ADMINISTRATOR'S DECISION ON THE PROPOSED DICKERSON
WASTEWATER TREATMENT PLANT GRANT APPLICATION
RUSSELL E. TRAIN
Administrator'
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
August 20, 1976
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ADMINISTRATOR'S DECISION ON THE PROPOSED DICKERSON
WASTEWATER TREATMENT PLANT GRANT APPLICATION
INTRODUCTION
On March 19, 1976, the State of Maryland transmitted
to the Environmental Protection Agency a construction grant
application for an advanced wastewater treatment (AWT)
facility proposed for construction by Montgomery County in
the vicinity of Dickerson, Maryland. The proposed facility
would have a wastewater treatment capacity of 60 million
gallons per day (mgd) and would have a capital cost of
about $273 million to build. In early April, EPA issued a
preliminary draft National Environmental Policy Act (NEPA)
review of the proposed project which raised several con-
cerns about the -or eject. Perhaps foremost among these were
concerns with respect to the high construction and operating
costs, and uncertainty about possible drinking water and
water quality impacts. These concerns were sufficient to
raise serious questions as to the appropriateness of
proceeding with that grant application.
The State of Maryland, Montgomery County and the
Washington Suburban Sanitary Commission (WSSC) were pro-
vided copies of the preliminary draft NEPA statement and
asked to comment upon it. The following month the State
provided its response. The response document addressed
many of the same issues raised in the preliminary draft
NEPA statement, but it also raised additional issues, and
on the basis of its analysis, reached different conclusions.
.Because of the complex, controversial nature of the
issues surrounding the proposed treatment plant, I appointed
a senior Executive Review Panel* within the Agency to
analyze and assess all major issues relating to the March
grant application. I asked the Panel to prepare a discussion
and options paper for me and to recommend a specific course
of action. The Panel has done that.
*Paul A. Hrands, Deputy Assistant Administrator for Planning
and Evaluation; John T. Rhett, Deputy Assistant Administrator
for Water Programs Operations; and Daniel J. Snyder III,
Regional Administrator, Region III.
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In addition, to help insure that I had maximum infor-
mation and a wide spectrum of views available to me prior
to making a decision, I held a five-hour public meeting on
August 11, 1976 to discuss these issues.
MY DECISION -
After extensive review of the available information,
consultation with public officials, and reflection upon
the views provided at the public meeting, 1 have decided to
return the-March 19, 1976 Dickerson AWT grant application .
to the State of Maryland and the Washington Suburban
Sanitary Commission and thereby suspend further processing
o f i t. -- . ."
BASIS FOR THE 'DECISION
Though there are several important issues associated
with-this grant application, my decision is based primarily
upon two factors: (1) plant capacity, given projected ..,
sewage flows; and (2) cost-effectiveness considerations..^.
Projected flow requirements. A review of population-
project io ns~ and sewage flow requirements was undertaken, as.
is the case with the processing of all construction grant
applications. The .Executive Panel's estimate of treatment
capacity needs for Montgomery County indicate .that about 35
ragd capacity beyond the'76.6 mgd allocation to the Blue
Plains treatment plant will he needed by the year 2000.
This flow estimate is substantially lower than the 60 mgd
estimate contained in the grant application and is based
upon our review of more recent population projections
prepared by various local and regional planning entities^..
In fact, the population projection selected as most appr-o-
priate by the Panel lies roughly in the middle of a range
of'available projections. It is consistent with numexo.us
projections indicating a substantially reduced rate of
population growth for the entire metropolitan area.
A 60 mgd capacity plant., such as that proposed in the
March grant application, could be justified only if its
capacity is allocated to serve existing and projected
regional needs, not just Montgomery County needs. Since no
other jurisdictions have formally requested permanent
sewage treatment capacity, and no commitments of cap-ac.ity ;
to other jurisdictions accompany thi.s application, I d.q_ not
see the justification for a 60 mgd plant. - ^ .
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COSE -effectiveness . Standard E ij A cost-effectiveness
analysis procedures call for development of comparable
alternatives which meet the wastewater treatment needs of
communities applying for construction grants. An analysis
is to be performed to determine which waste management
system will result in the minimum total resources, ovef~
time, to meet Federal, State and local requirements.
Non-monetary factors are to be accounted for descriptively
in the analysis to determine their impact and significance.
If the cost of the selected alternative is significantly
greater than other options, the grant applicant must either,
select a less -expensive alternative or demonstrate that . .,_
there are overriding adverse environmental and social
impacts associated with the less costly alternatives.
The design for the Dickerson plant incorporated in t he
March application calls for n capital expenditure of-about-
$273 'million 'to — c ons tr uc t the facility. Associated operation
and maintenance cost would be about $108 million over the
project life. " The high cost of the project stems from two..
factors: (l)'the need to provide a high level of treatment
to m in im-tze" -potent ial health risks to drinking water
supplies; and (2) the substantial operating costs associated""
with the treatment plant and conveyance facilities. . - .
' The cost-effectiveness review compared the designed -
plant at the -Dickerson site with two possible alternative
60 mgd treatment plants — a modified version of the
proposed plant, which would result in a somewhat lower-
quality effluent at the Dickerson site, and.a plant in the-
vicinity of Piscataway (Prince Georges County), which
would discharge into the Potomac River estuary below water.-_
supply intakes. " This comparison indicates that, on a
20-year present worth basis, the two alternatives would-be-.
abou-t $44 million and $145 million less costly, respectively,
than the -plant in the grant application. These added costs -
-would a:ppear especially burdensome to the citizens in the
metropolitan area in view of the fact that WSSC currently
estimate-s that sewage rates are already expected to double. ~
"betwe-en now and 1984. . 3. - ---
In discussions with state and county officials, as well
as po-'t'-e nt-i'a-11 y i-npacted citizens, it has been repeatedly---
stated that the possible Piscataway alternative is ".politi-.
cally" un tc ce pt ab-le . I recognize that cost comparisons -•_
must be based upon potentially viable alternatives. At-the-.
same time, however, 'the fact that our analysis shows that
at least two potential alternatives are substantially less
costly than the proposed facility necessitates that the
grant applicant explore other more c os t- e f.f ec t ive plant
designs, alternative approaches to treating wastewate-r
and/or other treatment plant sites.
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OTHER IHPORTANT FACTORS
Several additional issues have been raised in the
review of this grant application: health considerations
with respect to drinking water supplies; land treatment of ~
sewage; land use implications; meeting sewage treatment
needs on a regional basis; potential costs of construction
delay; augmentation of drinking water supplies; and others.
The August 6, 1976 Executive Panel Report addresses most of
these issues. I want to discuss three of them: health"
considerations with respect of drinking water supplies, the
land treatment of sewage, and resolution of treatment '
capacity needs on a regional basis. :
Health considerations and drinking water supplies .
The March grant -ipplication calls for wastewater effl'uen't
discharge about 20 miles above the Washington, D.C. drinking
water intakes an.l about 8 miJes above the proposed drinking
water intakes for Leesburg, Virginia. Because of the
possibility" that small quantities of organic contaminants,
trace metals and viruses could be found in the proposed"
plant's effluent, such a discharge would tend to decrease"'- •
the margin of safety associated with the metropolitan ~ '
area's drinking water supplies. The scientific unknowns
make it impossible to quantify this decrease; however, OUT"
conclusion at this time is that the risks to the drinking
water supplies would be minimal.
In many areas of the country, no alternatives exist for
communities to discharge above another community's drinking
water supply intakes. However, to my knowledge, few :
communities with other choices have Chosen to discharge ~ "
wastewater effluents above their own water supply intakes..'
EPA'S Cincinnati research laboratory and Water Supply ~ " '
Office have concluded that because of the unknowns associated
with a situation such as this, "the best alternative wo'ul'd
be to discharge.all sewage below the water intakes." As
actions are.cpnsidered toward meeting the long-term sewage
treatment needs in the metropolitan area, it is imperative "
that great care be taken to minimize any health .risks " " ' " "
associated with impacts on drinking water supplies. "~ -------
Land treatment of sewage. Much data and information
indicate that we should proceed expeditiously with the
development of land treatment facilities as a means of" ~
providing additional sewage treatment capacity where suclf
_an.approach" is economically and environmentally sound.
Numerous citizen comments at the August llth public Tiee'ting7 '
also.made this point.
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Regardless of the overal] approach selected by t lie
jurisdictions in the Washington metropolitan area to
provide for the long-terra regional sewage treatment n-e-ed-s-,-
the development and utilization of land treatment facilities
should be examined without delay. Land application employs
natural processes to provide waste treatment and holds the
potential of saving millions of dollars in both capital and
annual operating costs. Additional benefits can be deriv"e"d
from the sale of forage crops and from the preservation of
open space areas in urban corridors. Years of testing,"
demonstration, and experience across the United States "and"*
in several forejLgn countries support the feasibility of""'
land treatment in appropriate situations. . ".
More specifically, preliminary surveys indicate that
a 1.5 - 5.5 mgd land treatment system would be feasible on
~Fe"d"er*aT~ sfu r pi us' land currently available at the Bel t sv il 1-e—;—
Agricultural Research Station. In addition, the Montgomery
County ten-year water and sewer plan suggests that a la.n'd
treatment system at Seneca could provide up to 15 mgd of
treatme-nt capacity. Finally, it should be noted that EPA
grant- monies are available for the acquisition of land to.
be used in. a. .1 and treatment system. '.'''.'
As alternatives to resolution of the area's sew.ige"
.treatment needs are considered, I strongly urge the Leaders
of each.of t-he jurisdictions, singularly and jointly, to
investigate the advantages of land treatment and to move"
aggressively, where appropriate, toward implementing land
treatment systems in the metropolitan area.
Meeting Sewage treatment capacity needs on a regional
basis. At .several points in the August llth public mee'ting,
the question, was raised by State and local officials as to
EPA's commitment to encouraging the resolutio.n of tha.
metr o-pol i tan are.a's treatment capacity needs on a regional
basis. I want to state emphatically that there has been no
waivering on our part with respect to this question. The
very complex nature of sewage treatment requirements in the"
D.C. metropolitan areamandates that these long-term ''..',.
requirements be assessed and resolved on a regional b.'a'.si's , I
si nee. economic ally efficient and environmentally ad equafte "
long-term treatment capacity cannot be achieved witho'uV a
coopera-tive regional approach. It also requires that
treatment capacity commitments on the part of each j ur.is-
dic.tion be. specified and agreed upon before EPA can commit
funds, .for construction of a plant.
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I strongly encourage the regional leadership to initiate
the effective planning required to provide for additional-.
regional sewage treatment needs as soon as possible. The
technical and professional resources of the Washington : .-.
metropolitan area are among the finest in the country.-
If they are utilized in an integrated manner, I am sure .an
appropriate long-term plan can be developed expeditiously. .
Monetary resources are available to support such a
regional facilities planning effort. EPA grant funding ~of .
75% of project costs is available through the state priority
system for facilities planning. The ongoing Section. 208';::.
program" provides a source of expertise and Federal funds as-
we 11 as a vehicle for effective regional planning. ..: : : - -
In view of the strong need for an effective regional
solution to the metropolitan area's sewage treatment needs,
and the availability of funds to help provide for it,"-I-am.
instructing EPA's Mid-Atlantic Regional Office to give -
very se r io us ~c ons id er a t io n to the deferral, of any substantial
treatment capacity related grants to the Washington metro---•
politan area jurisdictions until an adequate long-term- :~ -. " ~
regional sewage treatment plan is developed. . : :~ : -
"GUIDANCE" TO THE APPLICANT
Both the Executive Review Panel and the public officials
with whom I have discussed this issue have stated that if:
the decision is to terminate further consideration of the"..
March grant application, then some EPA "guidance" should be
provided indicating how the applicant should proceed to ~
meet its future sewage treatment needs.
There are,~of course, certain risks inherent in such.-
a course of action. In view of the apparent commitment, a t-
least at .this time, of state and local political leadership
to the Dickerson plan, I have to assume that specific--'
alternative proposals put forward by EPA would be subjected
to critical analysis. I am also aware that in as contro-
versial a situation as the planning of a major sewage-.
treatment facility for a metropolitan area, there is - - :
seldom, if ever, a solution which commends itself to •-.--_.:--
universal approval. To offer specific alternatives isv:. £. .-;
therefore to invite shifting the burden of j us t if ica--.tio.n-to ;•
the Federal government rather than to keep it in the ::;-ri:
appropriateJregional, state, and local hands.
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While necessarily the municipal waste treatment
program requires shared responsibilities, the statutory
plan requires that the fundamental planning decisions as to"
location, capacity, etc., must be made by the appropriate -
local authorities subject to Federal review. I believe
strongly that the integrity of this process should be " ' "•
preserved and that the Federal government should not
arrogate to itself state and local responsibilities. At
the same time, in view of the extensive history of this
particular issue, as well as ray recognition of the desir-
ability of working together toward its solution, I believe"
it appropriate that EPA present "guidance" if not express""
specific alternatives. . •--
Keeping in mind the three important factors noted in
the previous section — i.e., health considerations with
respect to drinking water supplies, the need to move
ahead with the land treatment of sewage, and the necessity
to proceed with capacity planning on a regional basis —• as~
well as the. sewage flow projections and cos t-e f f ec t iv e nes s
criteria.,.I see the applicant's adoption of any of the ~ "
following three courses of action as being acceptable from
EPA's point of view:
1. A modified version of the. present Dickerson gr-a-n-t
. application which:
- has specific regional flow commitments for at
least 90% of the 20-year 60 mgd plant design
capacity,
- represents a reasonable cost-effective solution
to the need for additional regional treatment
... c apac i ty , and
- adequately safeguards the metropolitan area's
drinking water supplies.
2. Anew application for a 60 mgd capacity plant at
. another location or a smaller capacity modular""'
. . plant (range of 30-35 mgd) at Dickerson or at. •'••
another location. Review of alternative site-s"--
.. . should.include, among others, consideration of'- ""
."down-coun ty" sites in Montgomery County wi th - - -•" ~_ -
outflows below the water intakes, and sites in the'
vicinity of Piscataway. This course of action "
would involve a concentrated facilities planning
process followed by 9-24 months for the development
of plans and specifications. Such an application
must:
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- be accompanied by regional flow commitments for
at least 90% of the 20-year plant design capacity,
- be a reasonably cost-effective solution to
additional regional treatment capacity needs, and-.
- adequately safeguard the metropolitan area's
drinking water supplies. - • . ~
Applications for small treatment plants (including
land treatment facilities) in areas impacted by
se wer mo ra to r ia , in conjunction with the d ev elopment-
of a long-term regional facilities plan. Small
treatment plants (which are already planned) not - - :
yet under construction are eligible for EPA 75%
grant funds, as is land acquisition for land
treatment facilities. These (1 to 5 mgd) plants,-
or land treatment variations of them, would provide- -
Montgomery County with adequate treatment capacity
until 1 9 8"8. Assessment of this course of action
should recognize that: - - .
- construction of the 1-5 mgd plants would provide
adequate capacity and time (until 1988) to -
develop a sound long-term regional solution;
- this would provide an excellent -opportunity1 to
move forward with a substantial land treatment
pr og ram; and
- Federal facilities planning and Section 203 grant
monies are available to'help provide for tiis
planning.
As with the first two alternatives, this course of
action must consider the cost-effectiveness criteria
and potential impac.ts on drinking water supplies.
SUMMARY
I am terminating further consideration of the March 19,
1976 construction grant application and am returning it to
the State^-bf Maryland and the Washington Suburban Sanitary
Commission. My decision is based primarily upon concerns
related to projected sewage flow requirements and cost-effec-
tiveness analysis.
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I have outlined three alternative courses of action
which seem appropriate from EPA's point of view. These
alternatives should provide adequate "guidance" to help
insure a more expeditious resolution to the long-term
treatment capacity problem.
And, finally, I cannot emphasize too strongly the need
for all the j ur i sd ic a t io ns in the metropolitan area to
work together, to develop and implement an effective regional
plan, to provide for additional treatment capacity needs,
and to investigate thoroughly the possibilities of utilizing -
land treatment of sewage. I want to assure the officials
and citizens of the local jurisdictions that the EPA will
be more than willing to contribute on a cooperative basis
our expertise and resources to help bring about an expeditious
resolution to the metropolitan area's sewage treatment
needs.
- I -am sensitive to the fact that the planning for
additional sewage treatment facilities for Montgomery
County (which we all agree will be needed) has extended
over a prolonged period of time. The extended duration may
be attributed in part to- the many political jurisdictions-
involved and the many unusual complexities -involved. Of
key importance to the current reassessment has been the
radically reduced population growth projections for the
National Capital area in general and the Montgomery County
area specifically. These reduced growth projections,
involving the formation of significantly fewer households,
must result in substantially reduced estimates of future
sewage capacity needs. Unfortunately, these new projections;
Locally generated, became available only toward the close
of 1975.
While 1 am aware of the disadvantages some will-s-e-e—i-n-
any form of delay, the responsible administration of this
program, involving the expenditure of many millions of
public dollars, would in ray opinion make failure to recon- : •
sider the present Dickerson proposal irresponsible. In --•-
ad d i t io n, -in v ie-w of the significantly reduced sewage fTow •
projections, sufficient time exists to accomplish the - - -"
regional planning urged by this decision. Thus, whiter-some
further delay is inevitable, it is delay which we can
afford and which will, if properly utilized, be in the
p ublie in ter es t .
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