RECORD OF DECISION




    FINAL ENVIRONMENTAL IMPACT STATEMENT




    BEMIEJI WASTEWATER TREATMENT SYSTEM


         BELTRAMI COUNTY, MINNESOTA
United States Environmental Protection Agency


                 Region V


             Chicago, Illinois
                                   Approved by:
                                   Valdas V. Adamkjfcs           <^
                                   Acting Regional Administrator

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                            Record of Decision
                   Final  Environmental Impact Statement
                     Wastewater Treatment System
                            City of Bemidji
                       Beltrami County,  Minnesota

On May 15,  1981,  USEPA,  Region V published an official Notice of Availability
of the Final  Environmental  Impact Statement (EIS)  for the wastewater
treatment system  for Bemidji,  Minnesota in the Federal Register.  Consistent
with the regulations of  the Council on  Environmental Quality, 40 CFR 1505.2,
USEPA is providing this  public Record of Decision  as the final step in the
EIS process.

GSEPA Decision

It is the decision of  this  Agency to approve the facilities plan for the City
of Bemidji.   Approval  of the facilities plan allows Step 2 (engineering
design) and Step  3 (construction)  work  to proceed  with the aid of Federal
and State construction grants  funds. This decision is based on the analysis
presented in  the  Final EIS  document.

The approved  wastewater  treatment alternative for  Bemidji is the construction
of a new 2.0  M<3>  advanced-secondary wastewater treatment plant (WWTP)
at the site of the existing WWTP.   Treated effluent from the new plant will
be discharged directly to the  channel between Lake Irving and Lake Bemidji.
The new WWTP  will incorporate  the following treatment processes to attain an
effluent level of 25 mg/1 of EGD,  30 mg/1 of suspended solids and a
phosphorus level  of 0.3  mg/1:   primary  clarification; activated sludge
secondary treatment; two-stage alum and polymer addition prior to and after
secondary clarification; granular-media filtration; disinfection and discharge.
The Minnesota Pollution  Control Agency  (MPCA) issued the NPDES permit
containing the aforementioned  effluent  limitations on May 26, 1981 after
receiving no  dissenting  opinions during the 30-day comment period for
the permit.

Background

There is a need for the  City of Bemidji,  Minnesota, to improve the quality
of the effluent discharged  from its wastewater treatment plant (WWTP)
to the Upper  Mississippi River.   The WWTP effluent constitutes the first
major discharge of treated  wastewater to the Mississippi River.  The effluent
phosphorus contributes to the  total loading of phosphorus in Lake Bemidji
and the Upper Mississippi River Chain of Lakes downstream from Bemidji
(Wolf Lake, Lake  Andrusia,  and Cass Lake,  within the Leech Lake Indian
Reservation).  These lakes  are utilized for recreational fishing, swimming,
boating, hunting,  and  rice  production and  are an integral part of the
local tourist-based economy and the Native American Indian culture.

In 1978, the  City of Bemidji was required  by the MPCA Board to provide for
interim control of phosphorus  at the existing WWTP and to relocate the
point of discharge from  the Mississippi River downstream from the Lake
Bemidji outlet to the  inlet of Lake Bemidji.   This order was based on the
Board°s decision  that  the eutrophication problem should be reduced to the
maximum extent possible  with interim measures until a new WWTP with advanced
phosphorus removal capability  or a land treatment  system could be implemented.
The improvement in the quality of  the downstream lakes since these improve-
ments were implemented in June 1978 has been significant,  as evidenced by
1979-1980 water quality  data;  however,  the quality of Lake Bemidji is being
adversely affected.

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                                    -2-

Alternatives Examined in the BIS

An exceptionally large number of wastewater  treatment system alternatives
have been investigated as potential solutions  to  the  problem of wastewater
disposal at Bemidji.  Six of these wastewater  treatment system alternatives
were evaluated in the EIS; these alternatives  were determined to represent the
most feasible treatment options available  to the  City.   They included five
conventional treatment systems and one land  treatment system.  For each
conventional alternative, two phosphorus treatment options  were addressed:
reduction of the effluent phosphorus concentration to 1.0 mg/1, and
reduction of the effluent phosphorus to 0.3  mg/1.

Alternative 1 proposed the construction of a new  2.0  MGD advanced-secondary
WWTP at a site presently owned by the City adjacent to the  Mississippi
River about 2000 feet downstream from the  Lake Bemidji outlet.

Alternative 2 proposed the construction of a new  2.0  MGD advanced-secondary
WWTP at the site of the existing WWEP in Bemidji.  The effluent would be
pumped via a new force main to the Mississippi River  immediately downstream
from the Lake Bemidji outlet for discharge.

Alternative 3 proposed the construction of a new  2.0  MGD advanced-secondary
WWTP at the site of the existing WWTP in Bemidji.  Discharge would be
directly to the Mississippi River inlet Channel to Lake Bemidji adjacent to the
plant site.

Alternative 4 proposed the construction of a new  2.0  MGD advanced-secondary
WWTP at the site of the existing WWTP in Bemidji, with effluent pumped via a
new force main to Grass Lake, northwest of Bemidji, for discharge.

Alternative 5 proposed the construction of a new  2.0  MGD advanced-secondary
WWTP at a site adjacent to Grass Lake with effluent discharged directly
to the lake.

Alternative 6 proposed preliminary treatment of the raw wastewater at the site of
the existing WWTP.  From there it would be pumped via a new force main to
aerated ponds in Section 16 of Eckles Township northwest of Bemidji.
Pond effluent would then be applied to 1,170 acres of forest land via a
irrigation system and to 250 acres of cropland with a center-pivot irrigation
system.  Underdrainage would be required,  with collection and discharge, to
open ditches.  See Exhibit A for cost comparisons of  the alternatives.

Though only one land treatment alternative was considered in the EIS, the
concept of land treatment has received a thorough examination.  It has been
considered by some as the best solution because it would eliminate the direct
discharge of effluent to the Upper Mississippi River  system.  As a result,
numerous land treatment proposals have been  developed and considered  in
detail through at least five separate search efforts  (1972, 1976, 1978, 1979
and 1980).  These searches have identified many potential sites, some very close
to the City and others as distant as 25 to 30  miles.   Soil  borings and more
detailed geotechnical investigations were  conducted at a number of the more
promising sites.  At the conclusion of each  search effort,  land treatment
has been rejected because of unacceptable  social, economic  and/or
environmental impacts.

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                                    -3-

Draft BIS Preferred Alternative

Alternative 3 was the preferred alternative  presented in the Draft EIS.
The estimated capital costs  to achieve effluent phosphorus concentrations of
1.0 mg/1 and 0.3 rag/1 were $9,975,000, and $12,904,000,  respectively.  The
annual O&M costs were $417,000 and  $525,000, respectively.  Alternative
3 was the most cost-effective, especially when compared  to the land treatment
option which had an estijnated capital cost of $24,457,000 and a projected
annual O&M cost of $612,000.  It also is  the alternative that would have
the least potential for significant adverse  construction and operational
impacts.

Response to Draft EIS

Considerable public response was received on the Draft EIS, both in writing
and through testimony at the public hearing  held on September 11, 1980
at Bemidji.  Despite the number of  land treatment proposals studied and
rejected in the past, significant concern was expressed  by downstream interests
concerning the absence of a  feasible agricultural wastewater irrigation alter-
native and the lack of discussion of the  economic benefits of clean water
downstream in the Draft EIS.

The City proposed an "Alternative 7" concept, which was  to have been a viable,
on-land alternative east of  Bemidji, to be developed by  the City prior to
December 1980.  While there  was considerable support for the inclusion of
"Alternative 7" in the Final EIS, there also was significant criticism ex-
pressed at the potential to  further delay the EIS process and the implementa-
tion of a solution by considering yet another land treatment proposal.
Residents of Frohn and Eckles Townships,  where "Alternative 7" was to be
located, were especially vocal in their opposition to the proposal.

In an effort to provide the  technical basis  for the establishment of a phos-
phorus effluent limitation for a new WWTP, the MPCA prepared a document, dated
December 15, 1980, which is  a Supplement  to  the State Draft EIS and was con-
sidered as a formal comment  on the  Federal Draft EIS. The Supplement address-
ed the cost for construction and O&M of a new WWTP, the  cost to users, the
economic benefit to the downstream  recreation-based economy from improved
water quality, and alternative projections of water quality associated with
various levels of phosphorus reduction.

The information in the MPCA  Supplement demonstrated that there will
be water duality benefits associated with phosphorus treatment to the
0.3 mg/1 level.  The reduction of phosphorus to 0.3 mg/1 will preclude
acceleration of nutrient enrichment of Lake  Bemidji and  will provide
the maximum practicable protection  for the downstream Chain of Lakes.
The design proposal examined in the Supplement provides  for a filtration
system which is necessary to attain an effluent phosphorus limit of
0.3 mg/1.  If at a later date additional  treatment facilities are found to
be necessary to maintain an  effluent phosphorus level of 0.3 mg/1, funding of
such facilities would be subject to further  review and approval.

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                                    -4-

During the period that the MPCA was preparing its Supplement,  the City pro-
ceeded to develop further its "Alternative 7" proposal with  the assistance of
engineering consultants.  They concluded, as previous studies  of the  same
areas had, that because of site limitations (i.e., poorly suited soils and
high water table conditions), cropland irrigation could not  be accomplish-
ed in a cost-effective manner.  Only low rates of application  are suitable
because of the glacial till in Prohn Township.  Because the  short growing
season at Bemidji limits the application season, wastewater  must be stored
during an extended period (at least 7 months), requiring large amounts of land
for irrigation during suitable conditions.  Subsequently, the  City Council
determined that the high cost of an agricultural wastewater  irrigation alter-
native at the site in Eckles Township also eliminated it from  further consid-
eration.

The Maple Ridge alternative, located approximately 25 miles  north of  Bemidji,
was the final land treatment option considered by the City under the  "Alter-
native 7" concept.  This proposal called for storage of wastewater in natural
boglands for withdrawal by area farmers for cropland irrigation.  The total
construction cost was estimated to be $17,459,000 and an annual O&M cost of
?273,000.  Both MPCA and this Agency informed the City that  they could not
support further study of the Maple Ridge alternative because of its high cost
and the many engineering and environmental concerns associated with the  proposal.

Final EIS Preferred Alternative

Based on the response to the Draft EIS and the additional information in
MPCA°s Supplement, we concluded that the technically feasible, environ-
mentally and socially acceptable cost-effective solution to  Bemidji°s
wastewater problem was the construction of a new 2.0 MO) advanced-secondary
wastewater treatment plant at the site of the existing plant with discharge
to the Mississippi River channel to Lake Bemidji. MPCA's revised construction
cost estimate for the new plant, which will be capable of attaining an
effluent phosphorus level of 0.3 mg/1 is $11,945,000. The revised
annual O&M cost is $362,000.

A sludge disposal plan for four sites in Bemidji Township has  been approved
DyJfla^L^. MPCA evaluated the plan to determine whether me analysis o£
environmentally safe sludge application levels contained in  the plan  is
consistent with its criteria.  Application of the existing Sludge Disposal
Plan to the proposed situation once the new WWTP is operational will  require
further MPCA approval.

The sites proposed in the plan have adequate capacity to accommodate  the
additional sludge from the new WWTP for more than the 40- to 50-year  life
of the plant.  Monitoring reports on the sludge disposal activities will be
required annually by MPCA and routine site inspections will  be periodically
conducted by MPCA staff to determine whether the approved sludge disposal
plan is being implemented properly.

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                                    -5-

Sevecal methods of wastewater disinfection are still  under  consideration.
Chlorination, the most widely used process, must be followed  by dechlori-
nation to meet NPDES permit requirements.  Other disinfection alternatives,
including ultraviolet light and ozonation, have the potential for  providing
effective disinfection while being less detrimental to  streamlife  and
not reacting instream to form new compounds.  They have the disadvantages
of higher costs and a technical difficulty in readily knowing when a
satisfactory level of disinfection is achieved.  Hie  selection of  the
disinfection method will be made after a cost effective comparison in
Step 2.

Manor Environmental Impacts of the Final EIS Preferred  Alternative

Direct impacts from the construction of a new wastewater treatment plant at
the site of the existing WWTP will be localized to the  treatment plant
site and will consist mainly of short-term construction-related nuisance
conditions.

The 2.0 MS) design capacity of the new plant will allow for reasonable growth
in the Bemidji service area.  The expenditure of nearly $12 million for
construction will provide a direct economic stimulus  and will induce
secondary income and expenditures.

The most significant operational impacts are related  to the level  of phos-
phorus loading reduction attainable in Lake Bemidji and the downstream Chain
of Lakes, and the cost to system users for treatment  system opeation.  By
limiting the WWTP effluent phosphorus concentration to  0.3  mg/1, the water
quality of Lake Bemidji will be improved and the maximum praticable reduction
in phosphorus loadings to the Chain of Lakes will be  attained.   This will
result in reversal of the trend towards advanced eutrophication in these
lakes that was initiated in 1955 when the City began  discharging effluent
directly to the Upper Mississippi River downstream of Lake  Bemidji.

Cur regulatory requirements for proportionate user charge systems  for grantees
will necessitate a revision of Bemidji's existing rate  structure.   Although
the O&M and debt service costs associated with the new  treatment plant are
expected to be significantly higher than current WWTP costs,  residential user
costs are projected to remain close to the current level (because  of the con-
version of the rate structure).  However, conmercial  users, including the
University, are projected to pay higher user costs for  wastewater  service
in the future.

Wild and Scenic River

On December 30, 1976, the Secretary of the Interior,  through  the Bureau
of Outdoor Recreation, determined that the construction of  a  WWTP  at
Bemidji would have no direct and adverse impact on the  quality of  the
proposed Upper Mississippi Wild and Scenic River.  Furthermore, the
protection of the Upper Mississippi as a Wild and Scenic River  under
P.L. 90-542 expired on August 25, 1980.

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Mitigative Measures

1.  Construction Impacts

    Direct impacts from the construction of the new WWTP at the site
    of the existing WWTP will consist of fugitive dust, emissions
    from construction equipment noise, and the occasional  interruption
    of traffic flow.

    Fugitive dust should be controlled by periodically wetting spoil-piles
    and unpaved access roads or by covering them with matting or mulch
    to reduce susceptibility to wind erosion.  Trucks transporting spoils
    to disposal sites should cover their loads.  Proper maintenance of
    construction equipment and application of emission control devices
    should minimize emissions of hydrocarbons and fumes.   Construction
    activities should be scheduled to avoid evening and night work to
    avoid disturbance during periods of low background noise.

2.  Erosion and Sedimentation

    Erosion and sedimentation must be minimized at the construction site.
    USEPA has established requirements for erosion and sedimentation
    control in PEN 78-1.  The requirements include providing plans and
    specifications for erosion and sediment control, discussing specific
    control measures in the Operation and Maintenance Manual and reviewing
    the control measures during construction inspection.

3.  Archaeological/Historic Preservation

    No archaeological or historic sites are known to exist at the WWTP
    site.  A portion of the proposed site already was disturbed by
    excavations during construction of the existing plant.  There is
    a possibility, however, that archaeological resources  exist on undis-
    turbed portions of the site that could be damaged by excavations for
    new treatment units.  The State Historic Preservation  Officer should be
    consulted during Step 2 design work regarding the need for a detailed
    archaeological survey.  If archaeological resources are discovered
    on the site, the site layout may have to be altered or the resources
    salvaged to permit construction.

4.  Ploodproof ing

    The extreme southeastern portion of the proposed WWTP  site is within the
    100-year lake floodplain.  No construction activities  are proposed
    for that area, although future plant expansion in that area of the
    site may be required.  Appropriate floodproofing measures would then
    be required for future facilities in that area.

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                        Summary comparison of costs of advanced-secondary  wastevater treatment  options for the
                        six alternatives considered for Bemldll, Minnesota In the EIS (based  on RCM 1979 b and  1980).
                        Note that MPCA has refined  the estimated cost  of achieving a 0.3 mg/1 phosphorus level  for
                        Alternative 3 to an estimated $11,945,000 for  construction cost and $362,000 for O&M.
w
Alternative 1
(IILU Mlddlj^lp^l
River plant allu
wltli dluclur,;u lo



till.:



River)
l.U
•B/l r
Liic.l construction com 11.174
^•.JtiCJl u'urc 7,'J'Jl
il Hd »li. ITU 1,5yd
Ucal jlitrd l.7Bi
K
Anu.i-l U..i: 411
t*:to
Toui
Total
.'-: ..uj
t.O~ I j
i
S.M..
•i i
j
-jicj aalva^i: value 1,911
l-rckcnl wo ri!i caul 15.tt'j6
e-.ulvilcru atinu.il cost 1.515
l>jr I.O'JO Djllona 9 2.0S
(« $1.000)
0.1
aj/l r
U.litl
ID.OJ7
i,lM1
2.254
SJ'J
1.VJ1
IU.966
1.UII7
$ 2.61
Altarnailvc 2 Alternative 1
(nun plant
at existing alto (new plant at
with d 1 uchfl rt|il Jluch.ir^c lo Laku
Klvcr) (» 51,000) lli-ifl.||l) (« 51,000)
1.0
n^/1 P
11.649
a.idi
1.617
l,Ui9
417
1.901
16.2"J4
1.347
9 2.12
Cut Li.-l.i-o juiiiji: l.il c.ijiltul cot.1 for necJuil aaaar
ii-it incliiu^ Oiil cor collect luu
: o.i ?J >cjfj Ji 7.125; liiicccjt
>yuteu ($6
, ratu.

.50/uuiilli

0.1
n.C/1 f
14.57d
I0.2JO
2.046
2. J02
515
l.'JUl
19.291
i. ma
9 2.65
uyutdia
fur uvui

on Intoruiuilon or
1.0
0B/1 L>
9.975
7.009
1.402
1,565
417
3.184
14,3)1)
1.16d
9 1.87
0.1
»B/l V*
I2.V04
9.055
1.811
2,11)7
525
3.184
17.000
1.678
9 2.30
Alternative 4
(nuu plant
at exlutliic
alia with Jtu-
cturnu to Urajj
Luke) (K $1.0(10)
1.0

13.2'JH
9.J15
1.067
2.0C8
492
4.381
18.452
1.758
9 2.40
0.3
•i/l t
16.219
11,162
2.276
2, Sol
6UO
4,381
21.4U8
2,040
9 2.94
Altarnattvc 5 Alternative 6
(»uw pi en l
At Ctoaa (l»ni
L.ikvi Jltli .11*- tr>:.ilti:<>iit at
cliurud to Graja Ecklud Tc'.na'ilp
fjUj) (x $1.000) »ltc) (x 51, CCO )
1.0
uu/l P
12,912
9.046
t.m
2.029
492
4,151
10.094
1,724
9 2.16
0.3

15.U61
11.112
/.22Q
2.5i)i
60U
4,151
21.057
2.007
9 2.S9


24.417
19.451
2.0c'J
2,y;6
612
7,l!/l
Zi.^OJ
2.754
9 4.03
laproycmu n t u.
•act: hoiiiiuliolJ In I960).

cue n led la

MrCA fl98Q'j) •


— aca Table 2-4.

Similar

coal revlalo

CIS Alsd JU^lV E
              iilvun 1,  2. 4. juJ 5; Bucli rcvlulunu uoulJ not affect the proparclonutu differences la cost among the alternatives.

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