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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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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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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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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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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