«cret»ry
M. S. Cattrider
Administrator
January 5, 1983
Ms. Evelyn B. Schulz
EIS Preparation Section (3PM61)
United States Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
Dear Ms. Schulz:
An analysis of Keyser Point and Golf Course Roads indicates
they are adequate to handle current and projected traffic. The
assumptions made in the analysis are attached as enclosure #1.
An area which may be of future concern for these roads, is
the ability of traffic to get on, off, or across US 50. We do
not have the data to make that evaluation now. If it became
necessary, we would need to collect data in the summer, when the
worst delays for local residents are assumed to occur.
If we may be of any further assistance, please contact the
writer.
Sincerely,
John T. Neukam, Chief
Bureau of Highway Statistics
By:
JTN/BKO:cas
Enclosure
Barbara K. Ostrom, Chief
Traffic Forecasting Section
My telephone number is (301) 659-1327
Teletypewriter tor Impaired Hearing or Speech
383-7555 Baltimore Metro — 565-0451 D.C. Metro — 1-800-492-5062 Statewide Toll Free
P.O. Box 717 / 707 North Calvert St., Baltimore. Maryland 21203 - 0717
D-17
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Ms. Evelyn B. Schulz
January 5, 1983
Enclosure #1
Area
Current dwelling units.
Dwelling units - year 2000
Number of daily trips per
dwelling unit
Percent
in peak houi
69
426
9.1
10.8
Area £8
164
322
10.8
Are a._t 9
201
629
10.2
10.8
Assumptions:
The only access to US 50 will be Keyser Point or
Golf Course Roads for the areas in question.
Areas #1 and £9 will only use Keyser Point Road
with area £1 developing around Keyser Point Road
before: spreading East.
Area =8 will only use Golf Course Road.
No improvements to either road.
Average Daily Traffic from each area:
Current ADT
Current Peak Hour
Year 2000 ADT
Year 2000 Peak Hour
Area i
630
70
3 , 9 0 C
420
Area £8
1,525
165
3,000
325
2,050
220
6,415
"6S5
Both Keyser Point and Golf Course Roads are two-lane roads,
with 12 foot lanes and no shoulders. There is uncontrolled access
to these roads (i.e., driveways, other road intersections). Be-
cause of these conditions, either road can handle 1,500 vehicles
per hour at the posted speed of 30 miles per hour.
In the year 2000, the rushhour (pea/: hour) volumes for Keyser
Point and Golf Course Roads are forecast to be 1,115 and 325 vehicles
per hour, respectively. Traffic from the south side of US 50 going
across "US. 50 northbound .on these roads is assumed to be negligible
as is traffic from- MD 611.
D-18
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U.S. Environmental Protection Ageno*
Library, Room 2404 PM-211-A
401 M Street, S.W.
Washington, DC 20460
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