United States Region 3 August 1985
Environmental Protection 841 Chestnut Building
Agency Philadelphia, Pennsylvania 19107
A Final Environmental
«*ERf\ impact Statement
Parkway Wastewater
Treatment Facilities
Prince George's County, MD
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j*,l0SX UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
122Z
£ 841 Chestnut Building
Philadelphia,' Pennsylvania 19107
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS AND CITIZENS:
The U.S. Environmental Protection Agency (EPA) has prepared the Final
Environmental Impact Statement (EIS) on the proposed Federally funded
upgrade of the Parkway wastewater treatment plant in Prince George's
County, Maryland. Concurrently, the Washington Suburban Sanitary
Commission (WSSC) has prepared an engineering Facilities Plan which
examined alternatives for accomplishing the required upgrade.
This Final EIS was prepared pursuant to the National Environmental
Policy Act (NEPA), which requires that the environmental consequences
of major Federal actions be considered and publicly disclosed before any
final decisions are made, such as funding for wastewater treatment
facilities.
In order to achieve the National Pollution Discharge Elimination
System (NPDES) permit conditions issued by the State of Maryland, the
most desirable alternative was judged to be that system which comprised
metal salt addition for phosphorus removal and suspended growth denitri-
fication, belt press dewatering, and composting. This system was
determined to be environmentally sound, cost-effective with low energy
use and minimal sludge production. However, EPA's preference for this
option, designated Alternative 3 in the Final EIS, does not commit the
agency to provide construction grant funds for advanced treatment (AT)
processes that may be needed to attain effluent limits specified
in the NPDES permit. Construction grants funding decisions are currently
pending and will be made in accordance with EPA's AT review policy.
Comments or questions concerning the Final EIS should be submitted
to Mr. James L. LaBuy at the above address by no later than
I wish to thank the officials and citizens of Prince George's County
for the participation and assistance provided to EPA's staff during this
EIS process.
vSi nee rely
fJames
Regional Administrator
Enclosure
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FINAL ENVIRONMENTAL IMPACT STATEMENT
ON
PARKWAY WASTEWATER TREATMENT FACILITIES
PRINCE GEORGES COUNTY, MARYLAND
Prepared by:
U.S. Environmental Protection Agency
Region III
Philadelphia, Pennsylvania
Thomas Slenkamp, Project Monitor
With the Assistance of:
ESEI, inc.
Rockaway, New Jersey
Type of Action:
Legislative ( )
Administrative (X)
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TABLE OF CONTENTS
PAGE
List of Tables ii
List of Figures iii
FORWARD iv
EXECUTIVE SUMMARY v
I. INTRODUCTION 1-1
II. DRAFT EIS SUMMARY 2-1
The Facilities Plan/EIS Process 2-1
Study Area 2-1
Issues 2-1
Draft EIS Conclusions 2-1
Funding Considerations 2-6
Recommended Alternative 2-6
III. PUBLIC PARTICIPATION 3-1
Introduction 3-1
Public Meetings 3-1
Media/Public Contact 3-1
Steering Committee 3-2
Public Hearing 3-2
IV. CONCLUSIONS AND RECOMMENDATIONS 4-1
Impact Comparison 4-1
EPA Recommendation 4-1
V. PUBLIC AND AGENCY COMMENTS ON DRAFT EIS 5-1
Comments. 5-2
Public Hearing Transcript 5-41
Responses 5-70
REFERENCES 6-1
APPENDIX A: PARKWAY EIS DISTRIBUTION LIST
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LIST OF TABLES
Table Page
V-l Estimated User Coats 5-76
V-2 Wastewater Treatment Plant Flow Data 5-77
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LIST OF FIGURES
Figure Page
1-1 Parkway ultimate Service Area 2-2
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FORWARD
The discussion in this EIS regarding phosphorus and nitrogen control for the Patuxent
River should be understood as being based on the information available to EPA at the
present time. The Maryland government has taken tremendous initiative in acting to
resolve the longstanding nutrient controversy in the Patuxent River through a
cooperative scientific and public participation review process. Maryland's decision
to control nitrogen inputs to the River was based on several factors which bear
mentioning here: Additional research and monitoring continues to be conducted to
further analyze and understand the relationship of nutrients in the estuarine portion
of the Patuxent River; the model that was used for the River becomes less accurate in
a direct relationship to the downstream length of the River; the State of Maryland
continues to be concerned with the dissolved oxygen levels in the lower estuary which
may be seasonally attributable to nitrogen inputs; and finally, continued scientific
research data will improve our understanding of nutrient dynamics in an estuarine body
of water.
It must be understood that this process is and will be dynamic over future years and
that refinements in decision making can only be made with an increase in further
scienific understanding.
Funding decisions for projects on the Patuxent River have yet to be fully scrutinized
and the major funding decision associated with the project which is the subject of
this Environmental Impact Statement will not be made until engineering designs are
complete. Further, when costs are not excessive, land treatment or wastewater
recycling should receive the utmost consideration for implementation as in this
particular EIS.
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EXECUTIVE SUMMARY
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EXECUTIVE SUMMARY
This Excecutive Summary briefly reviews the text presented in the final Environ-
mental Impact Statement (EIS). It is recommended that conclusions be drawn only after
the complete document has been reviewed.
Background The National Environmental Policy Act (NEPA) requires all
Federal agencies to prepare an Environmental Impact Statement
(EIS) on major Federal actions significantly affecting the
quality of the human environment. The main purpose of an EIS
is to explain the environmental consequences of pending
Federal actions in order that government officials can make
responsible decisions. Federal funding for wastewater treat-
ment facilities through the U.S. Environmental Protection
Agency's Construction Grants Program is subject to the re-
quirements of NEPA.
Project This Final EIS concerns the upgrading of Parkway Wastewater
Treatment Plant (WWTP), near Laurel, Maryland. The facility
is operated by the Washington Suburban Sanitary Commission
(WSSC) which had received a facilities planning grant to
analyze the wastewater needs for the planning area. Previous
planning efforts for the Patuxent Basin determined that
existing treatment levels were inadequate to control
eutrophication (accelerated plant growth) in the Patuxent
River. This project is based on the need to improve the
Parkway Facilities to meet the effluent limitations of the
National Pollution Discharge Elimination System (NPDES) permit
issued by the State of Maryland.
Original Issues Over the last decade, information was developed concerning
water quality conditions and the causes of water quality
degradation in the Patuxent River Basin. Controversy arose
over proposed plant expansion, the feasibility of land
treatment of wastewater and the appropriate limitations on
discharges to the upper Patuxent Basin. In 1979, EPA issued a
Notice of Intent to prepare an EIS concurrently with
facilities planning revisions for the Parkway plant. The
issues focused on the feasibility of land treatment as an
alternative to conventional advanced wastewater treatment, the
design capacity of the facilities, and the effects on non-
point pollution loading caused by additional development in
the area.
Between 1979 and the present, several major developments have
changed the focus of this EIS. Initially, a water quality
modeling study of the Patuxent River was completed which
addressed both the causes and possible solutions to water
quality degradation in the river. Second, population
projections for the area were reduced, resulting in
abandonment of plans for expansion of the plant. Finally, a
nutrient control strategy was developed by the State of
Maryland for the entire Patuxent River Basin. As a result,
the State issued a NPDES permit which set limits on the
quality of discharge from Parkway WWTP (which involves both
nitrogen and phosphorus control) and reiterating the pre-
ference for land treatment, if feasible and cost-effective.
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Remaining Issues
The level of treatment required at Parkway WWTP.
0 In an effort to resolve basin-wide problems, the discharge
permit requires control of both nitrogen and phosphorus. How-
ever, EPA's analysis of water quality modeling suggests that
phosphorus or nitrogen control exhibited comparable results
and that control of both results in no further improvement.
For this reason, various levels of nutrient control were
examined.
The feasibility of land application.
0 Because of the preference for this type of alternative
wastewater management, site-specific analysis of land treat-
ment was conducted.
Public Comments EPA received several written and verbal comments on the draft
EIS during a formal comment period which ended March 1984.
Oral testimony on the Draft EIS was recorded at a Public
Hearing conducted by EPA at Laurel, Maryland on January 26,
1984. Written comments on the Draft EIS were also received by
EPA during a public comment period that commenced with the
distribution of the Draft EIS and was originally scheduled to
end on February 13, 1984. This comment period was subse-
quently extended to March 12 upon request. The public and
agency comments are addressed in Chapter V of this document.
Major Issues from Two major issues were raised during the public comment period
the Public on the Draft EIS.
Issue Is The principal issue raised was over the level of
treatment required for nutrient control and why
EPA is proposing phosphorus control and not
nitrogen.
Response: Modeling the factors affecting algal control
(eutrohpication) is a complex task. To date, no
model has conclusively shown that at present
wastewater flows, an effluent nitrogen limitation
of 3.0 mg/1 within the freshwater Patuxent would
significantly reduce chlorophyll "a" concentra-
tions in the lower (brackish) portion of the
system beyond those projected to occur if an
effluent phosphorus limit of 1.0 mg/1 were
imposed. The technical evaluations concluded
that approximately 30 to 50 percent of the
nitrogen load originates from point sources
(i.e., sewage plant effluents), and 50 to 70
percent of the nitrogen load originates from non-
point sources (i.e., stormwater runoff from urban
and agricultural land). Therefore, it can be
expected that nonpoint sources of nitrogen will
continue to contribute significant nitrogen loads
after point sources of nitrogen are reduced. in
addition, blue-green algae can fix nitrogen from
atmospheric sources (approximately 78 percent of
the atmosphere is nitrogen), thereby satisfying
their nitrogen growth requirement.
However, by regulating phosphorus concentrations
in STP effluents, 60 to 70 percent of present and
projected phosphorus (P) loads can be reduced.
If phosphorus concentrations in the upper and
lower Patuxent were reduced, the available N:P
vi
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ratio would increase, and phosphorus would become
even more limiting for algal growth than at
present. Controlling point source discharges of
phosphorus will provide a consistent basinwide
nutrient management approach to controling algal
growth and increasing DO concentrations in the
Patuxent River and Estuary.
In addition, because of the high costs and opera-
tional problems associated with nitrogen removal,
EPA regards phosphorus removal as the more cost-
effective method for improving water quality.
However, EPA will continue to encourage the State
to provide scientific justification to support
its contention that nitrogen removal is also
needed. If such measures prove feasible, EPA
would consider those options in a reevaluation of
the nutrient control needs of the Patuxent
system.
Issue 2: The feasibility of land application was also
evaluated.
Response: Because of the possible beneficial impacts asso-
ciated with this type of alternative wastewater
management, site-specific analysis of land treat-
ment was conducted.
Site A-l; Detailed investigation revealed that
rapid Infiltration could only be done by using a
system of underdrains and discharge to surface
waters because of groundwater conditions at the
site. The highly variable soils make
predicitions of hydraulic capacity difficult and
tests of phosphorus adsorption (necessary for
sufficient removal of phosphorus for discharge to
surface waters) showed that the infiltration
basins would have rather short lives before
phosphorus levels in the discharge would exceed
project limitations, necessitating phosphorus
removal during pre-application treatment.
The planned discharge of approximately 7.5 mgd to
Indian Creek or its tributaries will greatly
increase flows in the stream. During flood
periods, the additional flow may increase erosion
rates in the stream channel. Modifications in
the form of check dams to retard flow would
probably be necessary. Although the expected
quality of the discharge is good, the increased
flow may very well result in adverse changes to
the resident aquatic communities of the stream.
Since groundwater quality is quite high in the
area, the potential adverse impacts on ground-
water are of concern, especially in regard to
increasing nitogen levels due to leakage or
bypassing of the underdrain system. The poten-
tial significance of the impact is difficult to
estimate since the volumes reaching groundwater
cannot be quantified. Given the above con-
siderations, large scale pilot studies of the
underdrained rapid infiltration would be required
to support this approach.
Issue 1;
Response
Cont'd
vii
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Site W-l; The preliminary investigation con-
ducted for this site indicated that it was not
capable of accommodating a slow rate irrigation
system for treatment of 7.5 mgd of pre-treated
sewage effluent on the site itself. The appli-
cant identified an additional 300 acres adjacent
to the site which had suitable characteristics for
a slow rate irrigation system. With this
additional acreage, it was determined that
sufficient land area is available. Analysis of
hydraulic and nutrient loadings demonstrated that
with proper crop management practices, infiltra-
tion of incompletely renovated wastewater to
groundwater should not be a problem. Since there
is no discharge to surface waters, and sufficient
buffer zones between application areas and the
streams which cross the site are available, runoff
and stream er6sion should be minimal. Site
specific testing of soils and groundwater levels
are necessary to insure that the design criteria
can be met.
Site W-l was considered the most favorable land
treatment alternative, but was not recommended by
WSSC because of its high costs, potential imple-
mentation delays, and possible limitation on
useable land.
Alternatives Two alternative concepts were examined in the Draft EIS.
Conventional wastewater treatment processes to be constructed
at the Parkway WWTP which would enable the facility to achieve
higher levels of treatment, and alternative technology in the
form of land treatment of pretreated wastewater at several
potential sites.
Selected Alternative In order to achieve the NPDES permit conditions issued by the
State, the most desirable alternative was judged to be that
system which comprised metal salt addition for phosphorus
removal and suspended growth denitrification, belt press
dewatering, and composting. This system was determined to be
environmentally sound, cost-effective with low energy use and
minimal sludge production.
This option, designated Alternative 3 in the Final EIS, is
capable of achieving a level of treatment consistent with the
NPDES permit (seasonal total nitrogen limitation of 3 mg/1 and
phosphorus limitation of 1 mg/1). However, EPA's preference
for Alternative 3 does not commit the Agency to provide
construction grant funds for advanced treatment processes (ATP)
needed to attain the effluent limits specified in the NPDES
permit. Construction grant funding decisions are currently
pending and will be made in accordance with EPA's ATP review
policy.
Although the land treatment alternative has the most favorable
environmental advantages, its likely higher projected costs
(45% higher projected costs than Alternative 3), potential
implementation delays, and possible limitations on future land
use have eliminated this alternative from future consideration.
Issue 2;
Response
Cont.d
viii
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Chapter 1
Introduction
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CHAPTER I
INTRODUCTION
This Final EIS concerns the upgrading of the Parkway
Wastewater Treatment Plant, near Laurel, Maryland (see Figure
1-1). The facility is operated by the Washington Suburban
Sanitary Commission (WSSC) which has received a Facilities
Planning grant to analyze the needs of the facilities.
Parkway is one of several treatment facilities which discharge
treated wastewater to the Patuxent River. Planning for the
entire Patuxent Basin determined that existing treatment
levels were inadequate to control eutrophication (accelerated
aquatic plant growth) of the Patuxent River. The action
contemplated is based on the need to improve the Parkway
Facilities to meet the effluent limitations of the National
Pollution Discharge Elimination System (NPDES) permit issued
by the State of Maryland
Over the last decade, information was developed concerning
water quality conditions and the causes of water quality
degradation in the Patuxent River Basin. Controversy arose
over proposed plant expansion, the feasibility of land treat-
ment of wastewater and the appropriate limitations on
discharges to the upper Patuxent basin. In 1979 EPA issued a
Notice of Intent to prepare an EIS concurrently with facili-
ties planning revisions for the Parkway plant. The issues
identified in the Notice of Intent focused on the feasibility
of land treatment as an alternative to conventional advanced
wastewater treatment, the design capacity of the facilities,
and the effects on non-point pollution loading caused by
additional development in the area.
Between 1979 and the present several major developments have
changed the focus of this EIS somewhat. First, a water
quality model of the Patuxent River was completed which
discussed both the causes and possible solutions to water
quality degradation in the river. Second, population
projections for the area were reduced resulting in the
abandonment of plans for expansion of the Parkway plant.
Finally, a nutrient control strategy was developed by the
State of Maryland for the entire Patuxent River Basin. This
resulted in the states issuance of an NPDES permit for
Parkway, setting the limitations on the quality of discharge
from the facility (which involves both nitrogen and phosphorus
control) and reiterating the preference for land treatment, if
feasible and cost-effective.
Given these developments, the remaining issues that needed to
be addressed included:
o The level of treatment required at Parkway. In an effort to
resolve basin-wide problems, the discharge permit requires
control of both nitrogen and phosphorus. However, EPA's
analysis of water quality modeling suggests that phosphorus
control or nitrogen control exhibited comparable results and
that control of both results in no further improvement. For
this reason, various levels of nutrient control were examined.
o The feasiblity of land application. Because of the pre-
ference for this type of alternative wastewater management, a
site-specific analysis of land treatment was conducted.
1-1
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A Draft EIS on the Parkway Wastewater Treatment Facilities was
completed and distributed to the public in December, 1983.
The Draft EIS incorporated most of the Facilities Planning
Engineering analyses and cost estimates. The Draft EIS is
summarized in Chapter II of this Final EIS. Aside from that
summation, the contents of the Draft EIS are not repeated, but
are included by reference where necessary. The Draft EIS was
widely distributed to Federal, State, and local agencies as
well as to numerous citizens and interest groups. Copies of
the Draft EIS are available for review at local libraries and
municipal offices.
A public hearing on the Draft EIS was conducted by EPA on
January 26, 1984 at Laurel Maryland, at which time all
interested parties had the opportunity to present their
comments and recommendations concerning the Draft EIS and the
wastewater management alternatives. Written comments on the
Draft EIS were also received by EPA during a public comment
period that commenced with the distribution of the Draft Eis
on December 30 , 1983 and was to end on February 13, 1984.
This was later extended to February 27 and then to March 27,
1984. The public and agency comments are addressed in Chapter
V of this document.
The primary purpose of this Final EIS is to evaluate and
address questions, comments, and recommendations received
during the Draft EIS public comment period. By doing so, the
critical issues concerning this project are clarified,
enabling EPA to present its findings regarding wastewater
management in the area.
1-2
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Chapter 2
Draft EIS Summary
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CHAPTER II.
DRAFT BIS
SUMMARY
The Facilities Five steps were involved in the concurrent development of a
Plan/EIS Process Facilities Plan and EIS. These are: (1) identification of
existing conditions; (2) identification of wastewater treat-
ment needs over the 20-year planning period; (3) development
of alternatives capable of meeting those needs; (4) identifi-
cation 'of the environmental consequences of the alternatives;
and (5) identification of a cost-effective and environmentally
sound alternative for implementation.
Study Area The primary geographic area for consideration of impacts in
the EIS includes the Parkway service area and immediate
vicinity as shown in Figure 1-1. The service area encompasses
the city of Laurel and portions of planning areas 60 (North-
western) and 62 South Laurel-Montpelier) of Maryland National
Capital Park and Planning Commission (MNCPPC) in Prince
George's County. A small portion of the service area extends
into Montgomery County.
Issues Major issues addressed in the Draft EIS include:
o The level of treatment required at Parkway. The analysis
of water quality modeling of the Patuxent River showed that
phosphorus control or nitrogen control exhibited comparable
results and that control of both nutrients resulted in no
further improvements. However, in an effort to resolve
basin-wide problems, the discharge permit required control of
both nutrients. Therefore, in addition to alternatives which
satisfy the discharge permit, alternatives with phosphorus
control only, and with phosphorus and partial nitrogen control
were developed and analyzed.
o The feasibility of land treatment. Both the State and
Federal governments regard land treatment as a preferable
solution if feasible and cost-effective. Therefore, site
specific analysis of land treatment was conducted.
Draft EIS
Conclusions
Population and Waste- The 1977 draft Facilities Plan recommended an expansion of the
water Flow Projections Parkway WWTP capacity to 12.5 mgd based on population projec-
tions applicable at that time. Revised population projections
by the Maryland National Capital Park and Planning Commission
(July 1979), and corresponding flow projections by WSSC, have
indicated no need for an expansion beyond the existing design
capacity of 7.5 mgd at the plant over the 20-year planning
period. Concern over impacts associated with an expansion has
thus been eliminated.
Existing Wastewater During preparation of the Facilities Plan an evaluation of the
Treatment Capacity Parkway plant revealed that even though the design capacity is
7.5 mgd, flows in excess of 6 mgd bypass the trickling filters
and flow directly to the aeration basin. As a result, BOD
removal efficiency is reduced. Several other problems at the
influent pump station, grit chambers and secondary clarifiers
may adversely affect plant efficiency. With projected
increased flow to 7.5 mgd, it may be increasingly difficult to
maintain efficient process operation. Internal modifications
to existing facilities would be required to attain the 7.5 mgd
capacity.
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2-2
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Effluent Limitations The discharge limits specified in the September, 1982 State-
issued NPDES permit for the Parkway plant cannot be met by the
existing facility. The new limits require upgrading of treat-
ment to reduce effluent phosphorus and nitrogen levels to 1
mg/1 and 3 mg/1, respectively. These limits were set by the
State of Maryland as part of its overall nutrient control
strategy for the Patuxent River Basin.
EPA water quality criteria recommend prevention of any
nutrient discharge that causes enrichment which leads to any
major change in the natural levels of flora. However, there
are no generic nitrogen or phosphorus concentrations. Those
concentrations must be established on a case-by-case basis
depending on the results of individual water quality analyses.
Patuxent River Water Water quality in the Patuxent estuary has declined steadily in
Quality and Nutrient recent decades, as evidenced by high chlorophyll "a" levels in
Control the upper Patuxent and a gradual upstream intrusion of low
dissolved oxygen in the bottom waters of the lower estuary
(especially below river mile 20-25). Excessive growth of
phytoplankton as evidenced by high chlorophyll "a" levels
ultimately adds a significant amount of organic material to
the bottom sediments in the lower estuary, aggravating the low
dissolved oxygen problem. It appears that any action to
reduce the nutrient loads which trigger the algal overgrowth
will reduce the resultant accumulation of organic matter on
the river bottom. A review of historical water quality data
indicates that increases in both point sources (e.g. sewage
treatment plants) and non-point sources (e.g. urban and
agricultural runoff) are important factors in the cause of the
above water quality problems.
During periods of low freshwater flow, the combined wastewater
flows from all of the Basin's sewage treatment plants (except
for Western Branch) comprise about 30 percent of the total
river flow at the Route 50 bridge. The Parkway WWTP accounts
for approximately 14 percent of this wastewater flow.
Non-point sources have been estimated to contribute approxi-
mately 70 percent of the total nitrogen and 40 percent of the
total phosphorus loads to the Patuxent River. Therefore, the
State's Nutrient Control Strategy for the Patuxent Basin
includes measures for controlling both point and non-point
sources of phosphorus and nitrogen. For all point source
facilities in the Basin greater than 0.5 mgd, the State
strategy recommends control of phosphorus to 1.0 mg/1 and
nitrogen to 3.0 mg/1.
EPA's analysis of all available water quality data on the
Patuxent indicates that phosphorus control at 1.0 mg/1 will
produce comparable results to nitrogen control at 3.0 mg/1,
greatly suppressing chlorophyll "a" levels in the upper river
basin (above river mile 35). EPA further concludes that
controlling nitrogen to 3.0 mg/1 in addition to control of
phosphorus to 1.0 mg/1 will produce no further reduction in
chlorophyll "a" levels. Because of this factor and the high
costs and operational problems generally associated with a
conventional nitrogen removal facilities, phosphorus removal
is considered by EPA to be the more effective method of
nutrient control.
2-3
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. Two major alternative concepts were examined in the Draft EIS.
Alternatives Conventional wastewater treatment processes to be constructed
at the Parkway WWTP which would enable the facility to achieve
hiaher levels of treatment, and alternative technology in the
form of land treatment of pretreated wastewater, at several
potential sites,
, e . mo A muiti-step development, screening and evaluation procedure
conventional Systems Am e ^ faciiities planner in selecting a treatment
svstem for Parkway that would meet the requirements of the
NPDES permit issued by the State of Maryland. This permit
requires phosphorus removal to a level of 1 mg/1 and nitrogen
removal to a seasonal level of 3 mg/1. Liquid and sludge
handlinq alternatives were combined to form 24 plant-wide
treatment alternatives. The individual processes that were
combined to form these alternatives were as follows:
Nitrogen Removal
Suspended growth denitrification
Packed bed denitrification
Phosphorus Removal
Lime addition
Metal salt addition
Phostrip process
Sludge Stabilization
Lime stabilization
Mechanical composting
Incineration
Anaerobic digestion
Sludge Dewatering
Belt press
Plate and frame press
Centrifuge
Based on technical evaluations, the most desirable system was
iudaed to be that alternative system which comprised metal
«alt addition for phosphorus removal and suspended growth
denitrification (Alternative 3), belt press dewatering, and
composting. This system also had one of the lowest total
project costs, low energy use and low sludge production.
This svstem is capable of achieving a level of treatment
distent with the NPDES permit issued by the State of Mary-
land (Seasonal total nitrogen limitation of 3 mg/1 and
phosphorus limitation of 1 mg/1). Two other alternatives were
also examined, using different levels of nutrient removal,
jphlfirst involves phosphorus removal only (Alternatives 5 and
i .nd the second involves control of both nutrients but with
an allowable concentration of 4-6 mg/1 of total nitrogen
(Alternative 7 and 8).
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Land Treatment The required Parkway NPDES permit limits can also be achieved
by using land treatment technology. Preliminary investigation
through the Parkway Facilities Plan revealed that two (Sites
A-l and W-l) of the three sites identified in an earlier WSSC
report on land treatment in Prince Georges County were
potentially feasible sites for treating the Parkway flow.
Site A-l Detailed investigation of the geohydrological conditions at
Site A-l revealed that rapid infiltration at the site could
only be done by using a system of underdrains and discharge to
surface waters because of groundwater conditions at the site.
The highly variable soils make predictions of hydraulic
capacity difficult, and tests of phosphorus adsorption
(necessary for sufficient removal of phosphorus for discharge
to surface waters) showed that the infiltration basins would
have rather short lives before phosphorus levels in the
discharge would exceed projected limitations, necessitating
phosphorus removal during pre-application treatment.
The planned discharge of approximately 7.5 mgd to Indian Creek
or its tributaries will greatly increase flows in the stream.
During flood periods the additional flow may increase erosion
rates in the stream channel. Modifications, in the form of
check dams to retard flow, would probably be necessary.
Although the expected quality of the discharge is good, the
increased flow may very well result in changes in the aquatic
community of the stream. Since groundwater quality is quite
high in the area, the impacts on groundwater are of concern
especially in regard to increasing nitrogen levels due to
leakage or bypassing of the underdrain system. The signifi-
cance of the impact is difficult to estimate since the volumes
reaching groundwater cannot be quantified. Given the above
considerations, large scale pilot studies of the underdrained
rapid infiltration system would be required.
Site W-l The preliminary investigation conducted for this site
indicated that it was not capable of accommodating a slow rate
irrigation system for treatment of 7.5 mgd of pre-treated
sewage effluent on the site itself. The facilities planners
identified an additional 300 acres adjacent to the site which
had suitable characteristics for a slow rate irrigation
system. With this additional acreage, it was determined that
sufficient land area is available. Desk top analysis of
hydraulic and nutrient loadings demonstrated that with proper
crop management practices, infiltration of incompletely
renovated wastewater to groundwater should not be a problem.
Since there is no discharge to surface waters, and sufficient
buffer zones between application areas and the streams which
cross the site are available, runoff and stream erosion should
be minimal. Site specific testing of soils and groundwater
levels are necessary to insure that the design criteria can be
met.
Costs Capital and total present worth costs of the in-plant process
alternatives 3, 5, 6, 7 and 8, and the two land treatment
alternatives (A-l and W-l) as developed by the Facilities
Planner are shown in the following table:
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Present Worth
Capital Cost Total Present Worth
(thousands of (thousands of
dollars) dollars)
Alternative 3 17,620 53,270
Land Treatment A-l 39,460 66,580
Land Treatment W-l 47,990 77,270
Alternative 5 12,709 41,757
P Removal Only
Alternative 6 15,989 44,167
P Removal Only
Alternative 7 17,464 51,944
Alternative 8 23,750 57,943
• j 4.4^ „ The NPDES permit requires seasonal nitrogen removal at
Funding Considerations JS PKkway plant as part of its overall nutrient control
strategy for the Patuxent River. It is EPA's opinion that the
studies performed to date do not provide an adequate technical
basis to support nitrogen control in addition to phosphorus
control. As a result, if the funding decisions were made
todav, Federal construction grant funds could only be provided
to fund the cost-effective solution for achieving the
technically justified nutrient effluent requirements (i.e.
phosphorus removal to 1 mg/1).
At a meeting held in early 1983 between the State of Maryland,
WSSC and the County Executives of Montgomery and Prince
Georqes Counties, the State administration indicated it will
seek capital funding for the incremental capital cost of
nitrogen removal facilities for the Parkway and Western Branch
STP's if EPA funding is not forthcoming, thereby easing the
cost 'burden on local jurisdictions, who must otherwise fund
the additional facilities.
WSSC concluded in its July, 1983 Facilities Plan that the most
, famrable wastewater treatment alternative for upgrading the
Recommended Alternative existing Parkway effluent quality is liquid Alternative 3,
consisting of metal salt addition for phosphorus removal,
suspended growth denitrification for nitrogen removal, belt
presses for sludge dewatering, and mechanical composting.
Site W-l is considered the most favorable land treatment
alternative, but was not recommended by WSSC because of its
high costs, potential implementation delays, and possible
limitation on useable land.
The Draft EIS made no recommendation of an EPA preferred
alternative. EPA's recommendation is contained in this Final
EIS and is based, in part, on public comments made on the
Draft EIS and Facilities Plan and on testimony presented at
the public hearing.
2-6
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Chapter 3
Public Participation
-------
CHAPTER III.
PUBLIC PARTICIPATION
Introduction During the preparation of the Draft and Final EIS, EPA sought
participation from local, regional, state and federal
agencies, citizen associations, individual citizens and
interested environmental groups. EPA has considered sug-
gestions, criticisms and objections from the public in
documenting the need for upgraded wastewater treatment
facilities, in developing wastewater management strategies and
in assessing potential impacts. EIS newsletters, adver-
tisements and meetings with the public have been used to
insure that all concerned parties received an opportunity to
be involved in the process.
Public Meetings
Since the Parkway Facilities Planning/EIS process began in
1979, EPA has conducted three public meetings as listed below.
These meetings were intended to inform and involve the public
in all decisions as fully as possible.
Date
June 19, 1979
August 11, 1982
Location
Laurel Senior High School
Laurel, Maryland
Bowie Senior High School
Bowie, Maryland
Topics Discussed
EIS process,
scope and issues.
Status, discus-
sion of alterna-
tives evaluation.
November 30,
1982
Bowie Senior High School Costs, land
Bowie, Maryland application.
Media/Public Contact
In 1979, when the Parkway wastewater management planning
process was initiated, EPA prepared and distributed a news-
letter which described the project and its potential effects
on the public and the environment, and invited all recipients
to a public meeting. In addition, public meeting notices were
advertised in area newspapers. Approximately 20 persons
attended the June, 1979 meeting.
In February, 1980, EPA prepared and distributed a second
newsletter which informed the public of changes in scope and
time frame of the EIS, announcing the postponement of activity
on the EIS pending the outcome of studies on the nutrient
wasteload allocations for the entire Patuxent River basin. In
July, 1982, EPA prepared and distributed a meeting announce-
ment which detailed the history and updated progress on the
planning activities. Meeting announcements were also
advertised in area newspapers. Approximately 25 persons
attended the August 11, 1982 meeting and approximately 100
people attended the November 30, 1982 meeting.
During the early stages of the project, public concern
centered on growth in the area related to planned expansion
(at that time) of the Parkway WWTP, and the level of treat-
ment, especially in regard to nutrient removal, necessary to
protect the Patuxent River. Growth and planned expansion of
the WWTP is no longer an issue since as described in Chapter
II, upon examination of population projections, expansion of
the facility is considered unnecessary. Concern, and
3-1
-------
controversy, over the level of treatment necessary led to the
review and analysis of nutrient control plans for the Patuxent
River Basin, to determine the most cost-effective means of
achieving water quality goals. This culminated in a conflict
resolution meeting in late 1981, at which representatives of
diverse interests attended. It resulted in the issuance of a
Nutrient Control Strategy by the Office of Environmental
Programs, of the Maryland Department of Health and Mental
Hygiene. The NPDES permit issued by DHMH reflected the
conclusions of the Nutrient Control Strategy and in part
shaped the analyses of this EIS.
The last public meeting was a joint meeting to discuss both
the Parkway and Western Branch Facilities Plans and EIS's.
The major concern brought forth by ths public dealt with the
possibility of land application in southern Prince George's
County, and almost overwhelming opposition to the concept by
residents of that area. As explained at the meeting,
consideration of land application was required but would only
be considered feasible if cost-effective and implementable.
A steering committee was established as an advisory group
comprising WSSC and state agency representatives and
representatives of each o£ the counties affected by wastewater
management activity in the Patuxent Basin. The following
persons are members of the committee:
Name Affiliation
Steering Committee
Public Hearing
John Brosninghara
Jesse Maury
Seymour Bayuk
James Irvin
Craig Coker
Peter Tinsley
Vivian Marsh
Dennis Bigley
Larry Ludwig
WSSC
WSSC
Anne Arundel County
Howard County
Montgomery County
Maryland Office of Environmental
Programs
Calvert County
Prince George's County
St. Mary's County
This committee met three times to discuss land treatment
alternatives considered in the Parkway facilities planning
process and levels of treatment necessary at the Parkway WWTP.
The steering committee, because of its makeup, has provided
valuable insight by knowledgeable professionals at a local
level, who are intimately affected by the proposed actions.
A public hearing on the Draft EIS was conducted by EPA on
January 26, 1984 at Laurel, Maryland, at which time all
interested parties had the opportunity to present their
comments and recommendations concerning the EIS and the
wastewater management alternatives. Written comments on the
Draft EIS were also received by EPA during a public comment
period that commenced with the distribution of the Draft Els
on December 30, 1983 and was to end on February 13, 1984.
This was later extended to February 27 and then to March 27,
1984. The public and agency comments are addressed in Chapter
V of this document.
3-2
-------
Chapter 4
Conclusions and Recommendations
-------
CHAPTER IV
CONCLUSIONS AND
RECOMMENDATIONS
Impact Comparison An evaluation of in-plant process alternatives revealed that
upgrading of the Parkway plant to meet the requirements of the
NPDES permit could be accomplished within the confines of the
existing plant site. A technical and cost-effectiveness
evaluation by WSSC of liquid and sludge processes, both
separately and in combination, led to the conclusion that the
most feasible alternative overall consisted of a system which
uses a metal salt as the primary coagulant for phosphorus
removal, suspended growth denitrification, belt presses for
sludge dewatering, and mechanical composting for sludge
stabilization. EPA's environmental analysis of the in-plant
alternatives concludes that there is no appreciable difference
among the alternatives insofar as environmental impact. All
alternatives will improve the quality of the existing effluent
by reducing nutrient loading to the Patuxent River, and the
dechlorination facilities implicit in the systems will reduce
the potential for stress to aquatic biota in the river below
the outfall. Implementation of such facilities at another
treatment plant in the basin has been shown to be beneficial to
the aquatic community.
Land treatment alternatives would also meet water quality
objectives, but could have significant problems with respect to
land acquisition and implementation.
EPA Recommendation EPA recommends Alternative 3 as the most favorable wastewater
treatment alternative. This option is capable of achieving a
level of treatment consistent with the NPDES permit (seasonal
total nitrogen limitation of 3 mg/1 and phosphorus limitation
of 1 mg/1). However, EPA's preference for Alternative 3 does
not commit the Agency to provide construction grant funds for
advanced treatment processes (ATP) which may be needed to
attain the effluent limits specified in the NPDES permit.
Construction grant funding decisions are currently pending and
will be made in accordance with EPA's ATP review policy.
Although the land treatment alternative has the most favorable
environmental advantages, its likely higher projected costs
(45% higher projected costs than Alternative 3), potential
implementation delays, and possible limitations on future land
use have eliminated this alternative from future consideration.
4-1
-------
Chapter 5
Public and Agency Comments on Draft EIS
-------
CHAPTER V
PUBLIC AND AGENCY
COMMENTS ON DRAFT EIS
The Regional Administrator of the Environmental Protection
Agency (EPA) signed a Notice of Intent to prepare an Environ-
mental Impact Statement on the proposed upgrade of the Parkway
Wastewater Treatment Facility on March 29, 1979. A public
meeting was held on June 19, 1979 to present EPA's proposed
scope of the EIS.
A Draft EIS was completed and widely distributed to Federal,
State and local agencies as well as numerous citizens and
interest groups in December, 1983. Copies of this document
are available from the Region III Office of EPA.
A public hearing to receive testimony on the Draft EIS was
conducted by EPA on January 26, 1984. Written comments on the
Draft EIS were also received by EPA during a public comment
period that commenced with the distribution of the document.
EPA considered comments concerning the Draft EIS beneficial in
assisting the Agency to refine its analysis of the upgrade of
the Parkway Plant. Therefore, this Chapter includes a tran-
script of the public hearing, all written comment letters and
EPA's response to each substantive comment.
To assist you in using this Chapter, each comment is marked
with a number which corresponds to the list of direct
responses. The list of responses follows the written comment
letters and public hearing transcript.
5-1
-------
March 11, 1984
Tom Slenkamp, Project Monitor
SIS Preparation Unit
and Marine Policy (EPM70)
U.S. EPA, Region III
6th and Walnut Streets
Philadelphia, PA 19106
Re: PuDlic Comment on draft EIS
for Parkway STP
(PaRiver)
Dear Mr. Slenkamp:
The following brief comments are offered, wnich are
repeated in larger part from more extensive respective
comments on the concurrent draft Els for Western flrancn STP.
We would like to comment that the draftEIS for tne Parkway
STP, prepared under Dr. Lann/ Katz of ESEI, was found to be
more thoughtfully prepared and informative tnan cne draft £IS
for Western Brancn, which was prepared by another contractor
to EPA.
1. The "no action" alternative that is required by NEPA
to be evaluated must meet minimum requirements of tne law.
The no action alternative e--'-.^yed in the draft EIS is that of
continuing to hook up mor~ development to the sewerage
collection system, and simultaneously continuing to increase
the discharge, while providing no additional treatment sucn as
nutrient removal before discnarging. This would violate tne
discharge permit with nitrogen (N) and phosphorus (P) removal
required in 1987. Accordingly, some costs would be associated
with the proper no action alternative. The proper no action
alternative would require providing tne eff^ient limitations
of the issued permit out as to tne lower flow, for meeting the
relevant water quality standards which are presently admitted
by the State and EPA, according to our understanding, to be
violated as a result of loadings including point sources. If
this is denied by either tne EPA or the State, we would
appreciate being informed on what basis, and oe given an
5-2
-------
Tom Slenkamp
March 11, 1984
Page 2
opportunity to further respond. Certainly tne issuance of the
permit by the State constitutes such conviction, wnicn is
strongly supported in the scientific community.
The draft EIS admits that the present capacity is 6 mgd
(page 50 line 20) and yet illogically attempts to argue tnat
the projected increase of 25% to 7.5 mgd also corresponds to
"existing" flow (page 88 line 12) even though "internal
modifications ... would be required" (page 102 line 30).
Accordingly, the no action alternative snould take into
account tne present air quality condition of the region and
the extent to which the relevant facility is at or near
capacity, including traffic flow on surrounding roads
including the Capitol Beltway and tne jtJaltimore-Wasnington
Par Kway.
2. Relevant to the xatter points above, the other
alternatives evaluated in the draft EIS should include air
quality (p. 41) and traffic projections, and whether tnese
effects are desirable or undesirable for the region, namely
whether the proposed federal investment in the upgraded
treatment capacity beyond present flows in fact constitutes a
poor investment in view of any undesirable effects, an
investment that is in fact- inconsistent with otner federal
laws and policies. Other indirect effects, sucn as nonpoint
source pollution loads including sedimentation and runoff
associated with the projected 25% in served population, snould
be taxen into account as well. The draft iCIS reports tne
ozone standard is not being met (page 10), and we question
whether standards relative to acid rain are being met.
3. Neither th*. draft ££S, nor the final section 208
basin plan or EPA comment thereon, or any other comments or
discussions known to the undersigned, have openly or
intelligently dealt with the apparent issues concerning point
source discharges of nutrients and their affect on algae and
dissolved oxygen further down river, and neither document
acknowledges what is understood to be a nearly unanimous
opinion among the scientific community that (N) loads from
point sources should dc controlled at least seasonally, in
view of N limitation generally obtaining in tne summer time in
the saline portions of the Chesapeake Bay and its estuaries,
as indicated in the analysis by D'Elia and Boynton of Patuxent
River data taken by the State and others (July 1982, Ref. No.
UMCEES 82-101CBL), in the EPA Cnesapeaxe Bay progrm
publications including Technical Studies: A Svntnesis and
Framework for Action (Sept. 1982 and 1983, respectively) and
5-3
-------
Tom 31en
-------
Tom Slenxamp
March 11, 1984
Page 4
performed wnerein N was removed to 3.0 mg./l at tne
discharging points while applying 9 or 50 mgd to land. In
other words, the modelling that was performed removed only P
from the discharging points, while allowing 60 percent of the
flows to be absorbed by the land, it was assumed tnat 40
percent of the land-treated water returned to tne surface
water with only 67% of original N concentration removed
(HydroQual Inc. report, Aug. 1881, p. 104). Thus tne
projected results for N control was compromised. Verification
of these points and any comments would be appreciated. It
appears from Fig. VI-6, tnat a P control stragegy of 0.3 mg/1
for year 200U flows would in fact violate water quality
standards, under either low or moderate stratification, thus
at least for a significant portion of tne time.
4. In view of the point? above and the following points,
it is respectfully submitted tnat the EPA finding that only a
one-nutrient control strategy, and not a 2-nutrient control
strategy, is the only federally fundable approacn to nutrient
controls, is arbitrary and capricious. Ratner, it is noted
that the comments in tne draft EIS for tne Parkway STP
acknowledges an N limiting condition in the estuary (page 22,
lines 20-43, etc), which concludes that P is not limited even
upriver. In addition to the other available scientific
literature, data and opinion, this clearly establishes tnat a
two nutrient strategy is in fact necessary, and particularly
for minimizing algae growth in different portions of the
estuary and at different times. P control is indicated in tne
upper freshwater portion, particularly in view of the blue
green algae which usually form in tnis mesosaprobic zone (page
25 lines 7, in and 11 Western Branch EIS) which are capable of
fixing w -'iiectly from the atmospnere (page 40 lines 36 and
37) .
The State has recently gone on record as stating that it
intends to present to EPA a final commentary attempting to
justify the need for removing N, and why facilities removing N
therefore should qualify for federal funding. It is
respectfully submitted tnat such comments would be most
properly included within the final EIS, since tnis is
understood to be the precisely appropriate form for such
discussions, as intended by NEPA. Therefore, absent any
mention in the draft EIS to any such relevant comment by the
State, it would appear that the draft EIS is incomplete, and
that the undersigned in fa^t have a right to request that such
comments from an essential party De included, and, in view of
of what they might contain, and of what remains to be shown,
the undersigned snould have the opportunity to review same and
5-5
-------
Tom Slenkamp
March 11, 1984
Page 5
comment thereon, as part of tne record before a final £16 is
prepared.
5. A clear representation of tne cost per capita for
removing nitrogen is desirable, particularly in view of wnat
is seen in large extent to be a political decision as to wnat
constitutes allowaole discharges of nutrients, on the argument
that there is still insufficient scientific knowledge.
(Please refer to item 7 in attached comments on Western Branch
draft EIS.) Points that snould be clearly expressed are that
the user charges are charges attributed to ail WSSC users,
including users connected to other STP1s where advanced
treatment and nutrient removal may not occur. On tne other
hand, it is desirable for purposes of perspective to
understand how much nutrient removals to desired levels
actually costs for each sewered person, irrespective of
wl.2thQr paid in part oy federal and State funding for tne
facility, since a cost for rendering eacn person's daily waste
as least as compatible with the environment as possible is
what should be addressed in the political process ana which is
in fact missing from the draft EIS, tne j20d plan, etc. These
costs should be computed and clearly reported in the final
£IS, preferably on a per capita per day oasis, botn for total
cost and user cnarge.
6. It is noted tnat consideration of cne cost for sludge
nandling is disposed of early at page 6, and no costs therefor
are apparently included in any of the alternatives, some of
which must be expected to produce different amounts of sludge
and therefore have different respective costs. Since sludge
disposal is of growing concern, it is respectfully submitted
tha. its cost under the different alternatives should be more
fully considered, and particularly under a land treatment
system utilizing a lagoon wherein much of the solid sludge is
eventually dissipated into the liquid state and requires no
express disposal. It is also understood oy the undersigned
that certain of the other treatment alternatives produce
significantly smaller amounts of sludge than others.
7. It is respectfully submitted that excessive inflow
and infiltration (I/I) exists, in view of the prior
determination of no excessive I/I being based entirely on a
comparison of costs at plants with no advanced treatment.
Please verify, or explain how the cost of advanced treatment,
was in fact taken into account in the determination of no
excessive I/I. Please also provide the cost per mgd at the
plant and as well the cost per mgd for determining the
tnreshold of excessive I/I. Since I/I in fact occurs, its
5-6
-------
Tom Slenkamp
Marcn 11, 1984
Page 6
reduction to non-excessive levels could significantly impact
the costing of alternatives, and particularly tne amount of
land required for land treatment.
8. One of the undersigned in the past several years nad
noted an incidence of nose and ear infections in his two
children and wife on several occasions following swimming in
the Patuxent estuary. He pursued this with the Calvert County
and was given summer sampling data snowing violations for tne
swimming standard throughout tne estuary by factors of 10 and
higher. Although such levels are understood to be sufficient,
to prevent the licensing of a public beach, the State Health
Department declined to take a position that such levels
constituted a menace to public healtn, on tne basis of tneir
investigations establisning tnat tnere was no evidence of a
correlation thereof with human waste. Then, only recently ne
learned through tne newspapers that the State Healtn
Department has posed a fine of §190,000 on a private STP
serving 800 houses about 15 miles upriver, namely the
Marlborough Meadows STP, which for at least three years had
been in gross violation of treatment requirements and
practices. We would line to point out that the effective fine
was only $60,000 since up to $130,000 could be offset against
tne cost of improving the facilities. Thus the moral seems to
be that the State is still most lenient, in view of the saving
in interest costs and further delay provided by the slow
settlement.
However, our poinc nere is that large portions of tne
estuary in fact are in violation of the swimming standard
during the summer, and we question wnetner this is something
».nat has increased with development and population growth in
the basin coming primarily from nonpoint source runoffs, or
whether this is due at least in part to point sources. Our
concern is for more than the Patuxent Basin, since it appears
that in fact this could be occurring in every estuary on tne
ChespeaKe Bay where any growth or development is occuring.
However, to date, neither the County nor the State have
offered to shed any light on this concern. We submit that it
is entirely proper to conduct a full investigation into tnis
question in the EIS, for documenting any trends (in fact
referred to at page 26, lines 22-24) indicated Dy available
data, ascertaining the source of the fecal coliform, and
determining how much of the fecal caliform is E. coli wnicn
comes only from human sources, as we understand.
9. There is concern tnat the selected alternative nave
the capability of meeting a limit for P of 0.3 mg/1 tnat is,
5-7
-------
Tom SlenKamp
Marcn 11, 1984
Page 7
lower than the present limit of 1.0 mg/1, which concern is
particularly relevant in the Patuxent River, since it is tne
State's position that in the future all of the major STP's may
be required to meet this lower limit, if efforts of
controlling algae and dissolved oxygen are not successful. It
is doubtful, however, that the State would require this if the
equipment was not reasonably capable of being made to operate
to the more stringent level.
10. The reference to present waste water flows of 36
mgd, in the draft EIS dated December 1983, hardly seems
appropriate in view of its origin from the Hydroqual report
whicn relates essentially to 1980 (?) . Updating of tnis flow
seems appropriate, and it is expressly requested tnat tne 10Q7
low flow of tne Patuxent River at the confluence witn tne
Little Patuxent River be calculated and included in the final
EIS, and it is respectfully requested if a copy of the
calculation would be kindly supplied. Also, the comment at
page 17 line 30 is not understood, namely cnat a minimum low
flow in the river is "determined by cnanges in reservoir
levels". Does this mean that evaporation losses in the
reservoirs can substitute for river low flows?
11. As a matter of curiousity, it is questioned wnether
land treatment should be advocated for tne purpose of
absorbing C02 from the atmospnere, that is, for mitigating the
greenhouse effect in the future, in addition to the additional
oxygenation of the local air wnicn mignt result from a land
treatment facility as compared to developing the potential
land treatment site in parking lots, houses, etc.
12. If a viable experiment on nutrients control, that
is, for both N and P, is to oe conducted in the Patuxent
basin, one that will yield some definite conclusions in the
next 10 years, conclusions which may be applicable to otner
estuaries and possibly the Bay itself, then it appears that
funds for N removal should be spread to treat as many of the
major STP's as possible, instead of presently subsidizing
growth not expected until after tne conclusion of tne
exper iment.
* * * *
Please let us know if we may be of nelp in furthering
resolution of any of the above issues. We shall forward by
the enC of the month some further comments attempting to
clarify the status of the nutrients issues for iimiting algae
and maintaining dissolved oxygen in tne Patuxent estuary. A
5-8
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Tom Slenkamp
March 11, 1984
Page 8
further extension of time of the comment period is requested
for supplying same, or at least for allowing review and
comment on a final State position of item 4 above.
Respectfully submitted,
R. Graydon Ridley, Esq.
on behalf of
Davidsonville Area Civic Association
3019 Davidsonville Road
Davidsonville, MD 21035
(301) 261-4331
Jack Witten, President
Potomac River Association
Box 212A
Clarks Mill Road
Hollywood, MD 20636
(301) 373-5445
Garth Wilbur, President
Holland Cliff Snores Citizens
Association
Box 2B
Hun ting town, MD 20d639
(301) 535-2185
5-9
-------
! . 31"-" jl IV G-TO 1ST SUj i f j .• > > 3 .:- XnT
• '¦ S-fiJN\LTARY COM'Mi: oLoIOINT
4017 HAMILTON STREET » HYATTSVILLE, MARYLAND 20781 ¦ (30!) 699-4000
Department of Enaineenng AA-S-J^-S-CU 3-AUk AVE -l-' — 0?
8103 Sandy Spring Rd., Laurel, MD 20707 TRLEX 'Jt .-?t>'-tss
February 24, 1984
"'
-------
1-lr. Thoir.as P. Eichler
Page 2
February 24, ]984
3. Cta Page 53, the first paragraph concerning anaerobic digestion
discusses two stage digestion inferring it was evaluated in the
facility plan. Anaerobic digestion two stage was discussed but
eliminated and single stage used in the cost-effective analysis.
See Page 7-2 of the facility plan.
A. On Page 95, Table IV-4 the estimated user costs have numerous
inaccuracies. The land treatment alternatives use capital costs
from the first draft facility plan, not the final draft where they
were updated. Also the EPA/STATE grant shares will decrease
effective October, 1984. This change in percent fundable is not
reflected in the local share of the capital costs shown in the
table. One last point, Alternatives 5, 6, 7 and 8 shown in Table
I\'~4 are not alternatives evaluated ill the Parkway WWTP Facility
Plan. The STATE of Maryland requested the Commission prepare
costs for several nutrient removal scenarios not in our current
discharge permit. This information was developed and provided to
the STATE as requested and to EPA as a courtesy. They are not
discussed in the facility plan because they will not meet the
effluent permit limits the Commission must comply with. It is the
Commission's position, therefore, that all reference to these
alternatives in the E1S text and Table IV-4 be deleted from the
EIS document. Enclosed is a corrected Table IV-4.
If there are any questions concerning these comments, please feel free
contact .Robert M. Hayes of my staff at 441-4170, or myself.
Sincerely,
Stephen B. Profilet
Director
Department of Engineering
Enclosure
cc: Mr. Mike Friedman, ESEI
5-11
-------
i t-C<
ESTIMATED USER COSTS1
ALT
ALT,
ALT
ALT
ALT
ALT 31
A-l1
W-l
1
2
4
TOTAL PROJECT PRESENT WORTH
(THOUSANDS)
53,270
66,580
77,270
51,030
53,110
55,250
TOTAL CAPITAL COST
(THOUSANDS)
18,044
43,030
59,390
18,760
20,250
19,420
LOCAL SHARE OF CAPITAL COST
(THOUSANDS)
2,800
5,379
7,424
2,961
3,656
3,470
ANNUAL COST OF CAPITAL
(THOUSANDS)
318
611
843
336
415
394
ANNUAL, CAPITAL COST/USER
1.27
2.44
3.37
1.34
1.66
1.56
ANNUAL O&M COST3
(THOUSANDS)
263
(541)
(320)
(24)
(62)
321
ANNUAL O&M COST/USER
1.05
(2.16)
(1.28)
(0.10)
(0.25)
1.28
i
"'OTAL ADDITIONAL COST/USER
2.32
0.28
2.09
1.24
1.41
2.84
CURRENT AVERAGE ANNUAL COST/USER4
195.00
195.00
195.00
.195.00
195*00
195.00
FUTURE AVERAGE ANNUAL COST/USER
197.32
195.28
197.09
196.24
196.41
197.84
1. Table IV-4 of EIS, corrected for current
values.
2. Local share of capital
cost amortized at
9.5% over 20 years.
3. Based on the difference
between projected annual OSM
cost and
past year's
actual OSM cost.
4. Uased on the base rate
of $1.78 per thousand gallons
of water
consumption
for users of
300 gallons
per da'
-------
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HARRY JOHN STAAS
WM. O JOHNSTON HI
OAVID M PITCHER
ALLEN WOOD
GENE W STOCKMAN
JOHN C GARVEY
J RANOALL BECKERS
WILLIAM F HERBERT
< m*SS ¦ *» ONLY )
J©H Ni p mORAN
BiChapo a GOLLmOTer
ULL.MOlS ONLY)
maRm E mjuCW
STAAS c2
Cable Ar-wfitss Af.'PA*
Telex £ 45476
^aC5imii.E &72 - C »O £?
¦ c n / nx .
Tom Slenkamp
Environmental Impact and Marine
Policy Branch (3PM70)
U.S. EPA, Region III
6th & Walnut Streets
Philadelphia, PA 19106
Dear Mr. Slenkamp:
This is to confirm the very helpful extension for
comment on the draft ElS's for the Western Branch & Parkway
STP's in Prince Grorge's County on the Patuxent River, which
was arranged today by telephone with Mr. Labuy.
Accordingly, it is expected that these comments will be
deposited in the mails in time for your receipt on Monday 12
March. For your information, these will be from R. Graydon
Ripley, Esquire, as president on behalf of the Davidsonvilie
Area Civic Association.
"¦'•One question which appears to deserve some immediate
thought involves encouraging the State of Maryland to
provide their comments describing their current position as
to the scientific case for the need to remove nitrogen from
upstream discharges to prevent further algae growth and
dissolved oxygen depletions in the estuary. This is
particularly relevant to the issue of federal fundability of
nitrogen removal equipment, since, as you no doubt know,
present EPA policy is that the one single limiting nutrient
P is the only one for which water quality benefits can be
demonstrated to be reasonably expected. It is our
understanding that the State still intends to present its
case to EPA for federal fundability of N removal, at least at
the two plants above, if not in all major STPs^in the
Patuxent basin.
Our great concern is that any such facts and opinions
should be presented in time to be included in the f-inal
5-13
MAR ti ];;;#
air monitor;;
c -rr i?
-------
Tom Slenkainp
28 February 1984
Page 2
of these documents, namely the maximal dissemination of the
currently most comprehensive appraisals of such
environmental issues. We in fact feel strongly that it is
our right to request that the position of the State on this
issue be included in the EISs, and we would very much
appreciate any discussions with you as to how the State
might be encouraged to timely provide same.
As another important issue concerning the content of
the draft ElS's, we do not understand why it was not
considered proper to include an analysis as to the expected
population growth and the indirect environmental effects
such as nonooint source runoff, the contribution to air
pollution which presently does not meet standards in the
regional D.C. area and the contribution to traffic on the
D.C. beltway which we understand from several news reports
to be considered at capacity at this time.
With respect to nitrogen removal facilities of the
basin, in view of the experiment which nitrogen removal in
the basin represents, it would appear to us to be more
reasonable to provide for nitrogen removal only with respect
to current and short term future STP effluent flows from the
major plants in the basin, that is including at least the
Howard County STP on the Little Patuxent River, rather than
provding for nitrogen removal for the full secondary
capacity at Western Branch which is understood to be 30 mgd
with current flows at about 12.5. This would seem to be a
much wiser expenditure of available funds, if a viable
experiment is to be conducted.
We would very much appreciate any discussion by phone
with you on the above matters in the near future.
WDJ:crb
cc: Richard Sellers, Director
Water Management Programs
Office of Environmental Programs
Department of Health & Mental Hygiene
201 West Preston Street
Baltimore, MD
cc: Bernie Fowler
Very truly yours
William D. Johnston III
cc: Graydon Ripley
5-14
-------
MARYLAND
DEPARTMENT OF STATE PLANNING
301 W. PRESTON STREET
BALTIMORE, MARYLAND 21201-2365
HARRY HUGHES
CONSTANCE LIEDER
GOVERNOR
SECRETARY
March 14,1984
Mr. Thomas P Eichler
Regional Administrator
U.S. Environmental Protection
Agency
Region III
6th & Walnut Streets
Phi la. Pa. 19106
SUBJECT: REVIEW AND RECOMMENDATION
State Identification Number: MD 84-1-259/84-1-260
Applicant: Environmental Protection Agency
Description: DEIS - Western Branch WW Facilities Plan/ Parkway WWTF
Location: Prince George's County
Dear Mr. Eichler:
The State Clearinghouse has coordinated the intergovernmental review of the
referenced subjects. Acting under Article 88C of the Annotated Code of Mary-
land and Code of Maryland Regulations 16.02.03, the State Clearinghouse
received the following comments:
Prince George's County, Department of Transportation, Department of Economic
and Community Development including their Maryland Historical Trust section,
Department of Natural Resources, Office of Environmental Program and the Depart-
ment of State Planning indicated that the statements appear to adequately
cover those areas of interest to their agencies.
Maryland Historical Trust advised that the Trust has no objection to upgrading
the facilities; however, if the applicant utilized the land alternative the
Trust would have further comment.
Office for Environmental Programs also noted (copy attached) that the non-point
nutrient information presented on pg. 25, Table II-6, has serious limitations.
The Office f eels that the table is difficult to interpret without footnotes.
As the attached page indicates, the Patuxent nutrient loadings are controversial
and care must be taken in any such presentation.
Approving Authority: EPA
CFDA Number: 66.418
Recommendation: Endorsement with Comments
TELEPHONE: 301 383 7875
OFFICE OF STATE CLEARINGHOUSE
5-15
-------
Nr. Thomas P. Eichler
March 14,1984
Page Two
Department of Transportation recommended that the applicant continue coordination
with State Highway Administration to ensure compatibility with highway inprove-
ments.
Department of State Planning noted that the projects are consistent with Patuxent
River Policy Plan and the Department of Health's Nutrient Strategy.
In response to the review request, this letter with attachments constitutes the
State process recommendation. The comments and recommendations made in this
review should be considered and addressed in the development of the final
statements.
The State Clearinghouse should be kept informed of any decisions made with regard
to this subject. The Clearinghouse recommendation is valid for a period of three
years from the date of this letter. If a decision regarding the subjects have
not been made within that time period, information should be submitted to the
Clearinghouse requesting a review update.
We appreciate your attention to the intergovernmental review process and look
forward to continued cooperation.
CWH/ps
cc; Herbert Sachs
Clyde Pyers
Lowell Frederick
Max Eisenberg
Scrib Sheafor
Edmond Piesen
Sincerely,
Director, /
for Inte
, /Maryland State Clearinghouse
e Assistance
sistance
5-16
-------
! i i". '*,L t
tta: vl.iiui Strstc ( 1 c:.ir Lp.^litu:5,i
(or Ir.t.cryovtrmr.int-i'.l Assistance
301 1,'esl Preston Street
Baltimore, MD 21201-2365 rr3 - S
SUUJECT: FvEVIEU' C0M.HENT AND RECO'-L^EiNDATION
/
State Identification Number: 84-1-259 /,
Applicant: Environmental Protection Agency
Description: DEIS : l.'estern Eranch U*W Facilities Plan/Parkway lTU'TF
Responses must be returned to the State Clearinghouse on or before February 8,1934 .
Based on a revi'ew'of the notification information provided, we have determined that:
Check One:
1) It is consistent with our plans, programs, and objectives (and when
applicable, with the Coastal Zone Management Program and Historic
Preservation Standards).
XXXXXXX2) it is generally consistent with our plans, programs, and objectives,
but the qualifying comment below is submitted for consideration,
3) It raises problems concerning compatibility with our plans, programs,
or objectives, or it may duplicate existing program activities, as
indicated in the cogent below. If a meeting with the applicant is
requested,- please check here .
4) Additional information is required to complete the review. The
information needed is identified below. If an extension of the
review period is requested, please check here .
5) It dots not require our con-jents.
COIL/.-.NTS: Co:11I1 n- Tn'olt-, II-C on Page 25 of th? drsft P?.r,;'.-.'=y FIS. th" r'ori-ooint- nutrient
information presentee has serious limitations. Without units being listed, the tabie cannot
be interpreted.. Without footnotes listing the arsunptions made in assembling the table, it
is difficult to interpret its meaning. As the attached indicates, Patuxent nutrient
loadings ar^ controversial and care must be taker, in anv such presentation.
(Additional corr^ments may be placed on the back. c
-------
V'STi;:.vi£jj i K !'• ito":;.: :
j r ; ii'y:v-:>i• i:: • ¦ } : :v
i^rKitHKc:; mitf _ij»os};^K{u:i:;
}•; A-CiiF1 Dry year 1116.!» 'A'.i'i . 0
Avocc-zz year 124 f>. 5 2?>r). 0
Hot year 22S-.5 3 V, . r,
F:'A-EIS^ A 3 year Llu.O 233.0
year 2000 S<35.0 2m0.0
Jl'J-PSP3 732.0 180.0
EI'A-PAT S7i!l)7A ]1rv YL-ar 2B2.0 103.0
References;
1. - ErA-Clu-iiapriaUe Bay l'/o^rc-.TTi - An Action Plan, lSlcC
2. - EPA-Draft Envirc.: .ventral Iinpnc t Statement, Uttl e
Water Quality llanaytmcnt Center, EPA,
Region III 19cc;i
3. - 110 Bfpnrtrc&nt of State Planr.int;: "Esr n-.a tod Potcnti-"! tionpou;-
Poll «t ion Loading Undtr Exir.tii^; LAr.d Uce Condi tic nr. in Hi-'
Patu,:cn!: River lusin" K. Balka, I9.i2
4. - KPA-"Tntcasiv~ VJa tcrr shed Study: Tl:e Fa tr.::onr Kiv-ar V.>. i , 1933
5-18
-------
DEPARTMENT OF HEALTH AND MENTAt HYGIENE
201 WEST PRESTON STREET • BALTIMORE, MARYLAND 21201 • AREA CODE 301 • 383- 2761
TTY FOR DEAF: Balto. Aroa 383-7555
D.C. Metro 565-0451
Adele Wilzack, R.N., M.S., Secretary William M. Eichbium, Assistant Secretary
April 13, 1984
Mr. Thomas Slenkamp, Project Monitor
U.S. Environmental Protection Agency
EIS Preparation Unit (3ES12)
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
APR 16 '934
AIR MONITORING
SECTION (3cSi2)
Dear Mr. Slenkamp:
RE: C-240394-01 (.25), Step 1
Washington Suburban Sanitary Commission
Parkway Wastewater Treatment Facilities
Draft Environmental Impact Statement
This office has reviewed the Draft Environmental Impact Statement, as
well as Mr. Johnson's letter of February 28, 1984.
This office has no comments on the Draft Environmental Impact Statement.
Mr. Johnson's letter, however, raises several points we feel should be
addressed.
The second paragraph of the letter requests information regarding the
state's position on nitrogen removal. The "Nutrient Control Strategy for |"
the Patuxent River Basin", developed in 1982, indicates that lowering nitrogen \J
levels will improve the water quality of the river. |
The fourth paragraph of the letter refers to population growth and indirect
environmental effects. Population forecasts have been outlined in the Draft
Environmental Impact Statement, pages 38, and 40. Indirect (secondary) impacts
were not considered since there was no planned expansion for either the
treatment facility, or the conveyance system.
5-19
-------
-Mr. Thomas Slenkamp
Page 2
If you have any questions, please contact Mr. Alan Colter, of my staff,
at 301/383-6346.
Very truly your^.
ESQ:1m
Earl S. Quance, P.E.
Program Administrator
Construction Grants and Permits Program
cc: Mr. William Bulman, EPA
Mr. Richard B. Sellars
5-20
-------
fT?$)
FAIR WOOD TURF FARM, INC.
1230" Annapous Road wholesale — Retail —
-l-NX Dale. Mafviand 2(.:~6<) BUT GRASS .MiXTi'RE - KIN TP' KV 31 - i: . <•
(ioi .
X , ^ /
January 21, 1984 f ^ j
Mr. Thomas P. Eichler
Regional Administrator
Unites States Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Eichler:
!
\
I arc writing you in response to your request for public comment
on the Environmental Impact Statement No. 3ES12, concerning alternative
proposals for the upgrading of the Parkway Waste Water Treatment Plant
in Prince George's County Maryland. I will also be sending my comments
to the Washington Suburban Sanitary Commission and to Maryland's Assistant
Secretary of State for Environmental Affairs.
At the outset I would like to say that I appreciate the care and
detail with which the various agencies involved have researched alternative
proposals for the Parkway Treatment Plant. I have read with great care
your agency's "Draft Environmental Impact Statement", the WSSC's "Executive
Summary for the Parkway WWTP Upgrading Project", and the Metcalf and Eddy/
Sheaffer and Roland "Facility Plan". As a consequence, I would like to go
on record in support of Alternative 3, the inplant solution, as the :,»ost
economical and environmentally safe alternative proposed in your research.
I would also like to voice as a tax payer, a citizen deeply interested in
environmental issues, a turf grass farmer, a proprietor of a small business
and a landowner in Prince George's County, my vigorous opposition to Alter-
native V'-l, the proposed . land treatment • solution.
1. As a tax payer, I support "Alternative 3" the in-plant
"Solution which achieves the environmentally mandated
objectives at a considerably lower cost, $53 million
total preseftt net worth vs. $77 million.
5-21
-------
Mr. Thomas P. Eichler
Page 2
2. As a citizen deeply interested in issues of environmental
quality, I feel very strongly that product ive fannland "in
Prince George's County must be treated with the respect
due a scarce and vanishing resource. V.'e all realize that
in a suburban county such as this, land must gr adually
shift to its highest and best use. But as this process
gradually and inevitably takes place, I can see no
environmental benefit to the county of driving prime
farmland out of use prematurely.
3. As a turf grass farmer, I would like to point out that
vour report is siraplv factually in error. The report
states: "M^st crops "row" for liuman consumption are not
recommended for use with spray irrigation of treated
waste water. However, the principle existing agricultural
use for much of the significant farmland soils on the
site (turf farming) is well suited to the irrigation
treatment method. Continued practice of this farming
enterprise would be feasible ."
As President of Fairwood Turf Farm, the organization
growing turf grass on this site (and probably one of the
most successful turf farms in the state of Maryland) I
must point out that this statement is simply false, turf
grass management is not compatible with the amounts of
water and nutrients proposed to be put on the land. In
short, the effluent application rates suggested in the
proposal, 1.75-2.0 inches per week, would be adding approxi-
mately 75-100 inches of "rain" to the approximately 40 inches
we get annually in this area. If 140 inches of total "rain
fall" were applied to the land, and I remind you this would
have to take place during the spring, summer and fall months
because spray application is inappropriate when the ground
is frozen, the land would simply be too water-logged for our
equipment to get on the ground as often as is necessary.
Turf grass is a crop which requires intensive management
and we have to get equipment on the fields for a variety of
activities. During the spring and summer we mow the grass
at least twice a week so that the grass forms a mat that
can be easily rolled at harvest time. We also need to
get on the fields on a regular and unpredictable basis to
9pray herbicides, clean thatch from mowed grass, fertilize,
lime, treat insect and disease infestations, and finally to
harvest the crop. These steps are just part of the culture
of growing turf grass. Including mowing we have to get on
the land 50-80 times per year, depending on condition of the
fields. These requirements are just not compatible with
constant effluent spraying.
5- 22
-------
Mr. Thoii.as P. Hichler
r * t? e 3
Even if application rates were fine-tuned to the crop
cycle, I do not think that we would have a long-term,
viable product. Turf grass grown in "hot house" conditions,
i.e. unusually high applications of water and nutrients,
would have great difficulty surviving when installed in areas
where little additional care is given it. Many of our
largest customers are government and state agencies (schools,
highways, parks, playing fields, etc.) In these applications,
once installed turf grass has to survive with no irrigation
and little nutritional (fertilizer and lime) assistance. It
is my opinion that grass which had benefitted from abnormally
high amounts of water and nutrients would simply not survive
once put out to fend for itself. This is one of the reasons
that we at Fairwood Turf Farm have not invested in irrigation
equipment, even though Southern Maryland is often subjected
to significant drought periods in the late summer.
4. As a proprietor of a small business, offering employment
to 15-20 people, depending on the season of the year, etc.,
I am also vigorously opposed to the land treatment alternative.
If our land were taken from us, it is unlikely that we could
locate large areas of prime farmland required for our operation
in the county. If we lost our land, it would certainly threaten
the jobs at Fairwood Turf Farm and the livelihoods of the
40-50 people who are dependent on them.
5. As a landowner, and someone whose family has been lucky enough
to live in Prince George's County for many years, I am
principally opposed to this solution on prime farmland because
we would be downgrading a natural resource and a neighborhood.
If environmentally safe ways can be found to upgrade areas
that are being wasted, gravel and strip mine pits, fallow land,
etc., then land treatment may become a more attractive alterna-
tive. Converting the few remaining acres of prime farmland in
Prince Ceorge's County to a sewage treatment area is certainly
not its highest and best use.
In summary, as a tax payer, as a citizen interested in protecting the
environment, as a farmer and small business proprietor determined to continue
a successful agricultural venture, and as a landowner and someone interested
in preserving the county's environmental quality, I and others like me
vigorously indorse Alternative 3 and are opposed to the land treatment alter-
native VJ-1 discussed in 3ES12.
5-23
-------
Mr. Thomas P. Eichler
Pace h
Thank you very much for the opportunity to comment. Should you or
any of your people wish to discuss these matters with me, I can be reached
through ray farm office at the telephone number listed above.
Sincerely yours,
L/
E. B. Roberts, Jr.
EBR/jp
c.c. Mr. John M. Brusnighan
Acting General Manager
Washington Suburban Sanitary Commission
Mr. Willaira Eichbaum
Assistant Secretary of State
Office of Environmental Protection
Mr. Robert Hayes
Project Manager
Washington Suburban Sanitary Commission
5-24
-------
¦uxiiH>irfii*iq|
Maryland Historical Trust
March 12, 198A
Mr. Thomas P. Eichler
Regional Administrator
U.S. Environmental Protection Agency, Region III
6th and Walnut Streets
Philadelphia, PA 19106
ATTN: EIS Preparation Unit (3ES12)
Re: DEIS: Parkway Wastewater Treatment Facilities
Prince George's County, Maryland
Dear Mr. Eichler:
Through the State Clearinghouse, we have received a copy of the above-
referenced document.
We concur with the finding of the DEIS that upgrading the existing plant
according to Alternative 3 will have no effect on historic standing structures
or archeological resources. According to the draft statement, the land application
alternatives were not recommended by WSSC. In the event that a land treatment
alternative is reconsidered and selected, further coordination with this office
will be necessary to consider the impact(s) to cultural resources.
If you have any questions, please call Ms, Kim Kimlin (for historic standing
structures) or Ms. Beth Brown (for archeology) at 269-2438.
GJA/KEK/BCB/bjs
cc: Mr. William Bulman
Mrs. Sara Walton
Mr. W. Dickerson Charlton
Mr. Sam Baker
Mr. Lowell Frederick
Shaw House. 21 State Circle. Annapolis. Maryland 21401 (301 )269-221 2. 269-2438
Department of Economic and Community Development S—2^
Sincerely,
George J. Andreve
Environmental Review Administrator
-------
'' f\ A
United States Department of the Interior
ER 84/120
OFFICE OF THE SECRETARY
MID-ATLANTIC REGION
Custom House. Room 502
Second and Chestnut Streets
Philadelphia, Pennsylvania 19106
March 8, 1984
received
MAR 1 2 1984
EPA, REGION III
awf pGuiuus&wt.
Thomas P. Eichler
Regional Administrator, Region III
Environmental Protection Agency
6th and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Eichler:
This is in response to your request for the Department of the Interior's
comments on the draft environmental impact statement for the Parkway
Wastewater Treatment Facilities, Prince Georges County, Maryland.
The impact statement explores several alternatives for upgrading the subject
wastewater treatment facilities in order to improve the quality of wastewater
discharged into Patuxent River. The alternative recommended by the Washington
Suburban Sanitary Commission is in-plant processing within the existing plant
site. Land treatment alternatives would involve additional acreages, with
potential impacts on mineral resources. The document acknowledges past and
current sand and gravel mining operations on a large portion of the potential
land treatment site A-l. We note that this includes one active gravel pit.
Mineral resources found in Prince Georges County include sand and gravel, brick
clay and greensand marl (glauconite sand). The greensand is economically
unimportant at the present time, but proximity to the Washington metropolitan
area, and the loss of resources by depletion and being covered by urban sprawl,
make the remaining deposits of sand and gravel and brick clay especially
valuable. Prince Georges County planners discourage development over known
deposits until after they have been mined. The impact of the use of either
land treatment site on mineral resources and their extraction should be
addressed in the final EIS.
We would favor either the in-plant treatment alternative, which would not affect
the mineral resources, the utilization of land areas that have no economically
minable minerals, or if no such land is available, the extraction of valuable
minerals before other use of the land takes place.
5-26
-------
2
With the exception of the aforementioned concern, we find that the
environmental impact statement adequately addresses the concerns of the
Department.
Thank you for the opportunity to comment on this project.
Sincerely,
Anita J. Miller /
Regional Environmental Officer
5-27
-------
w
/*}rA
U.S. Department of Housing and Urban Development
Philadelphia Regional Office, Rogion III
Curtis Building
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
MA* 6 1984
S
Mr. Thomas P. Eichler
Regional Administrator
Environmental Protection Agency
Attention: Environmental Preparation Unit (3ES12)
Curtis Building
Sixth and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Eichler:
We have completed our review of the Draft Environmental Impact Statements
prepared respectively for the Western Branch Wastewater Facilities Plan in
Prince Georges County, Maryland, and the Parkway Wastewater Trea tment also in
Prince Georges County. Coverage of the pertinent issues in both projects
appears to be adequate and we have no comment to offer relative to HUD's
principal areas of concern.
Thank you for the opportunity to comment.
Sin 1 "
Kenneth J. Finlayson
Regional Administrator, 3S
5-28
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
MID ATLANTIC REGION
143 South Third Street, Philadelphia, Pennsyl
'ania 1 9106
ER 84/120
Thomas P. Eichler, Regional Administrator
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Eichler:
This responds to your request for the Department of the Interior's comments
on the draft environmental impact statement for the Parkway Wastewater
Treatment Facilities Plan, Prince George's County, Maryland.
We have reviewed the draft EIS and find it adequately addresses the concerns
of the Department.
Thank you for the opportunity to comment on this project.
Sincerely,
Anita Miller
Regional Environmental Officer
5-29
-------
date: March 1, 1984
UN'iTED STATES GCVFR:.'
memorandui
attnofr Field Supervisor, ES, Annapolis, MD
subject: Review of draft environmental impact statement for the Parkway Wastewater
Treatment Facilities, Prince George's County, MD (ER-84/120)
to: Regional Environmental Officer, Philadelphia, PA
Attached for your review and signature are the Department's comments on
the subject DEIS.
We received "no comment" responses from the National Park Service (National
Capital Region) and Geological Survey. Fish and Wildlife Service also has
a "no comment" response on this statement. We did not receive any comments
from the Bureau of Mines.
5-30
OPTIONAL FORM NO.
(Rev. i-aot
OS A fFMR 141 cm) 101
-------
February 28, 1984
Mr. Thomas Slenkamp
3-ES 12
United States Environmental
Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
RE: Environmental Protection Agency Draft Environmental Impact Statement For The
Parkway Wastewater Treatment Facility in Prince George's County, Maryland
Dear Mr. Slenkamp:
This letter is in response to the above-mentioned Draft Environmental Impact Statement
as it relates specifically to the issue of whether an in-house treatment alternative
or a land treatment alternative should be used in connection with the Parkway facility.
Our company owns approximately 184.2 acres of land located within the site W-l land
treatment alternative. Our land holdings extend from approximately 1500 feet west of
Church Road, north of Woodmore and Mount Oak Road, all the way to the eastern-most
boundary of the site W-l alternative.
In reviewing your Draft Environmental Impact Statement, it was clear that alternative
W-l was considered the most technically favorable location, (page 3 iii). It was
also pointed out on Page iv that minimal impacts would be expected from land treatment
alternative W-l. Understanding that EPA has traditionally limited its participation
in land treatment projects only where such projects are no greater than 15% more
expensive than the most cost effective conventional treatment system, the opportunities
presented by land treatment alternative W-l in this instance should be taken advantage
of, despite a slightly higher cost factor than EPA usually funds.
At this point in time, the idea of land treatment for wastewater is little understood
by the general public and many officials of state and local governments. Upon first
learning of the proposed project, those in our offices were somewhat skeptical of the
way in which such a project would be carried out, as well as its impact on the general
public in terms of it being a nuisance. Through discussions between representatives
of our office and various officials of the Environmental Protection Agency, the
Washington Suburban Sanitary Commission, and various consultants, we came to understand
how the process works and what its impact upon the land and the people would actually
be, and concluded that it would be an effective and safe method of disposing of waste-
water. By going forward with alternative W-l, the WSSC and EPA will have an oppor-
tunity to illustrate to the general public in the Washington Metropolitan area, the
minimal impact a land treatment alternative will have on the surrounding communities,
as well as the benefits to be derived from such an alternative.
' ^ t
'* t
fr'AF! ¦¦
Alfx .. j ^
5-31
7OUT- r-LrTi' SiT.TN ! A:JD COVJAJ CY INC
-------
Thomas Slenkamp
Page 2
We would greatly encourage the selection of site W-l and the land treatment alternative
as the recommendation of the Environmental Protection Agency to the Washington Suburban
Sanitary Commission for the expansion of the Parkway wastewater treatment facility in
Prince George's County, Maryland. The opportunities with which the EPA and WSSC are
now presented in the vicinity of the site W-l alternative, despite the somewhat greater
than usual cost will not be available in another ten years as development will grad-
ually diminish the amount of available land. If land treatment alternatives are to
be a serious consideration in the Washington Metropolitan Area in future years, the
public must understand, through experience, that it does not pose a threat to their
health, safety or welfare and is, in fact, an effective, sanitary, way in which to
dispose of wastewater. Site W-l gives you the opportunity to demonstrate this to the
general public.
Thank you for your consideration of our comments, we sincerely look forward to your
selection of land treatment alternative W-l as yo "Tffe Parkway
/Pi
cc: Mr. Robert Hayes
312 Marshall Avenue, 6th Floor
Laurel, Maryland 20707
wastewater treatment facility.
Glenn T. Harrell, Jr.
Cate Magennis
5-32
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Januery 19, 1584
UnHed Steles Environmental
Protection Agency
Reg i on III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
RE: Draft Environmental Impact Statement
To Whom This Concerns:
I am very Interested In your copy of the Draft Er.vironmental Impact
Statement (EIS) prepared by U. S. Environmental Protection Agency
(EPA) concerning the proposed Federally-funded upgrade of the
Parkway wastewater treatment plant In Prince George's County,
Maryland dated December 1983. I would appreciate a copy of this
book to be forwarded to me at the address Indicated below when It Is
convenient.
Thank you for your attention to this matter.
With best wishes.
Paula M. Ludwlg
C.e. OtlS -Sent
5-33
7KAriY:r.T:J JANDCOI.tPANY INC
-------
February 3, 1984
EIS Preparation Unit (3ES12)
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Phi 1adelphia, Pennsylvania 19106
Gentlemen:
We have reviewed the Draft Environmental Impact Statement (EIS) for Parkway
Wastewater Treatment Facilities, Prince George's County, Maryland. We are
responding on behalf of the Public Health Service.
We have reviewed this Draft EIS for possible human health effects and have no
comments to offer. Each of the alternatives presented will improve the quality
of the existing waste treatment plant effluent by reducing the nutrient loading
to the Patuxent River. Thus, each alternative would provide a positive
environmental improvement.
Thank you for the opportunity to review this Draft EIS. Please send us a copy
of the final statement when it becomes available.
Sincerely yours,
Joe H. Miller
Acting Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
FEB 0 9 1984
AIR MONITORING
SECTION (3ESI2)
5-34
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M.u.
.: v r *;
•.Y
r> C • X • / ¦ 5
- Vi03
REPLY TC> HTifcT.Ck OF
Planning Division
••'r. ioivis P. •r^'• ^ l'-f, Sr gional ArJ inist. r i tor
AiiN: tlS Pi c-paration Unit (3ES12)
Unitf.-d States Z'.vi :¦¦.>¦•; .intal Protection A^*acy C^agion III)
6th <~nd Walnut Streets
Philadelphia, Pennsylvania 19106
^ it Mr. ^"chi.rr:
This letter is in response to your Draft Environmental Impact Statement
(DEIS) for the proposed Federally-funded upgrade of the Parkway Wastewater
T r11 ¦nent Pl.»nt in P.ince Go or gas County, ry1«od. The comments provided
bcl"'w ,ire :-sr..'-d l: -i rd the prop-'d now facilities as they relate to Corps
of Engi r.c:^ t s1 f- '.s 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 Riv.^r -ind Harbor Act of 1399, and other direct and indirect
impacts on Ccups of Engineers' existing and/or proposed projects.
The alternative three preferred by the Washington Suburban Sanitary
Commission in the Draft Environmental Impact Statement (DEIS) will not require
a Department of the Army Permit.
The DEIS for the Parkway Wastewater Treatment Plant adequately addresses
floodplain concerns.
There are presently no existing and/or proposed Corps' projects within
the proposed project area which would become adversely impacted due to the
proposed pl-ns.
The Baltimore District appreciates your office making us aware of your
proposed project and we are looking forward to the review of the final
engineering designs and final EIS. If we can be of further assistance, please
contact us.
Sincere iy,
f William E. Trieschman, Jr.
Chief, Planning Division
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--r. T'io r.is P. >er
Regional Administrator. Keg ion ID
EnviroTienlal Protection Agc-rtcy
6th and U:?.]nut Streets
Philadelphia. Pennsylvania 1?206
Dear Vjr. £ier.ier:
This is to inform you that the Department of the Interior will have coaimenls on the
draft environmental statements for both the Western Branch and Parkv/ay projects in
P;ir»ee Geo-~2S County, r^-vland. Hov-c-ver, v.-e only j»jst reeei\f-d sufficient oopies
to provide a pd.-aKel review by our burets.
Please consider this letter a request for time extension. V«'e have established an
internal review schedule so that our consolidated comments can be forwarded by
March 5, 1984.
Sincerely,
Environmental Project Review
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U.S. Department of
Transportation
Regional Represen:ative
ol ihe Secietary
Region III
43< Walnut Sueei
Phitadaipnia. PA '9106
Office of the Secretary
of Transportation
17 January 1984
Thomas P. Eichler
Regional Administrator
Environmental Protection Agency
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Eichler:
This is in response to your Draft Environmental Impact Statements for waste-
water treatment facilities in Prince George's County, Maryland, Western
Branch and Parkway.
The DEIS for both facilities indicate that there will be no impact on the
roads of the regions. Thus, the Department of Transportation provides
no comment on the statements.
One question, however, stems from the Distribution List. Who is the
"Marine Environmental Protection Division" of the Department of Transportation?
There should be a more definitive listing of that division as well as a
listing of this office, the Regional Representative.
The Department appreciates the opportunity to review the DEIS1.
Sincerely,
George D. Bond, II
Lieutenant Commander
U.S. Coast Guard
Senior Staff Officer
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7 i
i
Federal Emergency Management Agency
Region III 6th & Walnut Streets Philadelphia, Pennsylvania 19106
February 6, 1984
Mr. Thomas P. Eichler
Regional Administrator
U. S. Environmental Protection Agency
Region III
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Eichler:
We have received copies of the Draft Environmental Impact Statement concerning
the proposed Federally-funded upgrade of the Parkway «?stp"afpr plan
and the upgrade of the Western Branch wastewater treatment plant, in Prince
George's County, Maryland. Based upon our review, we offer no comment at this
time.
Thank you for the opportunity to have reviewed plans for the proposed projects.
Sincerely,
Chief
Natural and Technological
Hazards Division
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T*. W
TRI-COUNTY COUNCIL lor SOUTHERN MARYLAND
Southern Maryland Working Together lor a Better Future
P O BOX 1634 CHARLOTTE HALL. MARYLAND 20622 (301)884 2144
(Metro) 870-2520
JAMES C SIMPSON. Chairman
GARY V HODGE. Executive Direcioi
Mr. Robert Hayes
WSSC
Department of Engineering
Arbitron Building
312 Marshall Avenue
Laurel, Maryland 20707
February 13, 1984
P.EChVtD
PnO.ltcn MAWAGF.MEN7
FEB
WAbhliUnUN ^UhUHbAN
SANITARY COMMISSION
Dear Mr. Hayes:
The Tri-County Council for Southern Maryland would like to submit some brief
comments on the Parkway WWTP Facility Plan and EIS.
Although the Parkway EIS is very comprehensive, it is still deficient in
one area, which has been consistently overlooked in all of the EIS and
208 Plans developed for the Patuxent. The EIS does not contain an adequate
analysis of the effect of increased sewage discharges on the water quality
and living resources of the lower river. The EIS does not adequately evaluate
the environmental and economic impacts of these increased sewage loads on the
recreational and commercial fishing industry in Southern Maryland.
However, we understand that this is a very difficult and expensive analysis
to perform and the benefits of this type of exercise, at this point in time,
is questionable. We feel that the plan developed at the 1981 Charrette to
address this problem is outstanding and that it is now time to move on with
the program.
In regard to the Parkway Facility Plan, the Council is satisfied with WSSC's
analysis of alternatives, as long as all conditions set at the I98I Charrette
are met, particularly the nitrogen removal recommendations.
The Council would like to take this opportunity to commend WSSC, Prince George's
County and the Parkway WWTP for taking the lead in implementing nitrogen removal
on the Patuxent. This is a very important step in solving this decade long
struggle to improve water quality on the Patuxent and your organization has
established a leadership role in this effort.
GVH :hf
CMABU5COUNTV
COWSVC** M OfTP-
' Cr'co
Jo*v t
fc*vw
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MARYLAND
DEPARTMENT OF STATE PLANNING
301 W. PRESTON STREET
BALTIMORE, MARYLAND 21201-2365
HARRY HUGHES
CONSTANCE LIEDER
GOVERNOR
SECRETARY
January 12,1984
Mr. Thomas P. Eichler
Regional Administrator
U.S. Environmental Protection Agency
Region III
6th & Walnut Streets
Philadelphia, PA. 19106
Dear Mr. Eichler:
This is to acknowledge receipt of the referenced subject. We have initiated the
Maryland intergovernmental review and coordination process as of this date. You
can expect to receive review comments and recommendations on or before the reply
date indicated. If you have any questions concerning this review, please contact
the staff member noted above.
The State Identification Number must be placed on any financial assistance
application form and used in future correspondence.
We are interested in the referenced subject and will make every effort to ensure
a prompt review. Thank you for your cooperation.
Reply Due: February 10,1984
State Identification Number: 84-1-259/84-1-260
State Clearinghouse Contact: Samuel Baker
RE: DEIS : Western Branch WW Facilities Plan/Parkway WWTF
Sincerely
/ Guy W. Hager
'Director, Maryland State Clearinghouse
* for Intergovernmental Assistance
GWH/ ps
cc: MWCOG
l.'SSC
TELEPHONE. 301 • 383- 7875
OFFICE OF STATE CLEARINGHOUSE
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
AND
THE WASHINGTON SUBURBAN SANITARY COMMISSION
County Council Chambers
Municipal Building
Laurel, Maryland
Thursday, January 26th, 1984
The above-entitled matter came on hearing at
x
In the matter of
PUBLIC HEARING ON THE PARKWAY
WASTEWATER TREATMENT FACILITIES,
PRINCE GEORGE'S COUNTY, MARYLAND
7:31 o'clock, p.m
BEFORE:
TOM SLENKAMP,
U. S. Environmental Protection Agency
REPORTING SERVICES
12611 CAMBIETON DRIVE
UPPER MARLBORO. MARYLAND 20870
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CONTENTS
SPEAKER PAGE NUMBER
TOM SLENKAMP
Welcome and Opening Remarks: 3
BOB HAYES
Introduction of W. S. S. C.
Consultants: 6
TOM WALSH
Presentative of Liquid
treatment portion of Facilities
Plan; 6
BETTY GOWEN
Presentation of Sludge Handling
Alternative; 18
TOM WALSH
Summary of Facilities Flar.: 20
TOM SLENKAMP
Summary of Draft EIS; 24
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MR. SLENKAMP: Good evening, Ladies and Gentlemen.
Welcome to this joint public hearing concerning the proposed
upgrading of the Paxkway Wastewater Treatment Facilities in
Prince George's County, Maryland. The purpose of this
hearing is to solicit public comments on two documents, one
a draft environmental impact statement prepared by the
Environmental Protection Agency, EPA, and two, a draft
facilities plan prepared by the Washington Suburban
Sanitary Commission, or W. S. S. C..
My name is Tom Slenkamp. I am the Acting Chief of
the Air Monitoring and EIS Preparation Section in the
Region 3 Office of EPA, located in Philadelphia. I will
serve as tonight's hearing officer. Seated to my right is
Bob Hayes, who is with W. S. S. C.. In the front row on the
left side of the room are Tom Walsh and Betty Gowen of
Metcalf and Eddy, the facilities planning consultants.
And also here with us here tonight is Ken Paul
from ESEI, the consulting firm that's assisting with the
preparation of the EIS.
For the record, we are opening the hearing at
7:35, on Thursday, January 26th, 1984, at the City Hall, in
Laurel, Maryland. Tonight's hearing is being held jointly
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by EPA and W. S. S. C. pursuant to Federal regulations
governing preparation of EIS's and administration of the
Construction Grants Program.
We are here tonight as part of a process by which
W. S. S. C, .is seeking Federal funds through the Construc-
tion Grants Program to make improvements to the existing
Parkway facilities * Improvements are necessary to enable
the facility to meet the most recent water quality permit
limits specified by the State of Maryland. These limits
represent some of the most stringent discharge requirements
anywhere in the Country. No expansion of treatment
capacity is being proposed, only an upgrading of the level
of treatment.
Before EPA can authorize the expenditure of any
Federal funds for the project, an environmental review must
be completed under the National Environmental Policy Act.
This to insure that the project is environmentally sound.
The EIS was prepared by EPA as part of this
environmental review process. Tonight's hearing will
satisfy the independent public hearing requirements of both
the EIS and facility plan. However, because the two
documents have differing perspectives, and are the respon-
sibility of different government agencies, I would like to
cf\S
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conduct the hearing in the following way. First I will ask
W. S. S. C« and Metcalf and Eddy to present a brief history
of the project, and a summary of the findings of the
facilities plan. Following this presentation, I will ask for
public comments concerning only the facilities plan.
completed, I will then summarize EPA's findings as pre-
sented in the draft EXS, and then ask for comments on the
draft EXS only. Should you have any comments pertaining to
both documents, please try to separate them in terms of
either the facilities plan or EIS. If you can't, we'll
allow for general project comments at the conclusion of the
two separate comment periods.
will be accepted by W. S. S. C. and EPA until February
27th, not February 13th as was indicated in the front of the
draft EXS. Please remember that the main purpose of
tonight's hearing is for EPA and w. S. S. C. to receive your
comments on the draft EIS and facilities plan. We are not
going to debate the issues. There have been other public
meetings held during the process for that purpose, rather
we are going to listen to your opinions of the issues that
must be resolved in the final plans.
After comments on the facilities plan are
And X want to remind you that written comments
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We will only interject for the purpose of
clarifying a point of procedure, or a major conclusion of
one of the documents. And with those thoughts in mind, I'd
like to call on Bob Hayes of W, S. S. C..
MR. HAYES: Thank you, Tom.
Good evening, Ladies and Gentlemen. The next
portion of this public hearing, we will have a presentation
by our consultants who prepared the facility plan, then we
will have the comment period. I'd like to introduce our
speakers tonight from Metcalf and Eddy, Tom Walsh, the
Project Manager, and Betty Gowen, the Project Engineer.
Tom.
MR. WALSH; Thank you, Bob.
Metcalf and Eddy is here this evening to present
the findings of the Parkway Wastewater Treatment Phase III
Facility Plan. As was said, I am Tom Walsh, the Project
Manager with Metcalf and Eddy. And with me is Betty Gowen,
the Project Engineer.
I will be going over a brief history of what we
did in the planning — facilities planning. I will be
presenting to you the liquid treatment portions of our
recommendations for Parkway. Betty will be going over the
sludge.portions of our recommendations on Parkway. And then
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I'll summarize our results and go over the costs for you.
Parkway is located in the Northern portion of
Prince George's County along the Baltimore-Washington
Parkway# and adjacent to the Patuxent River. The plant
discharges into the Patuxent River. Discharge standards
for the plant have recently been upgraded and made more
stringent to allow better treatment prior to discharge into
the river.
The major areas that have been changed in the
plant discharge permit revolve around total phosphorus,
total nitrogen, and total residual chlorine, the figures
that are present in yellow on this slide. BOD limitations,
solids limitations and coliforms limitations remain pretty
much the same.
BOD limitations are seasonal. In the summertime,
they must achieve 20 milligrams per liter of effluent
discharge, and in the winter, 30 milligrams per liter.
Suspended solids limitations are similar to the BOD limita-
tions. The total phosphorus limitation is set at one milli-
gram per liter currently, and in the future could be
reduced to three tenths milligrams per liter.
A total nitrogen limitation of three milligrams
per liter is imposed on the plant. That involves a total
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keldal nitrogen limitation of three milligrams per liter,
and a total nitrogen limitation of three milligrams per
liter as well. A total keldal nitrogen is a combination of
organic and ammonia nitrogen. For the purposes of waste-
water treatment, it ca,n pretty much be thought of as ammonia.
That is. converted generally to nitrates, and then
from nitrates it is converted nitrogen gas. The total
nitrogen limitation is really the inportant factor here.
There is also a total residual chlorine limitation
of three hundredths milligrams per liter at the plant.
That was to remove chlorine from the wastewater before
discharge into river. The flow from the plant would remain
seven and a half MGD. That is the current design flow of
Parkway, and it will remain seven and a half MGD after up-
grade of the plant. So there will be no increase in
capacity.
In the facility plan itself, we looked at two
basic methods of upgrading the plant. One was to upgrade
the plant internally by changing the facility as it stands,
and the second method was by looking at using the existing
facility to provide pretreatment prior to the land
application, and then discharge from the land application
system either to a stream or to groundwater.
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In land application, we looked at three basic
sites; one Site AA-1 about five miles North of Parkway, in
Anne Arundel County; a second site, Site A-l along the
Montgomery County border, in Prince George's County; and a
third site, Site W-l, along Route 50, in Prince George's
county.
Our review of those systems showed that on a
total present worth basis, they were not cost effective,
they were more costly than the in plant alternatives. There
would be significant implementation delays if we went with
the land treatment alternative, and it would be difficult to
obtain the land in a short period of time.
There was also some possible limitations as to
suitable land around each of the sites that we looked at.
So that each site may not have enough land to provide
adequate land treatment. And finally, there was significant
public opposition to using land treatment systems for
parkway Wastewater Treatment.
The in plant alternatives that we considered
were numerous, involving various combinations of liquid
treatment and sludge treatment. What I want to do is to
go over with you the recommendation that we made in terms of
the liquid treatment.
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All of the plant upgrading alternatives were
found to be cost effective. They can meet the discharge
standards for Parkway — which, by the way, are very
stringent, some of the more stringent imposed in the
Country*
There are significantly fewer implementation
delays with those, in that the land is available, and that
upgrading can be achieved within the limits of the current
plan site, and indeed, within the developed area of the
plant site.
The existing plant th.en consists of an advanced
secondary treatment plant. It starts off with preliminary
treatment housed in an influent pump station that has
aerated grid chambers. Wastewater is pumped from there tip
to the top of an incline through primary clarifiers, after
primary clarification, through, some trickling filters that
are used for rough, treatment, prior to treatment in an
activated sludge system at the plant.
That activated sludge system removes BOD and
seasonally can nitrify the wastewater. Following nitrifi-
cation, it goes into a microstrainer where additional solids
are removed. £t is then chlorinated for disinfection,
reaerated and discharged to the Patuxent River.
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Sludge handling at the plant currently consists
of gravity thickening, dewatering on centrifuges, with some
lime addition, and then trucking the sludge off-site.
Starting with that basic facility, as I said, we
looked at a number of options. The main goals were to
upgrade the plant to provide phosphorus removal, nitrogen
removal, and dechlorination.
What we selected was a phosphorus removal alter-
native that used metal salt addition. The metal salts are
added to the wastewater to form a compound with the phos-
phorus that can then be settled out of the wastewater in
the clarification steps. For nitrogen removal we looked
primarily to biological systems. In biological nitrogen
removal we first convert organic, or ammonia nitrogen,
using bacteria, to nitrates. The nitrates are then convert-
ed again, in another biological step, to nitrogen gas,
which is then stripped from the wastewater and goes into the
atmosphere.
And finally, the dechlorination, the major idea
there is to convert pre-chlorine, hypochlorite, to — which
is very similar to what you find in bleach — to the ionized
form of chlorine, which is non-toxic. To do that, we would
add sulfur dioxide which reacts with the hypochloride to
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form chlorine ion.
Our recommended liquid treatment alternative
involves a combination of biological treatment processes,
metal salt addition for the phosphorus removal, and
chlorination for disinfection, dechlorination and reaeration.
It starts out at the front end of the plant with
grit removal prior to primary settling. Grit removal at
Parkway has two major functions. The primary function is
to remove abrasive solids that can harm downstream processes.
The secondary function at Parkway is to provide a point
for chemical flocculation in order to form solids with
phosphorus so that they can later be settled out.
The existing units at Parkway operate rather
poorly, and are located poorly as far as using them as a
place for chemical treatment, so we suggeisted consturction of
new aerated grid chambers ahead of the primary settling
tanks.
The grid chambers then are followed by the
primary settling, which comes just before the biological
portion of the trickle filters. The primary settling has
two functions at Parkway, the primary one being to remove
suspended solids as well as some BOD. And 'the; secondary
function would be phosphorus removal. The chemicals that
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are added in the aerated grid chambers form solids that can
be settled out in the primary settling tanks.
settling tanks at Parkway, Following primary settling, just
before the nitrification system itself, we are suggesting
using the existing trickling filters at Parkway. Those
filters then, have a function of reducing the BOD level on
the nitrification system.
and mechanically limited, but we have suggested retaining
them as roughing filters for six million gallons per day
worth of flow. The remaining one a half MGD makes up the
seven and a half MGD design flow if we bypass'directly to
nitrification.
Trickling filters are a fairly high capital cost item with
very low operation and maintenance costs. Since there are
four existing filters at Parkway which you have invested in,
we suggested that you use them to the maximum extent, and
have estimated that that maximum extent is about six million
gallons per day. They can handle the six million gallons
per day, and then pass it along into the nitrification
system. The remaining one and a half can go directly into
We recscmrended retaining the existing primary
The existing units at the plant are hydraulically
A little explanation may be in order here.
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that nitrification system without harming it, so that the
plant flow would remain at seven and a half MGD.
Following the trickling filters then, comes the
combined sta,ge nitrification system. That system provides
two functions. It removes the remaining BOD that has to be
taken out of the wastewater, and it converts the ammonia
in the wastewater to nitrates so that it can later be
converted to nitrogen.
We suggested that that system be modified to
increase its operability and it's allowed to nitrify more
completely. By increasing the aeration capacity of that
system, by providing a better PH control system to allow
better control of the system, and by increasing the return
sludge capacity, this again, will allow better control of
that system.
We suggested reusing the aeration tanks that are
there, a,nd reusing two of the existing secondary clarifiers
that are there. There are two more existing secondary
clarifiers that may have some structural problems. And we
suggested that those should be looked at very carefully dur-
ing the design phase to determine whether or not they should
be kept.
And I've also suggested that some additional
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capacity is needed in the clarification system there.
Following nitrification, to finally remove nitro-
gen is a suspended growth denitrification system. That
system then has the main function of converting the nitrates
that we create in the nitrification system to nitrogen gas.
It would also serve, as a secondary function, as a second
point at which, we can catch phosphorus. We could add some
metal salts there, and remove some more phosphorus from
the wastewater, if it should happen to get that far.
of about one milligram per liter, the discharge standard for
Parkway <
denitrification system that would consist of reactors sim-
ilar to aeration tanks, nitrogen release tanks which is a
point at which the nitrogen and the wastewater can be re-
leased to the air, and finally, settling tanks to remove the
solids that are created in the denitirification system.
three tenths milligram per liter phosphorus standard; were
imposed, would be a multimedia filter system. The purpose of
that function would be to remove any residual phosphorus,
down to three tenths milligrams per liter — from one tenth.
That should bring the phosphorus down to a point
We suggested constructing a new suspended growth
Following denitrification would be — if the
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which, is what would come out of denitrification, down to
three tenths. Of course, that system would only be con-
structed if the three tenths phosphorus limit were imposed.
We have recommended th^t design and construction of that
system be done later on, if needed. It may never be re-
quired.
Then following either filtration or denitrification
would be a chlorination system to disinfect the wastewater.
As I said, the main function of the chlorination system is
to disinfect the treated effluent from the plant. We
recommended reusing the existing chlorine feed system at the
plant, but constructing new chlorine contact tanks.
The reason for constructing the new chlorine con-
tact tanks is that we want to use the existing ones down-
stream now for dechlorination and reaeration. Dechlorination
neutralizes the chlorine that's — the free chlorine that's
in the wastewater from disinfection, and the reaeration
brings the dissolved oxygen level in the wastewater up to
that required by the Patuxent River.
We suggested constructing new sulfur dioxide
storage and feed facilities, and modifying the existing
chlorine contact tank, to allow its use for dechlorination
and for reaeration.
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That's the end of the liquid treatment portion
of the train. I'd now like to ask Betty to talk to you about
the sludge portion.
MS. GQWEN: Good evening. Before I summarize our
sludge handling alternative, I'd like to briefly go over
what sludge handling actually is. There are two purposes for
adding in a sludge system. One is volume reduction of the
sludge, and two, is to stabilize it. When we reduce the
volume of the sludge, we take out the excess water. This
allows us to handle the sludge more easily, and also reduces
the number and size of equipment needed for sludge handling,
which reduces its cost.
genie organisms and reduce the odor potential. And, as you
can see in the slide, we start out with the raw sludge from
liquid treatment from about one half to one percent solids.
In the thickening process we remove some water, which
increases the solids content to four to six percent solids.
In dewatering, we concentrate the sludge even
further, to about 20 to 25 percent solids. At this point
the sludge has a consistency of mud. The stabilization pro-
cess further increases the solids content of the sludge, and
stabilizes it to a product which is similar to humus in the
When we stablize the sludge, we reduce the patho-
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composting process.
In our recommended sludge handling alternative,
we would have gravity thickening of primary chemical sludges,
dissolved air flotation thickening of waste activated
sludges, blending, off-line storage for peak sludge flows,
belt filter presses for the dewatering, and a mechanical
composting system for stabilization.
Our first process in this sludge system would be
gravity thickening of the primary chemical sludges. The
gravity thickeners would reduce the water content of the
primary sludge. We have recommended retention of the exist-
ing units out at Parkway, which would thicken the primary
sludge to six to eight percent solids.
The next process in the sludge handling alterna-
tive would be flotation thickening of the waste activated
sludge. We have recommended a different type of thickening
process for waste activated sludge, because it is a differ-
ent type of sludge. It has different characteristics than
the primary sludge.
Flotation thickeners would reduce the water con-
tent of the nitrification and denitrification sludges. The
new units would thicken the sludges to three to five percent
solids,
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The next major process in the sludge system is the
storage for peak sludge flows. This storage is provided for
two reasons. One, it reduces the peak sludge flow to de-
watering, and two, it optimizes the si.zi.ng of the dewatering
units, Vte would recommend rehabilitation and reuse of the
existing sludge storage units by improving the mixing and
withdrawal systems.
The dewatering units come after the thickening
processes, or the storage processes. At Parkway we
recommend the belt filter presses. These belt filter
presses would concentrate the sludge solids to 20 to 25
percent solids.
Currently the Parkway plant uses centrifuges.
However, with the sludge quantities expected with total
nitrogen and total phosphorus removal, these — we would
have more sludge than the centrifuges could handle. Also,
centrifuges have high operating costs. So to provide ade-
quate sludge dewatering capacity and reduce the operating
costs, we would recommend new belt filter presses.
Our last process in the sludge handling alterna-
tive is mechanical composting system — a mechanical com-
posting system. The mechanical composting system would
stabilize the sludge and render it suitable as a soil
Cf^
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amendment.
This new system would have an enclosed reactor —
process and curing reactors, as well as new facilities for
storage of bulking ^gent and finished compost. We recommend-
ed an enclosed system in order to control the process more
easily, and also to reduce odors.
At this time, Tom will summarize our facility
plan report.
MR. WALSH; Thank, you.
To summarize then, we have recommended that
W. S. S. C. upgrade the Parkway Wastewater Treatment Plant
by providing ihhancenient to the biological processes that
are there, upgrading the nitrification system to allow
better year around nitrification, and then adding a denitri-
fication system to allow removal of nitrogen from the
wastewater at Parkway, as well as adding on a dechlorination
step to a liquid process to make* sure that the chlorine is
adequately removed from the wastewater prior to discharge.
the system by providing some new thickening capacity, by
providing some better dewatering equipment, and by adding a
mechanica,l composting system to stabilize the sludge prior
to disposal of the sludge.
The sludge handling, we have recommended upgrading
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The last bit of information for you is on costs.
Before I get into the actual dollars and cents, I'd like to
go over with you some cost' estimate terminology/ some of the
words that you will see us use, and their definitions.
Capital costs for facilities are the costs to
construct those facilities, the costs for the structures,
the equipment, and so on, that goes into the facility, as
well as allowances for contingencies during construction,
for engineering and design of those facilities, and for
administration of the construction contract.
Operation and maintenance costs are the costs of
operating the plant, what you pay annually in terms of
labor, chemicals, energy and other materials and supplies to
make sure that the plant operates properly, and that it is
maintained in order to achieve its 20-year life.
Present worth — present worth is the thing that
most of us stumble over — is the value of money today. In
terms of capital cost, it's the capital cost of the facility
minus the salvage value of that facility at the end of its
20-year life, taking into consideration interest rates
throughout that 20—year period.
The present worth of 0 and M costs similarly, are
the annual costs, brought back to today's value of those
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costs. It's a calculation of how much money you would have
to have in the bank today if you wanted to pay those
operation and maintenance costs out annually over the next
20 years. You don't have to have that money in the -"bank
today, it's just an estimate of how much it would be.
Th.e total prQject present worth then, is the value
that we use to compare alternatives, and it is the sum of
the present worth of the capital costs, and the present
worth of the operation and maintenance costs. It is really
a mark against which, we can compare the various alternatives
that we look at. And it's an attempt to look at them in a
realistic vta.y with equal weight to capital and to operation
and maintenance costs when they are added together.
For the recommended alternative for Parkway, in
19 82 dollars the present worth of the capital cost, our
estimate is $17„6 million. In the annual operation and
maintenance costs, the energy cost would be about $340,000
a year. Other costs, chemicals, personnel, and materials
and supplies, $3 million a year, for a total operation and
maintenance cost of about $3.4 million.
The present worth of that cost is about $35.7
million. Adding those together, it gives us a total pre-
sent worth cost of the facility of $53.3 million.
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In terms of user costs, we calculated the user
costs based on the total capital costs of the facility. The
total present worth then, of $53,270,000 a year — which is
partly based on the total capital cost — excuse me the
capital cost estimate of $18 million, we calculate the local
share of that. We have to calculate how much people who are
served by W, S. S« C« would have to pay for the plant.
Their share of the plant after Federal funding, and State
funding is considered to be $2,800,000.
That converts to an annual cost of $318,000, or a
cost per user of $1.27. The annual 0 and M costs of
$263,000 converts to an annual cost per user of $1.05,
giving a total added annual cost to the user of Parkway of
$2.32.
Now the current annual cost per user is $195. So
the total future annua,l coats for the Parkway Treatment
Plant would be $197.32 per user. Now by user, I mean
basically per household. That number is derived by dividing
that total total cost number by the 250,000 bills that are
sent out by W. S. S. C.. So that it is not per individual,
it is per billed establishment.
That concludes our remarks. Thank you.
MR, SLENKAMP: Okay. Thank you very much, Tom, and
Cf^
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Betty. I would now like for any testimony pertaining to
the facilities plan. Does anyone wish, to testify about the
facilities plan per se?
CNo response.!
MR* SLENKAMP; If not then, I would like to run
through a few points related to the draft EIS. First, in
relation to the table that Tom just explained, there is a
similar table in the draft EIS on Page 95. And the only
point that I wanted to make was that some of those numbers
that appear on that table are somewhat outdated, but they
will be revised and the most recent figures will be presented
in the final EIS.
I think all the figures related to W. S. S. C.'s
recommended alternative 3 are accurate, but some of the
other ones need to be revised.
In regards to the conclusions of the draft EIS,
the findings of the draft EIS, most of those can be found
summarized in Chapter 6 and in the Executive Summary. And
what I'm going to run through, you can find in those two
locations.
First, EPA has no preferred alternative at this
time, as Bob, and Tom, and Betty explained, W. S. S. C.
has recommended a specific alternative in plant for upgrading
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the Parkway facilities. EPA has not taken a position in the
draft EIS, but will indicate a preferred alternative in the
final EIS, based in part on the testimony received tonight,
and on the written comments that we get between now and the
end of the comment period.
We feel that all alternatives will significantly
improve water quality in the Patuxent River Basin, all are
capable of meeting the NPDS permit limits set by the State
— both, the initial limits that would be in effect in 19 87
when the facility would be expected to go on line, and, as
well as possible future limits.
Third, the initial — many of the initial EIS
issues have been significantly reduced in severity due to
the fact that there is no longer-an expansion contemplated.
Issues involving secondary growth impacts, population and
flow projections, those sorts of things, have been rendered
moot because of the fact that we're only talking about an
upgrade here now, not an expansion.
The differences among the feasible in plant alter-
natives, from an environmental perspective, are considered
minor. And impacts from construction necessary to accomplish
the upgrade will be temporary, and can be minimized by
appropiate mitigative measures.
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The individual user costs that Metcalf and Eddy
presented for W. S» S, C. customers, as he indicated, will
increase by an average of about $2 and some change per year,
depending on the alternative selected, the final permit
limits and available funding sources. All of these increases
are well within EPA guidelines on affordability established
for facilities planning purposes.
And finally, in regards to possible funding
sources, the studies performed to date, the technical
studies do not, in EPA's opinion provide an adequate tech-
nical basis to support nitrogen control in addition
phosphorus control. As a result, if a funding decision were
made today, EPA could only provide funding for the cost
effective selection to achieving the required permit limits,
that is phosphorus control only.
Procedurally, testimony received tonight will
become part of the public record, as will any written
comments submitted to EPA or W. S. S. C. by February 27th.
You can send comments on the EIS to my attention, at the
address in the front of the EIS. .. Comments on the facilities
plan can be provided to Bob Hayes at W. S. S. C..
Then following the close of the comment period, a
final EIS will be completed by EPA. And this will include a
CRS
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summary of the public hearing, responses to all substantive
comments received during the review period, and an identifi-
cation of EPA's recpmmended, and other acceptable alterna-
tives .
The final EIS will then be published, and the
public will have 30 days in which to comment before any
administrative action is taken, for example, a grant award
made.
That is all I have to say about the EIS. Is there
anyone who wishes to provide testimony about the EIS docu-
ment?
(No response,!
MR. SLENKAMP: Does anyone have any comments in
general about the project?
Ma'am?
MS- YENGICH; How much sludge is being produced
today at Parkway, and how much will be produced once you
institute the in plant things — you know, to take out more
nitrogen and phosphorus? Does anyone know?
MR. SLENKAMP: Ma'am, would you please give us
your name and affiliation, if any, for the stenographer's
use?
MS. YENGICH: I'll write it down, because he'll
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never be able to spell it.
MR. SLENKAMP: Okay.
MS. YENGICH; My name is Karen Yengich, and I'm a
Reporter with, the Laurel Leader, here in Laurel.
MR, SLENKAMP; We're working on an answer.
MR. HAYES: Okay. The existing plant today, we
produce about 5.8 dry tons of sludge a day. And using the
recommended alternative we would produce about 6,000 wet tons
of compost a year. That's a yearly basis. The other one was
a daily basis.
MR. SLENKAMP: Do we have any other comments?
(.No response.)
MR. SLENKAMP: If not, I'd like to thank the
laurel Government for use of this facility tonight, and I
would like to thank you all for attending. And if there
aren't any further comments, this hearing is now adjourned.
(.Whereupon, the foregoing hearing was concluded
at 8:08 o'clock, p.m.)
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CERTIFICATE of court reporter
I, Charles F. Madden, Court Reporter, do hereby
certify that the proceedings herein contained were duly
recorded stenographically by me, and thereafter reduced to
typewriting by me; that the transcript of said proceedings
is a tsue ancl accurate record.
Charles F. Madden
Court Reporter
REPORTING SERVICES
12611 CAMBLETON DRIVE
UPPER MARLBORO, MARYLAND 20870
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Responses
1. The "Action" that is the subject of the EIS is the up-
grading of the Parkway Wastewater Treatment facility to meet
the effluent limits set forth in the NPDES permit. Expansion
of the plant's capacity is not part of the "Action" since the
plant's capacity of 7.5 mgd is adequate for the 20-year
planned period. The no-action alternative, therefore, would
involve the continued use of the Parkway WWTP without the
provision of nutrient removal. Anticipated growth within the
service area would result in increased wastewater being
treated and discharged from the facility, with effluent limi-
tations remaining unmet.
2. The annual average design flow of the Parkway plant is 7.5
mgd. However, the maximum efficiency of the trickling filters
is at flows up to 6 mgd. Above that, little additional BOD
removal occurs. Flows in excess of 6 mgd bypass around the
filters and are treated by the activated sludge system. The
facilities planners recommend that at flows less than 6 mgd,
the entire flow would be passed through the trickling filters.
For higher flows, 6 mgd would pass through the filters while
the remainder would bypass to the aeration basins.
3. The action evaluated in the EIS involved various treatment
alternatives. Since none of the alternatives will affect
population growth, the project will have no impact on air
quality, traffic levels, and non-point source pollutant
loadings.
4. The effects of point source discharges of nutrients on
Patuxent Estuary algae and dissolved oxygen levels were
addressed in both the Patuxent Mater Quality Management Plan
(MDHMH, 1983) and in thi report entitled Water Quality
Analysis of the Patuxent River, prepared by HydroQual, Inc.
(O'Connor et al., 1981, hereinafter referred to as the
"Hydroqual report"). The Hydroqual report, which is available
for inspection upon request to EPA, addressed the water
quality issues of major significance in the Lower Patuxent
River and Estuary. These issues are as follows:
a. The need for determining the sources of nutrients>
b. The need for identifying the limiting nutrients; and
c. The need for determining the causes of algae growth
and low dissolved oxygen levels in the bottom waters
of the Estuary.
According to the Maryland Department of Health and Mental
Hygiene (MDHMH, 1982 and 1983) typically from 30 to 50 percent
of the total nitrogen load and 60 to 70 percent of the total
phosphorus load for the Patuxent River originate from point
sources (i.e., discharges from municipal WWTPs). The
remaining nitrogen and phosphorus loads originate from
non-point sources which include surface runoff, groundwater
inflow, export of organic material from marshes, and intrusion
of Chesapeake Bay water (O'Connor et al., 1981).
Nitrogen and phosphorus are nutrients of major importance in
surface waters because they are essential to the growth of
algae and other aquatic biological organisms. A reduction in
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the amount of one or both of these nutrients can limit aquatic
production, depending on the relative predominance of each.
Generally, the following rules apply:
o When the available N:P ratio is less than 7, N is
limiting.
o When the available NsP ratio is between 7 and 12,
both N and P are limiting (or neither is limiting
if present in moderate to high concentrations); and
o When the available NsP ratio is greater than 12, P is
limiting.
According to the Maryland DNR (1977), the NsP ratios in the
Patuxent River between River Miles (RM) 25 (estuarine) and 55
(freshwater) ranged between 8 and 20, with the lower ratios at
RMs 25 and 55 and the higher ratios at RM 40. The Maryland
Department of Health and Mental Hygiene (1982) reports an NsP
ratio of 16 above RM 35. These data indicate that the
freshwater reaches of the Patuxent River above RM 35 are
phosphorus-limited. Below RM 35, the NsP ratios indicate that
neither of the nutrients is limiting, or that both are
limiting.
In the Patuxent River and Estuary, algal growth dynamics are
complicated not only by nutrient concentrations and NsP
ratios, but also by the change from fresh to brackish water
algae species. The location of this change is dependent upon
streamflow, but generally occurs in the neighborhood of RM 35,
and involves the death of the freshwater algae and their
gradual replacement by estuarine species. The decomposition
of the freshwater algae creates a biological oxygen demand
(BOD) and releases the nutrients stored in these organisms.
The estuarine algae utilize these nutrients as well as the
nutrients already present in the water. These two sources of
nutrients can cause algal blooms in the estuary. The algal
populations in the brackish waters of the lower Patuxent vary
with temperature, mixing, flushing by Chesapeake Bay waters or
freshwater inflow, light intensity, turbidity, nutrient con-
centrations, and grazing by zooplankton. In the estuary, DO
may become depleted as a result of oxygen demand exerted by
decomposing freshwater algae and other organic matter. In
addition, the daytime production and nighttime consumption of
DO by estuarine algae create a diurnal change in DO of up to 3
mg/L in the summer (O'Connor et al., 1981). DO levels below
3.0 mg/L have been recorded in the bottom waters of the
Patuxent Estuary during the summer and fall. DO levels below
3.0 for long periods of time would have significant adverse
impact on aquatic life, since fish and shellfish cannot
survive such conditions.
In the Hydroqual report (O'Connor et al., 1981), the DO
content in the bottom waters of the estuary was given for the
period 1936-1940. During that period, there were no signifi-
cant point source discharges to the Patuxent, and DO
concentrations of less than 2 mg/L were observed from Jack Bay
(located downstream of Benedict) to Drum Point. It was
therefore concluded in the report that under "natural condi-
tions," low concentrations of DO occur in the lower Estuary.
Under the existing sediment oxygen demand (SOD) and sediment
nutrient release (SNR) rates, DO levels of zero have been
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projected by using the Hydroqual model. It is expected that
these rates would persist for 3 to 10 years following imple-
mentation of either a phosphorus control strategy or a
nitrogen control strategy. After that time under either
strategy, both the SOD and the SNR rates would be reduced.
These reductions would improve the DO levels in the river and
estuary considerably, since under moderate stratification, DO
in the lower layer would be above 2.0 mg/L. However, the DO
levels would still be in violation of state water quality
standards under both low and moderate stratification.
Modeling the factors affecting algal growth is a complex task.
To date, no model has conclusively shown that at present
wastewater flows, an effluent nitrogen limitation of 3.0 mg/L
within the freshwater Patuxent would significantly reduce
chlorophyll a concentrations in the lower (brackish) portion
of the system beyond those projected to occur if an effluent
phosphorus limit of 1.0 mg/L were imposed. there are several
reasons why this is true. One is that approximately 30 to 50
percent of the nitrogen load originates from point sources
(i.e., sewage treatment plant effluents), and 50 to 70 percent
of the nitrogen load originates from non-point sources (i.e.,
stormwater runoff from urban and agricultural land). There-
fore, it can be expected that non-point sources of nitrogen
will continue to contribute significant nitrogen loads after
point sources of nitrogen are reduced. In addition, blue-
green algae can fix nitrogen from atmospheric sources (78
percent of the atmosphere is nitrogen), thereby keeping
nitrogen concentrations high.
By regulating phosphorus concentrations in STP effluents, 60
to 70 percent of present and projected phosphorus loads can be
reduced. If P concentrations in the upper and lower Patuxent
were reduced, the available NsP ratio would increase and
phosphorus would become even more limiting for algal growth
than it is at present. Controlling point source discharges of
phosphorus will provide a consistent basin-wide nutrient
management approach to controlling algal growth and increasing
DO concentrations in the Patuxent River and Estuary. In addi-
tion, because of the high costs and the operational problems
associated with nitrogen removal, EPA regards phosphorus
removal as the more effective method for improving water
quality.
The DEIS statement that point source control of phosphorus to
1.0 mg/L would have effects on algae similar to point source
control of nitrogen to 3.0 mg/L is correct for present waste-
water flows. In regard to the projected 2000 wastewater
flows, however, a phosphorus effluent limitation of 1.0 mg/L
does not have effects similar to a nitrogen effluent limita-
tion of 3.0 mg/L. Consequently, for the year 2000 wastewater
flow condition, it is EPA's opinion, based on the information
currently available, that a phosphorus effluent limitation of
0.3-0.5 mg/L is appropriate (Benning, 1982).
5. The discussion provided in the DEIS regarding the limiting
nutrient applies to the historical or present-day condition of
the river, and has no relationship to a condition that might
result under a future control scenario. The fact that
nitrogen may be currently limiting in the estuary does not
necessarily mean that a nitrogen control strategy should be
adopted for the Patuxent Basin as a whole, since the Hydroqual
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model showed that phosphorus could be made to limit if enough
of it is removed from the system. The control of phosphorus
is therefore seen as the most appropriate strategy in the
present case. However, EPA will continue to encourage the
State to provide scientific justification to support its
contention that nitrogen removal is also needed. If such
measures prove feasible, EPA would consider those options in a
reevaluation of the nutrient control needs of the Patuxent
system.
6. User costs for the various alternatives are shown in Table
V—1 (Table IV-4 of the Draft EIS, corrected for current
values). As indicated on this table additional user costs for
the alternatives range from $0.28 per year to $2.84 per year.
The additional cost for Alternative 3 (the recommended
alternative) is $2.32 per year. These costs include both
nitrogen and phosphorus removal even though under current
policy nitrogen removal will not be funded by EPA. The actual
cost of nitrogen removal is a very small percentage of the
projected increase in user costs.
7. Sludge handling costs are included in the total project
costs set forth on Table V-l.
8. The Facilities Plan for the Parkway Wastewater Treatment
Plant, indicates that the Parkway service area has an
infiltration rate of 2,280 gpd/in-dia/mile. This rate is
considered nonexcessive relative to EPA guidelines in effect
for this Facility Plan. EPA I/I policy has, however, changed
since the Facilities Plan was completed. The new policy is
based on I/I in gallons per person per day. The State of
Maryland, bearing I/I responsibilities will review this issue
relative to any future grant.
9. The issue of basin-wide water quality and its effect on
the public health is beyond the scope of the EIS. The
investigation of such issues is important and should be
conducted on a regional basis. Given the magnitude of total
point and non-point source flows into the basin in comparison
to the volume discharge of the Parkway plant, it is doubtfull
whether Parkway's contribution to the public is at all
significant or detectable. Nevertheless, an EIS for an
individual point source is not the proper forum for this
regional discussion. It should also be reiterated that the
upgraded Parkway plant will meet all discharge criteria which
have been established to protect the public health and
welfare.
10. WSSC must meet the 1 mg/L phosphorus limit set forth in
the NPDES permit for the Parkway WWTP. However, in meeting
this limit, future modifications to meet more stringent limits
cannot be precluded. WSSC's design for the recommended
upgrading provides for the future inclusion of additional
treatment units to meet the 0.3 mg/L requirement.
11. The wastewater flow data for wastewater treatment plants
that discharge into the Patuxent River are summarized in Table
V-2. The 1980 data were obtained from the Maryland Department
of Health and Mental Hygiene, and appear in their entirety in
reports referenced in the table.
With regard to the low-flow calculation, in the Hydroqual
study (O'Connor et al., 1981), groundwater and surface water
loads entering the Patuxent River and Estuary between the
Route 50 bridge and the Chesapeake Bay were assigned in
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proportion to the increased drainage area of the Patuxent.
This methodology was used to calculate the freshwater 7-day,
10-year flow of the Patuxent at its confluence with the
Western Branch. These calculations (given below in Equation
1) were made in the following manner:
DA2 (1)
Q2 ~ x Qi
where
DA-l
Ql = 7-day, 10-year low flow at Route 50
bridge (cfs)
Q2 = 7-day, 10-year flow at confluence of
Patuxent and Western Branch (cfs)
DAj = drainage area of the Patuxent above
Route 50 bridge (mi2)
DA2 = drainage area of the Patuxent at the
confluence with the Western Branch
(mi2)
Using equation (1), 56 cfs was calculated as the 7-day,
10-year low flow at the confluence of the Patuxent and the
Western Branch. The following values were used in the calcu-
lation :
= 36 cfs
DAj = 350 mi2
DA2 = 540 mi2
was calculated using the following
equation:
Qi = 16.5 + 1.42 x Q3 + 4.2 x Q4 (2)
where
Q3 = 7-day, 10-year low flow for USGS
gauge near Unity
Q4 = 7-day, 10-year low flow for USGS
gauge near Guilford
Values for 2.7 cfs and 3.8 cfs were used for Q3 and Q4,
respectively. These 7-day, 10-year low flow values were
derived through an evaluation of the period of record at the
referenced gauges through March, 1979.
12. The issue of potential greenhouse effects resulting from
land treatment is a global issue, well beyond the scope of
this EIS. In any event, land treatment is not the recommended
alternative.
13. Since it has not been conclusively determined that a
nitrogen control strategy is necessary, no experimentation
with such a strategy is warranted at the present time.
However, EPA will continue to encourage the State to provide
scientific justification to support its contention that
nitrogen removal is also needed. Should such a determination
be forthcoming, EPA would consider performing a study of this
kind.
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14. Comment noted. No response required.
15. Table IV-4 of the Draft EIS has been revised and is
included herewith as Table V-lf in the response to Comment No.
6.
With respect to why Alternatives 5, 6, 7 and 8 were included
in the Draft EIS, EPA recognizes that these alternatives were
included at the request of the State and represent nutrient
removal scenarios not within the current discharge permit.
Accordingly, these alternatives were not carried forward as
viable. However, since the federal regulations require the
Final EIS to summarize the facilities planning process and
DEIS, they are referenced in portions of this document. They
are not included on Table V-l (the revised Table IV-4).
16. The nitrogen and phosphorus loadings shown on Table II-6
of the Draft EIS are in pounds per day, and are taken from
studies published by the State of Maryland.
5-75
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TABLE V—1
ESTIMATED
USER COSTS
1
Alt 31
Alt
A-l1
Alt
W-l1
Alt
1
Alt
2
Alt
4
Total Project Present Worth
(Thousands)
53 ,270
66,580
77,270
51,030
53,110
5 5,250
Total Capital Cost
Local Share of Capital Cost
Annual Cost of Capital2
Annual Capital Cost/User
(Thousands)
(Thousands)
(Thousands)
18,044
2,800
318
1.27
43.030
5,379
611
2.44
59 ,390
7 ,424
843
3.37
18,760
2,961
336
1.34
20,250
3,656
415
1.66
19,420
3 ,470
394
1.56
Annual O&M Cost"*
Annual O&M Cost/User
(Thousands)
263
1.05
(541)
(2.16)
(320)
(1.28)
(24)
(0.10)
(62)
(0.25)
321
1.28
Total Additional Cost/User
2.32
0.28
2.09
1.24
1.41
2.84
Current Average Annual Cost/User4
195.00
195.00
195.00
195.00
195.00
195.00
Future Average Annual Cost/User
197.32
195.28
197.09
196.24
196.41
197.84
* Table IV-4 of EIS, corrected for current values.
2 Local share of capital cost amortized at 9.5% over 20 years.
^ Based on the difference between projected annual O&M cost and past year's actual O&M cost.
4 Based on the base rate of $1.78 per thousand gallons of water consumption for users of 300
gallons per day.
5-76
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TABLE V-2
WASTEWATER TREATMENT PLANT FLOW DATA
Wastewater
treatment
plant
Average
annual
flow (mgd)
based on
1978 data3
Average
annual
flow (mgd)
based on
1980 datab
Parkway
5.0
5.7
Maryland City
0.6
0.6
Horsepen
0.2
0.3
Bowie-Belair
2.6
2.5
Western Branch
11.4
11.9
Savage
8.7
7.8
Md. House of Corrections
0.7
0.8
Fort Meade 1 & 2
2.6
2.4
Patuxent
3.6
3.6
Total
35.4
35.0
Projected
average
annual
flow (mgd)
for the
year 2000b
7.5
2.7
1.5
3.3
23.7
18.3
-0-c
3.6
7.2
67.8
a Source: O'Connor et al., 1981.
b Sources MDHMH, 1982.
c Abandoned.
5-77
-------
References
-------
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6-6
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Appendices
-------
APPENDIX A
DISTRIBUTION LIST
-------
DISTRIBUTION LIST
FEDERAL AGENCIES
Federal Emergency Management Agency
U.S. Department of the Army
Corps of Engineers
Baltimore District
U.S. Department of Health and Human Services
Public Health Service
Center for Disease Control
U.S. Department of Housing and Urban
Development
U.S. Department of the Interior
Fish and Wildlife Service
Office of the Secretary
U.S. Department of Transportation
U.S. Coast Guard
MARYLAND STATE AGENCIES
Department of Economic and Community
Development
Department of Health and Mental Hygiene
Construction Grants and Permits Program
Environmental Health Administration
Office of Environmental Programs
Grants Management
Planning and Evaluation Program
Department of Natural Resources
Tidewater Administration
Wildlife Administration
Department of State Planning
State Clearinghouse
Tri-County Council for Southern Maryland
Department of Transportation
Maryland Historical Trust
LOCAL AGENCIES
Anne Arundel County
Calvert County
Charles County
Howard County
Montgomery County
Prince George's County
St. Mary's County
REGIONAL AGENCIES
Maryland-National Capital Park and Planning
Commission
Metropolitan Washington Council of Governments
Washington Suburban Sanitary Commission
ELECTED OFFICIALS
Honorable Harry R. Hughes
Office of the Governor
Honorable Charles MacMathias, Jr.
U.S. Senate
Honorable Paul S. Sarbanes
U.S. Senate
Honorable Marjorie Holt
U.S. Representative
Honorable Steny Hoyer
U.S. Representative
Honorable Michael Barnes
U.S. Representative
Honorable Beverly Byron
U.S. Representative
MARYLAND LEGISLATURE
Honorable Arthur Dorman
Maryland Senate
Honorable Leo Green
Maryland Senate
Honorable Thomas Yeager
Maryland Senate
Honorable William C. Bevan
Maryland House of Representatives
Honorable Susan Buswell
Maryland House of Representatives
A-l
-------
MARYLAND LEGISLATURE (cont.)
CITIZENS
Honorable Gerard Devlin
Maryland House of Representatives
Honorable Timothy Maloney
Maryland House of Representatives
Honorable Pauline Menes
Maryland House of Representatives
Honorable Thomas Mooney
Maryland House of Representatives
Honorable Joan Pitkin
Maryland House of Representatives
Honorable Charles Ryan
Maryland House of Representatives
LIBRARIES
Bowie Library
Hyattsville Library
Laurel Library
Upper Marlboro Library
Washington Suburban Sanitary Commission
Engineering Library
MEDIA
Annapolis Evening Capitol
Baltimore Sun
Bowie News (Prince George's County News)
Beltsville News
Greenbelt News Review
Laurel Leader (News Leader)
Prince George's Press
Prince George's Journal
Prince George's Sentinel
Prince George's Post
Washington Times
Allen, Dr. Scott
Anderson, Ray
Antonetti, Robert, Sr.
Armiger, Earl L.
Bell Joann
Dennis 0. Bigley, Chief
County Division of Environmental Planning
Bonton, Jim
Bowie, Oden
Brady, Patrick M.
Brennan, Robert E.
Brown, Sue
Cassels, James
Castaldi, Richard
Clark, F. S.
Clayman, Lee H.
Conrad, David
Crist, Howard
Crotty, Michael
Darcey, Roland
Dea, Stanley
Dew, Jim
Diggs, W. Mitchell
Dolesh, Richard
Downing, Dent
Eckert, Stephen
Edwans, Joseph H.
Epplemann, Andrew
Ferguson, Frank
Finney, Connie
Fohs, Linda
Foster, Dallert
Gammell, Paul
Gans, Roger
Geis, Aelrod
Giles, Michael
Gorman, Frank
Graham, Ken
Wastewater Operations Division, WSSC
Growen, E.M.
Gutman, James E.
Hall, Thomas
Hayes, Robert
Jeffrey, Edward
Johnston, W. D., ill
Jones, J. A.
Leahy, Vincent
LeCourt, Arthur
LeCourt, Vincent
Leaseburge, G.
Lewis, Greg
Livingstone, Walter
Ludwig, Lawrence
Maury, Jessie
Meagher, Pat
Meigs, Sharon
Milnor, John
Mohler, Phillip
Mohr, Shirley
Nichols, T. Hugh
A-2
-------
CITIZENS (cont.)
OTHERS
Ohlendorf, Harry University of Maryland - Botany Department
Parks, Reginald
Pisen, Edmond M. Metcalf & Eddy, Inc.
Price, Craig
Prince George's County Council Laurel Chamber of Commerce
Reeves, Merrilyn
Rhoderick, John C.
Ripley, R. Graydon
Roberts, James
Rumberger, Marge
Shagogue, Richard
Samuels, Vernon
Sauerwein, Jack
Schroeder, Werner
Shanks, Ken
Soltis, Ron
Solyst, Jim
Speicher, Jean
Stevens, N.
Stiko, Ed
Tacinelle, Gerald
Thomas, James R., Jr.
Tomazewski, Stanley
Vogel, Phil
Vogt, Donald R.
Metcalf, & Eddy, Inc.
Walker, Aubrey R.
Wilieczek, John
Wilson, Walter
Wirley, Laura A.
Wilbur, Garth
Witten, Jack
Yengich, K.
CITIZENS GROUPS
Clean Water Action Project
Davidsonville Area Civic Association
Holland Cliff Shores Citizens Association
Potomac River Association
patuxent River Civic Association
prince George's Civic Association
prince George's Civic Federation
Laurel Grove Civic Association
Laurel Homeowners, Inc.
Sierra Club
A-3
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