United States Region 3
Environmental Protection Sixth and Walnut Streets
Agency Philadelphia, PA 19106 May 1982
Final Environmental
Impact Statement *
Little Patuxent Water Quality
Management Center
(Savage Plant)
Howard County, Maryland
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UNITED
STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
6th AND WALNUT STREETS
PHILADELPHIA. PENNSYLVANIA 19106
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:
Enclosed is a copy of the Final Environmental Impact Statement
(EIS) prepared by the Environmental Protection Agency (EPA) in
relation to a grant of Federal funds awarded to Howard County,
MD for the upgrade and expansion of the wastewater treatment
facility known as the Little Patuxent Water Quality Management
Center.
This Final EIS is issued pursuant to the National Environmental
Policy Act of 1969, the Clean Water Act of 1977, and regula-
tions promulgated by this Agency (40 CFR Part 6, November 6,
1979 and 40 CFR Part 35, September 27, 1978). Comments or
questions concerning this Final EIS should be submitted to the
attention of Ms. Mary A. Sarno at the above address by July C,
This Final EIS has been prepared in response to an Order by the
U.S. District Court of the District of Columbia. The Court did
not enjoin construction of the facility, and it was completed
during the period in which this EIS was being prepared.
EPA has determined that Alternative 1, the facility as
constructed, is both cost-effective and environmentally sound.
EPA further determined that Alternative 1 will have no adverse
impact on water supply uses of the Patuxent River.
I wish to thank the applicant for the assistance they have
provided to EPA's staff during this EIS process. In addition,
I want to especially recognize the interest demonstrated by the
area's citizens and scientific community. Their participation
throughout this EIS process has greatly contributed to the
development of an acceptable solution to the wastewater treat-
Sincerely yours, ^7' ^
p^ter N. Bibko
Regional Administrator
Enclosure
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FINAL ENVIRONMENTAL IMPACT STATEMENT
on the
LITTLE PATUXENT WATER QUALITY MANAGEMENT CENTER
TOWN OF SAVAGE, HOWARD COUNTY, MARYLAND
Prepared By:
UP ENVIRONMENTAL PROTECTION AGENCY
REGION III
PHILADELPHIA, PENNSYLVANIA
Mary A. Sarno, Project Monitor
With the Assistance of:
ESEI, INC.
VIENNA, VIRGINIA
Carl Mitchell, Project Manager
Type of Actions
Legislative ( )
Administrative ( X )
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Executive Summary
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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, such as
funding for large construction projects, so that government
officials and the public can make responsible decisions. Federal
funding for wastewater treatment facilities through the U.S.
Environmental Protection Agency's Construction Grants Program is
subject to the requirements of NEPA.
The specific project studied involved the expansion and upgrade
of the Little Patuxent Water Quality Management Center (LPWQMC),
also known as the Savage fourth addition, from 10 million gallons
per day of secondary treatment to 15 million gallons per day of
advanced wastewater treatment.
This EIS is being prepared by the Environmental Protection Agency
(EPA) in response to an Order by the U.S. District Court of the
District of Columbia, based on a suit brought against EPA by the
Maryland Counties of Charles, Calvert, and St. Mary's. The Court
ordered EPA to prepare an EIS, as a result of a grant awarded to
Howard County, MD, addressing the possible impacts of increased
nitrogen discharges from the expanded LPWQMC on eutrophication in
the lower Patuxent Estuary. Also to be addressed was the impact
of the project on any possible future water supply, to be used in
considering denitrification facilities at the plant. The Court
further ruled that construction at the facility could continue
during the study period. Construction was completed during the
time the Draft EIS was being prepared.
The controversy over the Savage fourth addition was centered
around three major issues. These issues formed the basis of the
court suit and the environmental analysis in the EIS as follows:
Issue li The plaintiffs contended that the plant expansion
would have an adverse effect on the availability of
public drinking water.
Finding: An examination of the water supply users indicates
that, with the exception of the withdrawal by the
Washington Suburban Sanitary Commission (WSSC), very
little use is made of the Patuxent River and its
tributaries as a raw water source. Two of the largest
consumers are Fort Meade and the Maryland House of
Correction. The relocation of the discharge pipe
below Fort Meade adversely effects Fort Meade's
ability to meet its current and future needs.
However, they are acquiring permits for additional
wells to supplement water losses from this project.
The Maryland House of Correction, which only withdraws
from the Little Patuxent River when Dorsey Run is
threatened by accidental contamination or periods of
extreme drought, is negotiating to connect to Anne
Arundel County's water supply system. They will then
use water from the Little Patuxent River for
non-potable purposes.
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By relocating the outfall to below Fort Meade, the
LPWQMC discharge will not affect the ability of
downstream users to withdraw sufficient water from the
Little Patjxent and Patuent Rivets. In teems of flow
volume alone, future increased effluent flow from the
LPWQMC will add to and augment the ability of
downstream users to withdraw water from the river
system.
Issue 2: The plaintiffs contended that the plant expansion
would increase the bacteria and viruses in the
Patuxent fciver, the Patuxent Estuary, and the
Chesapeake Bay, thereby decreasing water quality and
harming aquatic organisms.
Finding: Although available data are not specific or detailed
enough to be conclusive, they do inoicate that the
present LPWQMC discharge is not a maaor source of
microbial water quality degradation in the Patuxent
River. In addition, studies by the Maryland
Department of Health and Mental Hygiene (1^76)
indicate an improvement in fecal coliform levels
correlating to improvements in sewage treatment
plants. Therefore, in spite of the expansion at the
LPWQMC, the upgraded treatment processes and more
efficient disinfection capabilities will provide an
extra measure of protection against increased health
risks.
Issue 3: The plaintiffs contended that the expansion will
increase eutrophication in the River, Estuary and Bay
through the discharge of increased amounts of
nitrogen. They alleged the nitrogen discharges will
promote algal growth which will lower the amount of
dissolved oxygen in the River, leading to a
significant loss of aquatic life especially in the
lower estuary.
Findings Using the water quality model developed by HydroQual,
Inc., we have determined that 0.3 mg/1 phosphorus
would have a significant.beneficial effect on Patuxent
water quality by reducing chlorophyll 'a' levels in
the upper estuary. Since such a decrease in algal
biomass in the upper estuary will reduce nutrient
transport, deposition and enrichment in the lower
estuary, we can infer a positive effect on the lower
estuary by the LPWQMC expansion and upgrade. Although
an equivalent control of nitrogen could produce the
same results on algal productivity, it is more costly
and presents more operational problems than does
phosphorus control.
Public Comments EPA received several written and verbal comments on the Draft Eis
during a formal public comment period which ended on December 21,
1981. Oral testimony on the Draft EIS was recorded at a Public
Hearing conducted by EPA at the George Howard Building on
December 8, 1981. Comments on the Draft were in the form of
questions, suggestions for improvement on the document and new
information, including the State's Nutrient Control strategy for
the Patuxent River Basin. Specific written comments received, as
well as a transcript of the oral testimony taken at the December
8 Public Hearing can be found in Chapter IV of thiB Final Eis.
All substantive issues raised during the public comment period
have been addressed in this document.
ii
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Major Issues from There were three major issues raised during the public comment
the Public" period on the Draft EXS as follows:
Issue Is Many commentors questioned the cost analyses for the
land application alternatives; most specifically, the
spray irrigation rate of .75 inches.
Responses The .75 inches per week application rate and 151 days
storage requirement used in the Draft EIS were
recommended in a study by Howard County and approved
by the State of Maryland for the preliminary design of
large scale spray irrigation systems within the
County. During this study, a maximum loading rate of
1.5 inches per week was calculated. However, without
a site-specific survey, the 1.5 inches application
rate cannot be recommended due to shallow depth-to-
bedrock in the area. Shallow depth-to-bedrock creates
the potential for groundwater mounding underneath the
application sites if the loading rate is too high.
The storage requirement of 151 days was determined
using the five months from November to March as a
non-application period. Therefore, without
site-specific information available on the
hydrogeologic conditions, EPA believes the .75 inches
per week application rate, while conservative, is a
reasonable assumption for the purposes used in the
preparation of this EIS.
Issue 2s Several commentors questioned the use in the Draft EIS
of the HydroQual Model in drawing conclusions relating
to nutrient control in the lower estuary.
Responses The model, developed by HydroQual, Inc., is a
two-layer, steady state water quality model of the
Patuxent River. However, the lack of time variability
in the model does diminish its applicability to the
lower estuary. Thus, the model's predictive ability
becomes more a qualitative indicator rather than a
quantitive predictor in the lower estuary. This
suggests that, although nitrogen may currently limit
phytoplankton growth in the lower Patuxent River, a
95% reduction in point source phosphorus (effluent P -
0.3 mg/1) may induce a phosphorous limitation in the
lower estuary. Although point source phosphorous does
not directly affect downstream chlorophyll 'a' levels,
it is likely that the reduction in upstream
phytoplankton levels associated with point source
phosphorous removal will reduce the overall
phosphorous level in the estuary sediment, which in
turn, may reduce overlying water column algal levels.
Reduction in estuary chlorophyll 'a* levels will
likely result in a reduction of sediment oxygen demand
and a corresponding increase in bottom water dissolved
oxygen levels, a water quality improvement.
Issue 31 Several commentors questioned the apparent
inconsistencies in the data base used in the Draft EIS.
iii
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Response: In order to simulate a realistic planning basis foe
use in assessing the project and any alternatives, EPA
decided to use 1977 data similar to that used at the
time of original project planning and construction
start-up. However, in determining the impact of the
project, we used more current data in order to more
accurately assess the effects of the completed project
on the area. Therefore, while it may appear that we
have been inconsistent in developing our data bases,
we believe we have provided a fair assessment of the
project as completed.
In addition, several commentors mentioned the
Charette, held by the State of Maryland in December
1981 and the State Nutrient Control Strategy for the
Patuxent River Basin, published on January 15, 1982
and their relevance to this EIS. A copy of the
Nutrient Strategy can be found in Appendix p of this
document.
Alternatives Four major alternatives, including the constructed project, were
developed and a present worth analysis was performed on each.
These alternatives and the results of the analyses are as follows;
1. Upgrade and expansion of the LPWQMC to 15 mgd of AWT
(advanced wastewater treatment - phosphorus removal), with a
discharge below the Fort Meade Intake structure. This is the
constructed fourth addition; the present worth is $54,760,000.
2. Upgrade and expansion of the LPWQMC to IS mgd of AWT with a
discharge to the Patapsco Riverj the present worth 1b $60,850,000.
3.A.I. upgrade the LPWQMC to 10 mgd of AWT with discharge below
the Fort Meade intake structure? construction of a new 5 mgd
secondary treatment plant with discharge to Deep Run; the present
worth is $56,120,000.
3.A.2. Upgrade the LPHQMC to 10 mgd of AWT with discharge below
the Fort Meade intake structure) construction of a new 5 mgd
aerated lagoon followed by land application) present worth is
$65,050,000.
3.B.I. Upgrade a 10 mgd portion of the LPWQWMC to AWT with
discharge below the Fort Meade intake structure; construction of
5 mgd of secondary treatment at the LPWQMC with discharge to Deep
Run; the present worth is $54,620,000.
3.B.2. Upgrade a 10 mgd portion of the LPWQMC to AWT with
discharge below the Fort Meade intake structure and construction
of 5 mgd of secondary treatment at the LPWQMC followed by land
application; the present worth is $72,860,000.
4. Conversion of the LPWQMC to a pump station to redirect the
sewage to an aerated lagoon (15 mgd) followed by land
application; present worth is $66,420,000.
6ince the present worth analyses Indicate that Alternative 1, the
project as constructed, is cost-effective, EPA decided to
concentrate the environmental impact analysis on that Alternative
only. The results are as followsi
Environmental
Impacts
iv
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1. Based on an analysis of current and planned water supply uses
of the seven counties within the Patuxent River Basin to the year
2030, the project will not adversely affect water quantity and
quality.
2. While current modeling of the lower estuary is inconclusive,
based on assumptions drawn from modeling the upper estuary,
either phosphorus and/or nitrogen control at the LPWQMC would
have similar impacts on water quality. In addition, the
upgrading of the LPWQMC should minimize microbiological
contamination of the river and should benefit aquatic biota
directly downstream of the discharge.
3. Current problems in the River, the Estuary, and the
Chesapeake Bay are caused by a combination of point and non-point
sources of water pollution.
4. The LPWQMC alone, as constructed, does not cause a
significant adverse impact on the Patuxent River.
Conclusions Based on the present worth analyses and an analysis of the
environmental impacts affecting the River, the estuary, and the
Bay, Alternative 1, the LPWQMC as constructed, is found to be
cost-effective and environmentally sound. Further, modeling
results indicate that the addition of nitrogen control
capabilities at the LPWQMC will result in no additional water
quality benefits, assuming the LPWQMC and all other treatment
plants control phosphorus at 0.3 mg/1. Of the two nutrient
control capabilities, phosphorus control is the more
cost-effective and easily maintained.
V
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TABLE OF CONTENTS
Page
Executive Summary i
List of Tables viii
list of Figures ix
I. Introduction 1
II. Development and Cost of Alternatives 5
III. Environmental Impacts of the Little Patuxent Water Quality Management Center 25
IV. Public and Agency Comments on Draft EIS 57
V. Conclusions 171
References 173
EIS Distribution List 193
Appendices
A. Alternatives A-l
B. Water Supply Users B-l
C. Public Health Impact.n C-J
D. Aquatic Biota Impacts D-l
E. Endangered Species List E-l
F. Nutrient Control Strategy for the Patuxent River Basin F-l
vii
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7
9
10
12
14
26
27
28
30
31
36
37
39
40
44
45
LIST OF TABLES
Effluent Limitations used in Evaluation of Alternatives
Summary of Alternatives
Comparison of Site Characteristics for Land Treatment Processes
Typical Wastewater Flow Reduction Methods
Comparison of Effluent Quality for Conventional, Land Treatment and
Advanced Wastewater Treatment Systems
Major Water Intakes in the Patuxent River Basin
Discharge Volumes of Major Wastewater Treatment Plants in the
Patuxent River Basin
Flow Data for Patuxent River and Little Patuxent River Gages
Fecal Coliforms from 11 Stations on the Little Patuxent River Sampled
Between April and November 1978
Fecal Coliform Controventions of Maryland's Water Quality Standards
for Water Contact Recreation and Shellfish Harvesting in the Undiluted
LPWQMC Effluent During 1980
19 80 and Projected Year 2000 Wastewater Flows and Nutrient Loadings
in the Patuxent River Basin
Average Annual Non-point Source Nutrient Loading Rates in the Patuxent
River Basin
Patuxent River Basin Population Projections by Sub-Basin Regions
Patuxent River Basin Land Use Distribution Projections by Sub-Basins
Calculated Annual Average Non-Point Pollutant Loadings from Surface
Runoff Alone
Comparison of Annual Average Point and Non-Point Source Pollutants
with Different Treatment Levels
viii
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LIST OF FIGURES
Il-l Patuxent Drainage Basin Treatment Plants and USGS Stream Gaging Stations 6
II-2 Potential Areas for Land Application 16
II-3 Transmission System Alignment for Land Application Alternatives 20
III-l Patuxent River Basin and MAGI Sub-Basin Regions 38
III-2 Total Dissolved Inorganic Nitrogen and Phosphorus and Nitrogen-Phosphorus
Ratio vs. Salinity in the Patuxent River 48
in-3 Total Dissolved Inorganic Nitrogen and Phosphorus and Nitrogen:
Phosphorus Ratio vs. Salinity in the Patuxent River 49
III-4 Comparison of Estimated Non-Point Pollutants Prom Different Sources on the
Predicted Water Quality (Present Flow With Present Treatment Level) 51
IH-5 The Effect of Nitrogen Removal at LPWQMC (10 ragd) Alone on the Predicted
Water Quality With Effluent Limitations of 0.3 mg/1 P Applied to all
Plants 52
III-6 The Effect of Nitrogen Removal at LPWQMC (18.3 mgd) Alone on the
Predicted Water Quality With Effluent Limitations of 0.3 mg/1 P Applied
to all Treatment Plants 53
III-7 The Effect of Effluent Limitation of 0.3 mg/1 P on the Predicted Water
Quality 55
ix
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LIST OF PREPARERS
U.S. Environmental Protection Agency
Mary A. Sarno, Project Monitor - Final EIS
Rochelle Volin, Project Monitor - Draft EIS
Rosemarie Baldino, Production Advisor
Karen Risoli, Support Services
BSEI, Ire.
Lanny Katz, ESEI Area General Manager
Carl Mitchell, Environmental Planner
Gaines Ho, Senior Engineer/Scientist
Andrei* Lapins, Earth Scientist
Teresa Dowd, Environmental Planner
Ronald Greenberg, Ecologist
Michael Dortnan, Engineering Technician
x
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Chapter I
Introduction
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CHAPTER I.
INTRODUCTION
The United States Environmental Protection Agency (EPA) prepared
this Final Environmental Impact Statement (EIS) in response to a
1980 Order of the U.S. District Court of the District of Columbia.
In 1977, EPA awarded a Step III (construction) grant to Howard
County for the upgrade and expansion of the Little Patuxent Water
Quality Management Center (LPWQMC) or more commonly the "fourth
addition." The court ordered EPA to prepare an EIS to assess the
environmental impacts of the Savage "fourth addition" and alterna-
tive wastewater treatment plans on the Patuxent River. However,
the Court's order did not enjoin construction and the fourth addi-
tion is completed and in operation.
Background The Little Patuxent Water Quality Management Center (LPWQMC) in
Savage, Maryland (formerly known as the Savage WTP) is one of eight
major wastewater treatment plants (WTPs) discharging into the
Patuxent River basin. Although 45 WTPs discharge into the
Patuxent, the eight largest plants combine to contribute 90 percent
of the total hydraulic load discharged into the basin. The LPWQMC
in 1980 processed an average wastewater flow of 7.9 million gallons
per day (mgd) from a 108-square-mile service area. This area
includes the town of Columbia and about three-fourths of Howard
County.
Because it is near the metropolitan areas of Baltimore and Washing-
ton, D.C., Howard County has changed over the past 40 years from an
essentially agricultural area to a residential and industrial
county. To serve the increasing residential and economic needs of
the county, the LPWQMC has expanded incrementally over the past 15
years.
The present population of Howard County is about 126,500, 72% of
whom live in the Little Patuxent Sewerage Service Area. The LPWQMC
currently serves 71% of the population of the service area.
Howard County submitted its original application for EPA funding to
expand the LPWQMC from 10 mgd to 15 mgd of advanced wastewater
treatment (AWT) on July 1, 1971. Major delays experienced by
Howard County in obtaining federal funding centered around three
issues: (1) impoundment of EPA funding, (2) initial draft of the
Patuxent River Basin Water Quality Management Plan (Section
303 [e] ), which proposed a regional plant concept, and (3) several
changes in effluent limitations which occurred in the Patuxent
River basin during the period 1973-1977.
In 1974 the draft Patuxent River Water Quality Management Plan
proposed the abandonment of the LPWQMC facility and construction of
an Upper Patuxent Regional Sewage Treatment Plant with a discharge
point below water supply intakes for Fort Meade and the Maryland
House of Correction. The rationale was that this step would pro-
vide higher quality raw water supplies and better dilution capacity
for increased wastewater discharge.
The plan met with disfavor, however, and in 1975 Howard County pro-
posed an amendment to the Patuxent Plan calling for the continued
use of LPWQMC and analysis of possible discharge alternatives.
Alternatives examined by the county were land application, indus-
trial and recreational reuse and the diversion of the effluent to
either (a) the Patapsco River basin, (b) the main stem of the
Patuxent River, or (c) a point below the Port Meade water intake.
1
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All but one of the alternate solutions were ruled out as either im-
practical or too costly. The exception was relocation of the
Savage effluent discharge point (Howard County Department of Public
Works, 1976). As a result of this study, and with the concurrence
of Fort Meade, Anne Arundel County and EPA officials, Howard County
decided to build a 3.5-mile outfall line from the LPWQMC plant to a
point just below the Fort Meade water supply intake. The outfall
pipe was designed and sized to meet a then-projected capacity re-
quirement of 25 mgd in the year 2000.
Controversy arose over whether denitrification or phosphorus re-
moval should be implemented in the fourth addition to the LPWQMC.
Water quality data from 1973 indicated that during times of low
base flow the estuary was nitrogen-limited and during high base
flow the estuary was phosphorus-limited. However, water quality
modeling, reported by the Maryland Water Resources Administration
(1977b), indicated that phosphorus removal to the degree possible
(0.3 mg/1 as P) would control eutrophication to a greater degree
than nitrogen removal to the degree possible (3.0 mg/1 as N). In
late 1976, the state decided that phosphorus removal would be re-
quired in the Patuxent basin. With Howard County's proposal to
construct the outfall below Fort Meade's water supply intake, the
proposed project was in conformance with the Water Resources Admin-
istration's Water Quality Management Plan.
The proposed fourth addition included the construction of 10 mgd of
primary clarification, 5 mgd of activated aeration and secondary
clarification, and 15 mgd of phosphorus removal, nitrification,
clarification, filtration, chlorination-dechlorination and post-
aeration. Upon completion, the plant was to be able to treat an
average flow of 15 mgd at advanced treatment levels (U.S. EPA,
1977a; Howard County, n.d.b).
In March 1977, EPA awarded a Step III grant for expansion and up-
grade of the LPWQMC facility. EPA's review of the environmental
impacts associated with this fourth addition to the LPWQMC con-
cluded that the center's expansion would not significantly affect
the quality of the environment and that an Environmental Impact
Statement (EIS), therefore, was not required. Accordingly, EPA
issued a Negative Declaration as required by regulations implement-
ing the National Environmental Policy Act (NEPA) (U.S. EPA,
1977a). Negative Declarations are presently known as Findings of
No Significant Impact (PONSI) according to current EPA regulations
implementing NEPA dated 1979. EPA did not conclude that the con-
struction of the treatment plant would adversely affect eutrophi-
cation in the estuary or result in an adverse increase in the con-
centration of bacteria and viruses in the effluent discharged.
County Commissioners of three southern Maryland counties adjacent
to the Patuxent estuary (Charles, Calvert and St. Mary's) took
issue with the findings of EPA's Negative Declaration. As a
result, the counties filed suit against EPA in the U.S. District
Court for the District of Columbia. The plaintiffs contended that
the plant upgrade and expansion would (1) have an adverse effect on
the availability of public drinking water, (2) increase the con-
centration and occurrence of bacteria and viruses in the Patuxent
River, the Patuxent estuary and Chesapeake Bay, thereby degrading
water quality and harming aquatic organisms, and (3) increase
eutrophication in these water bodies by discharging increased
amounts of nitrogen (U.S. District Court for the District of Colum-
bia, 1980).
2
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The three southern counties originaLIy sought to stop construction
and operation of expanded facilities at the LPWQMC; but later, they
decided to seek declaratory relief and an Environmental Impact
Statement. Affidavits of their experts, Drs. Mihursky, Heinle,
Ulanowicz, Colwell and Krantz, indicated that there was, at a mini-
mum, a significant scientific controversy surrounding the effect of
nitrogen discharges on the Lover Patuxent estuary. In addition,
the record of public participation indicated considerable and wide-
spread public concern over the nitrogen issue.
The plaintiff's scientists contended that the phosphorus control
strategy was speculative. They cited cumulative WTP discharges and
increased urban runoEf as primary sources of water quality degrada-
tion in the Patuxent, with WTPs as the major contributors to nitro-
gen over-enrichment in the lower estuary. They also pointed out
that there was no reported instance where phosphorus controls alone
significantly reverse the eutrophication process in the estuary.
Eutrophication resulting in anaerobic conditions, particularly in
deep water during warm weather, was blamed for the killing of
oysters.
The three southern Maryland counties were successful in their law-
suit. On July 28, 1980, the U.S. District Court ordered EPA to
prepare an EIS for the upgrade and expansion of the LPWQMC; this
decision permitted the ongoing upgrade and expansion to continue
during preparation of the EIS. Issues to be addressed included the
possible environmental impacts from increased nitrogen discharge
from the expanded LPWQMC on eutrophication in the lower Patuxent
estuary and on any possible future water supplies (U.S. District
Court of the District of Columbia 1980).
NEPA Process EPA has conducted this EIS process in accordance with the require-
ments of the National Environmental Policy Act (NEPA) and Agency
regulations implementing NEPA. Accordingly, EPA issued a Notice of
Intent to prepare the EIS in October 1980 and released a Draft
Environmental Impact Statement {EIS) in October 1981.
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 con-
cerning this project are clarified, enabling EPA to present its
findings regarding the upgrade and expansion of the LPWQMC. Fol-
lowing the close of the comment period on the Final EIS, EPA will
prepare a formal Record of Decision which will describe the conclu-
sions of the EIS Process.
3
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Chapter II
Development and Cost of
Alternatives
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CHAPTSS XI.
DEVELOPMENT AND COST OF ALTERNATIVES
Plant History The Savage Wastewater Treatment Plant was originally built in 1965
as a 1 ragd contact stabilization system. How designated the Little
Patuxent Water Quality Management Center (I/PWOMC), its location is
shown in Figure 11-1. In 1970, the plant was expanded to 3 mgd.
An additional 2 mgd expansion occurred in 1972. A separate and
complete treatment unit was added each time. Howard County used
this method of expansion to provide treatment facilities on an as-
needed basis.
In 1974 both EPA and the Maryland Department of Health requested
that the county stop building additional single contact stabiliza-
tion units. The County plan was ceatudied, and a new program was
begun that called for plant additions consisting of activated
sludge processes and additional treatment for both the existing and
planned plant facilities
In 1975, the County began building a third addition to provide
another 5 mgd of treatment capacity. The total plant capacity was
ID jsgd (see Figure A-l in Appendix A for a layout of the treatment
plant).
Planning for the fourth addition was completed in 1977 and Howard
County received a Step III grant from EPA to add 5 ragd in capacity
and to upgrade the plant to advanced wastewater treatment capabil-
ity.
As noted earlier, the actual upgrade and expansion of the LPVJQMC is
complete. This was permitted by tbft judge during the preparation
of the EIS. However, to comply with the intent of the EIS process,
alternatives to the original project were evaluated.
Assumptions The need for the fourth addition was determined through the pre-
viously mentioned Facilities Planning Study (Whitman and Reguardt
Associates, 1974) in which the 1985 population was estimated to be
150,000 people. Based on this projection, the design called for a
15 mgd plant with the capability to treat a short-term peak flow of
30 mgd. The EIS uses this as a basis for developing and evaluating
alternatives. With the exception of effluent limitations, any
changes in technology, service area, or treatment processes at the
LffWQMC that occurred after 1977 were not taken into consideration.
The effluent limitations used to determine the treatment level re-
quired for different eEEluent disposal options in this evaluation
are the current limitations. Effluent limitations for surface
water discharges ate presented in. Table 11-1. tt shows the current
LFWQMC -discharge limitations (Patuxent River Basin) and those for
discharges into the Patapsco River Basin below Ellicott City, Mary-
land. Any land application alternative that involved a surface
water discharge, such as overload flow, was evaluated baaed on
meeting the limitations set for the river basin that would receive
the effluent. It was assumed that there would be no legal restric-
tions nor implementation problems and resulting delays regarding
the discharge of effluent into a watershed in which it was not pro-
duced (inter-basin transfer). This assumption is acceptable for
planning purposes, but use of inter-basin transfer would normally
encounter significant problems in implementation.
The alternatives analyzed in the Draft EIS were similar to those in
the original Facilities Plan,
5
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QUN-KORD
/ !i(M.U;l>
IH (.Kh!
Hi. "'¦/ A'l'»//.'
MD. HOUSE OF
~ ^CORRECTION
UREL \A
MARYL/tND CITY
DE-2
LAUREL PARKWAtt>
ADE-1
PAfTUXENT
BOWIE-HOR3EPEN4
BOWIE-BELAIR
IBOWI
LEGEND
~ U8G8 GAGING 8TATIONS
SECONDARY TREATMENT WITH
* ADVANCED WASTEWATER
TREATMENT
WESTISRtNBQAMeH ~'
FIGURE 11-1
PATUXENT DRAINAGE BASIN TREATMENT PLANTS
AND USQS STREAM GAGING STATIONS
<1 H«sou'f*i tomotny
-------
Table II-l. Effluent Limitations Used in Evaluation of
Alternatives
Parameter
BOD5 (Dec. - Feb.)
UOD* (March - Nov.)
Suspended Solids
Phosphorus as P
Dissolved Oxygen
Total Conform
Total Residual Chlorine
pH
For Discharges to the Patuxent River Basin
Limitation
10 rag/1 (monthly average)
15 mg/1 (weekly average)
20 rag/1 (monthly average)
30 rag/1 (weekly average)
10 mg/1 (monthly average)
15 mg/1 (weekly average)
0.3 mg/1 (monthly average)
0.5 mg/1 (weekly average)
6.0 mg/1
70 MPN/10Q ml (maximum)
0.02 mg/1 (maximum)
6.0 - 8.5
"CJOD = Ultimate oxygen demand = 1.5 X BOD5 + x
For Discharges to the Patapsco River Basin
Limitations
Parameter
BOD5
Suspended Solids
Total Kjeldahl
Nitrogen
phosphorus as P
Total Residual
Chlorine
Fecal Coliforms
Dissolved Oxygen
PH
For 5 wqd
30 mg/1
(monthly average)
30 mg/1
(monthly average)
See Note 2
N/A
0.5 (maximum)
200 MPN/100 ml
(maximum)
5.0 mg/1 {minimum)
6.0 - B.5
For 15 ragd
20 mg/1
(monthly average)
20 mg/1
(monthly average)
5 (7.5)1
2.0 mg/1
0.02 (maximum)
200 MPN/100 ml
(maximum)
5.0 mg/1 (minimum)
6.5 - 8.5
1-5 mg/1 (maximum) between May 1 to September 30, 7.5 mg/1
(maximum) between October 1 to April 30'.
2State standards specifically mention no limitation for flows
less than 3.3 mgd. It is assumed there would be no limitation at
5 mgd.
7
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Because SPA requires that the cost of all wastewater treatment be
examined on an equal basis, a present worth analysis was under-
taken. Tiiis analysis compared the total capital and operation and
maintenance (Os.M) cost of each alternative. Present worth can bo
defined as the amount of money that must be invested, at a given
interest rate, at the beginning of a project to provide enough
funds to meet construction and annual O&M costs for the design life
of the facility. The following assumptions were used in the
present worth analysis:
° Ml costs are given in second quarter 1977 dollars.
® Twenty years was used as the planning period, from 1981 to 2001.
O&M costs are given in second quarter 1980 dollars and the
present worth of the O&M converted back to 1977.
0 Discount rate used was 6 1/8%.
° No cost preference was qiven to Innovative and Alternative Tech-
nologies.
Construction would take place in four years for all alterna-
t ives.
° Land costs that were used were $2,500 per acre. This price
would increase if homeowners were displaced and had to be relo-
cated.
° For all discharges to the Patapsco River Basin, the alignment of
the outfall system would follow the B&O Railroad alignment for
two reasons: (1) less environmental impacts and (2) possible
lower costs. Though the railroad usually charges a fee for the
use and occupancy of their land, these costs were assumed to be
less than any costs incurred in acquiring land from other
owners. This charge is not reflected in the cost of the alter-
natives using this alignment and therefore actual costs for
these would be higher.
° Use of the B&O right-of-way could create problems since rail-
roads are usually very reluctant to allow construction near rail
lines because of potential for disrupting rail beds.
° Discharge to the Patapsco River Basin could raise inter-
jurisdictional problems due to inter-basin transfer; delays due
to these problems would increase the costs of this alternative.
° All capital costs for the alternatives are based on EPA's Large
City Advanced Treatment (LCAT) and Complete Urban Sewer Systems
(CUSS) indices of 134 and 138, respectively, for the second
quarter of 1977.
° O&M costs include the costs for labor, chemicals, electrical
power, fuel, replacement parts and administration. The opera-
tion and maintenance costs are based on EPA's CUSS index of 173
for the fourth quarter of 1980.
A summary of the present worth cost of each alternative can be
found in Table II-2 along with a description, of their advantages
and disadvantages. A detailed breakdown of costs and required
treatment layouts can be found in Appendix A.
8
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Table II-2. Summary of Alternatives
Alter- Present Worth
native of Alternative^
1 $54,760,000
$60,850,000
3A.1 $56,120,000
($53,950,000)l/J/4
3A.2 $65,050,000
($62,88 0,000) '
3B.1 $54,620,000
($52,460,000) x/
3B.2 $72,860,000
($76,690,000)'
$66,420,000^
Advantages
Higher effluent quality
discharging into the
Little Patuxent River.
No discharge into the
Little Patuxent River from
the LPWQMC.
Higher effluent quality
and no increase of dis-
charge from LPWQMC into
the Little Patuxent
River.
Higher effluent quality
and no increase of dis-
charge from LPWQMC into
Little Patuxent River. No
increase in direct surface
water discharges.
Higher effluent quality
and no increase of dis-
charge from LPWQMC into
the Little Patuxent
River.
Higher effluent quality
and no increase of
discharge from LPWQMC into
the Little Patuxent River.
No increase in direct
surface water discharges.
No direct discharges of
effluent into surface
waters.
Disadvantages
Increased flows into Little
Patuxent River.
Increased discharges into the
Patapsco River. Possible
adverse impacts on future
discharges.
Possible adverse impact on Deep
Run. Possible adverse impact on
future discharges into Patapsco
basin. Two treatment plants to
operate.
Possible groundwater mounding
under application sites.
Displacement of homeowners within
application area. Two treatment
plants to operate.
Possible adverse impact on Deep
Run. Possible adverse impact on
future discharges into Patapsco
basin.
Possible groundwater mounding
under application sites.
Displacement of homeowners within
application area.
Possible groundwater mounding
under application sites. Dis-
placement of homeowners within
application areas. Not enough
suitable land has been identi-
fied. Extremely difficult to
implement because of the land
requirement of over 18.8 square
miles.
^Costs shown are preliminary estimates for screening and comparison purposes; actual
costs will vary depending on design factors.
^present worth of alternative without outfall below Fort Meade raw water intake
structure.
3Does not include any charge for use and occupancy of land along the BfiO Railroad
alignment.
^Does not include any increase in costs due to implementation delays as a result of
inter-basin transfer requirements, inter-governmental jurisdiction, or obtaining B&O
Railroad right-of-way access.
5Does not include costs for displacing persons within land application areas.
9
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Alternative
Development
The initial step used to evaluate treatment alternatives for the
LPWQMC service area was to prepare a list of potential options.
Each option was screened on its ability to treat and dispose of the
wastewater in an acceptable manner. The preliminary alternatives
that were initially considered are described below.
Advanced Wastewater
Treatment
Advanced wastewater treatment would be required for all discharges
into the Patuxent River watershed and for any discharges greater
than 5 mgd into the Patapsco River. Advanced treatment, where
necessary, might include phosphorus removal, nitrification and
filtration or a combination thereof.
Relocation of the
Discharge Point
Land Application
The LPWQMC could discharge into several receiving streams: the
main stem of the Patuxent River, the Patapsco River, Deep Run (a
tributary of the Patapsco River) or the Little Patuxent River (the
present discharge point). Under these discharge options, effluent
would be conveyed by gravity outfalls and/or a series of force
mains and pumping stations.
Land application of municipal wastewater can be used for treatment
as well as the recovery and reuse of wastewater nutrients. The
three most widely used methods of land application are spray
irrigation, rapid infiltration and overland flow. Each was
considered as a potential alternative for the LPWQMC. Table II-3
briefly compares the site characteristics required for each of
these processes.
Table II-3. Comparison of Site Characteristics for Land Treatment Processes
Characteristics
Slope
Principal Processes
Slow Rate Spray Irrigation Rapid Infiltration
Less than 20% on cul-
tivated land; less
than 40% on nonculti-
vated land
Not critical; exces-
sive slopes require
much earthwork
Overland Flow
Finish slopes 2
to 8%
Soil permeability
Moderately slow to
moderately rapid
Depth to groundwater 2 to 3 ft (minimum)
Climatic restrictions
Storage often needed
for cold weather and
precipitation
Rapid (sands,
loamy sands)
10 ft (lesser depths
are acceptable
where underdrainage
is provided)
None (possibly
modify operation
in cold weather)
Slow (Clays, silts,
and soils with im-
permeable barriers)
Not critical
Storage often
needed for cold
weather
1 ft = 0.305 m
(Source: EPA et al., 1977)
10
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t'pfiai Irrigation The most common method of treatment by land application is irriga-
tion. Spray irrigation systems are the most efficient for uniform
flow distribution but are generally more costly than other forms of
irrigation. This method controls the amount of discharge of
effluent onto the land to support plant growth. The wastewater is
"lost" to plant uptake, to air by evapotranspiration and to ground-
water by percolation. Hydrologic loading rates (how much effluent
can be sprayed) allowed by the State of Maryland range from .5 to
2.0 inches per week on a seasonal basis and should allow for stor-
age during either wet weather or periods when the ground is frozen.
This rate is determined by either the infiltration rate of the soil
or the nitrogen removal capacity of the soil and vegetation. Crops
are generally selected on the basis of climatic suitability and
their capacity to absorb large quantities of nitrogen. This method
of land application can produce the best level of treatment of all
land application systems.
In rapid infiltration land treatment (also referred to as
infiltration-percolation), most of the applied wastewater perco-
lates through the soil, and the treated effluent eventually reaches
the groundwater. The wastewater is applied to rapidly permeable
soils by spreading in basins or by sprinkling and is treated as it
travels through the soil matrix. Vegetation is generally not used;
and, therefore, there is little or no consumption by these plants.
Application rates vary from 1 to 15 feet per week and are highly
dependent on soil properties. In cases where groundwater recharge
is not desired, renovated water can be recovered by using under-
drains or wells with subsequent discharge to surface waters.
In overland flow land treatment, wastewater is pumped to the upper
reaches of sloped terraces and allowed to flow across the vegetated
surface to runoff collection ditches. The wastewater is renovated
by physical, chemical and biological means as it flows in a thin
film down the relatively impermeable slope. Loading rates range
from 5 to 25 feet per year of secondary effluent. The collected
runoff from most overland flow systems is discharged to surface
waters (EPA, 1975).
Many methods are available to reduce the amount of wastewater pro-
duced from a domestic source. These methods were initially
developed to reduce hydraulic loadings to on-site systems, but the
principle can be used to reduce the amount of sewage flow to be
treated at a centralized wastewater treatment facility. Table II-4
presents a number of these methods, both structural and non-
structural, that could be used to reduce the wastewater flow at the
LPWQMC. Many of these methods were not fully developed at the time
of the initial planning stages of the fourth addition and therefore
were not available to the planners during this stage. However,
Howard County now has a wastewater flow reduction program in place.
This program employs a number of the methods presented in Table
rr-4.
On-Site Systems Of the many types of on-site systems in use today, the septic tank-
sail absorption system (ST-SAS) is used most often. The ST-SAS
treats wastewater first by removing solids and scum within the
septic tank. Then the sewage is further treated as it percolates
through the soil before reaching groundwater. Anaerobic conditions
within the septic tank reduce the volume of solids by bacterio-
logical decomposition. Cesspools, privies and various alternative
on-lot systems are also commonly used individual systems.
Soil permeability, slope, groundwater level and depth to bedrock
are important factors that determine the suitability of on-site
systems. Properly designed, constructed and maintained ST-SASs are
11
Rapid Infiltration
Ov cz'Land Flow
Wastewater Flow
Reductions
-------
Table II-4. Typical Wastewater Flow Reduction Methods
I. Elimination of Nonfunctional Water Use (Non-structural)
A. Improved water use habits
B. Improved plumbing and appliance maintenance
C. Nonexcessive water supply pressure
II. Water-Saving Devices, Fixtures, and Appliances (Structural)
A. Toilet
1. Water carriage toilets
a. Toilet tank inserts
b. Dual-flush toilets
c. Water-saving toilets
d. Very low-volume flush toilets
(1) Wash-down flush
(2) Mechanically assisted
° Pressurized tank
° Compressed air
0 Vacuum
° Grinder
2. Non-water carriage toilets
a. Pit privies
b. Composting toilets
c. Incinerator toilets
d. Oil-carriage toilets
B. Bathing devices, fixtures, and appliances
1. Shower flow controls
2. Reduced-flow showerheads
3. On/off showerhead valves
4. Mixing valves
5. Air assisted low-flow shower system
C. Clotheswashing devices, fixtures, and appliances
1. Front-loading washer
2. Adjustable cycle settings
3. Washwater recycle feature
D. Miscellaneous
1. Faucet inserts
2. Faucet aerator3
3. Reduced-flow faucet fixtures
4. Mixing valves
5. Hot water pipe insulation
6. Pressure-reducing valves
(Source: EPA, 1980)
12
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an effective long-term treatment and disposal method. A Connecti-
cut study has shown that systems installed in stratified sand and
gravel have a half-life of 27 years. In another study (Abney,
1980), which evaluated six basic types of on-site systems, the
ST-SASs were found to have the lowest cost and highest level of
performance. Cluster systems, which work on the same principles as
the ST-SAS, serve several homes by a common treatment and disposal
system. Homes can have on-site septic tanks (or one large common
tank) with the liquid being conducted to one common subsurface soil
absorption field. The cluster system is especially suited to homes
with small lots that lack adequate area for a properly sized drain-
field.
Screening of
Alternatives
Advanced Wastewater Properly operated and maintained advanced WTPs can reliably meet
Treatment the effluent limitations for both the Patuxent and Patapsco Rivers.
Feasible alternatives developed using advanced treatment are des-
cribed later in this chapter.
The relocation of the outfall from the LPWQMC on the Little
Patuxent River was considered necessary to protect the integrity
of the raw water supply for the Fort Meade Army Reservation.
Several studies (Ludlow, 1976 and Friedman, 1971) had been done to
relate high nitrate levels and possible viral contamination in the
raw water supply for the Army Reservation to the upstream proximity
of the LPWQMC effluent outfall. These studies recommended a relo-
cation of either the raw water intake structure or the effluent
outfall. Other options, such as adding denitrification and chemi-
cal coagulation to the treatment process to remove those contami-
nants, were also suggested but were considered more costly than re-
locating the outfall.
In a report prepared by Howard County Department of Public Works
(1976) several discharge points were evaluated. The receiving
streams for the various discharge options were the Little Patuxent
River, the main stem of the Patuxent River and Deep Run, a tribu-
tary of the Patapsco River. In that evaluation, the selected
option was a relocation of the discharge point to below the Fort
Meade raw water intake structure since it was found to be the least
costly. This was mainly because the entire outfall was a gravity
system requiring virtually no maintenance costs, and therfore was
the selected option. Discharging to the main stem of the Patuxent
River was eliminated in the report prepared by Whitman, Requardt
and Associates due to excessive cost and therefore will not be con-
sidered further. The report also eliminated discharge into Deep
Run on a cost basis, without taking into consideration that some
savings in the treatment plant costs would occur because the
effluent limitations for the Patapsco River basin would be
different than those for the Little Patuxent River and therefore
might offset the high cost of conveyance to Deep Run. In this
evaluation, only discharges of 5 mgd or less into Deep Run are con-
sidered environmentally acceptable while greater flows could be
discharged directly into the Patapsco Riyer below Elkridge.
Land Application Each type of land application system (spray irrigation, overland
flow and rapid infiltration) was evaluated based on the draft
"Procedures Manual and Guideline for the Evaluation and Selection
of Discharge Alternatives - Land Disposal of Municipal Effluents"
(Maryland Water Resources Administration, 1976). Each system was
evaluated by its capability either to dispose of the effluent in an
environmentally acceptable manner without an ultimate surface water
discharge or to provide the equivalent of advanced treatment prior
Relocation of the
Discharge Point
13
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to surface water discharge. Table II-5 compares the typical
effluent quality from conventional, land treatment and advanced
wastewater treatment systems. This table is presented only as a
comparison of the general effectiveness of land treatment systems
to other systems.
Table II-5. Comparison of Effluent Quality for Conventional, Land
Treatment, and Advanced Wastewater Treatment Systems.
Effluent Constituent, mg/1
System BOD SS NII-^-N NO^-N Total H p
Conventional treatment
Aerated lagoon 35 40 10 20 30 8
Activated sludge 20 25 20 10 30 8
Land Treatment
Spray irrigation 1 1 0.5 2.5 3 0.1
Overland flow 5 5 0.5 2.5 3 5
Rapid infiltration 5 1 .... 10 10 2
Advanced wastewater
treatment3
1 12 15 1 29 30 8
2 15 16 .... .... 3 8
3 5 5 20 10 30 0.5
4 5 5 .... .... 3 0.5
aThe advanced wastewater treatment systems are as follows:
1 = biological nitrification
2 = biological nitrification-denitrification
3 = tertiary, two-stage lime coagulation, and filtration
4 = tertiary, two-stage lime coagulation, filtration, and
selective ion exchange
(Sources EPA, et al., 1977b)
Spray Irrigation Slow-rate spray irrigation can produce the best results of all land
treatment systems and does not involve a direct surface discharge.
This treatment system removes a high degree of organics, suspended
solids and nutrients, and produces lower concentrations of all
major residual pollutants than advanced wastewater treatment
methods. The only drawback to this method is the large land re-
quirements for the application sites.
Howard County (n.d.a.) screened most of the county to determine
suitable areas for slow-rate spray irrigation. Only Howard County
was screened for the following reasons; (1) its preference to
treat the LPWQMC wastewater within its own jurisdictional bounda-
ries; (2) the two most feasible sites outside the county, Fort
Meade and the Beltsville Agricultural Center, have requested that
their properties not be considered for wastewater irrigation due to
14
-------
conflicts in present and future land use plans; and (3) the
difficulty in implementing an irrigation system in another county
which could necessitate the condemnation of land (O'Hara, 1982).
Several parcels of land in the central portion of the county have
been identified as potential areas for spray irrigation (Figure
II-2). The soils within these parcels are primarily of the
Glenelg-Chester-Manor soil association, have minimal slopes and are
moderately permeable. These sites were also considered to be
satisfactory in terms of soil texture, depth of soil material,
depth to seasonal high water table, permeability, slope, flood
hazard and erosion hazard. For this evaluation, it will be assumed
that these major sites, totalling approximately 4,230 acres (1,692
hectares), would still be considered suitable following a detailed
hydrogeologic survey.
The application rate (.75 inches per week) and storage requirement
(151 days) used in the Draft EIS were recommended for a study by
Howard County as approved by the State of Maryland (Chicca, 1981)
for preliminary design of large scale spray irrigation systems
within the county. In the study (Guttenplan, 1982), a maximum
loading rate of 1.5 inches per week was calculated, based on the
nitrogen loading of 375 pounds per acre per year and using fescue
as the cover crop. This application rate represents an application
of 150 percent of the 10-year average precipitation. In the study,
this application rate could not be recommended without a
site-specific survey due to the shallow depth-to-bedrock in the
area. Because of the potential for groundwater mounding underneath
the application sites, the 1.5 inch per week loading rate is too
high. For this reason, the rate was halved to .75 inches per week
for planning purposes.
The storage requirement of 151 days was determined using the 5
months from November to March as a nonapplication period. During
this period consumptive water use by plants and evaporation from
the soil surface are minimal. The low soil temperature also
reduces the effectiveness of the wastewater treatment provided by
the soil (Guttenplan, 1982).
Several commentors on the Draft EIS felt that the loading rate and
storage requirement were too conservative but experience ir» the
State of Maryland shows that "projects must be evaluated on a
reasonably conservative basis" (Yu and 2aw-Mon, 1979J. Without any
site-specific information available on the hydrogeologic conditions
at the potential site, this EIS will use the rate and storage
requirement approved for Howard County by the State of Maryland,
The amount of application land needed for treatment of 5 and 15
mgd, at an application rate of 0.75 inches per week, would be about
2,943 acres (1,191 hectares) and 8,828 acres (3,573 hectares),
respectively. These reduced figures have been recalculated since
the Draft EIS. However, State Guidelines (MDWM, 1976) require at
least a 25% reserve to be set aside, which brings the total
acreages of suitable land needed to 3,678 acres (1,488 hectares)
and 11,035 acres (4,466 hectares). Additional land would also be
required for buffer zones and the 151-day holding pond.
When comparing the potential versus the required amounts of
suitable land, it is obvious that there is only sufficient land
available to treat 5 mgd of wastewater. Almost three times the
amount of previously identified suitable land would be required for
the 15 mgd spray irrigation system. For costing purposes in this
evaluation, it will be assumed that smaller parcels of suitable
land could be found in the general vicinity of the larger parcels
15
-------
*0,
°o,
V-
V
*>
%
•4
l=D
O
LEGEND
Quis.de o< Piann>ng Aisa
Porenttji Areas for r** Overiand
Flc»v» L*r>d AppUc*t«cwt Proceu
Poientisl Atm* tor the Slcjw Rate
frngation Land App)toal>C»n Proce^i
Currently Pla^rwtf Service Area
Boundary ,
Scale in Mil«
SOURCE; HOWARD COUNTY, HJDA.
COUNTY
HOWARD
COUNTY
O
6*
r'Kt.
FIGURE 11-2
POTENTIAL AREAS FOR
LAND APPLICATION
CITY *>,
COLUMBIA
fC LARKS V1LLE
c>
_ a* V T -
F<
y
-------
shown in Figure II-2 to allow the treatment of 15 mgd. Several
alternatives using slow rate spray irrigation for both 5 and 15 mgd
have been considered and assigned costs later in this chapter.
P.ar'id Infiltration Groundwater recharge and surface water discharge of recovered (by
underdrains) effluent are two possible methods of rapid infiltra-
tion. Rapid infiltration is very effective in treating secondary
effluent to Lavels equivalent to those using advanced treatment
except for nitrogen removal. The average concentration for total
nitrogen in the effluent after passing through the zone of treat-
ment is 10 mg/1 to 20 mg/1 (EPA et al., 1977b).
To project groundwater for use as drinking water, nitrogen removal
would be necessary prior to application when disposing the effluent
by groundwater recharge. Nitrogen removal would not be required
under current permits for the Patuxent or Patapsco River basins.
Phosphorus removal, however, would be required. Though some
removal of phosphorus occurs within the soil during infiltration,
the average concentration of the recovered effluent is 2.0 mg/1.
This level would have to be reduced to 0.3 mg/1 to meet the
effluent limitations for the Patuxent either before or after land
treatment.
Based on available soil survey report information (U.S. Department
of Agriculture, 1968), most soils around the LPWQMC are unsuitable
for the rapid infiltration treatment process. (A possible excep-
tion is the Rumford loamy sand or the Brandywine loam.) The amount
of land required to treat the effluent for 5 mgd and 15 mgd would
be 107 acres (43 hectares) and 322 acres (129 hectares), respec-
tively, at an application rate of 1.25 feet per week. The amount
of land required and the areal distribution of the possible soils
rule out this treatment option.
Overland Flow Several sites within Howard County have been identified as poten-
tial areas for overland flow wastewater treatment. These sites are
near Brown's Bridge Road in the south-central portion of the county
just north of the Patuxent River. These areas are relatively small
and would not meet the land requirements to treat 15 mgd, but they
are large enough to treat 5 mgd of wastewater as shown in Figure
II-2.
Almost 8 miles (12,6 kilometers) of force main, several pump
stations and a runoff collection system would be required for an
overland flow system. Since the phosphorus concentration in the
effluent would be about 5 mg/1 after overland flow, phosphorus
removal would be necessary prior to discharge into the Patuxent
River (limit of 0.3 mg/1 of phosphorus). The additional cost of
phosphorus removal makes this system impractical in comparison to
the costs of conveying secondary effluent to Deep Run (Alternatives
3A.1 and 3B.1).
Wastewater Flow In 1977 the Maryland legislature passed House Bill No. 44, which
Reduction requires the installation of water conserving plumbing devices in
all newly constructed or remodeled buildings. This bill, which has
been implemented by Howard County, spepifies that the following
water conservation fixtures be installed:
• Automatic flow showerhead. Maximum flow 3.5 gpm.
0 Spring-load sink faucet for a public facility. Maximum 1.0
gpm.
" Sink faucet for private facility. Maximum flow 4.0 gpm.
17
-------
° Water closet. Maximum 3.5 gallons per flush.
° Urinal. Maximum 1.5 gallons per flush.
Howard County has implemented a supplementary water conservation
program. This program, as provided for in the county's plumbing
code, requires:
" Reduction of water pressure to 60 psi in all new building con-
struction.
On-Site Systems
Description
and Cost of
Alternatives
0 Public involvement program.
This water conservation program has been implemented both on the
State and County levels and has reduced water consumption but has
not removed the need for the 5 mgd expansion.
The Soil Conservation Service, in the soil survey for Howard County
(U.S. Department of Agriculture, 1968), reported that 47% of the
county's soils had severe limitations for septic tank drainfields
and 19% had moderate limitations. Numerous failures have been
documented by the Howard County Health Department within the
planned service area.
In a site suitability analysis performed by the county, the results
showed "considerable limitations within the comprehensive service
area for the continued use of either shallow or deep drainfield
systems." Depth to bedrock and seasonal high water table are the
major limiting factors. The Master Plan for Water and Sewage for
Howard County (Howard County, 1980) calls for the more heavily
populated areas within the comprehensive service area to be con-
nected to the existing sewer system. County planning efforts for
future wastewater treatment needs include continual analysis of
feasible on-site treatment alternatives for less densely populated
areas.
This section provides a brief description of each alternative and
their total present worth cost. Please consult Appendix A for a
more detailed breakout of the treatment components and costs re-
quired for the upgrade and expansion. You will notice that six of
the seven alternative costs have changed since the Draft EIS has
been published. The first item involves recosting the alternatives
in response to comments from Howard County (12/8/81). For Alter-
natives 2 through 3.B.2, the contact stabilization units were con-
verted to sludge storage units and 5 mgd more of activated sludge
aeration basins and clarifiers were added. It was felt that this
change incorporated into these alternatives would make them more
comparable to Alternative 1. The commentor expressed the point
that this change was shown in Alternative 1 (in the Draft EIS) and
should also be incorporated into the other alternatives using a
similar process train. The incorporation of this change has in-
creased the cost of Alterntives 2 through 3.B.2. Also, flow equal-
ization was added to Alternative 2.
All of the land application alternatives were evaluated in more
detail for the Final EIS. The specific sites selected by Howard
County were divided into smaller parcels (mainly due to bisecting
roads). The acreages of these parcels were then determined (using
25% for reserve as per state guidelines) and the buffer require-
ments calculated. This resulted in an increase in total acreage
required as compared to just one site (as shown in the Draft EIS).
Also a detailed cost of the equipment and construction cost for the
land application system together with a detailed costing of the
transmission system required was determined. For Alternative 4,
18
-------
the conveyance cost nearly doubled. The reasons for this change is
mainly due to the need for conveying the effluent to several new
sites farther away from the LPWQMC. These new sites required 12
more miles of force mains (see Figure II-3). This detailed analy-
sis also found a need for six pumping stations rather than the two
costed in the Draft EIS.
Two costs that have yet to be determined are any right-of-way
acquisitions necessary for the transmission system to the land
applicatin sites and the relocation of persons displaced by the
acquisition of the land for the spray irrigation alternatives.
Alternative 1 This alternative, as developed and evaluated in earlier studies by
Whitman, Requardt and Associates (Howard County Department of Pub-
lic Works, 1974a, 1974b, 1976, 1977) was selected in 1977 for the
treatment and discharge of the wastewater generated in Howard
County. The alternative involves expanding and upgrading the
present 10 mgd treatment plant to 15 mgd of advanced wastewater
treatment (AWT) along with permanent sludge handling facilities and
a 3.8-mile gravity effluent outfall to discharge below Port Meade's
raw water intake structure.
This alternative adds 7.5 mgd of additional secondary treatment and
an extra 8 mgd of primary clarification capacity. The two 2 mgd
contact stabilization units are converted into a flow equalization
basin, and the other 1 mgd unit is used for sludge storage. The
flow equalization structures help to prevent the bypass of raw
sewage during storm events. Advanced treatment is provided by
biological nitrification (with lime addition for pH control) and
clarification, phosphorus removal by the "Phostrip" system, alum
flocculation, and 15 mgd of filtration. Denitrification facilities
were deleted from the original plan in 1977 due to a change in
effluent limitations for the Little Patuxent River but could be
added in the future if required by the State of Maryland. Disin-
fection of the wastewater is acheived by chlorination. Sulfur
dioxide is then added to reduce the residual chlorine from the
wastewater to a level of 0.5 mg/1 (maximum).
The final step before discharge is reaeration of the effluent to
raise the dissolved oxygen level to at least 6.0 mg/1. The efflu-
ent is then discharged into a 60-inch (152 cm) diameter gravity
outfall, which discharges 3.8 miles downstream of the LPWQMC near
Maryland Route 198, just below the raw water pumping station
serving the Fort Meade Military Reservation. As evaluated here,
the outfall is sized to carry the ultimate plant peak flow as well
as effluent from the General Electric Appliance Park. As now con-
structed, the outfall is not sized for this extra flow. Finally,
new permanent sludge handling facilities are added.
The old units will be used to back up the permanent facilities and
the dewatered sludge will be land spread on local farms. This is
consistent throughout the alternatives.
The total present worth for Alternative 1 is $54,760,000.
Alternative 2 Alternative 2 was developed to eliminate wastewater effluent dis-
charges from the LPWQMC into the Little Patuxent River by pumping
the effluent to the Patapsco Piver basin and discharging into the
Patapsco River, via force main/gravity outfall system, below Elk-
ridge. Although the effluent limitations for a 15 mgd discharge
into the Patapsco River allow for higher concentrations of pollu-
tants (BOD5, ss, P) than would be allowed in the Patuxent River
basin, there would still be a requirements for ammonia removal.
19
-------
FIGURE 11-3
CARROLL
COUNTY
TRANSMISSION SYSTEM
ALIGNMENT FOR LAND
APPLICATION ALTERNATIVES
•• ELUCOTTPi
CITY**-**
COLUMBIA
TRIADcLPnIA
ttesertvom
ClorhsviH#
POTENTIAL SITES FOR SLOW RATE
SPRAY IRRIGATION
LPWuMC
HOLDING POND (AND TREATMENT
PLANT FOR ALT. 3 A.2 & 4)
POCKY GORGE
Savage
TRANSMISSION SYSTEM
Co^ryV>^
\
Seal# m Miles
-------
As evaluated here, the effluent pump station and force main/outfall
system is sized for the ultimate peak flow and effluent from the
General Electric Appliance Park; as now constructed, the outfall is
not sized for this extra flow. The force main will consist of 3.3
miles (5.3 kilometers) of 48-inch (120 cm) diameter pipe followed
by approximately 5 miles (8 kilometers) of 54 inch (137 cm)
diameter gravity outfall. The force main/gravity outfall system
will follow the alignment of the B&O railroad from the treatment
plant to the Patapsco River. Prior to discharge into the Patapsco,
the effluent will enter a mechanically operated post aeration basin
to increase the dissolved oxygen level to at least 5.0 mg/1 and to
release any hydrogen sulfide produced under anaerobic conditions
within the 8.3 mile (13.3 kilometer) outfall system.
Alternative 2 has a present worth value of $60,850,000.
Alternative 3 Alternative 3 has four sub-alternatives, each consisting of 10 mgd
of advanced wastewater treatment (AWT) with discharge of the efflu-
ent through either the existing outfall or an outfall which dis-
charges below the Fort Meade raw water intake structure and 5 mgd
of secondary wastewater treatment with discharge either to Deep Run
or by land application using slow rate spray irrigation. With each
sub-alternative having a 10 mgd AWT at the LPWQMC site and a 5 mgd
of secondary treatment, the differences are:
° Alternative 3A: the 5 mgd secondary treatment plant will be
located at the effluent disposal site
3A.l-plant at Deep Run
3A.2-plant at land application site (treatment by
aerated lagoons).
0 Alternative 3B: the 5 mgd secondary treatment plant will be
located at the LPWQMC site (thus reducing the
need for duplicate facilities) and pumping the
effluent to the disposal site
3B.1-discharge to Deep Run
3B.2-discharge to land application site.
The 10 mgd portion of the flow that will receive advanced treatment
will use the same processes as Alternative 1. The effluent would
be discharged into either the existing outfall or an outfall below
the raw water intake structure for Fort Meade (both are costed).
Alternative 3A.1 will include a new 5 mgd activated sludge treat-
ment plant at Deep Run. Alternative 3A.2 would use an aerated
lagoon system for treatment prior to spray irrigation. A pumping
station located in front of the LPWQMC headworks would divert 5 mgd
of sewage to the new secondary plant via a force main/gravity pipe
system to either of the new plants (see Figures A-4 and A-5). With
Alternative 3B, shown in Figure A-6, 5 mgd of secondary treatment
capacity would be added to the LPWQMC, therefore allowing the pre-
liminary treatment process and sludge handling facilities to be
used by both the secondary and advanced treatment processes. In
this way, both the staffing requirements and treatment plant
operating and maintenance costs can be reduced.
Both sub-alternatives (3A.2 and 3B.2) will use the same land appli-
cation sites located near Clarksville and would require 29.9 miles
(48.1 kilometers) of 8 to 15 inch (20 to 38 centimeter) diameter
force mains to convey the wastewater (Alternative 3A.2) of effluent
(Alternative 3B.2) from the LPWQMC to the application sites (Figure
II-3). These alternatives would require 2,943 acres (1,191
hectares) for the application areas, 736 acres (298 hectares) for
21
-------
reserve and 480 acres (194 hectares) for buffer zones, roads and
the holding pond (the area for the treatment plant for Alternative
3A 2 is minimal). The total acreage required for both these alter-
natives is 4,159 acres (1,683 hectares) or over 6 square miles.
For Alternatives 3A.2 and 3B.2 (as well as Alternative 4 below),
slow-rate irrigation will be accomplished by a series of center
pivot sprinklers applying 0.75 inches per week of effluent. Appli-
cation would be performed 215 days per year. Also, a 151 day stor-
age lagoon would be required and would also be used as a polishing
lagoon for Alternatives 3A.2 and 4.
The present worth values have been estimated as follows:
° 3.A.1: $56,120,000
($53,950,000)*
• 3.A.2s $65,050,000
($62,880,000)*
° 3.B.1: $54,620,000
($52,460,000)*
° 3.B.2: $72,860,000
($70,690,000)*
*The present worth cost without the outfall below the raw
water intake at Fort Meade.
Alternative 4 Alternative 4 was developed to eliminate all surface discharges of
effluent from the LPWQMC by using slow-rate spray irrigation for
disposal of the wastewater. The treatment layout would convert the
existing plant units into partial flow equalization basins, pump
the raw sewage to a new aerated lagoon treatment plant located
south of Clarksville and after treatment, pump the effluent to the
various land application sites. This treatment alternative would
use more land than identified earlier. The transmission system
(from the "old" plant to the application sites) would require 29.9
miles of force mains, ranging in size from 8" (20 cm) to 24" (61
cm) and 7 pump stations. This transmission system is similar to
that shown in Figure II-3.
Alternative 4 would require 8,828 acres (3,573 hectares) for the
application area, 2,207 acres (893 hectares) for reserve, and 1,023
acres (414 hectares) for buffer zones, roads, treatment plant and
the holding pond. The total amount of land to be acquired for this
alternative is 12,058 acres (4,880 hectares) or 18.8 square miles.
The present worth cost for this Alternative is $66,420,000.
Reliability Several commentors expressed concern regarding the efficient and
reliable operation of the plant, especially during storm events.
It should be noted that all structures at the LPWQMC site have a
minimum wall height of 141 feet above mean sea level in order to
prevent possible flooding based on the maximum river height on re-
cord (June 1972). This is above the 100-year floodplain designa-
tion.
All alternative facilities will be provided with the following
maximum reliability features:
° Double ending of primary power supplied to the plant.
22
-------
Hydraulic volumetric design based on peak flow conditions (two
times the design flow).
Back-up units for all pumping blowers, sludge dewatering and
similar mechanical equipment.
Units of multiple design to allow for shutting down during
maintenance.
Flexibility of piping and pumping to allow rerouting flows as
conditions warrant.
Sludge storage facilities.
Back-up disinfection facilities.
Automatic monitoring to regulate and control disinfection and
other operations on the basis of plant flow.
Automatic alarm systems for high water, power failure or
equipment malfunctions.
Elimination of all interceptor bypasses and pipe overflows.
23
-------
Chapter III
Environmental Impacts
of the LPWQMC
-------
CHAPTER III.
ENVIRONMENTAL IMPACTS OF THE LITTLE PATOXENT WATER QUALITY MANAGEMENT CENTER (LPWQMC)
The results of the environmental analysis of the LPWQMC fourth
addition indicate that this project will have no adverse
environmental impact to the Patuxent River. In order to be
responsive to the Court's Order, and to meet the intent of the
National Environmental Policy Act (NEPA), the environmental impact
of the LPWQMC fourth addition was analyzed within the following
four parameters:
1. Water Supply Uses of the Patuxent River.
2. Health Risks.
3. Patuxent River Water Quality.
4. Nutrient Control in the Patuxent River.
Water Supply Uses Surface water movement in the Patuxent River basin occurs in both
of the Patuxent freshwater stream channels and the estuary. Above Hardesty,
River Maryland (see Figure II-l), water movement in the basin is
independent of tidal action (Crooks, et al., 1967). Downstream of
Hardesty, in the estuary, large quantities of water move upstream
and downstream with the tides. Because of the influence of tidal
fluctuations, no analysis was conducted of impacts on raw water
intakes downstream of Hardesty. Upstream, "worst case" conditions
represented by 7-day 10-year low flow conditions were used to
evaluate the ability of the river system to supply raw water to
present users and to meet future needs.
With the exception of the withdrawal made by the Washington
Suburban Sanitary Commission (WSSC) from the T. Howard Ducket and
Triadelphia reservoirs on the Patuxent River mainstem, very little
use is made of the Patuxent River and its tributaries as a source
of raw water for potable use. A listing of intake locations and
volumes within the Patuxent River basin is provided in Table III-l.
All ground and surface water withdrawals in Maryland require a
water appropriation permit from the State. Only individual
domestic users and farmers are exempted from the State water
appropriation permit process.
An examination of the locations and discharge volumes of the
basin's major wastewater treatment facilities (Figure II-l and
Table 111—2) and stream flow, data (Table III-3) indicates that,
with the exception of Fort Meade and the Maryland House of
Correction, the intake requirements of the downstreamn users are
sufficiently small that even during periods of greatly diminished
flow the stream flow will be more than adequate to meet present
and future needs.
Wastewater discharges from the LPWQMC before the relocation of the
outfall, comprised a large portion of the Little Patuxent River
flow at the Fort Meade and House of Correction water intakes,
serving to augment stream flow. With the outfall in this position,
treatment of water from the Fort Meade intake was very difficult.
Future problems with nitrate levels were also of concern. The
diversion project relocated the outfall to a new location down-
stream of the Fort Meade and The House of Correction intake
structures, significantly improving the ability of Fort Meade to
treat its water supply (Clark, 1982). However, the loss of stream
flow augmentation has limited the withdrawal of sufficient raw
water during low flow periods. To supplement water losses from the
25
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Table III-l. Major Water Intakes in the Patuxent River Basin.
Intake Name
Fort Meade
Maryland House of Correction
Crofton Country Club
Contee Sand and Gravel
Maryland and Virginia
Milk Producers
Reliable Asphalt, Inc.
Johns Hopkins Physics Lab
Washington Suburban
Sanitary Commission
Davidsonville Sand and Gravel
Annapolis Sand and Gravel
Reds Dove Sand and Gravel
E. L. Gardner Inc.
Academy of Natural Sciences
Benedict Laboratory,
Academy of Natural Sciences
Pepco
Maryland National Capital
Parks and Planning
Commission Golf Course
Intake Location
Little Patuxent
Dorsey Run/
Little Patuxent
Little Patuxent
Dorsey Run
Hammond Branch
Towsers Branch
Middle Patuxent
Patuxent
Patuxent
Patuxent
Patuxent
Patuxent
Patuxent
Patuxent
Patuxent
Average Maximum
Water Water
Appro- Appro-
priation priation
(mgd) (mgd)
3.5
0.8
0.04
0.006
0.43
0.036
0.095
55.0
0.0864
0.40
0.001
0.36
0.0324
0.012
720.0
6.2
1.2
0.155
0.108
0.43
0.09
0.16
0.129
0.60
0.0048
0.45
0.036
0.048
Lottsford Branch 0.075
0.30
26
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Table III-2. Discharge Volumes of Major Wastewater Treatment
Plants in the Patuxent River Basin.
Wastewater Treatment Plant
Little Patuxent Water Quality
Permitted
Design
Discharge
(mgd)
Average
1980
Discharge
(mgd)
*Estimated
Year
2000
Discharge
(mgd)
Management Center
o
o
7.0
18.3
Maryland House of Correction
0.75
0.80
(Abandoned
Fort Meade
3.6
2.4
3.6
Parkway
7.5
5.1
7.5
Maryland City
0.75
0.59
2.7
Patuxent
4.0
3.6
7.2
Horsepen
1.0
0.33
1.5
Bowie-Belair
2.65
2.5
3.3
Western Branch
15.0
11.9
23.7
45.25
35.12
67.8
*[Source: Maryland Office of Environmental Program, 1981]
27
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Table II1-3. Flow Data for Patuxent
River Gages.
River and Little Patuxent
Patuxent
near
Unity
Drainage Area 34.8
(mi.2)
7-Day 10-Year Low
Flow (cfs) 2.741
Period of Record 1946-80
Lowest Mean Flow
for 7 Consecutive 0.40
Days (cfs) (year) (1967)
Flow Exceeded 95%
of Time (cfs) 6.9
Minimum Daily Flow 0.20
for Period of (9/10-
Record (cfs/date) 12/66)
Patuxent
near
Laurel
132.0
6.492
1946-80
3.70
(1967)
9.2
1.1
(6/26/
56)
Little Little
Patuxent Patuxent Patuxent
at near
Savage Bowie
at
Guilford
38.0
3.783
1933-80
0.73
(1967)
8.4
0
(9/6-
12/66)
98.4
12.060
1941-80
10.0
(1942)
22.0
7.0
(9/19/
43)
348.0
33.7*
1977-80
97.0
100.0
61
(9/14 s
15/77)
Average Discharge
for Period of
Record (cfs) 39.7
42.9
108
*U.S. EPA, 1979a
[Source: U.S. Geological Survey, 1978; U.S. Geological
Survey, 1980]
28
-------
LPWQMC diversion project. Fort Meade is presently in the process of
acquiring permits for the addition of four more wells. Water
treatment officials at Fort Meade find the current situation
preferable to the previous difficulties in treating raw water with
a high percentage effluent (Clark, 1982).
The Maryland House of Correction currently acquires its water
supply from Dorsey Run and a small spring-fed pond. Water is
withdrawn from the Little Patuxent River only when water quality in
Dorsey Run is threatened by accidental contamination or during
extreme drought periods (Immler, 1981). Current water supply needs
at the House of Correction are relatively small (Table III-l), and
negotiations are underway for connection to the Anne Arundel County
water supply system in the spring of 1982. Water from the Little
Patuxent River will then be used by the House of Correction only
for non-potable purposes (Immler, 1981).
Future water supply needs for the seven counties within the
Patuxent River Basin (Howard, Montgomery, Prince George's, Anne
Arundel, Calvert, Charles and St. Mary's) and the means by which
they intend to meet their needs are outlined in each county's most
recently written water and sewage plan. Personal communications
with public works and planning officials from each county have
confirmed their water supply intentions, as presented in the plans,
with the exception of Anne Arundel County. A detailed discussion
of each county's water supply situation can be found in
Appendix B.
In summary, based on an examination of the current and projected
water supply uses of the Patuxent, with the outfall from the LPWQMC
relocated downstream of the Fort Meade intakes, neither expansion
nor removal of the LPWQMC discharge will adversely affect the
ability of downstream users to withdraw sufficient water from the
Little Patuxent and Patuxent Rivers. In terms of flow volume
alone, increased effluent flow from the facility in the future will
augment stream flow, enhancing the ability of downstream users to
withdraw water from the river system.
Health Risks to the The most detailed study of Patuxent River water quality was
Patuxent River from performed during 1977 and 1978 by the Maryland Water Resources
the LPWQMC Administration. The results of fecal coliform tests from 10
stations sampled on 11 days between April and November of 1978 are
presented in Table III-4. These data show that for over half the
days sampled, fecal coliform (PC) concentrations were greater
upstream of the LPWQMC than downstream. In addition, trends in
concentration are not readily discernible. On some days, FC
concentrations are similar at all stations; on other days, one or
several stations may have much greater concentrations than other
stations. Thus, if fecal coliform levels are used as an indication
of the presence of pathogenic bacteria and viruses, these data show
that the LPWQMC should not be considered the major source of
microbiological contamination in the Little Patuxent River.
To gain more insight into health risks associated with the LPWQMC
discharge into the Little Patuxent River, the plant's monthly
operational and analytical reports for 1980 were examined. Daily
fecal coliform (FC) levels in the actual plant effluent were
ordinarily quite low. Table III-5 shows the number of times the
undiluted effluent contravened Maryland's shellfish harvesting
(although shellfishing does not occur for at least 80 miles, or 128
kilometers, downstream) and primary contact recreation standards.
29
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Table III-4. Fecal Coliforms from 11 Stations on the Little Patuxent River Sampled Between April and November
of 1978.
Date Sampled
River
River
Kilometer
Sampling
Station
4/10
5/1
5/8
6/12
6/19
7/10
7/17
8/31
9/25
10/16
11/12
Little
Patuxent
above
Middle
Patuxent
48.36
34.41
Near Rt. 40
Rt. 32 (above
Savage)
150
230
150
230
230
230
1500
230
1500
750
2300
930
750
430
1500
43
230
750
230
230
93
43
DISCHARGE . . ,
Just below
confluence
of Little
and Middle
Patuxent
27.91
Downstream
of Rt. 1
75
43
150
430
93
4
2100
7500
230
93
930
Little
Patuxent
25.85
Brock Br. Rd.
Crossing
3
4
23
9
3
93
39
3
3
4
3
21.30
Below B/W Pkwy.
(near Ft.Meade)
3
3
4
43
93
230
930
21
93
93
4
18.88
Rt. 198
3
4
4
43
43
93
430
430
430
43
11
16.65
New Tank Rd.
3
3
3
23
73
43
7
4300
-
3
9
11.18
Above Wood-
wardville
4
9
21
930
23
14
43
43
-
230
43
4.82
Md. 424
3
9
15
23
23
43
43
43
-
23
7
.35
Just above
Patuxent River
3
9
23
93
230
230
93
43
230
-------
LPWQMC diversion project, Fort Meade is presently in the process of
acquiring permits for the addition of four more wells. Water
treatment officials at Fort Meade find the current situation
preferable to the previous difficulties in treating raw water with
a high percentage effluent (Clark, 1982).
The Maryland House of Correction currently acquires its water
supply from Dorsey Run and a small spring-fed pond. Water is
withdrawn from the Little Patuxent River only when water quality in
Dorsey Run is threatened by accidental contamination or during
extreme drought periods (Immler, 1981). Current water supply needs
at the House of Correction are relatively small (Table III-l), and
negotiations are underway for connection to the Anne Arundel County
water supply system in the spring of 1982. Water from the Little
Patuxent River will then be used by the House of Correction only
for non-potable purposes (Immler, 1981).
Future water supply needs for the seven counties within the
Patuxent River Basin (Howard, Montgomery, Prince George's, Anne
Arundel, Calvert, Charles and St. Mary's) and the means by which
they intend to meet their needs are outlined in each county's most
recently written water and sewage plan. Personal communications
with public works and planning officials from each county have
confirmed their water supply intentions, as presented in the plans,
with the exception of Anne Arundel County. A detailed discussion
of each county's water supply situation can be found in
Appendix B.
In summary, based on an examination of the current and projected
water supply uses of the Patuxent, with the outfall from the LPWQMC
relocated downstream of the Fort Meade intakes, neither expansion
nor removal of the LPWQMC discharge will adversely affect the
ability of downstream users to withdraw sufficient water from the
Little Patuxent and Patuxent Rivers. In terms of flow volume
alone, increased effluent flow from the facility in the future will
augment stream flow, enhancing the ability of downstream users to
withdraw water from the river system.
Health Risks to the The most detailed study of Patuxent River water quality was
Patuxent River from performed during 1977 and 1978 by the Maryland Water Resources
the LPWQMC Administration. The results of fecal coliform tests from 10
stations sampled on 11 days between April and November of 1978 are
presented in Table III-4. These data show that for over half the
days sampled, fecal coliform (FC) concentrations were greater
upstream of the LPWQMC than downstream. In addition, trends in
concentration are not readily discernible. On some days, FC
concentrations are similar at all stations; on other days, one or
several stations may have much greater concentrations than other
stations. Thus, if fecal coliform levels are used as an indication
of the presence of pathogenic bacteria and viruses, these data show
that the LPWQMC should not be considered the major source of
microbiological contamination in the Little Patuxent River.
To gain more insight into health risks associated with the LPWQMC
discharge into the Little Patuxent River, the plant's monthly
operational and analytical reports for 1980 were examined. Daily
fecal coliform (FC) levels in the actual plant effluent were
ordinarily quite low. Table II1-5 shows the number of times the
undiluted effluent contravened Maryland's shellfish harvesting
(although shellfishing does not occur for at least 80 miles, or 128
kilometers, downstream) and primary contact recreation standards.
29
-------
Table III-4. Fecal Coliforms from 11 Stations on the Little Patuxent River Sampled Between April and November
of 1978.
Date Sampled
River
River
Kilometer
Sampling
Station
4/10
5/1
5/8
6/12
6/19
7/10
7/17
8/31
9/25
10/16
ii/i:
Little
Patuxent
above
Middle
Patuxent
48.36
34.41
Near Rt. 40
Rt. 32 (above
Savage)
150
230
150
230
230
230
1500
230
1500
750
2300
930
750
430
1500
43
230
750
230
230
93
43
DISCHARGE . .
Just below
confluence
of Little
and Middle
Patuxent
27.91
Downstream
of Rt. 1
75
43
150
430
93
4
2100
7500
230
93
930
Little
Patuxent
25.85
Brock Br. Rd.
Crossing
3
4
23
9
3
93
39
3
3
4
3
21.30
Below B/W Pkwy.
(near Ft.Meade)
3
3
4
43
93
230
930
21
93
93
4
18.88
Rt. 198
3
4
4
43
43
93
430
430
430
43
11
16.65
New Tank Rd.
3
3
3
23
73
43
7
4300
-
3
9
11.18
Above Wood-
wardville
4
9
21
930
23
14
43
43
-
230
43
4.82
Md. 424
3
9
15
23
23
43
43
43
-
23
7
.35
Just above
Patuxent River
3
9
23
93
230
230
93
43
230
-------
Table III-5.
Fecal Coliform (MPN/100 ml) Contraventions of
Maryland's Water Quality Standards for Water Contact
Recreation and Shellfish Harvesting in the Undiluted
LPWQMC Effluent During 1980.
[Source: LPWQMC Monthly Operational and Analytical
Reports for 1980.]
Month
January
February*
March
April
May
June
July
August
September
October
November
December
No. of
Days
Sampled
N 0
29
31
30
31
N 0
31
31
28
31
31
N 0
Contraventions Contraventions
of Shellfish of Water Contact
Standard Recreation
(14 MPN/100 ml) (200 MPN/100 ml)
DATA
DATA
1
1
9
0
13
2
15
0
12
1
15
2
4
2
8
3
28
14
DATA
*Data are for total coliforms; therefore, 70 MPN/100 ml standard
was used.
Notes Chlorine residual average was usually between 2.0 and 4.0
mg/1.
31
-------
Except for the month of November, few contraventions occurred.
Kerwin (1981) gave the following explanation for elevated fecal
coliform levels in November: one of the old disinfection ponds was
cleaned and the contaminated, accumulated sludge in it was sent
back to the head of the plant for treatment. Kerwin added that the
new disinfection facilities {which include chlorination-
dechlorination) which have been on line since March of 1981 leave
even fewer fecal coliforms in the plant discharge than shown in
1980 data, and the discharge has a zero chlorine residual.
Microbial concentrations would be further reduced with the addition
of a phosphorus removal facility. Primary, mechanical treatment
alone generally reduces pathogenic bacterial numbers as much as 50%
from 107 to ltf5 per 100 ml. Virus reduction is probably
similar. Additional chemical treatment to remove phosphorus
compounds at the LPWQMC will use lime for flocculation. Although
flocculation causes only a small amount of bacteria removal, high
pH accompanying lime treatment assures an efficient disinfection of
most bacteria except for Mycobacteria and Vibrio cholerae (Lund,
1978). Chemical flocculation with sedimentation will remove
parasitic ova and viruses, as well (Mitchell, 1972).
Factors that influence the survival of coliform bacteria include
dissolved nutrients, organic matter, antibiotics, lysis, heavy
metals, competition for nutrients with other bacteria, predation,
algal toxins, degradation of the bacterial cell wall by protozoa,
seasonal variations, temperature, physico-chemical environment,
grazing by zooplankton, adsorption on sediments, salinity and
dilution (Colwell and Kaper, 1977; Faust, et al., 1975). The
phenomenon of bacterial regrowth in receiving waters is not well
documented in the literature. However, bacteria and viruses have
been known to survive for extended periods, particularly if they
have been adsorbed onto organic materials or sediments.
Since there is no opportunity for growth of viruses in sediment,
their continued presence appears to be due to some protective
effect of the sediment. Sediment may act as a reservoir of
pathogens that may be resuspended by any turbulent activity. jn
terms of public health significance, the number of fecal coliforms
and enteroviruses in sediment at a particular location may be ^
better indication of water quality over a long period of time than
the number of bacteria and viruses in the overlying water (LaBelle,
et al., 1980).
Determining the significance of the pathogenic content of the
LPWQMC on the Patuxent estuary is extremely complex. Factors that,
influence pathogenic survival are constantly changing. Survival
time not only varies from species to species, but often from day to
day. A further aggravating factor is the constant potential fot
introduction of bacteria and viruses through disruption of bottom
sediments.
Tables HI-4 and III-5 remain the best sources of risk information.
Data for fecal coliform concentrations in 1980 show that during the
warmer summer months, under proper plant operation, the undiluted
LPWQMC effluent itself was relatively safe for swimming in terms of
the fecal coliforms. Although some pathogens can infect humans
through the skin, most pathogens must be ingested before they
become infective.
Refer to Appendix C for further discussions of waterborne diseases
and microbial contamination in the Patuxent.
32
-------
In summary, very little is known about the microbial communities of
the Patuxent River and estuary. Total and fecal coliforms are the
only microorganisms that have been monitored, and neither is
considered an accurate index to concentrations of pathogenic
organisms in the water. Sewage treatment plants and such non-point
sources as urban and rural runoff are sources of microorganisms in
the Patuxent. Certain pathogens may be more abundant from one
source than from another.
The Maryland Department of Health and Mental Hygiene (1976)
compared the bacterial performance of sewage treatment plants on
the Patuxent River between 1970 and 1976. In 1970 the yearly
average of fecal coliform for all samples of effluents collected
from sewage treatment plants discharging into the Patuxent River
was almost 250 MPN/100 ml. With improvements to sewage treatment
plants over the following six years, the 1976 yearly average of
fecal coliform was about 10 MPN/100 ml in spite of an increase in
the volume of treatment plant discharges.
Thus, expansion of treatment facilities does not necessarily mean
that an increase in viral and bacterial concentrations will follow.
The upgrade at the LPWQMC includes additional treatment processes
and more efficient disinfection, both of which will provide an
extra measure of protection against increased health risks
associated with a larger discharge.
Although available data are not specific or detailed enough to be
conclusive, they do indicate that the present LPWQMC discharge is
not a major source of microbial water quality degradation in the
Patuxent River. The plant upgrade and expansion in itself should
not noticeably alter the microbiology of the river. However,
increased urbanization accommodated by increased treatment capacity
could increase microbial levels in the river during wet weather
periods since urban runoff contains some of the same constituents
as wastewater. The combination of the LPWQMC expansion and
subsequent urbanization could become a major non-point source of
microbial contamination in the basin during storm events.
Patuxent River The Patuxent River is a tributary of Chesapeake Bay. It is about
Mater Quality 110 miles long and is situated between the metropolitan areas of
Washington, D.C. and Baltimore, Maryland. The two major
tributaries to the Patuxent River are the Western Branch and the
Little Patuxent River, which receives LPWQKC's effluent and also
provides drinking water for Fort Meade. The drainage area changes
from about 38 square miles at Guilford, Maryland to 930 square
miles at the mouth.
Saline water from Chesapeake Bay intrudes 35 to 50 miles into the
estuary, depending on the magnitude of the freshwater flow entering
the river and prevailing tide and wind conditions. Mean tidal
range is about 1 to 2 feet, and tidal influence extends as far as
milepoint 55 {Hardesty, MD).
The Patuxent River is a partially stratified estuary. Freshwater
enters the head of the estuary while denser, saline baywater enters
at the mouth of the estuary. On a tidal' average basis, the denser
baywater exhibits a net upstream movement underneath the layer of
freshwater, which exhibits a net downstream movement. An important
aspect of stratification is its reduction of the mixing of surface
layer water (with its higher dissolved oxygen concentration) with
lower layer waters (with significantly lower oxygen levels).
33
-------
« t-hp southern counties borderinq the Patuxent have
Fishery Resources Waterm®"ri concern about the visual signs of deteriorating water
ZtlltTandreduced commercial fish production they feel is the
resilJ of upstream sewage treatment plant discharges. Future
expansion at the LPWQMC is of particular concern to them.
Analyses of diversity's an* TnaTStor" ^s TresulJ
Srthns »SjseB! TtfapAarsVetrhatyfish communities of the fresh-
Patuxent and tributaries in the Piedmont Plateau region and
Tn the estuLine portion of the Patuxent have not changed
^nfficantlv over the past 15 years. The most obvious changes ln
f-lh communities have occurred below sewage treatment plants (With
the exception of Horsepen WTP) and below the city of Columbia and
Triadelphia Reservoir, all located in the coastal plain region.
Trladeipn result of the increased species diversity found below
the6Horsepen Wastewater Treatment Plant, which is a tertiary plant
the Horsep we can impiy that advanced wastewater
practicing dechlorination planned for the LPWQMC upgrade may
treatment plus decniorina below the WTP outfaii (as
evidenced by the improvement below Horsepen WTP) in spite of the
increase capacity.
A more detailed discussion of the data analyzed in this study can
be found in Appendix D.
B further concern of the Patuxent watermen was that the additional
Salinity Hischarqe caused by the LPWQMC expansion would move the salt/fresh-
water interface sufficiently downstream, adversely affecting
Patuxent oysters.
The two extremes at which the LPWQMC expansion can affect the
saline distribution are at high and low freshwater flows. While
the results of studies show that natural high flows over prolonged
periods may cause a significant downstream movement of salt wedge,
the 5 mgd expansion at the LPWQMC will not reduce salinity enough
tn . 9, r>v?ter bars. Four flows were examined. At the
JS £ZeL flo»OfTooera, ti. 5 „gd l.q-1 .to '•'« CPS,
from the LPWQMC would cause the largest decrease in salinity.
However? even during low flow conditions, the salinity would remain
within acceptable levels for oyster survival at all charted oyster
bars. In addition, analyses of available data indicate that
salinity does not appear to be as much a maior factor in oyster
survival or health in the upper Patuxent as does water quality.
See Appendix D.
Mn<-rlent Control in
the patuxent River
nr,th Doint and non-point pollutant loads are important in the
Point and Non-Point ®°tuxent estuarv All roajor point source pollutants, except the
pollutants JSiS™ plant, are upstream from Route 50 briaw.
ana LPWQMC account for«. than 50 percent
the total wastewater flow discharge into the estuary. During
periods of low freshwater flow, the wastewater flows comprise about
?n oercent of the total flow at the Route 50 bridge. Non-point:
pollutan™ .lurces include runoff fro„ Lo^ur.l. »rb„.
residential and undeveloped areas, sediment releases in the
estuary, and Chesapeake Bay water.
SSEt'"bUT&JSwvF
upper Patuxent (above river mile 35) and an upstream expansion of;
34
-------
areas of historically low dissolved oxygen found in the bottom
waters of the lower estuary (especially below river mile 20-25). A
review of historical water quality data indicates that increases in
point source loads are one likely cause of these water quality
problems. At the same time, increasing non-point source loads from
farms, towns and suburban areas also must be considered. Excessive
growth of phytoplankton ultimately adds a significant amount of
organic material to the bottom sediments in the lower estuary. It
appears that any action to reduce the nutrient loads which trigger
the algal overgrowth will reduce the resultant accumulation of
organic detritus on the river bottom.
During the past 17 years, wastewater discharge into the Patuxent
River has increased from 3 to 35 mgd. Although treatment levels
have been upgraded, the total amount of nutrients discharged has
increased since conventional secondary treatment does not provide
efficient nutrient removal. It is believed that nutrient loadings
from point sources have increased 11-fold during the same 17
years.
The Office of Environmental Programs of the Maryland Department of
Health and Mental Hygiene has projected a wastewater flow of 67.8
mgd in the Patuxent River basin by the year 2000. Thus, the point
source nutrient input into the Patuxent estuary would nearly double
by the year 2000 if the present treatment level (secondary) is to
be maintained. Table III-6 shows the existing and projected year
2000 wastewater flow and nutrient loading in the Patuxent River
basin.
Non-point sources are scattered and discharge pollutants into
waterways by dispersed paths. As increased water pollution
abatement programs control point source loads, non-point sources of
pollutants may begin to contribute a larger share of the measurable
pollution loads.
In the Patuxent River Basin, land use is predominantly agricul-
tural, but residential uses are also important, especially in the
Piedmont region. Runoff containing nitrogen, phosphorus, solids
and organic carbon might add a significant pollution load to the
river and its tributaries. At present, however, the magnitude,
source and characteristics of this loading can only be estimated.
The only published data on non-point source pollutants in the
Patuxent River basin were collected by Correll et al., (1978).
They used a statistical approach to apply the Rhode River watershed
land use/non-point source model to the Patuxent River watershed by
measuring the size and land use composition of several sub-basins
of the Patuxent River. The area loading rates used in estimating
non-point source pollutants in the Patuxent River are shown in
Table II1-7.
Future non-point source nutrient loading estimates for the Patuxent
River Basin were developed using the best available population
estimates and most recent forecasts for the seven counties in the
basin. The data conform with sub-basin regions established by the
Maryland Automated Geographic Information System (MAGI) (Figure
III-l and Table III-8). Current population estimates in
conjunction with latest land use data generated by MAGI were then
used to extrapolate year 2000 acreage for various land uses within
each sub-basin (Table III-9).
The Tri-County Council supplied population estimates for the
portions of Calvert, Charles and St. Mary's Counties within the
hydrologic limits of the basin. These estimates and projections
35
-------
1 TTT fi 1980 and projected Year 20CC Wastewater Flows arid
Table Nutrient Loadings in the Patuxent River Basin.
1980
Proiected Year 200O
Facility Name
Plow
(mgd)
Total N
(lb/d)
Total P
(lb/d)
Flow
{mgd)
Total N
(lb/d)
TotaXp-
Ufc>/a>
Maryland City
0.59
90
34
2.7
412
1S7
patuxent
3.6
549
210
7.2
1,099
4 20
Ft. Meade
2.4
366
140
3.6
549
210
lpwqmc
7.9
1,190
455
ia.3
2,793
1,068
Bowie
2.5
381
146
3.3
503
192
Horsepen
0.33
50
19
1.5
229
88
Parkway
5.1
778
298
7.5
1,145
438
W. Branch
11-9
1,190
695
23.7
2,372
988
Md. House of
Correction
0.3
122
47
Aban-
doned)
0
0
35.12
4,716
2,044
67.8
9,102
3,561
Notes
Total N = 12 tag/1 and total P = 5 mg/1 for treatment
plant located below Route SO bridge.
Total N = 18.3 mg/1 and total P = 7 mg/1 for all
treatment plants located above Route 50 bridge.
As of 1982, permit limits for the LPWQMC have become
more stringent than shown above.
36
-------
Table III-7. Average Annual Non-point Source Nutrient
Loading Rates in the Patuxent River Basin
Total Nitrogen Total Phosphorus
Land Use Type
lb/ac/d
(Kg/ha/yr)
lb/ac/d
(Kg/ha/yr)
Low density urbane-
0.0216
(8.94 )
0.0035
(1.45)
High density urban2
0.017
(7.00)
0.0025
(1.04)
Cultivated farmland-*
0.0117
(4.855)
0.0033
(1.381)
Pasture^
0.00338
(1.403)
0.00076
(0.317)
Forest 3
0.0009
(0.0394)
0.00113
(0.470)
Note: •'¦Anderson, et al., 1981
2Northern Virginia Planning District Commission and
Virginia Polytechnical Institute and State University, 1978
3Correll, et al., 1978
37
-------
WARD CO.
LEGEND
PATUXENT RIVER WATERSHED BOUNDARY
• ••••a MAGI SUB-BASIN BOUND ARES
701 MAGI SUB BASIN DESIGNATIONS
. ANNE ARUNDEL CO.
TRWOftPHIA
ftEeenvomf
MONTGOMERY CO.
T. HOWARD DUCKETT
REMRVOtft
i 707
PRINCE GEORGES CO.
I
j-
SCALE IN MILES
3
CHARLES CO.
706 /cALVERT CO.
S
8T. MARYS CO:
FIGURE 111-1
PATUXENT RIVER BASIN AND
MAGI SUB-BASIN REGIONS
(SOURCE: MARYLAND DEPT. OF NATURAL RE8OURCE8. 1978)
38
-------
Table II1-8. Patuxent River Basin Population Projections by Sub-basin Regions
Sub-Basin Area
and Code
Brighton Dam to
Headwaters (701)
Subtotal
Western Branch
Drainage Basin (702)
Subtotal
Little Patuxent
Drainage Basin (703)
Subtotal
Middle Patuxent
Drainage Basin (704)
Subtotal
Briqhton Dam South
to Rocky Gorge Dam
(705)
Subtotal
Jug Bay to the
Chesapeake (706)
Subtotal
County
Howard
Montgomery
Prince George's
Howard
Anne Arundel
Howard
Howard
Montgomery
Anne Arundel
Prince George's
Charles
Calvert
St. Mary's
1980
Population"
2000
5,310
5,110
60,600
65,840
36,260
12,210
1,440
10,860
720
4,150
2,180
18,200
12,530
10,420
60,600
102,100
12,210
12,300
8,790
6,960
127,340
116,010
55,660
42,250
3,740
14,790
1,390
4,910
3,200
35,550
18,020
15,750
127,340
171,670
42,250
18,530
37,780
63,070
Rocky Gorge Dam
South to Rte. 214
(707)
Subtotal
Rte. 214 South to
Jug Bay (708)
Subtotal
Howard 5,100
Princes George's 65,680
Anne Arundel 7,030
Anne Arundel 4,930
Prince George's 9,870
Calvert 770
87,810
15,570
7,790
102,310
9,430
10,310
18,210
1,450
119,530
29,870
BASIN GRAND TOTAL
338,790
588,010
*0riginal estimates for Howard and Anne Arundel Counties have been adjusted to the
preliminary 1980 census population count. Estimates for other counties are in line with
1980 census figures.
39
-------
Table III-9. Patuxent River Basin
Land Use Distribution Projections by Sub-Basins
Brighton Dam to
Headwaters (701)
Western Branch
(702)
Little Patuxent
(703)
Middle Patuxent
(704)
1978
1980
2000
1978
1980
2000
1978
1980
2000
1978
1980
2000
POPULATION
10420
15750
60600
127340
102100
171670
12210
42250
LAND USE BY ACRES
Developed Land
High density urban
(.048)
Low density urban
(.144)
459
756
2268
3305
7875
6112
18337
4223
16250
8240
24720
92
1652
2028
6084
Subtotal
459
3024
11180
24449
20473
32960
1744
8112
Vacant Developable
Land
Cultivated
Pasture
Forest
34976
2387
11291
33132
2261
10696
22216
2753
33527
17186
2262
25779
14688
6057
24327
10753
4236
17596
20196
3305
10649
16392
2778
8612
Subtotal
48654
46089
58496
45227
45072
32585
34150
27782
Undevelopable Land
Wetlands
918
918
918
918
TOTAL
49113
49113
70594
70594
66463
66463
35894
35894
Assumptions: 1. There is a direct correlation between population and land use development.
2. All of the vacant developable land in a sub-basin has an equal chance of being developed.
3. By the year 2000, all developed land uses will be equally distributed throughout the basin
according to population, and the basic character of the area will not change.
-------
Table III-9 (cont.) Patuxent River Basin
Land Use Distribution Projections by Sub-Basins
Brighton Dam to
Rocky Gorqe (705)
Jug Bay
to Chesapeake
(706)
Rocky Gorge to
Rt. 214 (707)
Rt. 214
Jug Bay
to
(708)
1978
1980
2000
1978
1980
2000
1978
1980
2000
1978
1980
2000
POPULATION
12300
18530
37780
63070
87810
119530
15570
29870
LAND USE BY ACRES
Developed Land
High density urban
(.048)
Low density urban
(.144)
1377
1836
1377*
2668
184
14688
3027
14688*
6426
3947
6426*
17212
367
1193
1434
4301
Subtotal
3213
4045
14872
17715
10373
23638
1560
5735
Vacant Developable
Land
Cultivated
Pasture
Forest
18360
1836
12485
17835
1592
12422
55034
1515
132100
54211
1486
130109
8905
1836
20930
5154
1104
12148
30019
1285
30295
28138
1149
28137
Subtotal
32681
31849
188649
185806
31671
18406
61599
57424
Undevelopable Land
Wetlands
6426
6426
5416
5416
3580
3580
TOTAL
35894
35894
209947
209947
47460
47460
66739
66739
* In these instances when the multiplier yielded a decrease in developed acres, it was assumed that the land
uses remained constant.
-------
Table III-9 (cont.) Patuxent River Basin
Land Use Distribution Projections by Sub-Basins
Basin Total
1978
1980
2000
POPULATION
LAND USE BY ACRES
Developed Land
High density urban
(.048)
Low density urban
<.144)
Subtotal
Vacant Developable
Land
Cultivated
Pasture
Forest
Subtotal
Undevelopable Land
Wetlands
TOTAL
338790 588010
15974
47900
63874
204394
20974
275604
500972
17258
582104
29400
90278
119678
182801
16868
245499
445168
17258
582104
-------
were based on the historic growth trend of each county, as
reflected in their Comprehensive Water and Sewerage plans, and are
reported by the Tri-County Council to be reasonably accurate
(Etzler, 1981). The estimates have been submitted to the state for
review and final approval and are subject to possible minor
revision (Etzler, 1981). Virtually all of the tri-county area lies
within one of the major MAGI sub-basin regions delineated by MAGI.
The Baltimore Regional 208 Plan {January, 1980) provided
demographic data for Howard and Anne Arundel Counties. The
compilation of county-wide population data by water quality
districts eased the task of computing population totals by basin
and then MAGI sub-basin areas. For water quality districts divided
by a MAGI sub-basin boundary, sub-basin estimates were made by
dividing the population of a water quality district on the basis of
land area. Each county government was contacted to gauge the
reliability or accuracy of current figures; these were found to be
slightly overestimated (Landine and Charshee, 1981). Comparison of
the estimated 1980 total county population figures with 1980 census
figures showed this to be the case. The 1980 estimated and the
projected year 2000 figures therefore were scaled down in
proportion to the 1980 over-projection to give a rough, but more
accurate reflection of existing and future populations. New
estimates based on the 1980 census are still being developed and
will not be available for some time (Charshee, 1981).
Population estimates and projections for the portion of Montgomery
County within the hydrologic limits of the Patuxent River basin
came from the Maryland National Capital Parks and Planning
Commission (MNCPPC). These estimates were generated in late 1979
and early 1980. They were based on intermediate growth and are in
line with the growth trend of the county. The Commission considers
them to be very reliable and accurate (Hnat, 1981). The portion of
Montgomery County within the basin is subdivided into two MAGI
sub-basin regions. Population estimates Cor each sub-basin region
were approximated by proportionately dividing the figures within
the basin on the basis of land area.
Population figures by major drainage areas for Prince George's
County were used to approximate the subtotals within the basin and
the MAGI sub-basins. These data came from the Comprehensive Ten
Year Water and Sewerage Plan for Prince George's County (Prince
George's County, 1979). Since the estimated 1980 county totals,
based on intermediate growth, are in line with the 1980 U.S. Census
figures, the projected year 2000 figures are considered reasonably
reliable and accurate. Population projections based on the 1980
census will not be available for several years and are not
anticipated to deviate significantly from current estimates
(McLean, 1981). Portions of major drainage area populations were
broken out proportionately on the basis of land area in order to
approximate population totals within MAGI sub-basin areas.
Non-point pollutant loadings were calculated by multiplying area
loading rates by the estimated area of each land use. Since
freshwater upstream is regulated by discharge from Rocky Gorge Dam,
it is likely that contribution of non-point source pollutant
loadings from sub-basins above Rocky Gorge Dam are proportional to
discharge from Rocky Gorge Dam. The calculated non-point source
pollutant loadings from surface runoff are shown in Table 111-10.
43
-------
Table 111-10. Calculated Annual Average Non-Point Pollutant
Loadings from Surface Runoff Alone.
1978
2000
Relationship of
Nutrients to Algal
Productivity
Sub-basin
(MAGI Basin No.)
Little Patuxent (703)
Middle Patuxent (704)
W. Branch (702)
R. Gorge Dam
to Rt. 214 (707)
Rt. 214 to Jug Bay (708)
Jug Bay to
Chesapeake Bay (706)
Above Gorge Dam
TOTAL
Total Total Total Total
Nitrogen Phosphorus Nitrogen Phosphoru.«
627
285
543
546
622
151
88
152
108
160
1,182
833
376
732
776
696
1,282
701
166
92
167
128
165
392
203
4,470 1,274
5,396 1,313
Table III-ll summarizes annual average point source and non-point.
source pollutant loads as they relate to the present treatment
level and different nutrient control strategies. This table show
that without nutrient control, the point source loadings of nit*-QS
gen and phosphorus will increase by 93 percent and 74 percent, re ~
pectively, by the year 2000. Corresponding increases of surfac~
runoff non-point source loadings of nitrogen and phosphorus will kT
21 percent and 3 percent, respectively, over the same period, j
addition, existing point sources now contribute greater pollutant
loadings than surface runoff non-point sources. As a result
control of point source pollutants will be more effective and tech*
nically feasible now than semi-controllable surface runoff non
point pollutants and uncontrollable groundwater non-point soure
pollutants abatement. e
In all aquatic systems, nutrients are important raw material f0
basic biological activity. Estuaries, being open-ended and subjecT
to tidal flushing, are dependent on a continuous import of nutri
ents to maintain their productivity. When there is an oversuppt"*
of nutrients, however, this biological activity can be altered
resulting in changes to the ecosystem.
Nutrient loading is a relative state in which either low or hi
nutrient levels can produce undesirable conditions; high leve?
(Stimulate eutrophication while low levels limit productivit^®
Eutrophication is the normal environmental aging process of a baa*
of water. Early signs of accelerated eutrophication are exceasi^
growth of phytoplankton and/or vascular plants as well as a reduo
tion in species variety. The optimum nutrient load is a mid-lev«7
in which the estuary reaches stability in both productivity
species diversity. This optimum loading will vary with ?
estuary due to its natural assimilative capacity.
44
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Table III-ll. Comparison of Annual Average Point and Non-point Source Pollutants with Different Treatment
Levels.
Year 1980 flow with
1980 treatment level
Year 2000 flow with
1980 treatment level
Year 2000 flow with
1.0 mg/1 P
Year 2000 flow with
3 mg/1 N
Total Nitrogen (lbs/day)
Non-point Source
Point Surface Ground-
Source Runoff water*
4,726
9,102
9,102
1,696
4,470
5,396
5,396
5,396
5,611
5,611
5,611
5,611
Total
14,807
20,109
20,109
12,703
Total Phosphorus (lbs/day)
Non-point Source
Point Surface Ground-
Source Runoff water* Total
2,048
3,561
565
3,561
1,274
1,313
1,313
1,313
498
498
498
498
3,820
5,37 2
2,376
5,372
•Sources HydroQual, Inc., 1981
-------
The most visible symptom of increased nutrients is the often cited
"bloom" of certain types of algae. This usually results from the
rapid growth of a few species capable of readily using the incoming
nutrients and leads to the competitive exclusion of other species
present under normal conditions. When these imbalances among tjje
primary producers occur, the entire food chain may also be altered
and the secondary production prized by man, such as fish, may be
decreased.
Algal blooms also tnay led to more subtle changes in the ecosyst^^^
Decomposition of the dying and sinking bloom organisms results in
low oxygen conditions. This is true especially in areas of slow
flashing and stratification and can lead to fish kills and destruc-
tion of bottom dwellers. Some algae prominent in blooms are not
eaten by the fish and may clog their gills.
Nutrients enter rivers both through point sources such as waste-,
water plant discharges and non-point sources such as runoff from
cities and farms. In the coastal zone most nutrients
oriqinate within the basin and are transported toward the ocean
with river flow. However, in some estuarine zones, it is possible
for nutrients to be transported up river by flood tides? therefore,
an estuary cannot be considered immune to a nutrient source located
downstream.
The flushing of nutrients from an estuary is based on the volume
and flow rate of the water source as well as the topography of the
water basin. If the freshwater source is large, the water will
move quickly and nutrients will not have enough time to exert their
effects. If the freshwater flow rate is slow, the flushing acti0n
is reduced and the nutrients have note time to exert their influ-
ence. For this reason, estuaries differ greatly in their toler-
ances of nutrient loading.
Estuarine waters are a mixture of sea and fresh water. Seawat^r
contains large amounts of various salts, such as potassium arid
sodium, as well as trace elements that often limit photosynthesis.
Nitrogen and phosphorus that are low in concentration in both
and fresh water have been shown to control the growth of plants in
estuaries.
nitrogen represents the most abundant element (by weight} present
in plant tissues and, along with phosphorus, is one of the tv»o
generally considered to be limiting in aquatic production. Clark
(1974) reports that in coastal waters the amount of available
nitrate is the nutrient factor that controls the abundance
plants. The major unnatural sources of nitrogen in an estuary
include municipal and industrial wastes, fertilizers from agricul-
tural and forest practices, and urban runoff.
Phosphorus exists in many forms. The slightly soluble inorganic
phosphorus of the earth's crust is an unlimited reservoir that
slowly leaches into aquatic systems through the weathering of rocj^.
These soluble orthophosphates are quickly assimilated by plants an«3
transformed into particulate organic phosphorus. Ryther »r*d
Dunstan (1971) suggested that since phosphate is normally present
in concentrations twice that of nitrogen in the coastal marine
environment, phosphorus must not be a limiting factor. In combing
tion with nitrogen, however, phosphorus can cause signifies
changes (Redfield, et al. , 1963). Samples of water enriched wlth
phosphate alone show no more growth than in control whU%
nitrogen-enriched cultures have shown 10-fold growth (Ryther an^
Dunstan, 1971).
46
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EPA water quality criteria (U.S. Environmental Protection Agency,
1973) 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 EPA standards regarding nutrient
loading for "maximum acceptable concentrations" of nitrogen, phos-
phorus or their compounds.
In the upstream portions of the Patuxent River nitrogen and phos-
phorus concentrations are high. It is likely that factors other
than nutrients contribute to regulate phytoplankton growth. In the
lower estuary the ambient concentration of nitrogen is rather low
and during warm periods, phosphorus is typically more abundant than
nitrogen relative to the needs of growing phytoplankton. This sug-
gests that nitrogen is likely regulating growth of phytoplankton in
the lower estuary.
Cold weather data from 1970 show that total dissolved inorganic
nitrogen, when plotted against salinity, has a linear relationship
that indicates a simple dilution effect (Figure III-2). During
warm periods a rapid decrease in nitrogen occurs, indicating the
estuary is serving as a sink for this nutrient, which is being
utilized by phytoplankton and other biological activity. The total
dissolved phosphorus data reveal a similar cold weather pattern or
dilution, but the curve is relatively flat during the summer indi-
cating the estuary is not acting as a sink. The slightly higher
down-estuary values indicate that the Chesapeake Bay may be a sig-
nificant source of phosphorus to at at least the lower Patuxent
estuary.
Figure III-2 provides cold and warm weather data on the atomic
ratio of total dissolved inorganic nitrogen to total dissolved
phosphorus (N/P) for the tidal Patuxent. The shaded region sum-
marizes a threshold range suggested by the literature as to whether
nitrogen or phosphorus is the key nutrient depending on ratio
values above (phosphorus limiting) or below (nitrogen limiting) the
10-16 value. The chart shows that nitrogen is likely the limiting
nutrient during warm weather while phosphorus could become the
limiting nutrient during cold weather.
Field data collected by the Maryland Water Resources Administration
in 1978, plotted as atomic N/P against salinity (Figure 111—3),
show an interesting pattern. At any salinity, the value of atomic
N/P decreases as temperatures increase indicating biological utili-
zation of nitrogen in warm periods. This also may be caused by
phosphorus release from sediment and phosphorus import from bay
water during warm periods. The consistent low atomic N/P values (7
or less) and low ambient concentration of biologically available
nitrogen, again, indicate that nitrogen is likely the limiting
nutrient in the tidal estuary during warm periods.
Predicted Water
Quality Impacts and
the Effects of
Nutrient Control
An evaluation of the water quality response of the Patuxent River
to various waste loading conditions was accomplished using a two-
layer, steady state water quality model developed by HydroQual,
Inc. The HydroQual Model was calibrated using three sets of water
quality data collected by the Maryland Water Resources Administra-
tion during 1978, which represents a range of freshwater flow and
temperature conditions. This model is based on the principle of
mass conservation and incorporates nine state variables: chloro-
phyll "a", organic nitrogen, ammonia nitrogen, nitrite nitrogen,
nitrate nitrogen, organic phosphorus, orthophophate, carbonaceous
biochemical oxygen demand and dissolved oxygen. However, due to
the steady state nature of the model as well as various uncertain-
ties concerning some of the water quality interactions, it becomes
more an indicator than a predicter of water quality in the lower
47
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3 0-3-r
2 6
8ALINITY (PPT)
10
14
O
X
a.~*
S O
>,3
0.2 +
0.1 +
/#\
/ \ e/ro
2 6
8ALINITY
-------
7/78
10/78
5/78
6/78
8/78
8/78
6 8
SALINITY (PPT)
X7/78
6/78
10/78
SALINITY (PPT)
6/78
u
5
O
, 8/78
iKf~-10/78
7/78
8/78
» * — 8/78
NJ* UPTAKE
RATIO
6 8
SALINITY (PPT)
FIGURE III-3 TOTAL DI830LVED INORGANIC NITROGEN AND PHOSPHORUS
AND NITROGEN:PH08PHORU8 RATIO VS. SALINITY IN THE
PATUXENT RIVER (MARYLAND WRA. 1978)
49
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estuary. Nevertheless, the model does provide considerable insight
into the important water quality mechanisms affecting water qualitv
Like other water quality models, the Patuxent River model consists
of a transport component, which incorporates the Patuxent River
hydrodynamics, and kinetic component, which simulates the biologi-
cal, chemical and physical processes within the ecosystem. The
model makes allowance for the river's physical circulation
patterns, nutrient loads from both point and non-point sources and
tidal transport of nutrient from the Chespeake Bay.
The report generated by this modeling effort (HydroQual, Inc.,
1981) indicates the following:
o Under present loading conditions, non-point source nitrog^^
loads account for approximately 70% of the total nitrogen load
to the Patuxent River, whereas non-point source phosphorus
represents about 40% of the total phosphorus load.
° The upstream peak chlorophyll "a" level and high dissolved
oxygen concentrations are due primarily to the conversion of
point and non-point source nutrient loads to algal cell biomass
in the upper section of the river.
° Downstream chlorophyll "a" levels and low bottom layer dissolved
oxygen levels result from exchange with Chesapeake Bay watet,
release of nutrients from the sediment and sediment oxygen
demand.
o present wastewater flows (36 mgd) without nutrient removal win
result in upstream peak chlorophyll "a" levels of more than loo
ug/l with approximately 10 miles of river exceeding 80 ug/^
during the summer low flow period. Reducing the wastewater
effluent nitrogen concentration to 3.0 mg/1 will decrease peafc
chlorophyll "a" levels to 70 ug/l and also decrease chlorophyn
"a" levels in the middle estuary. An effluent phosphorus con-
centration of 0.3 mg/1 reduces upstream peak chlorophyll
levels to about 65 ug/l and also reduces chlorophyll "a" in the
middle estuary.
° projected year 2000 wastewater flows (68 mgd) without nutrient
removal will result in a chlorophyll "a" peak of about 90 ug/j_
with levels which exceed 80 ug/l over about 20 miles of rivet.
Reducing the effluent nitrogen concentration to 3 mg/1
reduce peak chlorophyll "a" levels to 75 ug/l. Reducing the
effluent phosphorus concentration to 0.3 mg/1 will reduce pe^fc
chlorophyll "a" levels to 45 ug/l.
in order to evaluate the specific water quality impact of the
LPWQMC discharge, HydroQual performed additional model runs on the
river. These runs indicate the following:
0 The revised present and predicted year 2000 non-point polluti0n
loadings do not show any significant change in water quality
compared to those predicted by using HydroQual*s constant non-.
point pollutant loadings. Figure III-4.
• Modelinq results indicate that, at projected year 2000 waste,
water flows, assuming 0.3 mg/1 P effluent limitations at ai^
treatment plants including the LPWQMC, the addition of 3.0 mg/;i
N effluent limitations at the LPWQMC will result in no addi„
tional water quality benefits. Figures III 5 and III-6.
50
-------
With Hydroqual's Nonpoint Pollutant Loads
120
100
80
o>
60
a
•TOP
40
X
u
BOTTOM
50
60
30
20
0
10
MILES ABOVE DRUM POINT
With ESEI's Nonpoint Pollutant Loads
120
100
80
60
o
20
v
30
50
MILES ABOVE DRUM POINT
20
60
40
FIGURE III—.4 COMPARISON OF ESTIMATED NONPOINT POLLUTANTS FROM
DIFFERENT SOURCES ON THE PREDICTED WATER QUALITY
(PRESENT FLOW WITH PRESENT TREATMENT LEVEL)
51
-------
LPWQMC 10 mgd with 0.3 mg/1 P, Others: Year 2000 Maximum Flows with 0.3 mg/1 p
izo
100
80
60'
o
I
u
40
20
20
50 <".0
MILES ABOVE DRUM POINT
GO
I
TOP
cn
r
Q
BOTTOM
60 '10 50 20 IO
MILES ABOVE DRUM POINT
LPWQMC 10 ,,d with 0.3 „/! P «- 3 «,g/l N. Others. Year MM H.x1„Flow
120
•01—
100
c/>
60
o
_J
X
o
40
20
30
0
20
50
MILES ABOVE DRUM POINT
40
60
60
50 40
MILES ABOVE DRUM POINT
20
FIGURE III-5 THE EFFECT OF NITROGEN REMOVAL AT LPWQMC (10 MGD) ALONE ON
THE PREDICTED WATER QUALITY WITH EFFLUENT LIMITATIONS OF
0.3 MG/L P APPLIED TO ALL TREATMENT PLANTS
52
-------
LPWQMC: 18.3 mgd with 0.3 mg/1 P, Others: Year 2000 Maximum Flow with 0.3 mg/1 P
10 —
TOP
O
o
BOTTOM
20
60
50
MILES ABOVE DRUM POINT
30
120 —
100 —
80
60
o
X
o
40
20
40
30
50
MILES ABOVE DRUM POINT
20
60
120
100
60
o 60
LPWQMC: 18.3 mgd with 0.3 mg/1 P and 3 mg/1 N, Others: Year 2000 Maximum Flow
121 with 0.3 mg/1 P
_i
x
o
40
20
10
o» e
O
a
50 40 30 20 10
MILES ABOVE DRUM POINT
I I I I » I I I I I
60 50 40 30 20 10
MILES ABOVE DRUM POINT
FIGURE 111-0. THE EFFECT OF NITROGEN REMOVAL AT LPWQMC (18.3 MGD)
ALONE ON THE PREDICTED WATER QUALITY WITH EFFLUENT
LIMITATIONS OF 0.3 MG/L P APPLIED TO ALL TREATMENT PLANTS
53
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° The effect of 0.3 mg/1 of P effluent limitations on the Patuxent
water quality is significant. For example, tor projected year
2000 wastewater flow, the peak chlorophyll "a concentration win
be reduced to 45 ug/1 and the stretch of estuary affected wo.li
be shortened. Figure III-7.
In summary, phosphorus control is projected to significantly reduce
rhloroDhvll "a" levels in the upper estuary. In addition, a
decrease in algal biomass in the upper estuary is postulated to
reduce nutrient transport, deposition and enrichment in the lower
pst-uarv. While an equivalent technological level of nitrog
-------
Year 2000 Maximum Flows with Present Treatment Level
— ioo —
E
O
d
50 40 30 20 10
MILES ABOVE DRUM POINT
BOTTOM
50 40 30 20 iO
MILES ABOVE DRUM POINT
120 —
IOO
en 80
jt
* o 60
_J
5 40
20
0
Year 2000 Maximum Flows with Effluent Limitations of 0.3 mg/1 P
12 —
10
cr 8
E
o 6
d
' I I I ' I I I I l
50 40 30 20 10
MILES ABOVE DRUM POINT
v- N
L.
60
I I I I I I I I I I
50 40 30 20 10
MILES ABOVE DRUM POINT
FIGURE III-7. THE EFFECT OF EFFLUENT LIMITATION OF 0.3 MQ/L P ON THE PREDICTED
WATER QUALITY
55
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CHAPTER IV
Public and Agency
Comments on Draft EIS
-------
CHAPTER IV.
PUBLIC AND AGENCY COMMENTS ON DRAFT EIS
The Regional Administrator of the Environmental Protection Agency
(EPA) signed a notice of Intent to prepare an Environmental Impact
Statement (EIS) on the fourth addition to the Little Patuxent Water
Quality Management Center (LPWQMC) in October 1980. A public
meeting was held on December 18, 1980 to present EPA's proposed
scope of the EIS. In February 1981, a responsive summary was dis-
tributed to all interested parties to address oral and written com-
ments received by EPA on the project up to that date.
A Draft EIS was completed and widely distributed to Federal, State
and local agencies as well as numerous citizens and interest groups
on October 23, 1981. Copies of this document are available for
review at local libraries and municipal offices.
A public hearing to receive testimony on the Draft EIS was con-
ducted by EPA at the George Howard Building on December 8, 1981.
Written comments on the Draft EIS were also received by EPA during
a public comment period that commenced with the distribution of the
document and ended on December 21, 1981.
EPA considered comments concerning the Draft EIS beneficial in
assisting the Agency to refine its analysis of the upgrade and
expansion of the Savage Plant. Therefore, this Chapter includes a
transcript of the pubic 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.
57
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DEPARTMENT OF HEALTH AND HUMAN SERVICES
REGION III
3535 MARKET STREET
PHILADELPHIA. PENNSYLVANIA 19101
December 4, 1981
PUBLIC HEALTH SERVICE
MAILING ADDRESS
P.O. BOX 13716
PHILADELPHIA
PENNSYLVANIA 19101
Ms. Rochelle Volin
Project Monitor
Environmental Protection Agency
6th and Walnut Streets
Philadelphia, PA. 19106
Re: Draft Environmental Impact Statement for
Little Patuxent Water Quality
Management Center,
Howard County, Maryland
Dear Ms. Volin:
Thank you for the opportunity to review referenced DEIS. We are responding
on behalf of the Public Health Service and have the following comments for
your consideration in preparing the Final EIS.
1.
Although this is an after the fact review, we recommend that discussion!
regarding the management and operation of the plant be included, I /"TN
particularly the monitoring techniques, and measures to insure the I
best quality of effluent.
2.
3.
Can it be understood that the disposal of the sludge in local farms
does not represent a problem? Are these farms outside the Little
Patuxent River's basin?
The Final EIS should clarify the increase of 5 MGPD in the expansion
and upgrading of the Savage Plant. Is it due only to the upgrading
of the plant or is it because of an expanded influent?
4. Are there any hazardous waste dump sites in the study area? I©
Please provide us with a copy of the Final EIS.
Sincerely,
|©
I®
,'H. McDonald Rimple, M.D.
Assistant Surgeon General
Regional Health Administrator
cc: Vernon N. Houk, M.D.
Calvin Watkins, ROFEC
59
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TRI-COUNTY COUNCIL for SOUTHERN MARYLAND
Southern Maryland Working Together for a Better Future
P.O. BOX 301 WALDORF. MARYLAND 20601 (301)645-2693
JAMES C. SIMPSON, Chairman
GARY V. HODGE, Executive Director
December 18, 1981
Ms. Mary Sarno
EIS Preparation Section
U. S. EPA
Reg i on ill
6th and Walnut Street
Philadelphia, Pennsylvania 19106
Dear Ms. Sarno:
Enclosed is a final copy of our comments on the Draft Environmental Impact
Statement for the Little Patuxent Water Quality Management Center. Please
note that these comments differ somewhat from our December 8 testimony on
the DEIS in that we have provided more detail in our criticisms. We would
be very happy to talk with you or your staff about any of the comments we
have made. Please advise us on what your next step will be in this EIS
process. If we can be of any assistance or if you have any questions
concerning our comments, please let us know.
GVH:hf
Enclosure
61
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TRI-COUNTY COUNCIL for SOUTHERN MARYLAND
Southern Maryland Working Together for a Better Future
P.O. BOX 301 WALDORF. MARYLAND 20601 (301)645-2693
JAMES C SIMPSON, Chairman GARY V. HODGE, Executive Director
COMMENTS OF
THE TRI-COUNTY COUNCIL FOR SOUTHERN MARYLAND
(on behalf of the Boards of County Commissioners of
Calvert, Charles, and St. Mary's Counties, Maryland)
ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
ON THE LITTLE PATUXENT WATER QUALITY MANAGEMENT CENTER
(EPA, Oct. 1931)
62
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As the draft environmental impact statement (DEIS) correctly states, this
document has been prepared in response to a court order, as the result of
litigation initiated by the Board of County Commissioners of Calvert, Charles,
and St. Mary's Counties, Maryland. DEIS at 3- The court agreed with these
counties that the proposed expansion of the Little Patuxent Water Quality
Management Center (Savage Plant) might have significant impacts on the quality
of the human environment, and that therefore a "detailed statement" on those
impacts was required by the National Environmental Policy Act (NEPA), k2 U.S.C.
§if332 (2) (c).
Thus, as we are directly responsible for the preparation of this document
in the first place, we are extremely interested in ensuring that it is done
properly. In addition to our obvious interest in EPA's full compliance with
the law, this EIS is the first opportunity to address the issues involved in
the several new permits which will soon be proposed for the sewage treatment
plants on the Patuxent River. This EIS should therefore accurately describe
the cumulative impacts of higher loadings of nutrients on the Patuxent River,
given the present state of knowledge. As we describe in detail below, this
draft EIS not only fails to describe these cumulative effects, but it fails
to accurately state the impacts of and alternatives to the expansion of the
Savage Plant itself.
The following comments on the Draft Environmental Impact Statement (DEIS)
for the Little Patuxent Water Quality Management Center (LPWQMC) deal with
three particular areas in which the DEIS is woefully inadequate. Those
areas are development and cost comparisons of alternatives, the water quality
impacts of the expansion and the impacts on commercial fisheries.
63
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I. Inadequate Analysis of Reasonable Alternatives
The discussion of alternatives has been held to be the "linchpin" of the
entire NEPA process. Monroe County Conservation Council v. Volpe, k~l2 F.2d 693,
697-98 (2d Cir. 1972). Despite the fact that NEPA requires that all "reasonable"
alternatives be examined, the DEIS fails to address the alternative of both
overland flow and rapid infiltration, which would result in acceptable reductions
of both nitrogen and phosphorus while using substantially less land than slow
rate spray irrigation. To document these and other inadequacies of the analysis
of alternatives, each alternative is stated below and comments are provided on
each.
Alternative 1 is the present facility, as constructed, which we feel is
inappropriate considering the other alternatives.
Alternative 2 was a proposal to divert the effluent from the LPWQMC, as
constructed, into the Patapsco River instead of the Patuxent. Because our
concern is not just for a clean Patuxent but instead to solve a Bay-wide problem
we could not support this proposal.
Alternative 3 includes four sub-alternatives. Two of the sub-alternatives
proposed the discharge of 5 mgd of effluent into Deep Run, a tributary of the
Patapsco. Once again we cannot support these sub-alternatives for the same
reasons given for alternative 2. The other two sub-alternatives dealt with
10 mgd of conventional treatment and 5 mgd of land application. Both of these
sub-alternatives had great potential but were rendered uneconomical in the
DEIS by faulty cost analysis.
For instance, the proposal called for only .75 inches per week to be
applied to the land, which is unrealistic and greatly increases the land area
required for treatment. The State of Maryland (DHMH) recommends a range of
application rate from 0.5 to 2.0 inches per week based on hydrologic capacity
of soil and the concentration of nitrogen in the groundwater'. We question
64
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whether the State was requested to analyze the proposed areas and recommend
an application rate. This application rate would necessitate 709 acres for
each 1 mgd.
The USEPA states that the average land area required for land application
2
is 300-400 acres per mgd using spray irrigation . Charles County in Southern
Maryland until recently had a spray irrigation land application site that was
"5
processing approximately 1 mgd on 150 acres . We would suggest that 709 per
1 mgd is excessive and unrealistic. Costs were also determined based on
conventional secondary treatment before land application. Conventional secondary
treatment is not necessary before land application and its inclusion in the cost
analysis increased costs for the land application sub-alternatives by approximately
$10,000,000 for each sub-alternative. EPA has stated that "a universal minimum
of secondary treatment for direct surface discharge... will not be accepted
because it is inconsistent with the basic concepts of land treatment."
PRM 79~3 (November 15, 1978), at 6 (now contained in FRP-20). The State of
Maryland does require secondary treatment before land application, but this
pretreatment can be performed by the 151 day holding pond, budgeted into the
alternatives, rather than an extremely expensive conventional treatment plant.
The pretreatment must only meet the requirements of 30 parts BOD and 90 parts
suspended solids, which can be achieved by a lagoon system^.
In addition, the costs of the land application sub-alternatives included
a $2,000,000 cost for a outfall pipe for discharge below Fort Meade water intake,
even though with the land application alternative this outfall pipe may not
be necessary, because no additional effluent would be discharged into the
Patuxent. Before the LPWQMC expansion, the plant was processing 8.5 mgd with
apparently no significant impact on the Fort Meade water supply. If the
additional flow was treated by land application, there should be no increased
impact on Fort Meade's water supply and therefore this additional cost should
not have been included Into the costs for these alternatives.
65
-------
Alternative k was a proposal to have no conventional treatment at all,
but instead require all 15 mgd to be applied to the land. We feel this was
a possible alternative that was once again determined to be infeasible due
to faulty reasoning in the DEIS.
For instance, the DEIS places the same unrealistic requirements of .75 inche
per week application rate and conventional secondary treatment, which both
greatly increase costs and land requirement. The DEIS states that this alternati
was not seriously considered because there was not enough suitable land in
Howard County. That is not unexpected considering the unrealistic land require-
ments placed on land application. In addition, the potential sites for land
application were identified by Howard County officials,not EPA who prepared
the DEIS. We don't question Howard County's integrity but we do question
their ability to give an unbiased appraisal of available land application sites.
While EPA may consider Howard County's position, EPA is legally responsible
for fully exploring possible land for land application.
In addition to comments on the proposed alternatives, we would also like
to comment on two other considerations mentioned in the DEIS. We realize that
Howard County has a Wastewater Flow Reduction Plan, however the County should
look further than merely the requirements of the Maryland House Bill and
pursue an aggressive strategy of water conservation. This is important not
only to reduce wastewater flows but also to assure adequate water supplies to
a county which depends completely upon neighboring jursidictions for public
potable water supply.
We also feel that considerable pressure for additional sewage treatment
plant (STP) needs could be relieved by consideration of on-site wastewater
treatment systems (septic tanks or small land treatment facilities) beyond
and even within the comprehensive service area of the Savage Plant. This will
be cost effective in the long run as stricter limitations are placed on effluent
discharge into the Patuxent River in the future.
66
-------
To summarize our comments on the development and cost comparisons of
alternatives, we feel that land area for land application was overestimated,
that potential land application sites were not reviewed by an objective agency,
that costs were inflated by unrealistic land requirements, conventional
secondary treatments requirements and unnecessary discharge pipe requirements
and that considerations of water conservation and on-site disposal should be
examined more closely.
1 I. Water Quality Impacts - Failure to Adequately Address the Impacts of the
Act i on
A. Public Health
We are in general agreement with the DEIS that under normal operating
conditions the LPWQMC will not be a hazard to public health or result in closure
of oyster bars because of high fecal coliform counts. However, we are concerned
with the effect of storms on direct discharge of raw sewage into the Patuxent
if the LPWQMC becomes overloaded. We note that no facilities were constructed,
such as holding ponds, to prevent a bypass of the LPWQMC during overflow
conditions. A storm of significant magnitude could force closure of downstream
oyster bars. The DEIS states "the LPWQMC expansions and resultant urbanization
could become a major source of microbial contamination in the estuary during
storm events." This problem actually occured in 1972 during Hurricane Agnes and
again in September of 1979 during Hurricane David. Although the discharge of
raw sewage in 1979 lasted only 1.5 days, the damage is still being felt in the
lower Patuxent^. It is interesting to note that these storm events occur
primarily in the winter, which corresponds with maximum oyster harvest and
could lead to economic impacts for southern counties if oyster bars are closed
for health reasons.
67
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B. Water Quality
The primary strength, and at the same time, the primary weakness of the
DEIS is its discussion of the role of point and non-point source nutrients to
the water quality of the Patuxent River. The discussion of limiting nutrients
in the OEIS is extremely ambiguous. The DEIS quotes many scientific papers that
point to nitrogen as limiting in most estuaries and then makes several statements
that nitrogen Is limiting in the lower Patuxent based on the nitrogen concentrati
in the River and the nitrogen to phosphorus ratio (p. 68). Then the DEIS makes th
statement that "the tidal Patuxent was nitrogen limited during warm periods.
However, this does not rule out the possibility of reversing to phosphorus
limiting conditions If phosphorus input to the Patuxent is reduced to a great
extent"(p. 68). This airounts to admitting that nitrogen is limiting, then
stating that STP will implement a phosphorus control strategy in spite of that
fact. The DEIS then proceeds to prop up the phosphorus control strategy by the
use of the Hydroqual Water Quality Model, which many qualified scientists view
5
as not applicable to the lower River .
The DEIS then evaluates the specific water quality impacts of the Savage .
expansion on the Patuxent River. We find fault with this for two reasons. I
One is that the analysis of Impacts of the Savage expansion on the Patuxent I
River was done using model runs of the hydroqual Model, which we believe is 1
flawed In Its capability to predict water quality in the lower River5. Secondly.!
, , mprelv to evaluate the incremental Impact due to the I
the model runs were done merely cva.u ¦
Savage expansion. It may be true that the Savage expansion alone will not have I
a major impact on the Patuxent River water quality, however we are concerned I
with cumulative impacts. There could be ten EIS's for ten STP's that all state I
that the incremental impacts on water quality are slight, but we are concerned I
with the combined Impact of the effluent from all ten STP's on the Patuxent I
River. The Patuxent River could be nickeled and dimed to death with Incremental I
impacts. tQ
-------
The regulations implementing NEPA are clear that an EIS must evaluate the
"cumulative" impacts of a proposed action hO C.F.R. S1508.8(a). These
"cumulative" impacts are defined as "the incremental impact of the action when
added to other past, present, and reasonably foreseeable future actions..."
AO C.F.R. SI508.7. In addition, the regulations defining the "scope" of an
EIS state that a statement should examine actions which "have similarities
that provide a basis for evaluating their environmental consequences together..."
kO C.F.R. SI 508.25(a) (3) -
The similar actions which have a cumulative impact are obvious - EPA and
Maryland are currently developing a strategy to deal with the overloading of
nutrients in the Patuxent River, from numerous sewage treatment plants. While
the DEIS does address these cumulative impacts occasionally, it does not discuss
the total impact of the various alternative strategies on the River; i.e., whether
limitations on nitrogen at all plants would improve water quality.
The DEIS should recognize that a major shift has occurred in Maryland's
approach to the Patuxent. Whereas the State has historically supported a strategy
of limiting phosphorus, and the Hydroqual model commissioned by EPA and the
State recommended that approach, the State has now agreed with the lower counties
that it is necessary to also limit nitrogen, as it appears to be the critical
nutrient in the lower estuary. At an intensive three-day meeting on these issues
(December 2-b), the State, EPA, the affected counties, and the scientific
community agreed that:
(a) the Hydroqual model is designed to predict affects of nutrient
loading on the upper Patuxent, and not the lower estuary;
(b) nitrogen, rather than phosphorus, is the limiting nutrient in the
lower estuary;
(c) the declining water quality in the lower Patuxent would be more
likely to be improved by limitations on nitrogen, rather than
phosphorus.
A complete copy of the findings reached at the meeting is attached as an appendix
to these comments.
69
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The implications of these new developments to this DEIS are two fold.
First, the technical discussion of the DEIS should be corrected to accurately
state the effects of nitrogen loadings in the Patuxent. Second, the analysis
of alternatives should be redrafted to consider whether the effluent from the
Savage Plant should be limited in nitrogen, to correspond with the new State
nutrient strategy.
As stated earlier, the nutrient discussion contained in the DEIS is also
commendable in parts. For the first time, EPA has done a basin-wide projection
of non-point source loadings of nitrogen and phosphorus. However, large parts
of the calculations depend on two studies of non-point source flows outside
the basin (Table lll-ll). Can these studies be relied upon to predict behavior
in the Patuxent basin? Are the geological and geographic features similar?
How will these projections be altered if the State suceeds in its new policy
of limiting non-point source contributions of nutrients? (See Appendix A.)
III. Commercial Fisheries Impacts - Inadequate Analysis of Impacts
A. Oysters
The DEIS does little justice to the problems that the oyster fishery
now faces. Most of the discussion of the Impacts of the Savage expansion on
oysters is concerned with changes In salinity in the Patuxent due to the
discharge of the Savage plant. However, the main problem is not reduced
salinity but instead poor water quality, specifically low dissolved oxygen in
the bottom waters.
There has been virtually no spat fall In the Patuxent River since
]969- Figure 1 shows the spat in all three sections of the River since 1939^
and the increase in STP flow since 1962^. A good case can be made for a possible
causal relationship between STP flow and absence of spat set, especially if
g
you consider the results of the 1980 oyster spat survey . The I98O survey
70
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FIGURE 1
COMPARISON OF OYSTER SPAT SET
AND SEWAGE TREATMENT PLANT FLOWS ON PATUXENT RIVER
OYSTER SPAT SET
PATUXENT RIVER
UPPER
MIDDLE
Oyster spat fall on natural cultch in the Patuxent River, 1939 to 1979-
1 I
1962 64 66 68 70 72 74 76 78 80
Sewage Treatment Plant Flow (mgd) into the Patuxent River, 1962 to 1980.
71
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shows very poor to completely absent spat fall in the Patuxent River, although
the Bay experienced a spat set as high as the three highest spatfalls recorded
since 1930 and the spat set at the mouth of the Patuxent was very high (21Vbushe 1 )
The 1980 spat survey states "some natural or perhaps man-induced factors may have
influenced spat settlement in (the Patuxent), since the salinity in these waters
(8-1^ parts per thousand) was more than adequate for the development of larvae as
well as the settlement and good survival of spat."
As the DEIS states, there has been relatively consistent annual oyster
harvest in the Patuxent since 1971- Oyster harvest, however, is not a good
indication of river condition because since 1971. growth in oyster harvests have
been due to an extensive seed oyster and shell planting program conducted by the
State of Maryland. Even with shell and seed oyster planting efforts, the Patuxent
oyster beds are in trouble. Figure 2 shows the condition and location of major
oyster beds in the Patuxent River in 1979- Note the absence of spat and small
oysters from oyster beds upstream from Broomes Island, as well as the comments of
heavy mussel growth and blackened shell, which are indicators of low levels of
dissolved oxygen. Some of the upstream oyster bars are totally dead and others
are below population levels for profitable economic harvest. The DEIS even states
that "several bars closed by the health department are dying of old age, and
oysters in deep water above the present patent tong line are also dying before
they enter the harvest. Several upstream oyster bars, especially above Broomes Isl-^
1 «nd
suffer from water quality problems." However, after this statement, the DEIS
drops the topic of water quality impacts and addresses itself to salinity
impacts, without discussing a solution to the problem.
The decline in oyster production in the Patuxent not only effects the
livelihood of watermen and the local economy but it threatens a way of life.
We feel these potential impacts deserve more discussion in the DEIS.
(§
72
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I
2
3
5
6
7
8
Q
10
11
12
FIGURE 2
CONDITION OF MAJOR OYSTER BARS
PATUXENT RIVER, 1979
%
of Oysters
Ma rket
Smal 1
Shel 1
Teagues
0
0
100
Holland Point
12
0
83
Buzzard Island
1 1
0
88
Thomas
10
0
85
Jack's Bay
55
0
40
Gatton (deep)
6
0
92
Gatton (shoal)
20
0
70
Broomes Island
h0
3
52
Hellen ' s Bar
15
1
83
Hungerford Hollow
35
1
63
Back of 1s1 and
20
2
76
Hog Island
20
3
76
§
Spat Notes
0 A11 dead
0 Recessive growth
0 Only one-half with gonads
0 Mussels heavy and dying
0 Mussels heavy
0 Shell black & buried
0 Mussels heavy and dying
0 Oysters poor w/recent
0 mortali ty
0 Only good bar in river
0
2/bushel
RELATIVE LOCATION OF OYSTER BARS
LOWER
MARLBORO
BENEDICT
CHESAPEAKE
BAY
:—13.
Taken from: Krantz, George E. and Donald W. Webster. 1980. Maryland
Oyster Spat Survey Fall 1979- Maryland Sea Grant Program
UM-SG-TS-80-01.
73
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B. Finfish
We agree with the DEIS that finfish landings information clearly cannot
be used alone to assess the health of the Lower Patuxent, even though the DEIS
does admit that annual harvests for almost all species were generally higher prior
to I960 than the present. We do, however, question the use of fish diversity
as an indicator of River quality. Fish diversity is merely an index of the
number of species of fish relative to the total number of fish. It does not
take into account the loss or decline of important fish species, such as striped
bass, and the replacement of these with less desirable fish species. In pollution
stressed systems, pollution intolerant fish often decrease in number or disappear,
while pollution tolerant fish increase in numbers and take over the habitat of
the fish that are declining. So in effect, while a river may contain the same
number of fish and species of fish as before, the majority will be "trash fish"
and not the "commercial fish" desired.
Finfish all over the Chesapeake Bay are undergoing change, wi th fish
that spawn in the Bay or its tributaries, such as American shad, hickory shad
and striped bass, declining in abundance, while fish that spawn at sea, such
as atlantic manhaden, bluefish, sea trout and flounder, are increasing substantially
The reasons for this appear to be that fish are much more sensitive to poor water
quality in their first few weeks of life (larval stages) than the juvenile or
adult stages. Therefore, fish that are spawned in the tributaries, where water
quality may be poor, will suffer, while fish spawned at sea will be in the juvenile
stage by the time they migrate from sea to the Bay tributaries. Although trends
in the decline of finfish in the Patuxent parallels the decline of finfish in the
rest of the Bay, it may be that poor water quality throughout the Bay is the cause
of this decline and therefore it does not relieve us of the responsibility to
stop this trend by first cleaning up the Patuxent River.
74
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FOOTNOTES
'personal communication, Pete Tinsely, Office of Environmental Programs,
Department of Health and Mental Hygiene.
2
Personal communication, Bob Bastian, Municipal Technology Branch,
U.S. EPA.
^Personal communication, Paul Corn, St. Charles Development, Charles
County, Maryland.
William T. Engel, Environmental Assessment/Water Quality Analyses,
Calvert County, Final Report, Charles County Community College, 1981 .
^Letter to Bill Eichbaum, Assistant Secretary for Environmental Programs,
DHMH, from Chris D'Elia, Chairman, Patuxent River Commission Technical Advisory
Group, February 6, 1981.
^George E. Krantz and Donald W. Webster, October 1979, Maryland Oyster
Spat Survey Fall 1979, Technical Report, Maryland Sea Grant Program.
^Donald J. O'Conner, Thomas W. Gallagher and James A. Hallden,1981 ,
Water Quality Analysis of the Patuxent River, U.S. EPA and Maryland DHMH, Office
of Environmental Programs.
^Harold E. David, Donald W. Webster and George E. Krantz, 1980, Maryland
Oyster Spat Survey, Fall 198O, Technical Report, Maryland Sea Grant Program.
^Coast and Bay Bylines, October 1981, Tidal Fisheries Issue, Maryland
Coastal Zone Management Publication.
75
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GEORGE F NEIMEYER
DIRECTOR
992 2400
Deaf Teletype Number
461 1111
DEPARTMENT of PUBLIC WORKS of HOWARD COUNTY
3430 COURT HOUSE ORIVE. ELUCOTT CITY. MARYLAND 21043
Bureau of Engineering
Wlllum E Ril«y. ChMf
Bureau of Environmental Services
JamM M Irvln ChMri
Bureau of Facilities
John Stnytr. Chief
Bureau of Highway*
GrtnvHIc W Chi«f
Bureau of Inspections. Licenses, and Permits
M Robert CH>«f
Bureau of Utilities
AolMn M Bfirtgm, Chi#/
December 8, 1981
Ms. Mary Sarno
Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Sarno:
Subject: Draft EIS
Little Patuxent Water
Quality Management Center
Public Hearing Testimony
Attached please find a written copy of Howard County's oral testimony
as presented at the public hearing on December 8, 1981. Should you or your
consultant ESEI, wish to discuss our comments further, please feel free to
contact me.
Very truly yours,
• Barnes n. irvin, Chief
Bureau of Environmental Services
JMI/mcc
Attachment
cc: File
77
WASTE-NOT RECYCLE
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GEORGE F NEIMEYER
PIRlllOR
992 2400
Deaf Teletype Number
461 1111
DEPARTMENT of PUBLIC WORKS of HOWARD COUNTY
3430 COURT HOUSE DRIVE, ELLICOTT CITY, MARYLAND 21043
Bura»u of En0ine«rino
. Cht«l
Bur»8u °' Environmental Services
jmmtm ** rvin cnul
Bur»au F»cilitie»
John ftoy*.. Ch,^
8ur"au °'
Gf«nvill« W VY,hl.«l Ch>«<
BurB»u of Inspection*. Licenses, and Permits
M Roban G«n>mill, Chml
Bur»»u Utilitiee
DRAFT ENVIRONMENTAL IMPACT STATEMENT
LITTLE PATUXENT WATER QUALITY MANAGEMENT CENTER
PUBLIC HEARING TESTIMONY, DECEMBER 8, .1981
Howard County has reviewed the draft Environmental Impact Statement tor
the Little Patuxent Wastewater Treatment Plant and concludes that the report
supports the decision to construct the Fourth Addition as planned. Accordinqlv
we generally support the EIS as dratted. The EIS provides a basis lor conclu-
ding that the Fourth Addition will not have an adverse environmental impact
on the Patuxent River and upholds the negative declaration tor the construc-
tion grant that was issued by EPA.
This report, coupled with the recent major study of the Patuxent River
performed by HydroQual, indicates that the Howard County Facility is both
a cost effective and environmentally sound alternative which provides waste-
water * * —j"1-1"1 "istent with scientific proposal- ~-f+-i-~
adverse water quality impacts.
We request that EPA promptly finalize this EIS so that Howard County may
proceed with the preparation of plans required to meet future wastewater
treatment needs. Specifically, completion of our 201 Facilities pian is re-
quired to insure orderly growth within the County.
Our review of the draft document resulted in the preparation of numerous
detailed comments which are attached to this testimony for yOUr consideration
Of particular interest was the evaluation of the land treatment alternative.
It is our understanding that the costs given in the Executive summary and on
Page 30 for Alternatives 3A2, 3B2, and 4 are incorrect. The correct cost
estimates appear on Pages 34, 36, and 37. Of particular note, for Alternative
4, the correct estimated cost is $67,730,000 rather than $56,300,000.
The EIS states that land areas required tor treatment 0f five and fifteen
mgd would equal 3,540 acres and 8,923 acres, respectively, not including
buffer zones and a 151-day holding pond. It must be noted that buffer zone
requirements can be quite extensive. Based on State guidelines requiring a
minimum of a 500 foot buffer zone surrounding a land treatment site, acreage
would be increased by between ten and twenty percent. In addition, acreage
must be acquired for equipment storage and maintenance facilities, offices,
access roads, and possibly for crop storage. Due to the irregular shape
of available parcels of land it is often necessary to purchase more property
than is actually required tor the treatment system and buffer area. Assuming
a 15 foot depth for the 151-day holding pond, acreage requirements could
vary from 160 to 460 acres. Therefore, we feel that land costs have been
significantly understated and should be increased to reflect these considera-
tions.
WASTE-NOT (TSW RECYCLE
-------
DRAFT ENVIRONMENTAL IMPACT STATEMENT (CON'T)
LITTLE PATUXENT WATER QUALITY MANAGEMENT CENTER
PUBLIC HEARING TESTIMONY, DECEMBER 8, 1981
It appears that the design life tor the land treatment alternative was
assumed equal to the 20 year discounting period. It is suggested that this
alternative be re-evaluated using a design lite which would be compatible
with the allowable loading rate for the site under consideration. It the
site life proved to be less than 20 years, then a significant capital cost
increase would be realized in providing for a new site within the 20 year
planning period. Likewise, if the site life is greater than 20 years some
salvage value would be realized. The property utilized tor a landspreading
site would be acquired by the County and thus would no longer generate
revenues through the payment of property taxes. For the large amount of
acreage involved, this cost to the County is significant and should be
considered in the cost analysis.
This concludes my oral testimony. Thank you.
79
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December 8, 1981
COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT -
LITTLE PATUXENT WATER QUALITY MANAGEMENT CENTER
The Howard County Government has reviewed the above referenced report and
the following comments are provided.
1. page 1, first paragraph - The E1S states that "expansion of the
existing service area is currently being planned...", toward
County is not planning to expand the existing service area
beyond the current limits of the metropolitan district. Portions 0,7
of the County which are not within the current district boundary
are generally zoned for three-acre development which could not
be served economically with a central wastewater collection and
treatment system.
2. Page 1, third paragraph - bssci ->n recent population data,
the present population of Howard County is estimated at approx-
imately 126,500. Seventy-two percent of the population lives in
the Patuxent sewage service area, and seventy-one percent of the
population in the service area is currently served.
3. Page 10,- Estimated Effluent Limitations for the Patuxent River Basin.
The limits stated are different than our current discharge permit.
The differences are:
a. TKN - This parameter is expressed as U.O.D. = 20 (monthly average)
= 1.5 (BOD) + 4.6 (TKN)
b. Tbtal Residual Chlorine = 0.02 mg/1
c. Dissolved Oxygen =6.0 mg/1 (minimum)
80
-------
Comments on Draft EIS December 8, 1981
Page 2
4. Page 15, fourth paragraph - The EIS states that land areas re-
quired for treatment of five and fifteen mgd would equal 3,540
acres and 8,923 acres, respectively, not including buffer zones
and a 151-day holding pond. It must be noted that buffer zone
requirements can be quite extensive. Based on State guidelines
requiring a minimum of a 500 foot buffer zone surrounding a
land treatment site, acreage would be increased by between ten
and twenty percent. In addition, acreage must be acquired for
equipment storage and maintenance facilities, offices, access
roads, and possibly for crop storage. Due to the irregular
shape of available parcels of land it is often necessary to
purchase more property than is actually required for the treat-
ment system and buffer area. Assuming a 15 toot depth for
the 151-day holding pond, acreage requirements could vary from
160 to 460 acres. Therefore, we feel that land costs have been
significantly understated and should be increased to reflect
these considerations.
5. Page 18, fourth paragraph - It is indicated that a discharge into
the Patapsco River would require denitrification of a discharge
of more than 5 mgd. However, while Patapsco discharge limitations
do establish a TKN limit, there is no requirement for nitrogen
removal. This should be reflected in the text and any cost analyses
that were performed under this assumption.
6. Page 20, second paragraph - It is indicated throughout the EIS that
vacuum filters are used for sludge dewatering. Although vacuum
filters were used as a temporary sludge dewatering method prior to
completion of the Fourth Addition, dewatering is now accomplished
using belt filter presses.
7. Page 20, last paragraph - The D.O. reference should be changed to|(5?\
6.0 mg/1. I—^
8. Page 22, second paragraph - While it is mentioned that alternative
tw is similar to alternative one, there is no mention made of the
need for flow equalization facilities for alternative two. It
appears that the contact stabilization units which were in service
prior to construction of the Fourth Addition were assumed to re-
main in service in lieu of providing flow equalization and sludge
storage, lb make cost comparisons between alternative one and
alternative two equitable, flow equalization and sludge storage
should be included in each alternative. Use of an activated
sludge system for secondary treatment of fifteen mgd should be
included in both alternatives.
81
-------
Comments on Draft EIS December 8, 1981
Page 3
13.
14.
15.
9. Page 29, item no. 8 - For the purpose of cost analysis the life of
treatment plant processes was assumed to be 35 years. It is noted
that while the life of structural improvements, such as tanks,
would probably be in excess of 35 years, the life cycle for
mechanical equipment, such as pumps, would be considerably less
than this assumption. Cost analyses should be performed considering
a life cycle for equipment of not greater than 15 years.
10. Page 39, third paragraph - A statement is made that the 7-day, 10-
year low flow of 7.75 mgd at the Savage gauge in combination with
8.08 mgd from the Little Patuxent Plant would provide 16 mgd at
the Fort Meade water intake. It should be noted at this point
in the report that the treated wastewater flow from the Savage
Plant would be diverted below the Fort Meade water intake.
11. Page 57, second paragraph - We question the statement that dissolved
oxygen levels in the bottom waters of the lower estuary have declined |/"r\
as there is evidence that, historically, lower estuary D.O levels have |\f7)
been consistently low (See Figure 9 - HydroQual Report, August, 1981)
12. Paqe 57, fourth paragraph - The estimate of 67.8 mgd (Referenced to
1 ¦ 1 i 1 .1 r 1 r , i - ~ —
Table 111-10) does not include the flows of the smaller plants on
the river. Additionally, this number and Table III-2 do not agree
1®
Page 58, table III-10 - We question the basis for the nutrient
loadings in this table. The nutrient loads for the Little Patuxent
Water Quality Management Center phosphorus release are way above
permit limitations. The loading given is apparently based on
secondary treatment.
Since the Little Patuxent Water Quality Management Center has
phosphorus removal facilities, the computation of nutrient loadings
based on secondary treatment is erroneous.
Page 86, fourth paragraph - This analysis of fish catch does not
compare to the entire bay and could have a significant correlation
with the results of the bay-wide problems.
Page 103, last paragraph - It is indicated that for the Fourth
Addition the design of the biological nitrification process may be
inadequate to meet an effluent limitation of 3 mg/1 TKN during
the period between March 1 and November 30. The basis for this
determination are several generalized removal percentages which
were presumably taken from EPA documents. It is felt that an
analysis of the nitrification process cannot be based on this
type of data. Nitrification processes involve the complex
| (25)
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Comments on Draft EIS
December 8, 1981
Page 4
15. (Con't) - interaction of several factors. Wiile it is true that
the hydraulic detention time (3.3 hours) under design flow con-
ditions) is less than the State established design standard of
five hours, this is not necessarily the determining factor in
whether or not the nitrification process will meet effluent
standards. Other important factors to consider are solids
detention time in the clarification units and wastewater tempera-
ture. It should be indicated that the determination presented in
the EIS is a gross approximation at best and that a detailed
kinetic evaluation must be performed to determine the actual
operating characteristics of the nitrification units. Such an
evaluation is, in fact, being performed as part of the 201
Facilities Planning Process.
JMI/mcc
Attachment
cc: File
83
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ES B COULTER
SECRETARY
STATE OF MARYLAND
DEPARTMENT Or NATURAL RESOUPCZS
TIDEWATER ADMINISTRATION
TAWCS STATE OFFICE BUILDING
ANNAPOLIS 214 01
TIDAL FISHERIES DIVISION
MEMORANDUM
TO: Sa^/ah Taylor, Director, Coastal Resources Division
FROM:
LOU;S N. PHIPPS. JR.
oi»uxysccrctarv
(301) 269-3558
I*. It fat
Jensen, Director, Tidal Fisheries Division
SUBJECT: DEIS] "Little Patuxent Water Quality Management Center (LPtfQMC)
(£>a\rage Plant), Howard County, Maryland"
The optimism conveyed in this DEIS is undue and not well founded In
regard to the present and future health of the Patuxent aquatic ecosystem.
In view of the ambiguous and limited datat the section on Aquatic Biota
Impacts is unrealistically optimistic and does not integrate all aspects of
the total impact assessment. Analysis of fish data does not support the
optimistic finding of insignificant impact. Insufficient recognition is given
to the incremental contribution of LPWQMC to future water quality particularly
as regards induced growth and subsequent increased nonpoint source pollution.
Inconsistant statements are made regarding the feasibility of land application
because of soil types. Analysis of effects of diverting effluent to the
Patapsco is insufficient.
General Comment - It is made clear in the Executive Summary and elsewhere in
the document that, although all the DEIS preparation steps as required by
NEPA and the CEQ Regulations for Implementing the Procedural Provisions of
NEPA, including the consideration of alternatives, are performed, in reality
ve are dealing with an "after the fact" environmental analysis. The DEIS and
IEIS are being prepared In response to a court order; this order did not
enjoin construction nor operation of the proposed project, which is now virtu-
ally complete. This being the case, it could be argued that comments are
superfluous and irrelevant.
As brought out in our Detailed Comments below, however, the LPi'QMC
Plant even with its large treatment capacity of 15 mgd will not meet the
advanced waste treatment needs projected for the year 2000 in the DEIS.
Comments on the adequacy of the LPWQMC environmental impact analysis as well
as the consideration of alternatives may therefore serve a purpose in the
context of future development in Patuxent River Basin ecosystem.
Detailed Comments - Since many of our interests and concerns are touched upon
several times at various points in the DEIS, we believe it will facilitate
our commenting to organize the comments by the items we consider most important
rather than attempting to follow the strict order and sequence of the DEIS itself.
85
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2
1 Present and future wastewater flows - This is a- critical question
to terms of analyzing water quality impacts and effects on fish and
aquatic life as has already been alluded to in tne t^neral Comment"
above. Table£EI-2 estimates a wastewater discharge _of 96.1 mgd from
treatment plants in the Patuxent Basin by 2000. This would appear to be
a sizeable discrepancy which is not explained. Using the lower fig-
ure of 67.8 mgd and subtracting the existing wastewater flows of 35.02
mgd (Table 111-10) plus the projected additional treatment capacity of
7.2 mgd at LPWQMC with the expansion currently being constructed, leaves
a"future treatment need for 25.58 mgd for the Patuxent Basin by 2000.
This is roughly the equivalent of two aore advanced waste treatment .
plants of the capacity of LPWQMC. We recognize that current realities
of the planning and construction of LPWQMC require that it be accepted
as a "given", but more recognition should be given in the DEIS to the
incremental nature of the contribution LPWQMC is making to the total
future water quality problem in the Patuxent Basin. This contribution
Is small compared to no treatment at all, as the DBTS mal.es clear.
Nevertheless, it is also clear that analysis of alternatives to LPWQMC-
type plants in the future will have to receive extreuely serious consi-
deration in contrast to the hypothetical treatment they get in this
document. •
7. Land application - Table II-4 clearly demonstrates the superiority
Cf this alternative over conventional treatnent and even advanced treat-^.
ment in vater quality improvement terms. It possesses many advantages
from the standpoint of fish and aquatic life, particularly if most of
the cleansed water returns to the stream ecosystem through an ultimate
groundwater route. We note the statement at the bottom of page
that "No single parcel is large enough to treat 15 mgd, but there would
be enough land if effluent were applied to four of these areas." Never-
theless, it is concluded on page 11-18 that "Land application of 15 mgd
is not feasible in Howard County due to the lack of adequate soils."
The statements are inconsistent. Hopefully when this alternative is
reexamined in the search for additional treatment capacity needs projecte,
in the DEIS this alternative will not be rejected so summarily. In this
connection, we note in the discussion of Alternate 4 (total disposal by
land treatment using slow-rate spray disposal) only irrigation of crop-
land or grassland is considered. More thorough analysis of this alter-
native could look into the use of forest and brushland which might be
In greater supply at less cost.
3. Discharge to the Patapsco River System - Three of the alternatives
mentioned in the Executive Summary involve full or partial discharge
to the Patapsco system. From the fish and aquatic life standpoint,
these options may warrant more analysis than they receive in the DEIS.
Both the Lower Patapsco River and Baltimore Harbor, into which it flows,
represent degraded fish and aquatic life habitat - particularly Balti-
more Harbor. The net effect of further degradation there could be
relatively minor compared with more productive, yet vulnerable, habitat
In the Patuxent River and Estuary, as described in the DEIS. This
consideration would have to be balanced with analysis Df effects from
86
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3
permanent withdrawals of substantial volumes of fresh-;;atcr flows
from the Patuxent system. These aspects receive little or no atten-
tion in the DEIS which is understandable in vicv of the hypothetical
nature of the alternatives discussion. As the. needs for projected
additional treatment capacity needs are confronted in the future,
more detailed analysis will be merited.
4. Dechlorination - As mentioned in the DEIS (pages 83 and 84)
excessive concentrations of chlorine belov treatment plants have
had adverse effects upon fish and aquatic life in the Coastal Plain
segment of the Patuxent Basin in the past (Haroan, 1978). On the
other hand, fish species diversity has increased below the Horsepen
Wastewater Treatment Plant with teritiary treatment and dechlori-
nation (TSAI and Golembiewski, 1979). The LPWQMC plant planners are
to be commended for drawing the logical conclusions from this
Information and building dechlorination into the proposed construction
and operation to provide an effluent limitation of 0.5 mg/l of chlorine
at the point of wastewater discharge. It will be icportant to monitor
and maintain this equipment to effectively implement this effueat
limitation on a continuing basis.
5. Urbanization and Non-point Source Pollution - The fifth full
paragraph on page 56 briefly touches on the relationship between
increased urbanization and stimulation by increased treatment capacity
availability. It does so only in the context of pathogen contami-
nation. It has been demonstrated that urbanization generates increased
non-point source pollution for other contaminants as well, including
nutrients,, pesticides, oil, and gas and sediment (CH2M Hill, 1977).
Such increases may be of the magnitude of 300 percent. By contrast,
Table 111-15 indicates increases of only 21 percent for nitrogen loadings
and 3 percent for phosphorus by 2000. We do not question these findings,
although their derivation is not spelled out in the DEIS. They probably
reflect the fact that the DEIS anticipates that a significant portion
of the Patuxent Basin will remain relatively thinly-settled despite
accelerated urbanization and suburbanization facilitated and stimulated
by the availability of increased treatment capacity. This indirect
(and usually adverse) effect stemming from provision of additional
treatment capacity is one of the more important long range impacts on
fish and aquatic life habitat. It deserves more attention in the DEIS
analysis. Incidentally, the page 56 reference already cited mentions
only effects transported to the estuary. Why aren't effects on fluvial
river habitat much closer to the projected urbanization and suburbani-
zation increase mentioned?
6. Nutrient strategy - The DEIS devotes approximately 16 pages to
discussion and analysis of this question. It appears to have
adequately covered the available literature and on-going research as
well as the outputs -from the HydroQual model operation. As a result,
the section reflects considerable ambiguity with regard to the complex
question of which nutrient (nitrogen or phosphorus) is controlling.
For example: on page-iH*-65 it is stated that phosphorus removal
will do more to improve water quality; on page nitrogen is cited
/
87
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as controlling plant growth in estuaries; on page X11-68 it is stated
that nitrogen controls in marine environnants; on page 1II-68 results
from HydroQual model indicated that phosphorus removal will be nost
effective. The concept is put forward that phosphorus may be critical
in the fluvial Patuxent while nitrogen controls in the estuary - but
this is never confirmed. A summary finding on page 111—73 states,
"Sufficient field data are not yet available to judge which eleneat has
more impact on algal growth in the Patuxent Paver." With this conclu-
sion we are inclined to agree.
There appears to be a discrepancy between figures presented ort
page IIZ-71 and Table 111-10. Page 111-71 indicates that point sources
show an increase of 72 percent for nitrogen and 83 percent for phosphoru
by 2000 under present levels of treatment. For non-point sources the S
corresponding increases are under five percent. Oa page IH-65, point
source loadings for nitrogen are said to be 93 percent and for phosphoru
74 percent. For non-point sources, the nitrogen increase is estimated to*
be 21 percent and the phosphorus increase 3 percent. This should be
clarified.
In keeping with our consistent perspective throughout these comment
we believe the LPWQMC environmental analysis should be viewed in terms
of the contribution to the ultimate impact of meeting the projected 2000
needs for treatment capacity. This is less than 20 years away. ia this
framework, two statements In this section of the DEIS are significant*
(a) On page 111-71 it is stated, "Current technology can achieve
an effluent of 0.3 mg/1 of phosphorus and 3.0 mg/l of nitrogen without
difficulty." By implication, further reductions, if necessary, would
be with difficulty and at higher cost.
(b) On page TII-74 it is stated, based on HydroQual results, that
bottom level DO would range to about 3.0 mg/l in the lower Patuxent
River with advanced nutrient removal and a sediment oxygen demand of
one-third present values. This is a stress level for many species of
fish and aquatic life. Adding the impacts from the equivalent of two
more LPWQMC plants (if this is the route chosen to raeet the projected
treatment capacity needs) would seem to spell serious difficulty for an
already stressed ecosystem.
7. Aquatic biota impacts - The thrust of the analysis in this section
as well as many of the conclusions in Chap. IV is that: *
(a) Water quality (and the fish and aquatic life resources
dependent on it) in the Piedmont Plateau portion of the
Patuxent is good to excellent and presumably will remain so.
(b) The Coastal Plain segment shows stress and water quality
degradation with hope of betterment through advanced waste
treatment.
(c) The Patuxent estuary segment does not show significant
degradation and is not likely to be signlf icatnly impacted
by LPWQMC operations.
8B
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5
We believe that these conclusions are, at best, oversimplifications
and should be examined in the light of the following co^aents:
(a) It is accepted throughout the DEIS that water quality (and
presumably the fish and aquatic resources dependent on it) in the
Piedmont Plateau section have not been seriously impacted by past
wastewater discharges. This assertion is probably generally true.
The possibility of change in this status should be mentioned, however.
Some of the human population increases projected for for the already
stressed Coastal Plain segment of the Patuxent Basin have already
begun to spill over into the Piedmont Plateau segment, facilitated,
at least in part, by LPWQMC expansion. The significance of such
development should be examined more closely in the DEIS.
(b) The point is made on page 111-82 that "These trends in chlorophyll
ji concentrations indicate that nutrient enrichment is occurring in the
Patuxent estuary." This reflects the contribution of expanding sewage
treatment plants at secondary levels. This long term, trend represents
at least a potential threat to fish and aquatic life habitat in the
estuary. However, at other places in the DEIS the lack of demonstrable
adverse impacts on estuarine habitat to date are emphasized (pages
111-83 and 111-84). Widespread application throughout the Patuxent
Basin of advanced wastewater treatment measures similar to those contem-
plated for LPWQMC would conceivably moderate this long term trend. However
such improvements must be measured against the impacts of providing sub-
stantial additional wastewater treatment capacity to meet needs projected
for the next 18 years. This section does not draw together and inter-
relate all the threads in this total impact assessment. We realize that
this is beyond the scope of this DEIS document, geared, as it is, to the
LPWQMC plant expansion. This being the case, however, perhaps this
section (and Chap. IV) should restrain its optimism in view of existing
ambiguities and limited data.
(c) The statement in the third paragraph on page 111-84 that "White
perch and spot were the only commercially important fish species domi-
nant in the estuary" Implies that It holds for the entire Patuxent
Estuary. A glance at Table 111-19 which presents the commercial fish
landings for the Patuxent Estuary makes it clear that such is not the
case. Appropriate qualification and/or revision of the statement should
be made.
(d) We agree with paragraph 4 on page 111-86 that interpretation of
trends from commercial fisheries harvest data Is difficult due to the
influence of externalities and the lack of precise information on kinds
and amounts of effort expended. With all due allowance, however, the
figures in Table 111-19, including the "percent of Maryland catch"
figures, can hardly be Interpreted as supporting the degred of optimism
and satisfaction expressed elsewhere In the "Aquatic Biota Impacts"
and "Conclusions" sections with regard to future fish and aquatic life
productivity.
(ej The extensive discussion of salinity/shellfish interactions (pages
88-96) is reasonably comprehensive. The statement is made on page 111-90
89
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6
that "During low freshwater flow periods, however, a 5 mgd incremental
discharge may reduce salinity enough to affect the life in the estuary •»
It should be pointed out that the effect of this incremental increase is
likely to be magnified by the additional wastewater treatment capacity
projected to be needed in the Patuxent Basin by 2000. The DEIS cites
criticality of high freshwater flows as a limiting factor in the suita-
bility of the Patuxent Estuary as shellfish (particularly oyster) habitat-
In view of this, perhaps more attention should be given in the DEIS to *
the possible beneficial shellfish impacts from diverting LPWQMC plant
flows (in whole or in part) into the Patapsco River system—as called f0
in three of the seven alternatives mentioned in the DEIS. This aspect i
not treated in the present discussion of salinity. In the light of thesS
considerations, the assertion on page TODZjr95 that "Although the data ar^
Insufficient to draw conclusions, salinity does not appear to be a major-
factor in oyster health or survival in the Upper Patuxent" is questional*!
To butress this assertion, anaerobic conditions, rather than salinity « C
suggested as a cause of oyster mortality in the same paragraph. If ver-£ &
fied, this would lead one back to nutrient enrichment and organic acctrm^"*
lation which, in turn, lead back to the same wastewater imputs. ~~
In summary, we recognize the limitation of most of the data on which
much of the discussion is this section is based and the difficulties of'pre-,
paring an adequate environmental analysis. In view of these limitations,
however, we believe that.many of the assertions as to the present and future
health of fish and aquatic life habitat in the Patuxent Estuary are overly
optimistic.
WPJ:krd
These comments were prepared by Bob Schueler, Technical Assistance Program.
90
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C S 0 COUlT£«
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5TATC O' MAR ft. *N0
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TID£WAT£R ADMINISTRATION
TAWES STATC omit C UIV.DINO
ANNAPQL'S 21401
V.OUI5 N
Dl*vrr 3£ c •£ f*
(301) 269-2734
Deceaber 9, 1931
MEMORANDUM
TO: Mike Nelson, ftlr'^-uHTnghouse Review Off
ic er
/
FROM: Sarah Taylor). CpaHtal Resources' division
Jri "
SUBJECT: Clearinghouse project £22-10-37 (DEIS-Little Patu/.ent Water Quality
Management Center—Savage Plant)
The Tidewater Administration has reviewed the above-refcrcnccd DEIS dated
October, 1981. The attached consents, prepared by the Tidal Fisheries Division,
represent the Tidewater Adninistration concents on this project. Due to their
thoroughness, the Coastal Resources Division has no additional comments to offer
on matters pertaining to water quality and protection of aquatic resources.
We note that the DEIS evaluates an alternative discharg-3 location to Deep Run,
a tributary to the Patapsco River. Unfortunately, this alternative was
recommended only as an after-the-fact situation once th^ plant was under
construction. Had this alternative been presented in EPA's "Negative Declar-
ation," dated December 4, 1978, for the "Relocation of Savage Sewage Treatment
Plant Point of Discharge," this alternative would have received serious considers
tion by this Administration is a possible alternative nethod to improve vater
quality in the Patuxent River. Section 3 of Tidal Fisheries Division consents
further address this point.
Despite the fact that cor.ncnts specific to this DEIS are superfluous in that
the plant and discharge line are presently under construction, we recocunend
that the attached consents by Tidal Fisheries Division be retained in the
files of the Federal and Ctnte agencies involved in sewage treatment plant
construction and operation for the Patuxent River Sasin. All future plans
for discharges to this river and its tributaries should ta'r.e into account a
nore thorough review and coordinated effort for fisheries and aquatic resources.
SJT:k.rd
Attachment
cc: W. P. Jensen, Tidal Fisheries Division
E. Cfiigiarelli, Coastal Resources Division
R. Wagner, Coastal Resources Division
TTY f°r Deaf - Baltimore 269-2609, Washington 'letro 565-0450
91
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J /< /r
United States Department of the Interior
OFFICE OF THE SECRETARY
Office of Environmental Project Review
15 State Street
Boston, Massachusetts 02109
In Reply Refer To:
FWS/ES
ER 81/2271
December 14, 1981
Mr. Peter N. Bibko, Regional Administrator
Environmental Protection Agency
Region III
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Bibko:
This responds to your request for the Department of Interior's comments
on the draft environmental impact statement for the Little Patuxent
Water Quality Management Center (Savage Plant), Howard County, Maryland.
General Comments
This DEIS was prepared by court order resulting from a lawsuit filed
against EPA by three southern Maryland counties adjacent to the Patuxent
estuary (Charles, Calvert, and St. Mary's). The stated purpose of this
DEIS was to provide information on the potential impacts of alternative
solutions which were developed through the EIS process. In response to the
lawsuit the Court specifically charged that the draft and final EIS address
the possible environmental impacts from increased nitrogen discharge from
the expanded plant on eutrophication in the lower Patuxent estuary and
on any future water supplies (U.S. District Court of the District of
Columbia, 1980). However, the court did not enjoin construction nor
operation of the proposed project, and it is now complete, albeit operating
below its capacity of 15 mgd. The document states that in order to comply
with the intent of the EIS process, the evaluation was prepared assuming
that a project had not been selected or constructed. This Department
believes that in regards to the overall intent of the EIS process, the
statement is inadequate in its assessment of the fish and wildlife resources
in the area and the impact of the project upon them.
The Statement lacks a description of other interrelated Federal actions
which would be required as a result of this project. The Statement
does not discuss construction activities requiring a Section 404 permit
from the Corps of Engineers for any of the alternatives. In actuality,
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2
the construction of the discharge pipe into the Little Patuxent required
a 404 permit and problems were encountered with excessive sediment
entering the river due to the construction activities. The impact of
such activities should be addressed because sedimentation and suspended
sediments are a major problem in the Chesapeake Bay region.
The Statement fails to discuss possible impacts of the project on endangered
species in the area, most notably bald eagles which breed along the estuarine
part of the river. Pursuant to the requirments of the Endangered Species
Act of 1973, as amended, the Statement should provide a list of endangered
species in the impact area and an assessment of the impact of the project on
those species. In the event that this assessment reveals that no impacts
will occur, this should be so stated in the final EIS.
This Department has no objection to this project in relation to mineral
resources because it is a modification of a previously existing facility.
However, if alternatives which propose construction of new facilities, i.e.
land treatment, are undertaken at a future date, it will be necessary to
clearly delineate all site locations and discuss the impacts upon either
mineral commodities associated with those sites or ongoing mineral activities
Specific Comments
Chapter II Development and Cost Comparison of Alternatives
Relocation of discharge point, p. 15. This discussion on the location of
the discharge pipe fails to mention the environmental impacts associated
with the various choices. This is the only section of the statement which
clearly addresses this issue and the limiting of the discussion to primarily
cost factors is shortsighted. Because discharge pipes are often located
in areas of high resource value (wetlands, riparian habitat, stream channels)
this section should more clearly delineate the potential impacts of the
alternatives.
Description of alternatives to be evaluated, pp 20-37. This entire section
is limited to the methodology and costs associated with alternatives to the
project selected and constructed. Since the subsequent chapter on Environ-
mental Impacts reviews only the selected alternative, no assessment is pro-
vided on the environmental impacts of these other alternatives. This
point should be addressed in the final EIS to keep with the stated objective
of maintaining the intent of the EIS process which allows for equal consi-
deration of environmental and economic parameters.
Chapter III Environmental Impacts
Sources of pathogens in the Patuxent River, pp 50-52. This section of
the Statement reviews health risks associated with nonpoint runoff and
natural sources such as wetlands and waterfowl. Health risks from sewage
effluents are considered separately. This section provides an adequate
94
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3
review of the existing and potential hazards from nonpoint runoff, but
through incomplete analysis has perhaps overstated the threat from wetlands
and waterfowl. Water quality degradation and public health risks can occur
due to large concentrations of waterfowl. However, such conditions are
most commonly limited to small waterbodies with poor flushing characteristics
and high densities of waterfowl. It is misleading to claim that waterfowl
contribute to water quality degradation on the Patuxent when the Statement
completely lacks any review of the available data on waterfowl use of the
river. To adequately assess the potential impact of wetlands and waterfowl on
water quality, the final EIS should include data on species, abundance,
and time-of-year use of the river by waterfowl and relate those data to the
flushing capability of the river due to low or high flow if this is an
important issue. Claims such as significant fecal contamination by refuges
during the nesting season may be difficult to support with the low
densities of waterfowl using the river at that time.
Water Quality Impacts, pp 55-81. This section discusses the nitrogen/phos-
phorus ratio in the river and the various merits of controlling amounts of
either nutrient in sewage effluent. Interpretation of available data is
quite difficult and variable as evidenced by the current split in scientific
opinion over which nutrient to control in the Patuxent. The Statement
reviews the data which indicate that estuarine systems are generally nitrogen
limited. Yet, the analysis presented implies that phosphorus control will
reduce eutrophication in the estuary more than nitrogen control. Undoubtedly,
phosphorus control will benefit the upper reaches of the Patuxent which are
phosphorus limited. However, the strong belief of many Maryland scientists
that nitrogen control, not phosphorus, is needed to improve water quality
in the Patuxent has convinced this Department of the need to examine a policy
of two-nutrient control. The failure of the Statement to address this
alternative should be corrected in the FEIS. Such an analysis should consider
the possible benefits of both phosphorus and nitrogen control to water
quality and aquatic resources and weigh them against the added costs.
This Department believes that a two-nutrient control strategy would
encompass all aspects of prevailing scientific opinion concerning the
best methodology to clean up the Patuxent.
Chapter IV Conclusions and Recommendations
Aquatic biota, p. 100. The discussion presented here is confusing and
contradictory. After stating that treatment plant discharges do not
seem to have greatly affected the estuary, eutrophication is clearly
linked to increased sewage discharges and nonpoint runoff. The low
dissolved oxygen level due to decaying organic matter is a direct result
of eutrophication and is foremost in the problems of the Patuxent. This
inconsistency lends no support to the conclusion that increased discharge
from the Savage Plant alone will not degrade water quality in the estuary
sufficiently to cause significant damage to aquatic life. The increased
discharge from the plant can not be considered alone, but must be analyzed
for the additive effect it will have on the existing load. Also, phrases
such as "significant damage to aquatic life" do not clearly express
95
©
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4
potential problems. If problems are foreseen the degree of damage and
affected species should be described, even if the impact is believed
minimal.
Recommendations, p. 101. Instream aeration is presented as a possible
mitigation measure to alleviate the low DO problem in the estuary. However,
this section consists almost entirely of a literature review which discusses
various methods of aeration and several small studies which have been done.
The discussion should focus more on the feasibility and effectiveness of
using instream aeration on the Patuxent. Other mitigation measures to lessen
the impact of the discharge should be included if mechanical means of raising
the DO are not suitable. Other means of reducing the nutrient input should
be elucidated, i.e., addition of nitrogen removal or land treatment, or inter-
basin transfer of the effluent.
Summary Comments
Although the Savage Plant fourth addition as reviewed in this document (DEIS)
is virtually complete, it is currently operating close to its old discharge
level, well below the 15 mgd capacity. Therefore, review of this Statement
analyzing the environmental impact of the project discharge level of 15 mgd
remains a valid exercise.
This Department does not object to the subject project per se, but finds
the DEIS inadequate in many aspects of its analysis of the project impacts
on fish and wildlife resources.
The resources of the Patuxent River have played a key role in the history
of Maryland and remain of high economic and recreational value today. However
the intense developmental pressure put on the river in the past 30 years has
decreased water quality through eutrophication and sedimentation and sewage
treatment plants have played a significant role in this decline. Future
development will only exacerbate this problem. Admittedly, the upgrading
of the Savage Plant to advance treatment marks an improvement in the
effluent discharged from the plant. But the lawsuit which prompted the
writing of this DEIS reflects the concern with which each increase in
discharge is viewed.
Accordingly, tins Department believes that the Savage Plant should not
be allowed to operate at full capacity until the State of Maryland has
completed its Nutrient Control Strategy for the Patuxent River. The
increase to 15 mgd should be in compliance with standards and controls
set forth in that document.
Thank you for the opportunity to comment on this document.
Sincerely yours
William P. Patterson
96
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OFFICE OF ENVIRONMENTAL PROGRAMS
DEPARTMENT OF HEALTH AND MENTAL HYGIENE
201 WEST PRESTON STREET • BALTIMORE. MARYLAND 21201 • Area Code 301 • 383- 2 7 3 7
Ms. Mary Sa rno
EI3 Preparation Section
EPA Region III, 3PM80
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Sarno:
The Water Quality Administration of the Office of Environmental
Programs has completed its review of EPA's Draft EIS for the Little
Patuxent Water Quality Management Center (Savage Plant). Though OEP
has various comments on the Draft EIS which should be incorporated in
the course of the Final EIS preparation, none contradict the overall
conclusions presented in the Draft. The details of these comments
are attached.
As you may be aware, a re-organization of water related programs
has been completed in Maryland and the mailing list used for the Draft
EIS should be updated before the Final EIS mailing is made. Attached
are two lists of individuals. The first, "Former Staff Who Received
a Draft EIS Mailing," is a list of individuals no longer associated
with the program who should be removed from your mailing list. The
second, "Partial List of Individuals Concerned with Patuxent Issues,"
includes individuals who should be on your mailing list for the Final
EIS. I hope you Tinu the above helpful.
Harry Hughes, Governor
Charles R. Buck, Jr., Sc.D. Secretary
December 18, 1981
Richard B. Sel lar-v; ,
Acting Director /
Water Management Adm
Richard B. Sellars< Jr.
Acting Director /
Water Management Administration
RBS:pbs
cc: Mr. John O'Hara
Mr. William Johnston
97
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Chapter III. Environmental Impacts
Water Quality Impacts
p. kk, par. k The Patuxent River is not now and never has been a sourcel
of raw water to the Baltimore metropolitan area. |
p. 57, par. 2 Lower dissolved oxygen in the bottom waters of the lower
estuary generally occurs below river mile 20-25.
Any action to reduce STP discharge of inorganic nutrients
which could be ei ther incorporated into organic material
or transported directly to the lower estuary, will reduce
the resultant accumulation of nutrients in the sediments
of the lower estuary.
65, par. k Existing point sources account for 6?& of the phosphorus
and load, but only about 30-35% of the nitrogen load to the
71, Par, 5 river. (See HydroQual report E-9.)
I'
66 The report greatly underestimates the nonpoint source I
Table III-14 loadings of nitrogen. (HydroQual estimates 10,400 1b/dayl'
Table 111-15 vs. ESEI 4,^70 lb/day.) I
71, par. 1 HydroQual model runs show that the resultant water quality
improvement with .3P or 3.0 N limitation are not signifi-
can11y di fferent.
p. 71, par. 2 Report grossly underestimates NPS nitrogen
I®
p. 7k, par. 2 Projected year 2000 flows without nutrient removal will
raise projected chlorophyll £ levels _to_ 100 mg/1, not
by 100 mg/1.
|<§>
p. 8^, par. 2 Although diversity indices may be quantitative1y similar
important species shifts (striped bass, white perch) may
have occurred in the Patuxent River.
p. 89-96 The available data, collected during three low flow periods
in 1978, is not statistically adequate for the type of
analysis presented in this report. To assume a direct
linear relationship exists between the spatial distribution
of salinity and river flow may be a gross over-simplificati
101 A nutrient control strategy is a much sounder approach tol .
mitigating the D.0. problem in the lower estuary than is |(
in stream aeration. I
98
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United States
Department of
Agriculture
Soil
Conservation
Service
4321 Hartwick Road
College Park, Maryland
20740
December 21, 1981
Ms. Rochelle Volin
U. S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Volin:
The loading rates for agriculture presented in this environmental impact
statement are based on the Rhodes River Study by Correll, et al. 1977.
This study was widely questioned by the agricultural community in Maryland
including the University of Maryland and the Maryland Agricultural Experiment
Station. Based on these objections, SCS does not feel that the figures
presented are an accurate picture of the non-point source loadings from
agriculture.
Table III-II, page 59 compares loading rates gathered from four different
sources. Data gathered on urban runoff from the Northern Virginia Planning
District Commission and Virginia Polytechnical Institute and State University
contained in this table were collected in the Piedmont Physiographic Region
and are possibly not transferable to the Coastal Plain setting of the
environmental impact statement.
Subject: DEIS on the Little Patuxent Water
Quality Management Center
Sincerely,
Gerald R. Calhoun
State Conservationist
cc: Norman Berg, Chief, SCS, Washington, D. C.
99
The Soil Conservation Service
is an agency of the
Department of Agriculture
-------
United States Department of the Interior
FISH AND WILDLIFE SERVICE
PATUXENT WILDLIFE RESEARCH CENTER
LAUREL, MARYLAND 20811
December 22, 1981
Ms. Mary Sarno
3PM 8l Curtis Bldg.
6th and Walnut Street
Philadelphia, PA 19106
Dear Ms. Sarno:
Enclosed you will find a statement prepared "by my wife concerning
the "Public Health Impacts" of the E.I.S. relative to the Savage Sewage
Treatment Plant in Howard County. You will note this elaborates on my
verbal comments at the public hearing concerning the inappropriateness of
this section, especially the implication that wildlife is a source of
pathogens.
Sinv vniivc
AELRED D. GEIS
Urban Wildlife Specialist
Encl.
101
TEI.EPHONE—ARKA CODE 301 776-4800 (MARYLAND EXCHANGE)
TEI.EORAM3—FISH AND WILDLIFE SERVICE, WASHINGTON, D.C. 20240
-------
Statement by Shirley A. Geis, 5710 Trotter Road, Clarksville, Maryland 21029
(relative to the Draft Environmental Impact Statement, Little Patuxent Water
Quality Management Center (Savage Plant) Howard County, Maryland), home phone
(301) 286-2U00, business phone (301) 6-6931•
I wish to focus attention on the section of the E.I.S. dealing with "Public
Health Impacts" starting at the last paragraph on page 1+8 and closing on page 56.
This entire section reads like it was written by someone ignorant of even basic
Microbiology and Epidemiology. More importantly, the Author's effort to down-grade
the importance of sewage from human dwellings and the attempt to place the blame of
pathogenic microbial contamination upon unlikely animal sources raises the suspicin
that this report was written under pressure from development interests. The resul-t
is serious misinformation!
Before embarking on a point by point rebuttal of this document, I should like
to offer my personal credentials. I have been a professional microbiologist since
1951. Ify formal university training was in zoology, microbiology, parisitology, and
mycology. I have added to that 30 years of laboratory experience. At the Michigan
Department of Health I worked in pathogenic bacteriology and parasitology. Since
moving to Howard County, Maryland, 25 years ago I have made bacterial diagnostic
reagents for the Armed Forces Medical Laboratories and worked in pathological,
microbiological, and parasite research at the Patuxent Wildlife Research Center. j
then spent 10 years doing bacterial and epidemiological research at National
Institutes of Health. For the past 10 years I have been doing research in virolotrv
and cell mediated immunity at NIH. It is not immodest to say that I enjoy a
reputation of doing meticulous work.
I have no quarrel with the possible pathogens listed on pages U9 and 50;
however, there is need of some practical explanation of some of these organisms.
Leptospira is indeed one of the few bacteria pathogenic to both humans and other
mammals and birds. However, it is a rather fragile organism which is difficult to
culture and not likely to live long enough in a stream to be a major hazard. It is
spread from animal to animal by licking fresh infected urine or urine soaked earth-
most humans contract it through the direct handling of urine while caring for an *
infected pet or family member. Pseudomonas aerugenosa is a highly motile bacteria
and will over-grow everything else in culture, while may lead to errors in estimate
of its relative abundance in comparison to Shigella and Salmonella. The most
important organisms are the pathogenic residents of the human intestional tract:
Salmonella, Shigella, Vibrio comma, S_. typhi, and Endomeba hystolytica. Only
Eschericha coli of HUMAN ORIGIN is of any public health significance, and that mostJ
as an indicator of human fecal contamination as a potential source of human Pathogens
The most important fact that the author has ignored is that most parasites
bacteria, and viruses are HOST SPECIFIC: that is that they infect only one species
of animal, such as cows, chickens, or humans. There are relatively few organisms
which infect more than one species of animal, and they are not water borne diseases
Therefore, there is no public health significance to the human population that ther*
may be fecal contamination from run-off from barnyards or a wildlife sanctuary.
statements starting on the bottom of page 51 and continuing on page 52 that the
various wildlife areas along the Patuxent River contribute to pathogenic contamina-
tion for humans are incorrect and misleading. Enteric bacteria and viruses from
non-humans do not affect humans; only human enteric bacteria and viruses affect
humans.
Species specificity also brings up the problem of the routine laboratory test
for E. coli as an indicator of fecal contamination. ALL animals have their own
102
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sub-species of E. coli as a normal part of their entestinal flora. All E. coli
bacteria break down carbohydrates to produce acid and gas (C02). Yet, this is the
common laboratory test for fecal contamination in water; the water is added to a
sugar solution containing a dye which changes color at different pH levels (such as
brom-thymol-blue) and which contains a glass ampule which will fill with the gas (if
produced) and rise to the top of the culture tube. The innoculated cultures are
incubated at body temperature for about 18 hours. If acid and gas are present, there
is presumed to be E_. Coli present and the water is deemed to have fecal contamination.
However, that fecal contamination could be from any species source, including the fish
which obviously defecate in the water. The acid/gas production test used for water
samples was designed to identify fecal contamination in wells. It is used for
routine monitoring because it is easy, fast, and, most important, cheap. It is not
really suitable for monitoring streams without further work. In a case involving the
safety of a human sewage treatment plant it would be essential to identify the species
origin of the coliforms and especially to identify human E. coli in the stream. This
can be done serologically or with bacteriophages. In diagnostic bacteriology labs,
E. coli is usually reported as a pathogen only for stool specimens from young infants
for which it is a pathogen; however, it is reported as a pathogen in all urine
specimens. In these cases, the E_. coli is further identified by serology or
bacteriophage.
Parasites are also host specific. Tapeworm eggs deposited in deer feces are
a danger only to another deer. The few helminth parasites transferred from animals
to humans are usually by ingestion of the larval forms in insufficiently cooked
tissue; i.e., the famous story of the Jewish ladies preparing Gefiltefish, or contract-
ing Trichinosis from eating rare pork. The most important human intestional parasite
in this area is Endomeba hystolytica, which is definately a water-borne disease.
There is no statement of how this protozoan is either monitored or destroyed.
In view of the sketchy bacteriology data offered, I should like to know the
methods used for detection of viruses, including the exact cell lines used. Isolation
of viruses is an exacting business. Viruses, except for Rabies, are also extremely
host specific. The main problem seems to be Hepatitis virus living in the gut of
clams and oysters, and this is an infectious problem only when the infected bivalves
are eaten raw. The most probably source of this problem is direct fecal contamination
of the bay. The clams and oysters, of course, are not affected by the virus; it
just lives in their simple gut. However, in the case of a Polio or intestinal
influenza outbreak, it would be important to have adequate means of isolating and
identifying their virus, and it is not unreasonable for an interested virologist to
ask just what these means are going to be.
On page 5k there is a statement that flocculatlon will remove most bacteria
except for Mycobacteria and Vibrio cholerae. Since these are two potentially
extremely dangerous human pathogens it is important to tell us how these are going
to be destroyed. Although we do not have the severe problem of cholera in the U.S.A.
that exists in Asia, it could certainly cause a water-bourne epidemic. Mycobacteria
tuberculosis is a frequent pathogen of the human urinary tract and can also infect
the intestinal tract. Both these organisms are difficult to culture in the laboratory;
Mycobacteria requires six to eight weeks to grow in culture. These organisms are
almost never found in direct smears of specimens unless the concentration of bacteria
is fantastically high. Mycobacteria are extremely resistant organisms which are capable
of living a long time outside the body. Vibrio comma is much less resistant than
Mycobacteria but more resistant than Salmonella and Shigella. How will these
organisms be monitored?
103
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Common laboratory procedures make me skeptical of the statement that parasite
ova and viruses are settled out by flocculation. The common method of recovering
parasite ova for diagnostic examination is by FLOTATION: the solids of the specimen
are centrifuged to the bottom of the tube and the ova float to the top and are picked
up on a cover glass. In preparing viruses for use, we centrifuge the preparation at
2000 RPM, discard the cellular debris at the bottom of the tube, and use the super-
natant as the virus pool. If we wish to further concentrate the virus, this supernat-
ant is spun in the ultra-centrifuge at 30,000 (thirty-thousand) RPM for two hours.
The rotor of an ultra-centrifuge is a precision instrument which spins in a refriger-
ated vacuum. It is difficult for me to believe that viruses just settle out with
flocculation.
The entire section on public health is full of contradictions, most of which
are reitterated in the summary. However, the most outrageous statement is that since u ><
run-off water contains many of the same pathogens as wastewater from the sewage an
treatment plant that it is perfectly all right to increase the capacity of the
sewage treatment plant. The simple fact is that human pathogens come from humans;
that human water-borne pathogens come from human wastes from human dwelling units;
and that the more human dwelling units that are dumping sewage wastes into the
Patuxent (or any other) River, the greater chance there is for water-borne infection
to other humans who are using this source of water. Run-off water from barns and
wildlife refuges is not a problem; sewage effulent from human homes is a problem.
The capacity of the Savage Sewage Treatment Plant was allowed to increase by
l/3 to satisfy development interests in Howard County without an environmental
impact statement. The residents of the Counties downstream on the Patuxent River
who have to use this water have rightfully questioned what this increase in sewage
effluent into a relatively small stream means to the quality of their water. A large
part of this question has to be public health safety. You have presented us with
a document that is a pure, albiet poor, snow job. As an outraged, hard working tax
payer who is paying for both this report and for the expansion of the sewage treatment
plant and thereby subsidizing every new home built in Columbia, it is not unreasonable
to demand that an honest, accurate report be presented to the citizens this concerns
We are, after all, paying for it in many ways.
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JAMES D- HALSEY, JR.
MARRY JOHN STAAS
JOHN W HUCKERT
WM D JOHNSTON HI
L ALLEN WOOD. JR
HENRY M ZYKORtE
DAVIO M PITCHER
JOHN C GARVEY
ROBERT GROOVER m
LAW OFFICES
STAAS & HALSEY
182 S K STREET, N.W.
WASHINGTON, D C. ZOOOO
11 January 1982
TELEPHONE (2021 S72-OI23
Cable Address "AMPAT"
Telex 24.8476
OF COUNSEL
GENEW. STOCKMAN
Mr. George Pence
Chief EIS Preparation Group
U.S. Environmental Protection
Agency, Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Pence:
As discussed with Ms. Mary Sarno on 21 December, Tom
Slemskamp on 28 December and yourself on 4 January 1982,
attached are the formal comments for the record following the
brief thoughts presented at the 8 December 1981 public hearing
of the DEIS for Howard County's STP at Savage, Maryland. As
specifically mentioned during each phone call, substantial
reasons have necessitated the delay of this submittal. We are
pleased to formerly participate in this EIS process, which
shows some promise for producing an objective analysis for
attempting to accomodate projected growth in an environ-
mentally compatible manner, at least insofar as water quality
in the basin is concerned since that is our primary expertise.
Do we correctly understand that air quality, as impacted
by the projected growth in the service area of the sewage
treatment plant, together with the projected growth generally
in the area (the southern end of the Boston-Washington D.C.
urban corridor), should also be briefly covered, in terms of
this urbanizing island? Also, we wonder if it would not be
proper to consider another alternative that has not yet been
mentioned in the DEIS, that of slower growth than projected,
at least for the service area's projected growth by a factor
of approximately 2 between 1980 and 2000. This question is
considered important for several reasons, a first being that
at least 25% of this projected growth is presumably reserved
for population increase in the basin by legal immigration,
unless demonstrated otherwise by demographic trends. This
figure of 25% is believed to be the present value for that
component of our total national population growth, the other
components being effectively only illegal immigration and the
sons and daughters of U.S. citizens.
105
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Mr. George Pence
11 January 1982
Page Two
Each additional person within our borders makes his own
individual contribution (1) to our national dependence on
foreign oil, (2) to the acid rain that falls on Canada as well
as within our own borders, and which originates from emissions
within our own borders, particularly from burning coal which
is our primary fuel resource, (3) by consumption of food and
fiber, to the continuing loss by erosion of our top soil
resource which is the backbone of our agricultural strength,
and (4) to the general problem of providing jobs and social
benefits for the population, particularly the lower economic
sectors with which the immigrants primarily compete. Ml of
these points raise basic but unanswered economic questions, as
to whether more people is necessarily always better. Our
national policies on these issues should speak clearly to the
rest of the world for us, for whatever wisdom they contain.
Therefore, it seems that some perspectives on this
alternative of projected growth should be properly included in
the EIS, instead of accepting as a given the county
projections, even if the county projections are consistent
with the present state and national projections. if such
projections exist (national and state), then it would be
extremely interesting to quickly review this in the EIS, in
one or two paragraphs explaining also the consistency
requirement. This is important for public education as to
these important economic and political matters, and government
programs relevant thereto. Such a brief summary on broader
but relevant perspectives should be a basic part of any EIS
involving growth, etc. You may be assured that these broader
economic and political issues, and their relation to specific
issues concerning development in the basin, are of real
interest to the parties represented in the enclosed.
For historical accuracy, the original plaintiffs in the
action leading to the order of this EIS included the Calvert
County Watermen's Association and the Davidsonville Area Civi
Association. The complaint was refiled when the Boards of G
Commissioners of the Southern Maryland counties joined the
action, fortunately, and the case was subsequently reassigned
to a second judge, Judge Oberdorfer, who eventually ruled in
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Mr. George Pence
11 January 1982
Page Three
the case. His comments in the order possibly reflect a lack
of familiarity with the original filing, relative initiatives
at different times of the action, etc.
Enclosed also is a copy of the comments on the DEIS by
the Tidewater Administration, which for some reason may not
have been forwarded by the Clearinghouse Review Officer.
These comments are quite relevant to the pending issues.
Very truly yours,
Cov-.-o. —C-ffj
W. D. Johnston III
Enclosures
WDJ:crb
107
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PATUXENT TECHNICAL and LEGAL COMMENTARY
ISSUE 82-1
PATUXENT T.L.C.
R.R. 1-4BB
HUNTINGTOWN, MARYLAND 20639
COMMENT ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR HOWARD COUNTY'S SEWAGE TREATMENT PLANT
ON THE LITTLE PATUXENT RIVER AT SAVAGE, MARYLAND
(For the Record of the Public Hearing of 8 December 1981)
1. Context and Goals of the EIS
The purpose of this court-ordered environmental impact
statement (EIS) is confusing, since the 15 million gallon per day
(mgd) sewage treatment plant (STP) has already been built, al-
though illegally, since no EIS was timely prepared for evaluating
the alternatives which might have been possible and which are
only now hopefully to receive fair appraisal, along with con-
sideration of present alternatives for mitigating impacts of the
STP as constructed. Obtaining an injunction to prevent the con-
struction would have placed a significant burden on the opposing
parties, that of demonstrating "irreparable" harm, a burden
possibly as difficult as writing the EIS itself. In any case,
the court was never requested to forbid construction, contrary to
the indication at p. 5, par. 1 that the court had been asked to
rule on halting construction. Whatever the court may have stated
on the subject is dicta.
For these reasons, the EIS must now assess also alternatives
for mitigating impacts that are now found in the EIS to arise as
a result of the newly constructed facility, after appraising
these impacts according to the best information now available.
For instance, the recommendations of the "charette" held in
Marriottsville, Maryland in early December 1981 makes several
relevant recommendations, in view of the scientific evidence for
the relationship between point and non-point pollution and the
observed trend of eutrophication and degradation of the estuary.
Thus, the draft EIS (DEIS) should estimate the cost for
installing seasonal nitrogen removal facilities in the plant, f
after verifying that it was built to accomodate such additional
facilities, consistent with state law and alleged state policy.
A Public Participation Journal ol Patuxent River Water Quality
108
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Also, the alternative of seasonally piping the effluent at some
stage of the process to an available site for land treatment, for
instance for nitrogen (N) removal by overland flow (requiring
generally 35 to 40 acres per mgd), with possibly gravity return
to the plant for phosphorus (P) removal, should be costed. The
evaluation of alternatives for mitigating impacts is fundamental
to the National Environmental Policy Act under which ElS's origi-
nate .
Thus there appear to be two main purposes, the first being
to provide a fair appraisal of alternatives to the plant which
has been constructed, and of their costs. If it is necessary to
employ as cost values those costs which prevailed at the time the
decision was being made as to what to construct, (1977?) this
should be better explained. The second goal is to evaluate
alternatives for mitigating any impacts which might be found by
the EIS, and it would be senseless to utilize anything other than
the latest available knowledge. For this reason we would
endorse, except for the points noted below, the use that was made
for this DEIS of the model of the river developed by HydroQual,
Inc., and the findings of the charette should be similarly con-
sidered. However, we cannot understand why the rather critical
comments by the scientific community during the peer review of
this modeling work was not mentioned in the DEIS, nor even listed
in the References. These comments were submitted with a letter
early in 1981 from Drs. D'Elia and Ulanowicz to Bill Eichbaum of
the State Office of Environmental Programs (OEP), and was
followed by a second important letter concerning the failure of
the model to demonstrate any significant difference in total
algal growth in the estuary by limiting either N or P from point
discharges, as mentioned further belcw.
The DEIS uses the words "existing" and "current" throughout
the text in a manner that is unclear as to whether 1977 values or
values from other years are being employed. This applies to cost
values, population levels, etc. The entire document needs to be
closely edited for this point for clarity. Other inconsistencies
need to be resolved or commented on. Since the DEIS admits of
the eutrophication problem, and discusses the causal connection
between the increasing STP discharges and total algae in the
estuary, alternatives for preventing the discharge of any
increasing amounts of N, from either point or non-point sources
connected with the STP must be addressed. (The charette
recommended a reduction in N from both types of sources, without
identifying at which STP's in the basin the point source
reductions should occur.) Also, it is not proper for the DEIS to
limit the environmental assessment only to the impact of the "5
mgd incremental discharge" (p. ii, par. 2), instead of to the
full impact of the 15 mgd discharge of the project which is the
subject of the Court's order. Such improper narrowing of the
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evaluation prevents comparison of the the beneficial effects of
others of the seven major alternatives (p. i), involving less or
no discharge to surface waters than the alternative which has
been built. The additional need to address the cumulative
effects from all of the STP's and the sewered population in the
basin, is addressed further below.
Concerning Table II-l at p. 10, the flow of 15 mgd might
have been the flow that was used for some of the calculations, as
in the wasteload allocations of appendix K of the prior basin
plan (§303e of the Clean Water Act), but the permits which have
expired but which still govern the discharge were limited
specifically to 13.4 mgd, at the relocated outfall point. These
permits would not be issued today, in view of the concensus as to
eutrophication of the estuary. Those permits would not have been
issued in the first place, had the available concerns of the
scientific community been given fair appraisal (as in Fig. III-2
etc.).
2. Population to be Served and Per Capita Needs
It is strange that the DEIS does not identify either the
population to be eventually served by the 15 mgd facility, nor
even the average person's daily water supply requirement and
sewage contribution. Since the DEIS mentions demand reduction
for reducing total sewage flows, in addition to the recom-
mendation of the charette that residential units with their own
on-site facilities be allowed to disconnect from the collection
system or not be required to connect in the first place, such
points should all be considered to estimate the time when the
presently permitted flow of 13.4 mgd and when the actual 15 mgd
capacity would be reached in the future. Also, some remarks have
been heard, that in fact the constructed capacity is greater than
15 mgd, and this also should be clarified in the final EIS. This
should include discussion of adding an integration pond, so that
the peak capacity of the constructed STP could be used more of
the time. This should explain whether a "15 mgd" design capacity
(average flow) is actually designed to handle peak flows of 30
mgd, and whether this peak capacity can be sustained so as to
handle larger average flows than 15 mgd.
We also at this point would request to be notified as
interested members of the public of any public meeting or hearing
in the basin under the Clean Water Act, including particularly
§201 construction grant program, since rumor was heard of a
recent §201 public hearing in Howard County, which none of us
knew of. We would appreciate some reassurance from EPA and the
state OEP on this. Our experience is that parties well known to
be interested are often not supplied with notice by letter for
§201 hearings, even in the counties in which they live. Please
no
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let us Know if this request is not properly presented here, for
the purposes stated.
Also, the system of sewage collection pipes is apparently
extremely leaky, so that groundwater leaks in and must be treated
at the STP, currently exceeding 40% of the total average flow at
the STP, as admitted by Howard County in a draft §201 facility
plan for expansion to 18.3 mgd. This is further discussed below,
but the excerpt from the newsletter attached at the end of this
comment suggests that a more objective consideration of this
matter is in order. Also, although reduction in demand through
conservation, etc., is generally discussed, no numerical estimate
is incorporated.
The information on p. 1, par, 3 allows computing the
"present population" served by the 8.5 mgd flow (p. 1, par. 1,
but 8.08 mgd at p. 39, par. 3, revised, and 7.8 mgd in Table
111-10, p. 58) to be 53,419 people actually connected to the STP
who live in this sewage service area of Howard County, based on
the "present" population of Howard County being "about
129,500". It is not clear whether "present" means 1981 or
1977. In either case, this total population of Howard County is
larger than that which is added up from the data of Table 111-12
at p. 61. The latter adds up to a total Howard County 1980
population of only 89,900 (44% lower than 129,000), and it is
stated that the population numbers for the different portions of
Howard County are "adjusted to the preliminary 1980 census
population counts." (Does this mean the sewered population is
actually 44% lower than the 53,419?) Totalling the projected
year 2000 population of Howard County from Table 111-12 yields a
population of 174,840, an increase by a factor of about 1.9 over
20 years. If the "present" population is thus drastically
reduced, then should not also the year 2000 projected
population? Such inconsistencies within this DEIS, without any
explanation thereof, makes understanding of this document quite
difficult.
As another example, it is not clear whether the projected
year 2000 total flow of treated sewage effluent that as used in
the model runs (p. 76-81, Figs. TII-4 to 9) was 96.1 mgd (p. 41,
Table III-2) or the much lower value of 67.8 mgd {p. 58, Table
111-10). Clarification is necessary, if the EIS is to be a
useful, informative document. The value of 96.1 mgd comes from
the old §303e basin plan, and ignores the recent revisions in
these numbers, for instance as utilized in the HydroQual work.
In fact, the status of this §303e basin plan is quite unclear,
since it has been the subject of litigation by the Commissioners
of the downstream counties, and was only conditionally approved
by EPA, etc. Rome explanation of the status of this document
would be certainly helpful for public understanding. In any
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case, it appears that very little significance should be
attributed to this document, which even EPA admitted in writing
to be deficient on 12 of the 14 regulatory criteria governing
content of the document.
3. Scientific Evidence
The scientific community has attempted to indicate that the
HydroQual Inc. model in fact does not support the conclusions
which it advances, and that in any case the model alone should
not be relied upon for a decision on a basinwide nutrients
control strategy for reversing the observed trend of eutrophica-
tion in the estuary (for instance in the two letters mentioned
above). Specifically, the conclusion parroted in the DEIS with-
out critical analysis, that control of point source P to 0.3 mg/i
should provide greater control over the total growth of algae in
the estuary than control of point source N to 3.0 mg/1, is
without basis, which is seen also (besides being indicated in the
second letter above) on overlaying the two bottom curves of Pig
46 of the report.
This overlay comparison of the two control approaches shows
that there is an upstream peak of algae at river mile 43 that can
be reduced more by P control than N control, but that there is
another lower peak downstream, where the estuary is much larger
between river mile 20 and 30, where a greater advantage is '
available by N control. When the two areas of these Deaks are
weighted by the relative estuary volumes or surfaces/utilizing
data from Table 3 on p. 69 of the HydroQual report, it is seen
that both approaches to point source control produce equivalent
reductions in algae, and possibly most importantly, that
controlling both N and P together in fact would achieve the
greatest reduction in the total amount of algae, if such
differences are not statistically significant, this should be
admitted.
It is interesting to see that the 1978 data taken by the
State, when plotted in Fig. III-3 as per the method of Fig. ijt
2, demonstrates strongly that nitrogen is the limiting nutrient""
for the primary portion of the estuary during the critical warm»
months. This is also indicated by Heinle et al., 1980, Figs c
17 and 18, showing that N virtually disappears while Premains
abundant. In view of this, the conclusion at the bottom of o
68, that the N/P ratio "must be used in conjunction with ambient-
nutrient concentration in the early summer (right before alqal
bloom) to decide which nutrient is limiting" is certainly not
understood, and is in fact believed to be in error, in any can
the text is badly garbled and redundant at this point. Also u
is not understood how the data of Table 111-16 is derived and *
appears to be quite speculative. The conclusion based thereon
<§)
112
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(p. 71, par. 6), that either N or P control may limit algae, is
inconsistent with the main thrust of the bottom plot of Fig.
III-3, (in which the atomic N/P ratio for at least the 7/78 data
at a salinity of 2 ppt appears to be plotted incorrectly).
The entire discussion as to the ability to reduce N and P,
based on relative contributions from point and non-point sources,
should be supplemented by the concensus for these loadings that
was reached at the charette, and the seasonal variation in these
various loadings should be taken into account, since the charette
suggested seasonal nitrogen control, in view of the large ground
water and runoff contributions of N. (It is not understood why
the Consensus Statement which was drafted and finalized at the
charette, and the supporting materials, have not been distributed
to the participants, as promised.) Since Fig. III-3 show sub-
stantial nitrogen limitation during the critical warm months when
algae grow, and an abundance of P during these times, it is not
likely that any P removal alternative will have much influence in
the main body of the estuary where the nitrogen limitation has
been admitted to occur even by the OEP (Eichbaum, 28 Oct. 81,
Benedict, Md., Tri-County Environmental Seminar).
Concerning the N and P loading rates from non-point sources
in Table III-ll, which were then used to project that there would
be no substantial increase in nonpoint loads for the year 2000
(5% increase for both N and P), it is strange that the values for
these loading rates are taken apparently without any examination
of their validity for either the Costal Plain or the Piedmont
Plateau portions of the basin. Most of these data appear to be
'76 or '77 data, which had very low spring and annual rainfall
according to Dr. Correll, and are thus scarcely representative or
typical. The low density urban loading rates are believed to be
for a coastal plain with high ground water, thus also not rep-
resentative. The one relating to wetland has been stated in
print by Dr. Correll not to have taken into consideration the
drainage from the basin behind the wetland, so that that value
should be deleted entirely from the table. He has measured
loading rates for a number of years, including the seasonal
variations, and has supplied this data as part of his contribu-
tion to the peer review of the HydroQual modeling, including a
second letter contradicting the HydroQual defense of the original
critique. The data that Dr. Correll has supplied in these two
letters should be considered, and a more candid appraisal of the
uncertainties in the literature as to what should be considered
the "typical" values to be used in the computation in the EIS for
the total non-point source loadings more honestly assessed.
Attached please find copies of the annual average loading rates
that were agreed upon by the participants of the charette. It is
noted that Tables 111-14 and 15 of the EIS report significantly
different N and P loadings from point and non-point sources.
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A very important point, concerning any trend in nonpoint
sources, is that: as a result of the selected loading rates,
even the projected doubling of the present population in the
basin does not change the nonpoint source N and P loadings.
Since the projected growth may be assumed to be representative of
present types of development, this invites the curious
conclusions (1) that nonpoint loads have essentially always been
the same, and (2) that the trend of degradation in the estuary
could be attributed solely to point sources. A much more intel-
ligent appraisal of nonpoint loads, resulting from existing and
projected growth in the basin, is clearly called for.
Also, the HydroQual model runs were calibrated on nonrep-
resentative data, since only one data point for one of the three
days of data approaches a zero value for dissolved oxygen, even
though Fig. 9 of the HydroQual report shows that the dissolved
oxygen picture is generally worse than that represented by the
model calibration data. This figure in fact shows that the model
is more representative of historical dissolved oxygen levels
prior to the present day degradation (compare the upper and lower
curves of Fig. 9 with the HydroQual calibration runs of Figs. 14,
16, and 18).
The lack of candidness and/or thoroughness which the DEIS
has been prepared is truly evident in the statement that the
water quality modeling in the 303e basin plan (1977b) "indicated
that phosphorus removal ... would control eutrophication to a
greater degree than nitrogen removal ..." (p. 3, par. 1). As has
been pointed out in a letter from Dr. Heinle, which was submitted
for the record on another DEIS on the downstream Patuxent STP
(serving Crofton etc., in Anne Arundel Co.), this modeling was
limited only to the fresh water portion of the river. Further,
for this limited portion of the river, the P limiting approach
showed a numerical advantage over the N limiting approach of only
about 15 percent, which, in view of the uncertainties in the
model, cannot under any standards of fairness or objectivity be
seen a supporting the decision.
4• Specific Points
4a. Excessive Infiltration and Inflow (I/I)
In the first public meeting of the §201 facility plan which
was held about a year ago in Howard County to plan for expansion
beyond the 15 mgd of the new STP, it was admitted that approxi-
mately 45 percent of the current average flow into the STP from
the existing portions of the collection system of the sewage
service area was due to infiltration, that is the leaking of
ground water into the pipe through the cracks and joints in the
pipes, with inflow, that is the running in of rainfall from the
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surface of the ground through leaky manhole covers, etc., adding
additional flow. All of this non-sewage flow must be treated at
the STP. This means that the additional newly constructed
capacity of at least 6.5 mgd (= 15-8.5) is considerably more than
the present flow of sewage alone, "currently" about 5 mgd only.
The position advanced by both Howard County and its
contractor for the §201 plan, is that the infiltration was not
"excessive", meaning that it was cheaper to treat this additional
flow at the STP and to discharge it into the stream, rather than
to attempt to correct the leaks in the collection system. For
this determination, the infiltration in each portion of the
collection system was normalized for comparison to a criterion of
1500 gallons/(day, mile of pipe, inch of pipe diameter). But the
internal EPA document (PRM ? ) setting this numerical criterion
for determining when infiltration become excessive, was based on
a national survey during a time period which clearly indicates
that the costs involved were for secondary treatment. Therefore,
when the advanced treatment at the Savage STP is taken into
account, it is clear that a lower numerical value for this
criterion is applicable. With any reasonable lowering of this
numerical criterion, at least three further portions of the
collector system must be deemed to have "excessive" infiltration,
according to the infiltration values for these portions of the
system that have been made public. Tt is also noted that most of
this collection system was admitted to have been less than 10
years old.
The question raised is whether we must provide equal future
treatment capacity for such infiltration from future portions of
the collection system in the service area. It is not understood
why the DEIS ignores this very significant aspect of the entire
problem of defining sewage treatment needs. Specifically, does
technology exist for leak-proof collection systems, at a
practical cost, or should large collection systems generally be
associated with the disadvantage of large I/I flows? This whole
problem suggests that investing in smaller, more leak-proof
systems, for instance for a local land treatment site, with the
simpler pretreatment (which does not require a large flow for
economical operation), would result in substantially smaller
flows per capita. This indicates that a shift entirely away from
the concept of a large collection system with a large STP is
possibly in order. The smaller flows per capita without the I/I
would reduce the local land requirements. These considerations
are fully appropriate in defining the alternatives for the EIS.
While the plant is indicated to have been designed to pre-|
vent possible flooding based on the 100 year flood level (p. 9
par. 2), it is not clear that this consideration includes the
flooding within the collection system (I/I) which must be
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expected under a rainfall leading to a 100 year flood level. The
report should make this clear. It appears that substantial
allowances should be made for I/I for future portions of the
collection system. In this regard, it is interesting that some
of the blame for the I/I has been placed on the "lateral"
connections to individual houses, and not on the larger pipe
portions of the collection system, which are possibly already
installed (the BIS should make this clear). Thus, a large margin
in the future should be allowed for the leaky collection system
particularly the house connections. '
4b. Alternatives Without the Pipe
It is not understood why it is necessary or proper to in-
clude the 3-1/2 mile pipe relocating the discharge point below
the Fort Meade water supply intake in all the alternatives
involving some discharge to the Little Patuxent. At least some
discharge above the intake was apparently regarded as safe in the
past, when the treatment by the old STP was less stringent and
reliable. Since the existing 10 mgd capacity or less could
simply have been upgraded, as it has been, and since a new water
supply treatment facility is believed to have been built at Fort
Meade, certainly a great improvement" in any health risk would
have resulted, without the need for the pipe, if 5 mgd or more
had been disposed of by spray irrigation, or discharge outside
the basin.
What is the estimated cost for Fort Meade to develop new
wells to substitute at least 3 mgd or more of water which in the
future it will not be able to withdraw from the Little Patuxent
River at low flow? This should be included in the cost
comparison of alternatives. Was a new treatment plant for the
water supply also built, and if so what was its cost, and what
are the relative treatment capabilities between the old and the
new facilities? We note there are still some wastewater
discharges upstream, including heavy metals from the G.E.
facility.
It is noted for the record that the decision to build the
"3.5 mile outfall line" relocating the discharge below the Fort
Mead water supply intake is attributed to a document in 1976 (p
1, par. 7). Nevertheless, the entire issue of this long pipe
(having a peak capacity of about six times the low flow of the
stream, and which has now been buried in the floodplain adjacent
the stream, with at least one crossing) was not addressed in the
original negative declaration concerning the upgrading and ex-
pansion to 15 mgd, but was rather the subject of a separate and
much later negative declaration. Now, however, it is represented
as an integral part of the project. It is disengenuous at best
the way the issue of the relocation of the discharge point is
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avoided by Impliedly stating this to be "the present discharge
point" (p. 11, par. 2). The EIS must now address whether or not
the relocated pipeline should have been built at all. This is an
issue over which there was very much public contention, and very
little objective explanation.
4c. Ts a Stream that is All Effluent "Swimmable and
Fishable"?
It is considered quite misrepresentative to formulate Table
III-6 at p. 44 as though the pipe had not been installed, while
including the pipe, without discussion of its need, in defining
the alternatives. The result is that the table represents the
stream flow at the Fort Meade intake point to be only 53% treated
effluent at low flow. In fact, with the outfall pipe in place,
essentially little or no natural stream flow will pass the water
supply intake at low flow, immediately after which the discharge
from the Savage STP occurs, followed by that from the Fort Meade
STP, the Patuxent STP, etc. The presentation in the DEIS
obscures the fact that the Little Patuxent River becomes
essentially 100% treated effluent at low flow. It is
respectfully submitted that this EIS must address the percentage
of effluent in the stream, down to the confluence of the Little
Patuxent river with the Patuxent mainstem, including the
concentration just below the Fort Meade water supply intake but
with the relocated outfall. The main point is whether EPA and
the State endorse such waters to be "swimmable and fishable"
waters, as they are classified by the State.
"Water borne disease continues to be a potential threat to
public health, principally through primary contact recreation,
contaminated shellfish and contaminated water supplies" (p. 49,
par. 1). This and the following section of the DEIS provide
support for the concern that a stream that is essentially 100%
effluent cannot be regarded as swimmable and fishable. Also, it
appears that non-point contributions of viral and bacterial
sources are not properly addressed. If the water supply treat-
ment facility at Fort Meade is inadequate to safely treat the
bacteria and viruses instream, to provide a safe water supply
from the 50% effluent in the stream at low flow without the pipe
then we question how safe the stream can be for human recreation
contact such as swimming, etc., since the bacteria, viruses,
etc., instream must be many orders of magnitude higher. There
should be a more candid discussion of whether it is state and
federal policy that the stream is now considered to be safe for
for its designated purposes.
(§)
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4d. Land Treatment Alternatives
Consideration of alternatives should include a fair
appraisal of land treatment systems, particularly those allowing
the establishment of smaller, more local service areas, possibly
only with primary treatment, followed by application to a locally
available smaller field. Sites should be searched for where the
collection system passes reasonably close to available land.
Innovative systems such as artificial wetlands should be
considered, since it is understood that one is presently
operating an Easton on the Eastern shore, involving two shallow
lagoons, that were constructed without federal funds. The
scientific community has pointed out that a wetland metabolizes
nutrients for conversion into biomass at a rate of up to 10 times
faster than of ordinary cropland. Since the charette has
recommended seasonal N control, this must be evaluated. Again it
is noted that no overland flow alternative has been fairly
evaluated. A layer of clay can be laid over percolable land to
create an overland flow site.
The requirements of over 700 acres per mgd (p. 15, par. 4)
and a 151 day holding pond are not credible. Neither EPA nor the
State requires such long storage, which inflates the land
requirement. These points require explanation. (The statement
at p. 40, par. 5 is very ambiguous.) Also it is entirely fair to
question whether any properties in local, state or federal
government hands would in fact be suitable. It is not seen why
at least local or state lands are not subject to fair considera-
tion for this purpose, particularly if presently being used only
Cor forest cover, agricultural uses, etc. The political
leadership of Howard County has long advocated the use of tax
dollars for agricultural preservation programs, so that
politically the (phony) issue of removing developable land from
the potential increased tax base should be considered most. Also
no areas in either Montgomery County, Prince Georges County, or
in the less developed Anne Arundel County are shown in Figure II-
4, although all of these counties lie closer to the STP than the
nearest available land site shown in Howard County.
Reference to the 1976 Whitman Requardt study for the county
(at p. 20, par. 1) is interesting since it in fact discusses only
a 30 day storage capacity, with ranges for different types of
land treatment of 62-560 acres per mgd for irrigation and 46-100
acres for overland flow. Although the cost data in this report
is extremely difficult to understand, the bottom line for the
land treatment alternative was stated to be $38 million (p. viii-
01) for the year 2000 flows, involving over 5,000 acreas (see
appendix 15). The inconsistencies between these different plans
essentially reduce the credibility which may be placed in any of
them, particularly when the present DEIS presents such extreme
values, totally inconsistent with the previous numbers.
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4e. Cummulative Effects on Salinity, Algae and
Dissolved Oxygen in the Estuary
Since the release from the WSSC reservoirs are required to
be equivalent to the low flows from the upstream drainage areas,
the result of all the STP discharges in the basin is to increase
the low flow into the estuary. The conclusion that "the upper
river oyster bars are below population level for profitable
economic harvest" (p. 88, par. 4) ignores the commitment by the
State at the charette to increase the seeding activities in the
estuary. The admission that during low flow "even a 5 mgd
incremental discharge may reduce salinity enough to effect the
life in the estuary" (p. 90, par 1) becomes more significant when
the full 15 mgd discharge is considered, as the law requires.
When the cummulative affect of all the proposed discharges in the
basin are taken into account, also as the law requires, then
clearly there is impact on the upper oyster bars. These oyster
bars rely critically on the limited periods of low flow and high
salinity as part of their natural growth cycle. The DEIs points
out how critical even a 100 cfs flow differential can be (compare
pars. 4 and 5 on p. 94).
Similarly, the model runs on pages 76-81 must be formulated
and discussed in terns of cummulative effect, within the context
of a basin wide nutrients strategy. It is totally improper to
consider the effects of one STP alone, especially when assuming
all others provide different treatment.
Further, the statement at p. 57, par. 2, that during low
flow wastewater comprises 30% of the total flow at the Route 50
bridge appears to be too low a value. In any case the 7-day, 10-
year low flow at this point of the river should be specified and
the percentage cummulative effluent at low flow projected. Also,
as a cummulative effect, the percentage of effluent in the low
flow into the head of the estuary, below the Western Branch STP
discharge, should also be specified. The §303e basin plan showed
the low flow values at different points in the river, which
numbers were subsequently revised in a letter from Howard Wilson,
due to much lower run off in dry periods from the Costal Plain
than from the Piedmont Plateau. The low flow values of Table
III-3 relate primarily to Piedmont Plateau drainage.
4f. In-Estuary Aeration
The discussion on in-stream aeration is very interesting
whether (1) by stirring the seasonally stratified lower layer for
mixing with the upper layer, so that the entire water column
circulates to the surface to pick up oxygen and again to the
bottom to supply oysters, or (2) by bubbling or diffusing air or
oxygen into the lower layer. This should be given more serious
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consideration before being discarded either as not cost
effective, as not aesthetically acceptable, or as producing oth
environmental complications. It is believed that restoration 0fC
the aquatic health of the estuary may well require not only up-
stream efforts to control point sources and basin wide efforts
control non-point sources, but as well such other possible
remedial measures.
Since an oyster, and particularly during the growing seaso
filters a very large volume of water each day, converting a par?'
of the suspended microscopic plant and animal life to body
tissue, a body of water with a healthy oyster community must
expected to provide its own significant contribution to reducti
in algae. Harvesting of the oysters, or of the fish which can
also migrate out of the basin, all potentially contribute to
additional beneficial reduction in algae. The cost economics f
such an aerator or stirrer, for achieving the goals defined at
the charette, may very well be cost competitive with the larq~
capital investments upstream. "
4g. Costs
It is interesting to compute that the average cost per
person per day, for the overhead and management for alternative*
one (table II-7) reduces to only 0.9 cents per person per day
less than one penny per day. Such a number is considered to be
quite unrealistic, in view of the advanced treatment now
required. Costs for secondary treatment alone generally run on
the order of $1 to $2 dollars per thousand gallons, and since
generally 100 gallons per capita per day is assumed, this means
daily per capita cost of at least 10 cents. This suggests that a
the costing procedures are totally fallacious, at least the O
cost. Another point as to the credibility of the cost figures **
is that the pipe for relocating the outfall is believed to hav4
actually cost approximately twice the 2-1/2 million dollars re-
ported in Table II-7. ~~
4h. Other Regulation
If the health and productivity of the estuary is to be
restored, then greater control of sport and commercial fishina
will likely be necessary, besides the point and nonpoint sourc
controls. If there were more fish, then there would be even
harvesting pressure, both professional and sport. In the spr™°re
there are an amazing number of nets suspended in the estuarv f '
the spawning runs, and it is clear that there would be manv mn°r
if the catches were any better. Also, the undersigned has e
personally joined groups of floating sport fishing boats on!
realize that only juvenile spot were being hooked, for hours to
end. 0r*
******
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Please feel free to call or write in the event we may be of
help in or locating any document or other source indicated above,
or in clarifying or supplementing any point above.
The right to submit further comment for the record,
concerning the feasibility of land application as a basinwide
strategy, is respectfully requested. By letter of 15 December
1981, HydroQual admits of some error in their modeling report,
promising a letter later that week. A copy of the letter has
been requested from the State O.E.P.
Very truly yours
W. D. Johnston III
Staff
Patuxent TLC
Submitted on behalf of:
Calvert County Watermen's Association
Thomas Abner, President
Davidsonville Area Civic Association
R. Graydon Ripley, President
Holland Cliff Shores Citizens'Association
Ron Dunham, President
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THOMAS C. ANDREWS
DIRECTOR
STATE OF MARYLAND
DEPARTMENT OF NATURAL RESOURCES
WATER RESOURCES ADMINISTRATION
TAWES STATE OFFICE BUILDING
ANNAPOLIS. MARYLAND 21401
(301) 269-3675
October 29, 1981
Ms. Rochelle Volin
United States Environmental
Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
Dear Ms. Volin:
The Maryland Water Resources Administration, Water Supply Division has
completed a preliminary review of the "Draft Environmental Impact Statement,
Little Patuxent Water Quality Management Center." The document is well
organized and contains a wealth of useful information.
Our primary comment relates to an incorrect statement made in
paragraph two on page 39: "Withdrawals of less than 1,000 gallons per
day (gpd) do not require a water appropriation permit from the State of
Maryland, and therefore are not represented." In fact, all appropriations
of groundwater and surface water, regardless of the amount, require a
water appropriation permit from the State. Only individual domestic users
and farmers are exempted from the State's permit process.
A copy of Maryland's Water Appropriation Law is attached for your
information. If you have any questions regarding the allocation of water
in Maryland, please do not hesitate to contact me.
Sincerely,
Robert D. Miller, Chief
Water Supply Planning
RDM: emp
Attachment
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Natural Resources
§ 8-802
accordance with the best interests of the people of Maryland, it is the policy of
the state to control, so far as feasible, appropriation or use of surface and
underground waters of the state. Also, it is state policy to promote public
safety and welfare, and control and supervise so far as is feasible, construction,
reconstruction, and repair of dams, reservoirs, and other waterworks in any
waters of the state.
REVTSOR'S NOTE
This subsection presently appears as Article
96A, § 10 of the Code. The only changes made
are in style.
(b) This subtitle is in addition to and not in substitution for any existing laws
of the state.
REVISOR'S NOTE
This subsection presently appears as Article
96A. $ 22 of the Code. The only changes made
artfiirstyle: -
(An. Code 1957, art. 96A, §§ 10, 22; 1973,1st Sp. Sess., ch. 4, § 1.)
§ 8-S02. Permit to appropriate or use state waters.
(a) Required. Ev^ry person is required to obtain a permit from the
department to appropriate or use, or begin to construct any plant, building, or
structure which may appropriate or use any waters of the state, whether
surface or underground. The permit is obtained upon written application to the
department. The applicant shall provide the department with satisfactory
proof that issuing the permit will not violate the state's water quality
standards or jeopardize its natural resources.
(b) Exemptions. — This section does not apply to use of water for domestic
and farming purposes, use of water for an approved water supply of any
municipality if the use was in effect on July 1, 1969, or to any particular use in
existence on January 1, 1934, if that use has not been abandoned.
(c) Application for certificate of public convenience and necessity associated
Iffith power plant construction same as permit application. — Notwithstanding
any other provision of this subtitle, application to the Public Service
Commission for a certificate of public convenience and necessity associated
with power plant construction involving use or diversion of waters of the state,
under Article 78 of the Code construes an application for the permit required
by this section and is handled in accordance with § 3-306 of this article. If an
application i» made to the Public Service Commission, the hearing provided for
by this subtitle shall be required. Any pertinent evidence shall be presented at
the hearing required by Article 73, § 51A. The permit required by this subtitle
is included in the certificate of public convenience and necessity issued by the
Public Service Commission. (An. Code 1957, art. 96A, § 11; 1973, 1st Sp. Sess.,
ch. 4, § 1.)'
REVISOR'S NOTE
This section nrt-fently ap(*ars as Article The word "person" is used in li«ht of its
06A, 111 of the Code. In subsection (a), the first definition in $ 8-101 (h). The only other changes
cltusc is proposed for deletion because it is made are in style,
obsolete.
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UNITED STATES
ENVIRONMENTAL PROTECT I OH AGENCY
DECEMBER 8, 1931
r ?. A FT F ' IV I R O M r, !JTAL I M ? A C T STAT E V, w H T
LITTLE PATUXENT WAT EE QUALITY
MANAGEMENT CENTER
(SAVAGE PLANT)
I30VJARD COUNTY, MARYLAND
GEORGE' HOWARD PL DC.
3430 COURTHOUSE DTIVE
ELLICOTT CITY, MA7YLAMD
THE ABOVE-ENTITLED PUPLIC HEARING ',/AS HELD
DEFORE GEORGE PENCE AT 7s30 P.M.
IIALLOCK & BETZ, INC
2 HOPKINS PLAZA
SUITE ^000
BALTIMORE, MARYLAND
(301) 752-1733
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PROCEEDINGS
MR. PENCE: GOOD EVENING, LADIES AND
. welcome to this puplic hearing
CONCERNING TIIE UPGRADING AND EXPANSION OF THE LITTLE
PATUXCNT MATER QUALITY MANAGEMENT CENTER, SAVAGE
PLANT .
THE PURPOSE OF THIfi nrM?IMC. IS TO SOLICIT
COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
OR AS WE WILL REFER TO IT, EIS, PREPARED THE
ENVIRONMENTAL PROTECTION AGENCY.
MY FAME 13 GEORGE PENCE, I AM TEE CHIEF OF
THE ENVIRONMENTAL IMPACT BRANCH FOR THE REGION Tl'RCE
OFFICE OF THE EPA, WHICH IS LOCATED IN »HILAHELPHI a .
FOR THOSE OF YON WHO HAVE NOT ALREADY r>OUE;
SO, I WOULD LIKE TO REQUEST THE SIGNING OF THE
ATTENDANCE SHEET LOCATED AT THE TABLE AT THE RACK op
THE ROOM• ALSO PLEASE INDICATE IF YOU ARE GOING TO
Of TESTIFYING TONIGHT.
THIS HEARING IS BEING MELD BY EPA nUR3'JART
TO THE FEDERAL REGULATIONS OF THE COUNCIL OF
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E IT VIR OIJ MENTAL QUALITY, PUBLISHED NOVEMBER 20TM, 1970.
AMD EPA'S REGULATIONS COVERING THE PREPARATION OF
EIS WAS PUBLISHED ON NOVEMBER 6TH, 1979.
THE PURPOSE OF THIS HEAPING ir. TO PROVIDE
INTERESTED PARTIES AN OPPORTUNITY TO COMMENT ON
EPA'S DRAFT ENVIRONKENTAI, IMPACT STATEMENT THROUGH
PUPLIC TESTIMONY. TESTIMONY GIVEN TONIGHT WILL
3ECOMC PART OF THE PUPLIC RECORD. THE COMMENT
"ERIOD FOP THIS DRAFT ENVIRONMENTAL IMPACT STATEMENT
WILL REMAIN OPEN UNTIL DECEMBER 21, 1901. ALL
WRITTEN COMMENTS SUBMITTED BY DECEMBER 21 ST AND ORAL
TESTIMONY PRESENTED TONIGHT WILL BE DISCUSSED IN THE
FINAL ENVIRONMENTAL IMPACT STATEMENT. WRITTEN
COMMENTS CAN BE SUBMITTED DIRECTLY TO EPA AND
ADDRESSED TO MS. MARY SARNO, EIS PREPARATION SECTION,
MAIL CODE 3PMB1, CURTIS BUILDING, 67 H AND WALNUT
STREETS, PHILADELPHIA, PENNSYLVANIA, 19106.
FOLLOWING THE CLOSE OF THE PUBLIC COMMENT
PEPIOD A FINAL EIS WILL BE PREPARED BY EPA. THIS
'7 ILL INCLUDE A SUMMARY OF THE PUBLIC HEARING
PROCEEDINGS, RESPONSES TO ALL SUBSTANTIVE COMMENTS
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RECEIVED DURING THE 45 DAY COMMENT PERIOD, AMD A
DESCRIPTION OF THE RECOMMENDED AND ACCEPTABLE
ALTERNATIVES. THE FINAL EI3 WILL THEN BE PUBLISHED
AND THE PUBLIC WILL HAVE 30 DAY S IN WHICH TO COMMENT
TO EPA BEFORE ANY ADMINISTRATIVE ACTION IS TAKEN.
A NUMBER OF INDIVIDUALS HAVE EXPRESSED AN
INTEREST IN TESTIFYING TONIGHT. I WILL BEGIN
CALLING ON PERSONS WHOSE REQUESTS iJF. HAVE RECEIVED.
AFTER I HAVE GONE THROUGH THE LIST I WILL OFFER
ANYONE ELSE WHO WISHES TO TESTIFY AN OPPORTUNITY TO
DO SO. IN ORDER TO OBTAIN A COMPLETE RECORD OF YOUR
COMMENTS, A COURT STENOGRAPHER IS PRESENT, AND A
COPY OF THF TRANSCRIPT OF THIS PROCEEDING AS WELL AS
ALL WRITTEN COMMENTS RECEIVED BY THE ^'PA WILL RE
INCLUDED IN THE FINAL FIS.
WE ASK THAT YOU KEEP YOUR ORAL
PRESENTATIONS AS BRIEF AND TO THE POINT AS POSSIBLE.
EQUAL WEIGHT WILL BE GIVEN TO SIMPLE CONCURRENCES IF
SOMEONE SPEAKING BEFORE YOU HAS STATED YOUR OPINION.
WE WOULD ALSO ASK THAT INITIALLY ONE SPOKESPERSON
SPEAK ON BEHALF OF ANY ORGANIZATION OR INTEREST
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GROUP. PLEASE SUBMIT A COPY OF ANY EXTEMGIVF
WRITTEN TESTIMONY TO THE STENOGRAPHER FOR INCLUSION
117 TO THE RECORD IN FULL. I DO REQUEST THAT WHEN I
CALL YOU!? NAME IF YOU WILL COME UP TO THE PODIUM AND
THAT YOU PLEASE STATE YOUR NAME, AODRF.SS A N ^ ANY
AFFILIATION APPROPRIATE, FOP IJSF. TO TUT STFHOGRftnHKR .
BEFORE I BRIEFLY A DP RE S3 THE 1ST, ij E F,
SURROUNDI KG THIS EIS I UOULP LIKE TO Mi*NT I OH TJ'AT
THERE WERE TYPOGRAPHICAL ERRORS IN THE FIGURES For
SOME OF THE ALTERNATIVES APPEARING IN A F EW "LACES
IN THE. DRAFT DOCUMENT. FOR THOSE OF YOU WHO HAVE
NOT RECEIVED THEM, THERF ARE COPIES OF ERRATA SHEETS
AT THE BACK OF THE ROOM WHICH CORRECT THOSE ERRORS.
IN 1977 EPA ISSUED A NEGATIVE DECLARATION
ON THE PROPOSEE FOURTH ADDITION TO THE LITTLE
PATUXENT WATER QUALITY MANAGEMENT CENTER, SAVAGE
PLANT. IT WAS FPA'S POSITION THAT THE PROPOSED
DPGPAD E AND EXPANSION OF THE PLANT FROM 10 MGO TO 15
MOD OF ADVANCFD WASTE TREATMENT WOULD NOT ADVERSELY
IMPACT THE RIVER IN ITS CAPACITY AS A WATER SUPPLY.
HOIJFVFR, MARYLAND COUNTIES OF CHARLES, CALVERT AND
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ST. MARY'S TOOK ISSUE WITH KPA'S FINDINGS AND FILED
SUIT AGAINST US.
IK JULY or 1980 THE COURT ORDERED F; ° A -n0
ADDRESS THE POSSIBLE ENVIRONMENTAL IMPACTS FPOM
ISCHKASEH NITRCGKB DISCHARGES FROM THE EXPANDED
PLANT ON THE LOWER PATUXENT ESTUARY ANC OU ANY
POSSIEiLE FUTURE WATER SUPPLIES. THIS DRAFT, K1S,
WAS PREPARED IN DIRECT RESPONSE TO THAT COURT ORDER.
WHICH ALSO STIPULATED THAT CONSTRUCTION CONTINUE On.
THE FOURTH ADDITION. IN THE COURSE Ol THIS K I f> ,
SEVP.N ALTERNATIVES WERE EVALUATED. TRI5FLV , OMR
FINDINGS ARE AS FOLLOWS:
ONE, THE DIVERSION OF WASTE WATER EFFLUEM?
TO BELOW THE FORT MEADE INTAKE STRUCTURE WILL CAUSE
FORT HEAPS TO LOSE THE AVAILABILITY OF APPROXIM ATP T.-y
3 MOD FROM THE RIVER AT CERTAIN TIMES. FORT ME ADD
IS PRESENTLY ACQUIRING PERMITS FOP. T FJ E A D D I T I O! J OF
FOUR WELLS TO OFFSET THE LOSS. DOWNSTREAM L'^RS OP
THE RIVER WILL NOT BE AFFECTED.
TWO, THE LITTLE PATUXENT WATER QUALITY
MANAGEMENT CENTER IS NOT A MAJOR SOURCE OF
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MICROBIOLOGICAL CONTAMINATION TO THE RIVER.
EXPANSION WILL HAVE MINIMUM IMPACT, AND UPGRADING
THE FACILITY SHOULD ENSURE THAT ANY CONTAMINATION
POTENTIAL IS FURTHER MINIMIZED.
THREE, MODELING STUDIES SHOW THAT
PHOSPHOROUS REMOVAL WOULD BE MOPE EFFECTIVE THAN
NITROGEN REMOVAL IN ACHIEVING ALGAL CONTROL.
FOUR, GIVEN THE INFORMATION AVAILABLE AT
THIS TIME, IT IS OUR CONCLUSION THAT THE PROPOSED
INC P E A t j h I. DIE,CHARGE AT Til E LITTLE PATUXENT WATER
MANAGEMENT CENTER ALONE WILL NOT D EG R A Pn WATER
QUALITY IN THE ESTUARY TO THE POINT WHERE IT WOULD
CAUSE SIGNIFICANT DAMAGE TO AQUATIC LIFE.
MP. BILL JOHNSTON?
MR. JOHNSTON: I WAS A MEMBER OF THAT
COMMITTEE THAT WAS FORMED, AND I WAS REQUESTED TO
MAKE A FEW REMARKS AS HAVING BEEN A MEMBER OF THAT
COMMITTEE FOR THE PUTTING TOGETHER THE DRAFT OF EIS.
ONE QUESTION I GUESS WF. ALL HAD IS WHAT IS
THE SIGNIFICANCE OF THIS DOCUMENT? SINCE IT TAKES
US BACK IN TIME, TRIES TO FIGURE OUT WHAT ELSE WE
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SHOULD HAVE DONE, NOW THAT WE HAVE DOME SOMETHING
ELSE, WHAT ABE WE SUPPOSED TO DO WITH WHATEVER WE
FIND IH THIS DOCUMENT? THE RE MUST BE SOMETHING,
ROME SJBSTAJJCE, SOME SIGNIFICANCE THAT COMES OUT OF
THIS DOCUMENT IN THE WAY OF PROCEDURES, THE ONGOING
PPOCF.DURE5 FOP THE PLANNING AND BASIN . ACTUALLY,
POST, I ELY HOW THAT MIGHT TIE TOGETHER WITH THE
R ECOf ii I END AT I OH S WHICH -J ERF. ARRIVED -AT LAST WEEK P. Y
THE STATE AS TO WHAT COMBINATIONS MIGHT NATURALLY
RESULT BETWEEN THE SIGNIFICANCE OF THE CIS.
EVEN THOUGH IT IS AFTER T I! E FACT, AMD
"ARTICJ.LAP T.. V AS TO THE HITROGFN, T H E GOAL r»ICI! HAS
BEEN SET AMD SOFT OF AGREED UPON AS A RECOMMENDATION
BY ALL PARTIES IS GUIDIMG IT EQUALLY RETWEEN THE
POINT SOURCES AND NON-POINT SOURCES TO TRY AMD
REDUCE IT FROM 3,00 0 POUNDS A DAY F.AC!!, POINT AND
NON-POINT . THE EPA MAN, JIM MULLEN FROM EPA, FEEL?!
THAT THE NON-POINT GOALS CAN EASILY BE ACHIEVED.
FOR INSTANCE, WESTERN RRANCH HAS FIVE
RETENTION DAMS, AND THF F15 A FELLOW'S OPINION WAS
THAT 2,000 POUNDS A DAY WAS QUITE ACHIEVABLE,
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PARTICULARLY DURING THIS SIX MONTH PERIOD OF THE
SEASONAL STRATEGY FOR THE NUTRIENTS, SO IT IS KIND
i
OF REACHED DY CONSENSUS. ;
i
i
SO THERE IS A QUESTION OF WHAT THE I
SIGNIFICANCE OF THE DOCUMENT REALLY IS AT THIS POINT j
AND TO WHAT EXTENT IT CAN RE USED FOR UK ATI:,Vr.S. IT |
IS NOT TOO CLEAR. UNFORTUNATELY, I ADMIT Til AT I i
HAVEN'T COMPLETED STUDY OF THIS DOCUMENT YET. AS A j
I
CITIZEN INVOLVED THREE DAYS LAST WEEK. IT WAS QUITE A j
BIT . |
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NOW, I DON'T BELIEVE, THOUGH, JJST FRO!! j
THE BRIEF LOOKING, THAT THE OVERLAND FI.OW
ALTERNATIVE WAS ACTUALLY RUN THROUGH A FY KIND 0*
i
DEFINITIVE COST. IN FACT, IN ONE OF THE LITTLE !
I
I
S U E C 0 D "41 T T E E S WE JUST O'JICKLY PRICED OUT. YOU KNOW, !
USING THE EPA ESTIMATE LITERALLY, T HE NEW DESIGN j
MANUEL, AND ESSENTIALLY THE THOUGHT WAS HEY, TAKE IT
AUD APPLY IT TO OVERLAND FLOW, COLLECT IT, BRING IT
BACK TO THE PLANT WUEPE YOU GOT YOUR -- REMOVE THE
NITROGEN AT THE OVERLAND FLOW, BRING IT BACK TO THE
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RETURN FLOW WITH FLOW PIPES — AND YOU CCHLD
PROBABLY RELAY A SECOND PIPELINE OH TOP OF THE FIRST
PURLIN* FOR AS CHEAP AS LAYING THE FIP.ST OH" '/FERE
the PUMPS ARE ALL UPHILI., BUT YOU FLOW IT 5: ATURALLY
CACK DOWNRIVER IT MAY VERY WELL P.JT THAT TUT. OVKHLMiT.
FLOW ALT F P> f1A TIV E XI G'.IT PPOV* A VERY COST
AHVAtTTACEOUS ALTERNATIVE I'l PEKOVILT, THE i J T T R O n
TO THE nMTF.riT THAT THAT CAN EE DF.FFH^P .1 S A
STRATEGY OR A HESIRA.PL E ALTERNATIVE OR TO Ti^ F. X T F
that that Kir.iiT nr. included in 'ii?rt tut: cost for tup.
GREATEST ALTERNATIVES FOR REMOVING NITROGEN AHD
OTHER PLANS, SAVAGE IS THE S ECO I'D TMSCHAROF
PI TMI-: RIVER, so IT IS SORT OF IMPORTANT .
I N T F R E S T I M G T MAT THE JiO»!-"OI!:TS ARE TO * P
rpo^vr DOWU ItTTO ALL COm'TIFS OF THE nACIN A HP TO
Ti,y T0 cnT THE TOTAL OF 7,0^0 A DAY I". TOTAL
POUTPS A YFAR "MS ALMOST ? MILLION POULTS A Yr AR ^
NITROGEN. THAT COMES DOWN TO FIVE A tl D A HALF A DAY ,
IS THAT RIGHT, GARY? DO YOU WANT TO COVER SOME OF
THESE N 'J M H E P. S ?
A SPECTATOR: WO
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MR. JOHNSTON: I WILL TRY Afjn G 57 IT ALL
STRAIGHT.
I MOULD LIKE TO REQUEST AT THIS TIM E IF
MARY SARNO COULD ASK THAT THE STATU OTP SUtlT) ME A
COPY OF THEIR WRITTEN S U RC.ITTAL AS SOOH A" IT
BECOMES AVAILABLE. ARC YOU MARY GARWO ?
MS. SARNOs YES.
MR. JOHPSTON: OKAY. I WOULD LIKE TO
REQUEST IF YOU COULD REQUEST THAT THE STATE COULD
SEND ME A COPY OF THE STATE'S WRITTEN INPUT AS SOOH
A S I T IS AV.» I L ABLE , PLEAS E .
ONE THItJG I WOULD WANT TO CHUCK IS THE
CONTRIBUTIONS AND THE -- NOi'3-POI'!T SFWER
CONTRIBUTIONS FROM THE PROJECTED GROWTH WHICH THE
EX-'AH SI ON , THE FOURTH ADDITION, IS DESIGNED TO COVE?
WHICH JTASK'T OCCURRED YET. I WOULD LIKE TO TAKE
ISSUE WITH YOUR REPRESENTATION THAT THE OUTCOME OF
THE CHARFTTL AND OF THE HYDROQUAL 'WATER QUALITY
MODEL FOR THE RIVER REPRESENTED THAT YOU HAD GREATER
CONTROL OVER THE ALGAE BY GOING AFTER PHOSPHOROUS
INSTEAD OF NITROGEN, BECAUSE I TflINK IT Hi FACT IS A
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LITTLE BIT MORA COMPLEX THAN THAT. WHAT C A M E OUT OF
THK CtlARFTTK , THE FINAL CONSENSUS PAPER, WHICH WILL
BECOME AVAILABLE SOON. IS THERE JS A PHOSPHOROUS
r K II IC fl'1 E IT T PROBLEM It! THE UPTf RIVER AMP A MITROGENJ
EMRICIIMFKT PROBLEM IN THE LOWER RIVER, AND KF.flOVING
PHOSPHOROUS DOESN'T HELP THE LOWER RIVER. THAT, I
RELIEVE, IS WHAT THE CONSENSUS OV. THOSE I1A7TEP.S ARE.
SO THAT IS SOMETHING THAT SHOULD PR ACCURATELY
REFLECTED 111 THE FINDING OS* EIS.
I AM SORRY I DOM'T HAVE FULL POINTS AT
THIS TIME.
MR. PEUCE: THANK YOU, WR. JOHNSTON.
JAMES IP.VIN REPRESENTING HOWARD COLPiTY?
'•'.R. I RVIU: MY NAME IS JAMES IRVIH, T Ml
CHIEF OF THE BUREAU OP ENVIRONMENTAL SERVICES FOR
THE HOWARD COUNTY DEPARTMENT OF PUBLIC WORKS. I
HAVE A SHORT STATEMENT THAT I WILL GIVE YOJ A COPY
OF WITH OUR TESTIMONY. ALSO I HAVE A SET OF
DETAILED COMMENTS ON THE REPORT THAT I WOULD LIKE TO
INCLUDE INTO THE HEARING TONIGHT.
HOWARD COUNTY HAS REVIEWED THE DRAFT
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ENVIRONMENTAL IliPACT STATEMENT FOR THE LITTLE
PA7UXENT v.' AS T E WATER TREATMENT PLANT >\ND CONCLUDES
THAT T'lF REPORT SUPFORTS THE DECISION TO CONSTRUCT
THE FOURTH ADDITION AS PLANNED. ACCORDINGLY, WE
GENERALLY SUPPORT THE EIS AS DRAFTED. THE F. IS
PROVIDER A BASIC FOR CONCLUDING THAT THE FOURTH
ADD IT 10*4 WILL NOT HAVE AN ADVERSE ENVIRONMENTAL
IMPACT OH THE PATUXEMT RIVER, AND UPHOLDS THE
NEGATIVE DECLARATION FOR THE CON STRUCT I OH GRANT THAT
ijm; issued hy epa.
Tl'IS REPORT, COUPLED WITH THE RECENT MAJOR
STUDY OF THE PATUXENT RIVER PERFORMED UYDROOUAL.
INDICATES THAT THE HOWARD COUNTY FACILITY IS BOTH A
COST EFFECTIVE AND ENVIRONMENTALLY SOUND ALTERNATIVE
WHICH PROVIDES WASTE WATER TREATMENT CAPABILITY
CONSISTENT WITH SCIENTIFIC PROPOSALS FOR MITIGATING
ADVERSE WATER QUALITY IMPACTS.
WE REQUEST THAT EPA PROMPTLY FINALIZE THIS
EIS SO THAT HOWARD COUNTY MAY PROCEED WITH THF
PREPARATION OF PLANS REQUIRED TO MEET FUTURE WASTE
WATER TREATMENT NEEDS. SPECIFICALLY, COMPLETION OF
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OUR 2 01 FACILITIES PLAN IS REQUIRED TO INSURE
ORDERLY GROWTH WITHIN THE COUNTY.
OUR REVIEW OF THE DRAFT DOCUMENT RESULTED
IN THE PREPARATION OF NUMEROUS DETAILED COMMENT^,
WHICH ARE ATTACHED TO THIS TESTIMONY FOR YOUR
CONSIDERATION. OF PARTICULAR INTEREST WAS THE
EVALUATION OF THE LAND TREATMENT ALTERNATIVE. IT I s
OUR UNDERSTANDING THAT THE COSTS GIVEN IV THE
EXECUTIVE SUMMARY AND ON PAGE 3 0 FOR A L TE R N A T I V ^ S
3A2 , 3 B 2, AMD 4 ARE INCORRECT. THE CORRECT COST
ESTIMATES APPEAR ON PAGES 34, 36 A^D 37. OF
PARTICULAR NOTE, FOR ALTERNATIVE 4 THE CORRECT
ESTIMATED COST IS $67,730,000 RATHER THAN
$5 6,300,000.
THE EIS STATES THAT LAND AREAS REQUIRED
FOR TREATMENT OF FIVE AND 15 MGD WOULD EQUAL 3,540
ACRES AND 8,923 ACRES, RESPECTIVELY, not INCLUDINg
BUFFER ZONES AND A 151-DAY HOLDING POND. IT MUST
NOTED THAT BUFFER ZONE REQUIREMENTS CAN BE OUITF
EXTENSIVE. BASED ON STATE GUIDELINES REQUIRING A
MINIMUM OF A 500 FOOT BUFFER 20NE SURROUNDING A
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TREATMENT SITE, ACREAGE WOULD BE INCREASED BY
BETWFEN 10 AND 20 PERCENT. IN ADDITION, ACREAGE
MUST BE ACQUIRED FOR EQUIPMENT STORAGE AND
MAINTENANCE FACILITIES, OFFICES, ACCESS ROADS, AND
POSSIBLY FOR CROP STORAGE. DUE TO THE IRREGULAR
S H A P ^ OF AVAILABLE PARCELS OF L A N D IT IS OFTEN'
N EC E G 3 A RY TO PURCHASE MORE PROPERTY Til AM IS ACTUALLY
REQUIRED FOR THE TREATMENT SYSTEM AND 31JFFFR AREA .
ASSUMING A 15 FOOT DEPTH FOR THE 15 1-DAY HOLDING
POND, ACREAGE REQUIREMENTS COULD VARY FROM 160 TO
4 CO ACRES. THEREFORE, WE FEEL THAT LAND COSTS HAVE
BEEN SIGNIFICANTLY UNDERSTATED, AND SHOULD RE
INCREASED TO REFLECT THESE C ONSID EEAT I ON c .
IT APPEARS THAT TEE DESIGN LIFE FOR THE
LANE TREATMENT ALTERNATIVE WAS ASSUMED EQCAL TO THF.
20 '.'EAR DISCOUNTING PERIOD. IT IS SUGGESTED THAT
THIS ALTERNATIVE RE REEVALUATED USING A DESIGN LIFE
WHICH WOULD BE COMPATIBLE WITH THE ALLOWABLE LOADING
RATE FOR THE SITE UNDER CONSIDERATION. IF THE SITE
LIFE PROVED TO BE LESS THAN 20 YEARS, THEN A
SIGNIFICANT CAPITAL COST INCREASE WOULD BE REALIZED
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IN PROVIDING FOR A UEW SITE WITHIN THE 20 YEAR
PLA.'IWIMG PERIOD . LIKEWISE, IF THE SITE LIFE IS
GREATER THA'I ?0 YEARS, SOME SALVAGE VALUE ViOMLD BE
RE A L I Z E D . THF, P ROPERTY UTILIZED FOR A LAND
f,DREADING SITE YJOLJLD BE ACOUIRED BY THE COUNTY ANn
TIUJS WOULD NO LONGER GENERATE REVENUES THROUGH THE
PAYMENT OF PROPERTY TAXES. FOR THE LARGE AMO'JKT OP
ACREAGE INVOLVED, THIS COST TO THE COUNTY IS
SIGMIFICAMT AMD SHOULD RE CONSIDFP.ED IN THF. COST
ANALYSIS .
THAT IS MY BASIC TESTIMONY, LESS THE
DETAILED COMMENTS.
MR. PENCFJ: THANK YOU.
B. ROME?
GARY V. HODGE, EXECUTIVE DIRECTOR,
TRI-COUNTY COUNCIL?
MR. HODGE I I AM HERE TONIGHT REPRESENTING
THE TRI-COUNTY COUNCIL FOR SOUTHERN MARYLAND, VHIICH
INCLUDES THE THREE SOUTHERN MARYLAND COUNTIFF. OF
CHARLES, CALVERT AND ST. MARY'S.
I APPRECIATE TKF. OPPORTUNITY TO PRESENT
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COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT .
COPIES OF MY REMARKS WILL B E AVAILABLE AT THE
CONCLUSION OL" THE MEETING.
r 1V 7 if, S T I M011Y T Oi: T GHT ON TM E 0 RA PT
ENVI POril'ENTAL I M°ACT STATEMENT FOR TIT, LITTLE
PAT'JXENT WATER OUALITY f-; AN A GEME N T CHIITR 'JILL DEAL
WITH THREE A RE AS IN WHICH WE THINK THE ENVI P ON H ENT A I,
IN PACT STAT EMEI.T IS P A E? I CU LA f? L Y WEAE . TNG EE AREAS
ARE ONE, DEVELOPMENT AND COST COMPARISONS OF
ALTERNATIVES; TWO, THE WATER QUALITY IMPACTS OE THE
EXPANSION; AND THREE, THE IMPACTS ON COMMERCIAL
F I S M E R I E S .
FIRST, DEVELOPMENT AND COST COMPARISONS OP
ALTERNATIVES. I WILL START BY STATING EACH
ALTERNATIVE THAT WAS CONSIDERED IE THE ENVIRONMENTAL
I K P ?. C. T STAT F. f 1 P. N T A N E CO t'l M F. N T ON EACH.
ALTERNATIVE ONE IS THE PRESENT FACILITY,
AS CONSTRUCTED, WHICH WE FEEL IS LESS INAPPROPRIATE
TiJAN 0 T F» 1: I'. A L T E R N AT IVES .
ALT E R NATIVE TWO WAS A PROPOSAL TO DIVERT
TflE EFFLUENT FROM THE SEWAGE TREATMENT PLANT, AS
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CONSTRUCTED, INTO THE PATAPSCO RIVER INSTEAD OP THE
PATilXE IJT. Bf-C^SE OUR GOAL IS HOT 3UST A ¦_ L £. A ^
PATUX^T OUT TaE SOLUTION OT A HAY-WIDE PHORI.E*', \?T
COlJLP POT SO^ORT THIS PRO^OSM, TO PPOTECT 7HF
i? AT Ma r. AT THE F.X»MSP. ^ MIOTHCH aiVF*.
Al.Tf-".Rf^TIVr: THREE ltlCMIPF.I. POI.R VJi.-
MjTI,k;1.,»iv,s. OF THE ™b-altv:^ivf = nF.opomrr>
T-,V rlSOlAKOP OF 5 :..ap» '¦ ot'
1bto or.W *«». A »"«'« 0F T!'3 °tiCE
MAllj, cm; not support Tm-sv. "¦ ,*-<.wzW™r.s fo?
the BMlS RSAB0R8 OIVRH ""FVIO'lsl.Y. TW Ot.lS" T«0
5!J„.UT™,WI«= CQHStnnFKH 1" Mtr.LIO.i GALLON >, OAY
0!, COWW'IOM'' TREATMENT ASH 5 KILLira r,«,I.O!aS A
D.,v or «,%«* *ppli<=¦"!"«• B0TK CF "a**«
nw> OIKM mwui. but wsp.f
j;,rcr.D yarcoMOMicM. in t»e ">cv
8Tvr*nr«T m
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REQUIRED FOR TREATMENT. THIS AMOUNTS TO 709 ACRES
FOR EACH ONE MC.D. COSTS WERE ALSO DETERMINED BASED
ON SECONDARY TREATMENT BEFORE LAND APPLICATION.
SECONDARY TREATMENT IS NOT ALWAYS NECESSARY DFFOPE
LAND APPLICATION, AND ITS INCLUSION IN THE COST
ANALYSIS INCREASED COSTS FOR THE LAND APPLICATION
ALTERNATIVES BV APPROXIMATELY $10 MILLION FOR EACH
ALTERNATIVE.
IN ADDITION, THE COSTS OF THE LAND
APPLICATION SUB-ALTERNATIVES INCLUDED A MILLION
COST FOR AN OUTFALL PIPE FOR DISCHARGE BF.LOW FORT
MEADE WATER INTAKE, EVEN THOUGH WITH THE LAND
APPLICATION ALTERNATIVE THIS OUTFALL PIPE WOULD BE
UNNECESSARY, BECAUSE NO ADDITIONAL EFFLUENT WOULD BE
DISCHARGED BY THE PATUXENT.
ALTERNATIVE FOUR WAS A PROPOSAL TO HAVE NO
CONVENTIONAL TREATMENT AT ALL, CUT INSTEAD REQUIRE
ALL 15 MILLION GALLONS A DAY TO BE APPLIED TO THE
LAND. WE FEF.L THIS i! AY HAVE BEEN A VIABLE
ALTERNATIVE THAT WAS ONCE AGAIN DETERMINED TO RE
IN F L" A S IR L H , DUE TO FAULTY REASONING IN THE
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environmental impact statement.
FOR INSTANCE, THE EIS PLACES THE SAME
UNREALISTIC REQUIREMENTS OF .75 INCHES PER W E E K
APPLICATION RATE Ail D PRELIMINARY SECONDARY ? R V. AT IWZ H T ,
W'ICli ROTH INCREASE COSTS OF LAND ACQUISITION. THE
EIS STATES THAT THIS ALTERNATIVE WAS HOT SERIOUSLY
CONSI DF.RED BECAUSE THERE WAS MOT ENOUGH SUITABLE
LAMT" IN HOWARD COUNTY. THIS IS < O T UMFXr>nc?KD,
CONSIDERING THE UNREALISTIC LAND REQUIREMENTS PLACET)
ON THE LAND APPLICATION ALTERNATIVE. IN ADDITION ,
THE AVAILABLE SITES FOR LAND APPLICATION WERE
IDENTIFIED BY HOWARD COUNTY OFFICIALS, HOT EPA,
WHICH PREPARED THE EIS. WE DOhl ' T CUESTION HOWARD
COUNTY'S INTEGRITY, BUT WE DO «UERTIO!J THEIR AH ILI l»\*"
TO GIVE AH UNBIASED APPRAISAL OF AVAILABLE LAND
APPLICATION SITES.
IU ADDITION TO COMMENTS ON THE PROPOSED
ALTERNATIVES . WE WOULD ALSO LIKE iO COilfiENT ON
OTHER CONSIDERATIONS MENTIONED IN THE 01S . WE
REALIZE THAT HOWARD COUNTY HAS A WASTE WATER FLOW
REDUCTION PLAN. HOWEVER, WE FEEL THAT THE COUHTY
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SHOULD PERHAPS LOOK FURTHER THAU MERELY TRT;
REQUIREMENTS OF T H F MARYLAND ilOUST BILL MUMPER 4-5
AND oi'JRS';^ AN A G R r: S S IV E STRATEGY OF WATHR
CONSERVATION' . THIS IP IMPORTANT "OT ONLY TO RE DUCT
WASTE WATER FLOWS, JUJT ALSO TO VSSURE ADEQUATE WATpfi
SUPPLIES TO •*« COUNTY WHICH D E PEN P S COM TL STEI-Y
neighboring jurisdictiohs tor public pot7irle water.
WE ALSO F E r L THAT CONSIPERA.Bt,'? j\r! CS SUP E
POK ADDITIONAL SEWAG5 TREATMENT PLAMT NEEDS COULP Hr
RELIEVED 11Y CONSIDERATION OP1 CH-SITE W A. S T E '/ATE P.
TREATMENT SYSTEMS, OR SEPTIC TANKS, "flEYOND A£-TD EVn:
WITWIi: THE COMPREHENSIVE SERVICE AREA OP TEE SAVAGE
PLANT . WE ACKMO W L p D G F THIS CONCERN THAT ftrVEfWS
TOE THE CAPITAL INVESTMENT COULD BE DIVERTED, RUT
:1AY \Y COST EFFECTIVE IN THE LONG RUM A3 STRICTER
LIMITATIONS A R B PLACED OtJ EF FLUE KT DISCHARGES INTO
'?! i E PATL'X E •! T RIVER III THE FUTURE.
TO SUMMARIZE OUR COMMENTS O.J THE
DEVELOPMENT AND COST COMPARISONS OF ALTERNATIVES, WF
PEEL THAT LANE AREA REQUIRED FOR LAtlD APPLICATION
WAS OVERESTIMATED, AND COSTS WERE INFLATED PY
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UNREALISTIC LAMP REQUIREMENTS, SECONDARY T REATML!' T
RE ONI REMEUTS , AND UNNECESSARY DISCHARGE PIPE
REQUIREMENTS, AND THAT POTENTIAL I,AMD APPLICATION
SITES UF.RE NOT REVIEWED QY AN OBJECTIVE AGENCY , AMD
THAT CONSIDERATIONS OF WATER CONSERVATION AND
ON-SITE DISPOSAL SHOULD IIP. EXAMINEE ;• 1 O P F. CLOSELY.
I WOULD NOW LIKE TO DIRECT MY TESTIMONY TO
iji|ip V, t.TC R OUALITY IMPACTS TEE 3 E NAG E EXPANSION,
AS GIVEN IN THE EI3. WE APE I i'J GENERAL AGREEMENT
,;IT!i the FIS THAT UNDER NORMAL OPERATING CONDITIONS
THE 3AVAGE PLANT WILL NOT BE A NAZARO TO "URLIC
HEALTH OR RESULT IN CLOSURE OE OYSTER EARS BECAUSE
01' high fecal COLIFORM COUHTS.
HOWEVER, WF. ARE COMCFRNEn WITH TEE EFFECT
OE STORE, S ON DIRECT DISCHARGE OF RAW SEWAGE INTO THF.
?A TL'XELT IF THE SAVAGE PLANT J3FC0MES OVERLOADED. WT?
NOTE THAT NO FACILITIES WERE CONSTRUCTED, SUCH -\E
HOLDING PONDS, TO PREVENT A BY-PASS OF THE SAVAGE
PLANT DURING OVER-FLOW CONDITIONS. A STORM OF
SIGNIFICANT MAGNITUDE COULD FORCE CLOSURE OF
DOWNSTREAM OYSTER BARS. THE F.IS STATES "THE PLANT
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EXPANSIONS AMD RESULTANT 'JRI3ANI2A? IO!? Cor;Lr C ".COME A,
MAJOR SOURCE OF f'tCROOI AI» COMTAMIJTATIOH 1?; TTJF
ESTUARY DURIKC STORM EVENTS. ' IT IS IH 7 E RE RT I f?C TO
UOTI- 7'I AT THESF STORM SVEHTS OCCUR ° R T M A R. I £. V I -i T3F
",fi"jtr•!, vrucn corrbspowps wiT!'t riAxrnan oyett.r
HA RUES? A*3D COULt LEAD TO ECONOMIC IMPACTS FOR THE
SOUTHERN MARYLANE COUNTIES IF OYSTER PARS A R' - CLOSEP
FOR HSALTR REASONS .
the mscu ssion of >-utrie?,*Ts ih
tite ris is extremely A;mic.uour>. the eis qootfs ma;"y
SCIENTIFIC PAPERS THAT POIUT TO HITRO^FN AS L I IT1K 3 |
in ! iOST ESTUARIES AND MAKES SEVERAL STATRMEHTS THAT
MITROGES 13 I j 1111 T I G IM THF! LOWER P>TUXEUT PA SEE OH
THE MITROGEM C O WC EM T R ATI OK IS Tf£R RIVER AND THE
M I T 3 O 0 E N TO f> MOT P IJOROUS RATIO. THEM THE EIS " A K E S
j
THE STATEMENT THAT 'THE TIDAL PATUXEWT WAS N'ZTPOOR'J j
i
j
J.IMITHD !>t)F. 2 MO SVARM PT^IOE-R . HOlfEVER r TiltS HOE« HOT |
|
RULE OUT THE POSSIBILITY OF RKVERSIHG TO PHOSPHOROUS
LIMITING CONDITIO W S IF PHOSPHOROUS INPUT TO ?f!K
PATUXEN? IB REDUCED TO A -GREAT EXTENT." THIS
AMOUNTS TO ADMITTING THAT HITROC!EN IS LIMITIWG, THEM
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stating that the sewage treatment plant will
implement a PTIOSPHOROUS control strategy in SPITE OF
THVr rkCT, THE SIS THEH PROCEEDS TO PROP UP THE
PHOSPHOPOnS CONTROL STRATEGY PY T H E USE OF THF
HYHROQUAL HATE P. QUALITY MOLEL, WHICH MA 13 Y OUALIFIFE
SCI EUTI S?S VIEW AS NOT APPLICABLE TO THE LOWER RIVER.
THE EIS THEN EVALUATES THE SPECIFIC WATER
QUALITY IMPACTS OF THE SAVAGE EXPANSION ON THE
PATUXENT RIVER ~ WE FIND FAULT WITH THIS FOR TWO
REASONS. ONE is THAT THE ANALYSIS Oi IMPACTS OF "HE
SAVAGE EXPANSION ON THE P ATUXEIJT RIVER T>A S P0FF
rjc;I;jG M0EEL RONS OF THE HYDROQUAL MOTEL, WHICH v#B
BELIEVE IS FLAWED IN ITS CAPABILITY TO POETIC? WATF ^
o' 1AL t T Y Id THE LOWER FIVER « SECONDLY, THE f' O T* E I,
Rfjv.s v.rnr. done merely to evaluate the incremental
impact due to the savagf. expansion.
it may be TRUE THAT THE SAVAGE EXPAiJSIOi-l
ALONE WILL NOT HAVE A MAJOR IMPACT 0!i THE PATUXEHT
P.I VH?. UP TEE QUALITY. HOWEVER, -WE ARE CONCERN ED WITH
CUMULATIVE. IMPACTS. THERE COULD BE TEV UIH'S FOR
TFN SEWAGE TREATMENT PLANTS THAT ALL STATE THAT THE
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6
7
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0
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13
14
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16
17
18
19
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INCREMENTAL impacts on water quality are slight, BtJT
WC ARC COKCERTJEn WITH THE COMBINED IMn ACT OF THE j
EFFLUENT FROM ALL TF.H STP * S 03 THE PATUXEHT RIVER .
the pvruxrriT river could be nickeled and dijird to
DFATH V;iTH INCREMENTAL IMPACTS.
PI H ALL Y , I WOULD LIKE TO COMMF.WT OK THF:
EISCUS-SIO"! OF COMMERCIAL F I S M K RI EE. IMPACT" IN THE
lis. T-jfs agree witei the eis that data om fimfish
LAUriNOS CLEARLY CANNOT BE USED ALONE TO ASSESS TrIE
HEALTH qf THE LOWER "ATUXEKT , tVEii THOUGH '"HE PIS
DOT'S ADMIT THAT ANNUAL HARVESTS FOR ALHOST ALL
SJ>ECT E5 WERE GENERALLY HIGHER Pi'.IOR TC 1960 THAN AT
PRESENT- viE DO, HOWE VSR, QUESTION THE USE OF FISH
I
i
DIVERSITY AS A ¦ f INDICATOR OF RIVER QUALITY . FISH
DIVERSITY IS MERELY AW INDEX OF THE HUMBE* OF
I
SPECIES OF PIS'! RELATIVE TO THE TOTAL NUMBER OF FISH .
IT DOES NOT TAKE INTO ACCOUNT THE LOSS OR DECLINE OF
IMPORTANT FISH- SPF.CIF.S SUCH AS STRIPED BASR, AND THE
REPLACEMENT CP THESE WITH LESS EES IRA HI,E FISH
SPECIES. in ADDITION, ALTHOUGH TRENDS IN THE
DEC LI fir OF PINFISH IU THE PATUXENT PARALLELS THE
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DECLINE OF FIMFISri IN THE RFST OF THE BAY, IT MAY BE
THAT POOR WATER G U A L I T Y THROUGHOUT THE BAY IS THK
c /v0 c;»r op THIS DECLINE. THEREFORE, IT DOES HOT
,:.v] Tl,vn us 0F THr: «*F.SPOIISIPILITY TO c'TOn THIS TPF.flD
J;Y PIR3T ri..f;a''tfic UP THE patuxr.ft river.
TH:t r;is MjSO DOF" LITTLE UUST T CF. TO ?KF.
pPMM.rr.i-3 THAT T ~1 F OYSTER FISH CRY 'SOU FACE* . MOST OF
Tf!r ;-! o.cu r,:: i or; o- -mr. ih^ct or r.ir: ex^wf.iotj
0'4 OYSTERS IS COtJC3R?TF^ WITH C'WiGFS IN 8 P.LIN1 TY J p
T.IF; :> vrtlXFlfiT F U F TO THE !M SCI'ARC L OF THS S AVAOF
VLv,r. HOWEVER, WE COHTF.KD THAT HIE HAW P ROr;LrM IS
S0T Rf-D(ICf: D SALINITY, BUT IL1ST EAT> -OOR 'WATT* P QUALITY
SPECIFICALLY LOW PISSOLV.C OXYGEN IW Tl.F POTTO f
ATE P. S .
THERE HAS HHr.fJ VIRTUALLY ''O S"AT FALL I'J
T.1;, r»ATUXFirr p.ivfr Sificr. 1969. the fi.o'.:- o- ffflultt
fn,wv^ treatment PLANTS ;iah triplet: over ?m.s
SMir. TIKIS PERIOD. S!>M SIT J38T OtI-'Jinn TBS IIOUTH
¦->•>, -1M* y r:; >}T ( HOUKVER, HAS coFtl lloll
ffcfftly, strongi.y suggestiho that there are uater
quality PP.OT1I.EMS in THE PATUXEHT P. IV F. P AFFECTING
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SPAT SET.
AS THE FIS STATES, A RELATIVELY CONSISTENT
AUKJJAL OYSTER HARVEST IN THE PATUXF.HT 13 NOV? DUE
PRIMARILY ?n STATS SEEDING EFFORTS. HOWEVER, EVE 11
THESE STATE SEEDED OYSTER EARS ARE I FT TROUBLE DUE TO
THE ?OOR '..'AT E R QUALITY . SOME OF THE UPSTREAM OYSTER
PAHS ARE TOTALLY DEAD, AMD OTHERS ARK BELOW
POPULATION LEVELS FOE PROFITABLE ECONOMIC H».RVF<3T .
TEE EIS EVE N STATES THAT "SEVERAL BARS CLOSED PY TME
HEALTH DEPARTMENT ARE DYING OF OLD AGE, AND OYSTERS
U:i DEEP WATER ABOVE THE PRESENT PATENT TOUR LINE ARE
ALSO DYING BEFORE THEY ENTER THE HARVEST. SEVERAL
UPSTREAM OUSTER PARS , ESPECIALLY AUOVE PROOMES
ISLAND, SUFFER FRO?" 17ATFR QUALITY PROBLEMS . ''
HOWEVER, AFTER TRIE, STATEMENT, THE EIS DRO!=>!?
TOPIC OF Vf ATE R OUALITY IMPACTS AND ADDRESSES ITSELF
TO SALINITY IMPACTS, WITHOUT DISCUSSING A SOLUTION
TO THE PROBLEM.
THE DECLINE IN OYSTER PRODUCTION IN THE
PAT'JXCNT NOT ONLY AFFECTS THE LIVELIHOOD OF WATERS EH
AND THE LOCAL ECONOMY, OUT IT THREATENS * WAY OF
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1,1 FK. WF. FEEL THESE POTENTIAL IMPACTS DESERVE MORE
PlSCUnSltN IH ?flF ENVIRONMENTAL IMPACT STf^^f'PNT .
3 I j.R. PENCE: THANK Y01J, M P • HOPGP .
4 IS vhkke A'TYOT-IF, else \no VJOULP LT' it if
it WAS POSTED EARLIER. I HAVE l-'OT HAP * CH AMO.R TO
LOOK AT THF FIS OR DRAFT OF THE SIS, P?JT I HAVT p,
, m.3rtl.riif <3 THAT I WOULD J'JST LIKE TO
COUPLF. OF TtlOtJFjUlo
Tr-,-..v T M O ° F THEY ARE APPROPRIATE. I INTEND
COWTRIKUTL . I i n
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TO TAKE A LOOK AT THE DOCUMENT, AND IF THEY AHF. NO^
APPPOPRIATE TliEV WILL PASS UNMOTICED .
I'Y CONCERN IS ABOUT THE GPOUTi! IN THE
COUNTY SPRAWL AND THE NEFn FOR LOOKING AT TUK IT 5? 7
FO& THE SERVICE TO BE PROVIDED PY THE EXISTING PLANT
AND ANY UPGRADING OF IT. ABOTJT FIGHT YEARS AGO, IN
THE REPORT PUBLISHED BY THE COUNCIL ON ENVIRONMENTAL
QUALITY CALLED T.IE COST OF SPRAWL, IT MADE Ml EFFORT
TO LOOK AT THE EFFECTS OF EXTENDING SEWER LINES AMP
SEWAGE TREATMENT CAPACITY IN THE AREAS WHICH ARE
PRIMARILY RURAL AND BEING DEVELOPED I>-, A .MANNER TH.\T
WERE BEING DEVELOPED IN A MANNER THAT DTD NOT
NECESSARILY BLEND ITSELF TO TRACT AND URBAN G^JTU
STYLES, BUT MORE OR LESS A LEAPFROGGING AND RANDOM
MELTF.R SKELTER, AND IN MANY CASES, UNPLANNED USE OF
TREATMENT FACILITIES WHICH WAS BEING SUBSIDIZED TO
THE EXTENT OF 70 TO 90 PERCENT BY THE FEDERAL
GOVERNMENT BY THE USE OF GRANTS.
THE UNDERSTANDING I MAVF. IN THE VJAY IN
WHICH THE CAPACITY OF THE SAVAGE PLANT IS TO PF, USED
IS TO PRINCIPALLY SERVE THE METROPOLITAN DISTRICT,
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W"ICH IS A FMRLY COMPACT, COHESIVE, UNIFIED CENTRAL.
ARHA OF THE COUNTY AMD CENTERED ABOUND COLUMBIA, AND
SUPROUHDSD BY A RURAL ARFA WHICH IS UNDERGOING
E'! 0 R i i O U S PRESSURES TO BE DEVELOPED HY CO-M^nAL
1MTEp^Tc( OY RESIDENTIAL INTERESTS, AND BY
COrJPETINO 70»MS .
„y thought is THIS, that 1-v oimiKSTAWiwo
r,,W HAVI-.C LtSTFKC1> I., OS »OMf OF TH-. HEARINGS THAT
,.,.E ola.iming m.»m> mo ti"! coobty coimcn. .-Ave IH
T,,r COHHTY HAS BROUGHT TO "Y ATTENTION THE fACT TWT
THE MET ! A RRQUIREHEWT por treathekt plamt
>1P0PA!>I!:« SUCH AR THIS WERE PET HC out TOGETHER.
m, the OTHER BAUD, A GREAT REAL OF GROWTH
HAS ".P.EH OCCHRRIM C., Ut!EXPECT EDLY , PERHAPS. IK THE
AREA SURSO'JWBIHG THE METROPOLITAW DISTRICT. I AM IH
THAT AREA. I AK 0O«K BY THE H0"KI7S PHYSICS l.AB.
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THERE IS A GOOD DEAL OF ACTIVITY GOING ON NOW TO
RE ZONE MUCH OF THIS RURAL AREA INTO A HIGHER DENSITY
AREA IN THE METROPOLITAN DISTRICT, GET YJATF.P AMD
SEWER IN THERE A3 QUICK AS WE CAN.
I AM VERY CONCERNED ABOUT THIS FOR SEVERAL
REASONS. FIRST BECAUSE I THINK IT I S GOING TO PRINO |
A SUBSTANTIAL COST INTO THE COUNTY FOR PAYING FOR |
THESE THINGS, BECAUSE THE MANNER IN WHICH THESE |
i
GRANTS ARE HEI NO ADMINISTERED OR FUNPFD APPEARS TO
HE UNDERGOING SUBSTANTIAL CHANGE IN CONGRESS EIGHT
NOW, AND I AM VERY CONCERNED ABOUT THE EFFECTS THAT
COST WILL HAVE.
ENVIRONMENTALLY, I AM CONCERNED BECAUSE I
SEE THERE IS A GREAT DEAL OF PRESSURE TO CONTINUE
THIS GROWTH OUTSIDE OF THE METRO r>OL IT AM DISTRICT AND
BRING IN ADDITIONAL WATER ANE SEWER HOOKUPS BEFORE
THE METROPOLIAN DISTRICTS NEEDS THEMSELVES ARE
ADDRESSED OR CONSIDERED OR "RESERVED OR SOMEHOW
MAINTAINED OR SET ASIDE. THE FACT OF THE MATTER IS
THAT THE "RESENT ADDITION THAT IS BEING CONSTDTRkt
THROUGH THIS ASSESSMENT WILL NOT BF SUFFICIENT.
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3 ">
THERE will nr. a hf.ed for more, kuv, tkf, fact of
'1ATTFR I r> THAT THIS ADDITIONAL GROWTH WTLL PF
I M i' LI 01 P< L E » IN ALL LIKELIHOOD, FOR MUCH OP AMY
FK PER AL ASSISTANCE BECAUSE OF THE VERY FACT THAT
CONGRESS IS THINKING OP SHOTTI1C OFF THE FU -IP I f'G OP
growth.
MOW, E H V I R 0 N M E M T A L L Y , THIS MEANS THAT THF
COUWTY V:iLL WAVE A SERIOUS DILEMMA IN ?R«*K«S OF
nhtWLlVG THF GROWTH THAT IS EXISTING OR THAT IS
OCCUPYING Lb THE OUTLYING AREAS AND LEAVIMC A VACUUM
IM TF1E CEUTFP IN THE METROPOLITAN DISTRICT , WHICH IS
UNLIKELY TO BE MET THROUGH THIS KXPM.'SIO'T OF ?»F
SAVAGE PLAHT IF IT IS USED F PO R F H A'-i
THE3F. ARE COMMENTS THAT I OO'J'T KHOU IF
TIICY ARE ^PROPBIATS AT THIS TIME. I '• /QUI. F. LIKE TO
TAKE A LOOK AT TIT F STUDY. I AM FAMILIAR VJITH MOST
nF ?MIS> r MAve WORKED WITH THE ENVIRONMENTAL
^ F.OT f.CT 10 ; AGF.MCY. SO I KNOW THE GENERAL GMRJECT
M<\Tr- R I M> • I HAVE WOT SEEN THE STUDIES, SO I K\
APOLOGIZING IV IT IS OFF THE MARK, RUT I U07K IT
>(jl jji, be considered.
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MR. PENCE: THANK YOU, HP. ARNDT.
MO H L n ANYONE KLSF LIKE TO M AK E A STAT^'-^MT?
MR. GF. IS : MY HAM E IS ALFRED G E I S , I HAVE
BP,EN A MEM BE P. OF THE PUBLIC ADVISORY COMMITTEE OF
THE PATUXENT FOR f. AMY MANY YEARS. MY ADDRESS IS
5710 TROTTER ROAD, CLARKSVILLE , HARYLA'ID .
I WOULD LIKE TO POINT OUT WHAT I RELIEVE
TO RE A 1E P. IO U SLY MISLEADING IMPLICATION 1*7 THE
I
SECTION OF THIS REPORT TITLED "SOURCES OF PATHOGE?!S
IN THE PATHXENT RIVER." IT BEGINS on PAGE p> 0 .
SPECIFICALLY, I THINK IT IS TOTALLY
INAPPROPRIATE TO IMPLY THAT WILDLIFE AMD W^TLAHOS
ARE A SOURCE OF PATHOGENS TO HUMAN BEINGS. THAT IS
JUST P L AI N ABSURD. PEOPLE DON'T GET DISEASE FROM
D'JCKS AND CEESE, THEY GET DISEASE fROM OTHER "rOP!,r..
SO IT IS ALMOST HUMOROUS I 'J A SICK SORT OF W AY TO
HAVE A SECTION THAT SERIOUSLY CRITICIZES, IN EFFECT,
WETLANDS, WHICH ARE IMPORTANT, HAVE A VERY POWERFUL
POSITIVE EFFECT ON WATER QUALITY, IMPLYING THAT IT
HAS A NEGATIVE IMPACT.
IT IS JUST PLAIN INCORRECT TO IMPLY THAT
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34
WILDLIFE IS A SOURCE OF HUMAN DISEASE, WHICH IN THIS
CONTEXT IT CLEARLY IS NOT. ADMITTEDLY, VON CAM
CATCH RABIES PROri WILDLIFE, BUT IT IS VERY DIFFICULT
TO RUN INTO AMY SERIOUS DIFFICULTY CAUSED ny rrc\L
CO 'J T A M I N AT 101-7 FROM WILDLIFE. I THIN'C THEY ARE
TECHNICAL. PROBLEMS RELATING TO MICROBIOLOGY , AMD I
REGRET THAT ANOTHER PAPTY I'? EOT HERE TO COMMENT OM
TriAT. I THINK THIS SECTION IS PARTICULARLY V?EAK,
A;;D DIISLP.VES SUBSTANTIAL REVISION.
I MIGHT add T'TAT I T H IN K !•: R . MODGE'S
TKS'i'tf-'ONY '.J AS ALSO COMPLETELY P I N T - C'i IE A GENERAL
CjTf.-sF VJHEt? HE DIRECTED ATTENTION TO MORE PU 'ID A'iRVTAL
A IT D WIDER RANGING ASPECTS OF TNI ¦' HE PORT .
MR. PENCE : THANK YOU, MR. G HIS.
V/OULD ANYONE ELSE LIKE TO M A E E A STATEMENT?
ALL P.IU"T. I V1ILL RE,"'. I FT YOU THE HEARING
RECORD WILL REMAIN OPEN UNTIL DECEMBER 2 1, 19P] , Alp
ANY AND ALL OF YOU APT' UPGE^ TO S"P"IT NRTtTSN
COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT.
A G A I N , IF YOU WOULD ADDRESS THOSE TO MS . MARY S A R N O ,
EIS "REPARATION SECTION , U.S. ENV I EO'lMEN T A L
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PROTECTION AGENCY, CURTIS BUILDING, 6TH AND WML-'J UT
STREETS, "HILAPELPHIA, 19106 .
THANK YOU ALL FOR A T T F. H D I N G TOHIGIlT. THIS
'lEA^If'G I? ADJOURNED .
( TM PPJZil PO*J . AT 8 : ?0 P . !' . , nFE HEARING WAS
AT J 0 U Rfir. P . )
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36
I I S T A. T E OF MARYLAND
? I CITY OF BALTIMORE, TO WIT:
3| I, REBECCA A. BIEREft, A NOTARY PUBLIC O»
THE STATE OF MARYLAND, CITY OP BALT I MO R F , CO HERERY
CERTIFY THAT THE WITH IN-NAMED PROCEEDINGS TOOK PLACE
BEFORE ME AT THE TIME AND PLACE MERE IN SET OUT.
I FURTHER CERTIFY THAT THE PROCEEDINGS
WERE RfclCOttDED STENOGRAPHTCALLY FY PS AND THIS
TRAN SCR. I nT IS A TRUE RECORD OF THE PROCEEDINGS .
I FURTHER CERTIFY THAT I AM NOT OF COUNSEL
TO AN Y OF TiiE PARTIES, HOP. AH EMPLOYEE OP CO UN S CI, ,
-•'OR RELATED TO AMY OP THE PARTIES , MOP IN amy ?.^y
I b! T E P. E S T1 D IN THE OUTCOME OF THIS ACTION.
A ¦ i 11 J
,'ITNESS i! Y HAND AND NOTARIAL SEAL THIS
D A Y O E
19 8 2.
REBECCA A. BIERER,
NOTARY PUBLIC
¦IV COr.f.ISSION EXPIRES:
7/1/82
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1. The Little Patuxent Water Quality Management Center (LPWQMC) is
operated and maintained by the Wastewater Treatment Division of the
Howard County Department of Public Works Bureau of Environmental
Services. The Division Chief has the overall responsibility for
wastewater treatment in the county while the Plant Superintendent
has the specific responsibility for the operation and maintenance
of the LPWQMC. The plant currently has a staff of 44 operation and
maintenance personnel.
Laboratory facilities at the LPWQMC have recently been expanded to
insure that the plant, through continuous monitoring of wastewater
characteristics throughout the plant, is operating at its optimal
level. These characteristics, such as suspended solids, volatile
solids, sludge age, the sludge volume index and phosphorus levels
are used to determine operational variables such as aeration
requirements, sludge return rate, settling velocities and the
amount of chemical additions required to meet the advanced
treatment levels required by the plant's NPDES permit (Table II-l,
page 7 ). Effluent monitoring provides a final check on treatment
performance within the plant; results are reported monthly as
required by the plant's discharge permit. A maintenance program is
currently being developed to insure timely inspection of all the
treatment components and to determine the needs for adequate
replacement parts to be stored at the plant in case of a need for
immediate repair or modification of any of the process units.
2. All of the farms are located in Howard County, split between
the Patapsco and the Patuxent River Basins. Sludge from the LPWQMC
which is land applied is placed on agricultural land, reclaimed
industrial land and land owned by the Howard County Department of
Recreation and Parks. While corn, grass or turf are grown on the
land following application, rates are determined by the Maryland
Department of Health and Mental Hygiene (DHMH). The DHMH issues
permits for these operations; one important consideration is the
uptake of heavy metals by crops grown on the land. There have been
no problems with the land application process.
3. The expansion and upgrading of the plant from 10 to 15 mgd was
based on forecasted increases in flow. Discussions of population
and flows have been incorporated into the text on page 5
4. There are three potential hazardous waste sites in Howard
County. The State of Maryland has the lead for preliminary assess-
ments of these sites.
5. Both rapid infiltration and overland flow land application
methods were addressed in the Draft EIS and determined to be
infeasible or non-cost competitive. See page 17 .
6. Land application loading rates and land requirements are
re-evaluted in the Final EIS on page ^5 .
7. The state guidelines used in this evaluation required secondary
treatment for spray irrigation,, at least secondary treatment for
rapid infiltration and, for overland flow, the ability to meet
discharge standards. This determines the amount of pre-application
treatment. New developments or guidelines, such as those stated
in the comment, cannot be considered due to the fact that this
analysis was performed using 1974 through 1977 as the evaluation
period. Federal requirements of 30 parts BOD and 30 parts
suspended solids (in effect during the evaluation period) could not
be met using either the holding pond or a conventional lagoon.
Aerated lagoons were added to replace the conventional secondary
plants used in Alternatives 3A.2 and 4 on pages 21 and 22.
161
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oK^>un for the alternatives discharging 10 mgd to the
8. The costs s^nf°/rethsehown With and without tte costs for the
Patuxent b^sin ar fo0tnotes at the bottom of the pages
detailing the costs of each of the alternatives in question (pages
A-3 through A.-15 of Appendix A) .
, ~ „ Ma(,^r Plan for Water and Sewerage Facilities
9. Howard C°U!} ^ lonq-term use of onsite systems in the LPWQMC
has concluded ,that X°nJL , due to poor soil conditions (low
"e"lc;-ftrtv w bearock, hlgt, <,roona»,t«). The
permeability, shalloi P qrowth shown in land use planning by
service area ie forecast outsit, the planned
^?^rV»,.80t5*"^rr4"5Strion.l now, »m o^inate
these areas.
<=v^m »-h<=> nraft EIS regarding microbial
10. The ^tat^!ef^.sqto WPS runoff and not treatment plant bypasses
contamination refiei in thig comment. Although holding ponds
of raw sewage as reauired by state regulations), two 2 mgd
were not converted to flow equalization
contact stabilizat recent plant expansion. These basins pro-
bf^n 500U000 gallons of temporary storage. Also, the plant can
= Of the nutrients in the Patuxent River, nutrient
by ~al-Inc-
„ ^ r„ns were performed evaluating the cumulative effect of
12. Model run: *e P and without the expansion of the
all basin discharges ^ incremental effect of expan_
sIon"at the1SLPWQMC in no way failed to consider cumulative impacts.
Refer to pages 34 through 55.
„ rv-.i nt source loading data were not available from
13. Since d ta were used from a study which related
the Pat.u*e.ntmJ£Ja o* non-noint loadings in the nearby Rhode River
statistical mod ,Correllf et al. , 1978). Because both
basin to fcl® Pat" t Rivers are located in Maryland's coastal
the Rhode and Pat their non-point loading characteristics
plain, it is iik Y ize the limitations of this approach,
are comparable. not obtainable. Studies of th non-point
however better dat the Patuxerlt River now being undertaken
loading ^haract land and tfie university of Maryland should
by the State of y ^ accuracy of the estimates used in
provide a way ot vculi h
the EIS.
mu njc riiccasses salinity at length because originally the
14. The EJ of freshwater flow were identified as a major
potential imp agree with the comment that low DO levels
ar^robLly the -ain caus'e of the problems in the oyster fishery.
i* as stated in the Draft EIS, oyster mortality and lack of spat-
il'w avsnear to occur as a result of poor water quality . primarily
f oxvqen and turbidity. Expansion and upgrading of the
lpwomc facility should have no adverse impact on dissolved oxygen
\nlte upper estuary as demonstrated by modeling results.
We recognize that poor water quality in the Chesapeake Bay
« „««*»Hhiites to adverse changes on the finfish community and
t^a^ betted water quality in the bay's tributaries (the Patuxent
Eluded) will improve the situation. The more stringent effluent
imitations placed on the LPWQMC and other dischargers to the
Patuxent are a first step in a program to improve water quality.
162
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As discussed on page 34 , the imposition of AWT and dechlorination
requirements on facilities in the Patuxent has shown positive
results regarding finfish communities. Similar requirements for
the LPWQMC can be expected to show similar results. Therefore, the
LPWQMC project should have no adverse impacts on the finfish
community and should bring about improvements.
17. The text has been changed to reflect this comment.
18. The text has been changed to reflect this comment. See page
1 .
19. Table II-l has been changed to reflect this comment. See page
7 •
20. The buffer areas and holding pond acreage requirements, though
not specifically mentioned in the text, are included in the cost
analysis. The new land application analysis details the required
acreage. See pages 14 and 15 .
21. The text has been changed to reflect this comment. See page
17 . The nitrogen requirement contained in the Draft EIS was an
editorial oversite and was not included in any cost analyses.
22. This evaluation was performed using data and information
available in 1977. At that time, vacuum filters were being
considered for sludge dewatering.
23. The text has been changed to reflect this comment; see page
19 .
24. Flow equalization has been added to Alternative 2, and 5 mgd
of activated sludge and the conversion of the contact stabilization
units to sludge storage have been added to Alternatives 2 through
3.B.2. See page 18,
25. The cost information used in this analysis is generally given
for an entire process and is not broken down into structural and
mechanical components. Without knowing the breakdown in costs of
the different types of components, it is virtually impossible to
give an accurate salvage value. Based on cost-effectiveness
guidelines which give the useful life of structural and process
(mechanical) components to be 30-50 and 15-20 years, respectively,
we feel 35 years is a good estimate for calculating the salvage
value. We feel that the cost of replacing any mechanical
components are offset by the increase in salvage value of the
structural components and, therefore, the relative costs of the
alternatives will not significantly change due to this assumption.
26. The text has been changed to reflect this comment. See page
25 .
27. The text has been clarified to include a discussion of the
expanding area of low dissolved oxygen to further upstream. See
page 34 .
28. The flows from the smaller plants mentioned would be less than
1.5 mgd. Table III-2 has been corrected; see page 27 .
29. Analysis of effluent nutrient concentrations at the LPWQMC
provided by Howard County indicate that effluent P was about 7 mg/1
before the "phostrip" system was put into operation in July 1981.
163
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The table refers to conditions in 1980; the heading for Table III-6
has been changed to clarify this point. See page 36 .
i «i c r,f fi^h catch was performed solely to indicate
11't t^Serawas similar to that occurring in the general area
{tish landed in Maryland) over a period of years.
recoqnize that calculations performed to estimate
31. We r-ecoqtl\ . were approximate. The discussion of
nitrification effic ^ included to point oat a potential
process efficiency ^ addressed as part o£ the current
Facilities Planning process, the process reliability review is not
included in the Final EIS.
un ttt ? in the Draft EIS contained typographical errors.
32. Table III-2 i {_r1n(qed in the flow analysis. The projected
future'effluent flow is 67.8 mgd. See the corrected Table III-2 on
page 2 7
33. The or.ft «.
Sufis'ITlUerfn the\e*t of the vlnal EIS.
future population growth on water quality in the
34. The ^PaCt „ualuated using the following steps: (1) year
Patuxent River was ev' for the seven basin counties were
2000 population tore . n_wide year 2000 population forecast
disaggregated to develop a basin^ rahJ XJI_Q on page 39 ); (2) land
(text pages 35, _ forecast for river sab-basins (Figure III-l
use changes were the g ^ pageg 4Q _ 42 j. (3) year 2000
on page 38 and ia contributions were then estimated using
sur£ace runoff non^
on page 37 , generating estimated
loading rates in "la 111-10 on page 44 and described on page
loadings shown in non-point estimates were then combined
43 . (4) these year Jo no Table ^ on page
with estimated year 2000 p quality model runs. The results
It these "runs OT 5''
c "estuary" was not meant to imply that the
V- not .fteot fluvial habitat as «u. TK«
Sf hL bee0" corrected accordingly. See page 33
• nf the effect of nutrients on algal
^duct^y^^" See pages 44 - 54.
„ The comment is correct and the discrepancy has been corrected.
Refer to the discussion on page 44
. c, cf development in the Patuxent was considered in
"• source loads as »ell as point source
;5LsDr«e prated to^ the year 2000.
3,. The statement t^oraft
white perch and sp estuary. The text has been corrected to
species " the only commercially important fish species
riirant'^'tS'c'ofucSns staled. see p.,. D-l. Appendix „.
Draft EIS because it was^ origin Yaffecting the oyster fishery,
.alt ahaVeaj7ndicated that, even at low flows, all
charted'oyster bars are well within the acceptable salinity range,
164
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and that the LPWQMC increase of 5 mgd would have no overall adverse
impact relative to salinity. See pages 34 and 0-6 thru D-13. In
addition, see pages 29-33 relative to the LPWOMC imoant on PafliYpnf
water quality.
41. A section 404 permit was obtained by Howard County Cor
construction of the outfall. Special requirements placed in this
permit included (1) a limitation on dredging between March 1 and
June 15, (2) a requirement that the six stream crossings involved
were to be buried at least two feet below the streambed, (3)
standard erosion control measures including riprap, seeding and
earthwork area controls, and (4) a requirement that any necessary
Maryland State Highway Admin istration permits be obtained prior to
construction.
42. A listing of endangered species in the area has been included
in Appendix E. None of these species will be affected by operation
of the LPWQMC.
43. This is a Court-ordered EIS which was developed during the
time the project was being completed. To meet the intent of the
EIS process in the most practical, timely and cost-effective
manner, EPA performed a two part analysis. The first part was a
present worth analysis of the alternatives including the
constructed project. The results of this analysis indicate that
Alternative 1, the constructed project, was the more cost-effective
(see page 9 ). Based on these results, an environmental analysis
of Alternative 1, relating to the Court-ordered issues was
performed. EPA believes this Pinal EIS meets the intent of thaNEPA
process as well as fulfills the Court Order.
44. The discussion on microbiology, contrary to the commenter's
impression, did not state that since runoff "contains many of the
same pathogens as wastewater... that it is perfectly alright to
increase the capacity of the sewage treatment plant" but rather
that (1) an increase in capacity at the LPWQMC would not be a
major source of microbial contamination in the Patuxent River; (2)
that in addition to upgraded disinfection facilities, proposed AWT
processes contribute to microbial reductions and (3) that based on
commonly used methods of risk assessment, the LPWQMC effluent
itself (under proper operating conditions) is relatively safe for
contact recreation. It is not practical to continuously monitor
either raw sewage or effluent for the variety of potential
pathogens therein, in every sewage treatment plant. Both EPA and
the scientific community continue to investigate adequate
techniques for the isolation and enumeration of such organisms in
wastewater, the correlation between such organisms and those that
are monitored, and the efficacy of various disinfection processes
in destroying such organisms. Good public health practice
requires the assumption that pathogenic organisms are present and
disinfection practices are geared towards reducing the density of
pathogens to acceptable limits. Adequate disinfection levels are
reflected in water quality standards. Space does not permit the
enumeration of the techniques used to isolate microorganisms in
wastewater, in this EIS, nor the relative efficacy of disinfection
under specific conditions. The commenter is referred to the EPA
publication "Disinfection of Wastewater Task Force Report"
(EPA-430/9-75-012, 1976) for a discussion of the subject and a list
of references.
45. The Conclusions and Recommendations section of the Draft EIS
has been rewritten (see page 171 ). However, throughout the
165
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environmental analyses section, the incremental increase of the
LPWQMC is evaluated as a portion of the total loads to the Patuxent
system.
46. The Comment is correct, and the text has been changed.
The text has been changed to reflect this comment. See page
35
rofipft this comment.
47. The text has been changed
35 .
Thp discussion refers to
""/.d of total "on-P=int source,. See
page 44 .
• • „ n>o Draft EIS, Table II1-16 has
«;n ieethcomrmeVntS4 8 above for discussion of the issue.
50. Tables IIJ"14 /tables" III-10 ^nd ^-Irrespectively. Table
and are now numbered. as the annual average NPS loadings from
111-10 is now identified a XII_H now includes groundwater in-
surface runoff alone. Table
put.
t 47 - 54 for a revised discussion of
51. Please refer to pages
nutrient control.
ThP oaraqraph referenced in this com-
-t s: sisis
53. The best \nfo™*taine63 in'^wo^studies! One was done over a
Patuxent River is .^on^ir\e960s and one in 1978 (Mihursky, et al.,
five year period in tne and white perch maintained
1980a). in both the five year span of the first
the same relative position. ^ 1980# variatl0ns in species
study, cited by Mlh,urs^; in an years striped bass were not an
composition occurred, COmmunity. White perch was one of the
important component^ ^ hout the period. The later study
major species obser showed the same result. The most
(Mihursky, et al., t een the two studies was the emerg-
striking dif**'*"C® of spot as an important member of the com-
munity" terms of numbers.
„ t-he results presented may be a simplifica-
54. It is agreed that¦ "i the limited data did not permit a
tion of conditions.Howe ^ approach taken was conservative,
more thorough analyse
. , been deleted in the Final EIS. The
55* ITSMtirt-raimentecont?ol Strategy for the Patuxent River Basin has
been1included in Appendix F.
,he Rhodes River Study by Dr. Correll related to
56. Questions on the wio herbicide data and not on his esti-
nnalitv assurance problems
mates of non-point nutrient loadings.
ft,at estimates of urban non-point source pollu-
57. We recognize that e Piedmont may differ from those of
tants based on sampJ-ing due fco variations in underlying
the Coastal Plain, p*r. xtent of urbanization increases, unpaved
geology. However, a:sc in determining non-point characteris-
areas become less or a characteristics of urban non-point
Coastal PUi. -11 *
166
-------
58. The final Maryland Nutrient Control Strateqy for the Patuxent
River Basin, while calling for nitrogen removal at some facilities
in the basin, does not specify nitrogen removal at the LPWQMC at
this time. In keeping with the strategy, however, nitrogen removal
will be evaluated in any future facilities planning for further
plant expansion. See Appendix F.
59. Population estimates in Table III-8 only include the Patuxent
River basin portions of Howard County; it is for this reason that
their total is less than county-wide population estimates. Dis-
crepancies in current flow figures have been corrected in the text
on pages and
60. 67 .8 mgd is the correct flow; this figure was used in the
model runs. Table III-2 was incorrect and has been revised; see
page 27 •
61 and 62. See Appendix F, Maryland Nutrient Control Strategy for
the Patuxent River Basin for a discussion of dual nutrient
control.
63. Table III-7 has been revised. Wetlands have been deleted
since Dr. Correll's data already includes wetlands. In addition.
Table III-ll has been revised to include groundwater, which in-
creases the non-point source loadings.
64. The projected minor change in non-point source loadings is due
to the fact that approximately half of the change in land use
occurs from agricultural to developed land, both of which contri-
bute large amounts of non-point loading. See Table III-9.
65. The Howard County Infiltration/Inflow Analysis (Howard County,
1981) reported a total infiltration/inflow (I/I) from October 1978
to August 1979 of 1,174 million gallons. This results in an average
I/I of 3.5 million gallons per day (mgd) or approximately 40 percent
of the average daily total plant flow at the LPWQMC. The average
daily infiltration and inflow for the same period were 2,35 mgd and
1.15 mgd, respectively. Howard County initiated its sewer rehabil-
itation program in the Town of Savage in the spring of 1978, As of
February 1982, an estimated 1,0 mgd of I/I has been removed; cor-
rection of ar additional 0.2 mgd of I/I is under engineering design
(Gilvanniello, 1982), Thus, an estimated 1,2 mgd of I/I will be
removed from the Town of Savage alone. This would reduce I/I to 26
percent of present plant flow, Howard County is planning to
further reduce X/I iTi the study area, It is not likely that I/I
will contribute significant flow to the LPWQMC when the sewer rehabil-
itation program is completed. In addition, current construction
techniques will minimize I/I in new sewers. It is anticipated that
in the near future, I/I will be under control and contribute only a
minor portion of total plant flow at the LPWQMC.
66. The cost-effectiveness of treating I/I at the treatment plant
versus alleviating this in the sewer system is dependent on several
factorsj plant capacity, effluent standards (degree of treatment
required), length of sewers and operation and maintenance of the
sewer system and treatment plant. It is not certain whether all^
these factors were used to arrive at the non-excessive infiltration
rate criterion cf 1,500 gpd/in/mile used in Program Requirements
Memo 78-10. However, current guidance in Facilities Planning 1981
does reflect consideration of the factor of sewer length; the mini-
mum non-excessive infiltration rate is increased from a previous
rate of 1,500 to 2,000 to 3,000 gpd/in/mile for sewer lengths
greater than 100,000 ft. It is possible that the degree of
167
-------
treatment should be considered in the cost-effective analysis of
X/i; however, current regulations do not permit this approach.
67. As indicated in response 65, Howard County is now conducting a
sewer rehabilitation program. It is estimated that total average
daily I/I will be reduced to about 26 percent of present plant Clow
when the sewer rehabilitation program in the Town of Savage is
finished. Once sewer rehabilitation in the remaining study area is
completed, total average daily I/I will be significantly reduced.
In addition, current sewer construction techniques will also limit
I/I For these reasons, a low future infiltration rate was used in
determining treatment plant capacity. Current techniques will
allow for reducing leaks in the collection system, however,
marginal costs would increase dramatically if Howard County tried
to eliminate virtually all I/I. Also, it is not true that large
collection systems are necessarily associated with large I/I. The
quantity of I/I depends on pipe diameter, pipe length, type of
pipe, type and number of joints, groundwater tables and manhole
coverings.
68. The treatment plant itself has been designed to prevent
flooding based on the maximum river height on record (June, 1972);
this level is above the 100 year flood. It is very likely that
inflow will increase under severe rainfall as the collection system
design did not include special flood prevention measures. However,
it is very unlikely that the corresponding infiltration rate would
increase significantly, since the groundwater table which controls
infiltration rates does not respond to rainfall quickly. Currently,
small lateral sewers can be constructed without significant
leakaqe. In addition, manholes (which have been blamed for
contributing significant inflow in the sewer system) are not
installed in lateral systems. Thus, it is reasonable not to
include an additional I/I allowance for house connection systems.
69. Alternative costs both including and not including the
relocated outfall were prepared to enable the reader to examine the
cost of either approach.
70 When all applicable water quality standards for ^lass 1 waters
are met, under Maryland regulations, these waters are safe for
contact recreation and aquatic life.
71 The consideration of small land treatment systems was not
Foible due to the limited amount of suitable land available
within the study area. The commenter is referred to response
number 7 for a discussion of treatment levels,_ and to page 5 for
a discussion of the planning assumptions usea in the development of
the Draft EIS. The use of an artificial wetland treatment system
is not a viable alternative to the LPWQMC. At the present time
th^re are insufficient long-term performance data that can be used
1*a basis for making a thorough comparison between an artificial
wetland and the constructed alternative. Although spectacular
removal efficiencies have been reported, they are either for a
specific wetland system or the results of short-term testing
nrnorams There are no reliable process design criteria or
Procedures for such systems nor are there any proven operational
techniques. (Page 36 Aauaculture Systems for Wastewater Treatment-
EPA 6.80.)
72. Correction has been made. See page 25 .
71 Howard County's adopted water and sewer plan, as well as the
nt revision of the Howard County General Plan both call fQr
limiting sewer service to the current metropolitan district in
168
-------
order to concentrate growth. Development outside this district is
restricted to one unit per three acres and must rely on septic tank
drainfields for wastewater disposal. While some smaller areas
which drained toward the district were recently added for
consistency, the county remains committed to restricting central
sewer to the existing metropolitan district (MacNantara, 1982).
This process will effectively contain sprawl and promote
concentraiton of Howard County's future growth.
169
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Chapter V
Recommendations
-------
Based on the present worth analysis and an analysis of the environ-
mental impacts affecting the River, the estuary and the Bay, Alter-
native 1, the LPWQMC, as constructed, is found to be cost-effective
and environmentally sound. Further, modeling results indicate that
the addition of nitrogen control capabilities at the LPWQMC will
result in no additional water quality benefits, assuming the LPWQMC
and all other treatment plants control phosphorus at 0.3 mg/1. Of
the two nutrient control capabilities, phosphorus control is the
more cost-effective and easily maintained.
171
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Holland, A. F., M. H. Hiegel, D. G. Cargo and N. K, Mountford
1980. Results of Benthic Studies at Chalk Point. Interim
Report. Martin Marietta Environmental Center and
Chesapeake Biological Laboratory. PPSP-CP-80-2; NTIS
#PB80~173669. Maryland Power Plant Siting Program,
Annapolis, Maryland. January, v.p.
170
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Hoskings, T. W. , T. D. Reynolds and R. W. Hann, Jr. Jr977.
Supplemental Aeration System Design for the Houston Ship
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Howard County Department of Public Works. 1974b. Savage
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Howard County Department of Public Works. 1975. Fourth
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Howard County Department of Public Works. 1976. Savage
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179
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Jack Faucett Associates, Incorporated. 1976, Evaluation of
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PPRP-14. Maryland Power Plant Siting Program. January.
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Tributaries of the Chesapeake Bay.jonns Hopkins
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Krantz, George E. 1977. Letter to Stephen D. Sulkin, Head,
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ny*t*r Spat Survey Fall 1979. Maryland Sea Grant Program.
UB-<3
180
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Kretschmar, K. 1981. Personal Communication with Andris
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LaBelle, Raymond L-, Charles P. Gerba, Sagar M. Goyal, Joseph
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LaBuy, James, 1968. Biological Survey of the Upper and
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Water Pollution Control Association. CB-SRBP Working
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Lanaine, Jean. 1981. Personal Communication with Andris
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Howard County within the Patuxent River Basin. Planner,
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Leofor, R. C. 1974. "Characteristics and comparative
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Lomax, Nancy and Frank Hetrick. 1978. Monitoring Chesapeake
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Maryland Sea Grant Program, College Park, Maryland.
December. 10 pp.
Luckman, S. 1981. Personal Communication with Andris Lapins,
ESEI, re: Wastewater dischargers in the Patuxent River
Basin. Water Resources Engineer, Department of Health and
Mental Hygiene. February 18. Baltimore, Maryland.
Lucas, Richard C. 1975. Anne Arundel Ground-Water
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Ludlow, Raymond W., Jr. 1976. Study on Nitrates in Fort
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Lukacovic, Rudy. 1981. Letter to Jane Cameron, ESEI, re:
Documented fish kills in the Patuxent River since 1965.
Chief, Maryland Fish Kill Team, Maryland Tidewater
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Lund, Ebba. 1978. "Human pathogens as potential hazards in
the reuse of water". Arrtbio. Vol. 7, No. 2. 56 to 61 pp.
181
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Mack, Frederick K. and Claire A. Richardson. 1962. Ground-Water Su
Industrial and Urban Development in Anne Arundel County. BulFotv
Maryland Department of Geology, Mines and Water Resources. Balti
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Marks, James W., Orterio Villa, Anna R. Favorite and Evelyn P.
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Marks, James W., Orterio Villa, Anna R. Favorite and Evelyn P.
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Marks, James W., Orterio Villa, Jr., Anna R. Favorite and
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Maryland Agricultural Experiment Station and U.S. Soil
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Maryland Crop Reporting Service. 1980. Maryland Agricultural
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Agriculture, College Park, Maryland. June. 69 pp.
Maryland Department of Health and Mental Hygiene. 1976.
Report Indicating Plans and Possibilities for the
Alleviation of Pollution in the Lower Patuxent River.
November. Baltimore, Maryland. 30 pp. ~
Maryland Department of Health and Mental Hygiene. 1977a.
Quarterly Report of Air Pollution Measurements in Maryland:
January, February, March 1977. May. Baltimore, Maryland.
25 pp.
Maryland Department of Health and Mental Hygiene. 1977b.
Ouarterly Report of Air Pollution Measurements in Maryland;
April, May, June 1977^ August. Baltimore, Maryland. 25 ~
pp.
Maryland Department of Health and Mental Hygiene. 1977c.
Ouarterly Report of Air Pollution Measurements in Marylands
July, August, September 1977. December. Baltimore, ~~
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Maryland Department of State Planning. 1973. Natural Soil
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153 pp.
182
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Maryland Department of State Planning. 1974a, Topographic
Slope, Technical Report. August. Baltimore, Maryland. 15
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Maryland Department of State Planning. 1974b. Geology,
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Maryland Department of State Planninq. 1976. State Planning
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Maryland Department of State Planninq, Maryland Comprehensive
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Maryland Department of State Planning. 1979. Maryland
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Publication #349. January. Baltimore, Maryland. 35 pp.
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Maryland-National Capital Park and Planning Commission. 1976.
An Amendment to the 1964 Master Plan for the Patuxent River
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Maryland Water Resources Administration. 1975. Policy on
Phosphorus Reduction Requirements, Nitrogen Reduction
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Residual Reservation for SpecTfied Waters of the State.
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Maryland Water Resources Administration. 1978. Patuxent
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Unpublished^ Annapolis, Maryland^ n.p.
Maryland Water Resources Administration. 1977a. NPDES
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Maryland Water Resources Administration. 1977b. Patuxent
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183
-------
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the Maryland Portion _gf~"_the Chesapeake' Bay, 1939 - 107^—~
Appendix~A~and B. Horn Point Environmental L^boratoFiiT"
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Meyer, Eugene L. 1977. "Fresh Water Ruins River Industry
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Mihursky, Joseph A. and Walter R. Boynton. 1978. Review of
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Mihursky, J. A., M. Homer and W. Caplins. 1980. Condition
Factors and Length/ Weight Regressions AssociateTTwiTR—~
Certain Fish Species Near Chalk Point Power PfsmT—o^irrr...
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Power Plant Siting Program, Annapolis, Maryland. 66 pp
Mihursky, J. A., M. Homer, p. w. Jones and R. Bradford jr
1979. Fish Community Studies in the Patuxent Estuarv "
1978-79^ PPSP-CP-80-6. Maryland Power Plant Siti.no
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Mihursky, J. A., M. Homer, P. w. Jones, R. Bradford and J m
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Cooperative PPSP/WRA Project, 1978. PPSP-CP-80-9 ~
Maryland Power Plant Siting Program, Annapolis, Maryland.
Mihursky, J. A., M. Homer, p. w. Jones, R. Bradford j m
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and D. Elam. 1980b. Demersal Fish Pood Habit £
the Chalk Point Power Plant, Patuxent fclstuarv. ~
1978-1979. PPSP-CP-80-12. Maryland PoweFTltKrlrfT^-11-
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Mihursky, J. A., E. M. Setzler, k. V. Wood, D. Shelton and r
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Miller, Robert E., Tibor T. Polgar and Paul A Sauza. 1970
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184
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Moffet, Jesse. 1981. Personal Communication with Andris
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Montgomery County. 1976a. Comprehensive Ten-Year Water
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National Marine Fisheries Service. 1978b. Maryland Landings
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National Marine Fisheries Service. 1979b. Summary of
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185
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January 22.
1Q6
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Sizemore, Ronald K. and R. R. Colwell. 1977. "Plasmids
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from Municipal Wastewater Treatment Facilities. U.S.
Government Printing Office Rpt. No. 1979-281-147/30.
April. Washington, D.C. v.p.
U.S. Environmental Protection Agency. 1979a. Draft
Environmental Impact Statement Support Document on Patuxent
Wastewater Treatment Facilities, Anne Arundel County,
Maryland. WAPORA, Inc. U.S. Government Printing Office
Rpt. No. 1979-603 087-EIS-08. September. Washington,
D.C. 46 6 pp.
U.S. Environmental Protection Agency. 1979b. Draft
Environmental Impact Statement, Patuxent Wastewater
Facilities, Anne Arundel County, Maryland. WAPORA, Inc.
June 27. Philadelphia, Pennsylvania, v.p.
189
-------
U.S. Environmental Protection Agency. 1980. Onsite
Wastewater Treatment and Disposal Systems-Design Manual.
EPA-625/1-80-012. October. Washington, D.C. 392 pp.
U.S. Environmental Protection Agency. 1981. Water Quality
Analysis of the Pauxent River, Preliminary Draft.
HydroQual, Incorporated, Philadelphia, Pennsylvania. n.p.
U.S. Geological Survey. 1965. Ground-Water Levels in the
United States 1959-63, Southeast States. Geological Survey
Water Supply Paper 1803. Reston, Virginia. 265 pp.
U.S. Geological Survey. 1974. Water From the Coastal Plain
Aquifers in Washingtn, D.C. Metropolitan Area. Circular
697. Reston, Virginia.
U.S. Geological Survey. 1978. Water Resources Data for
Maryland and Delaware, Water Year 1977. U.S.G.S.
Water-Data Report MD-DE-77-1. Reston, Virginia. 320 pp.
U.S. Geological Survey. 1980. Water Resources Data for
Maryland and Delaware, Water Year 1980. MD-DE 80-1.
Reston, Virginia. 431 pp.
Vokos, Harold E. and Jonathan Edwards, Jr. 1968. Geography
and Geology of Maryland. Bulletin No. 19. Maryland
Geological Survey. Baltimore, Maryland. 243 pp.
Wanielista, M. P., Y. A. Yousef and M. McLellon. 1977.
"Nonpoint source effects on water quality". Journal Water
Pollution Control Federation. March. Vol. 4
-------
Williams, Jr., D. C., David J. Etzold and Edward Nissan.
1980. Oyster Depuration Facility: Economic Assessment.
MASGP-79-Q11. College of Business Administration,
University of Southern Mississippi. June. Hattiesburg,
Mississippi, n.p.
Zaborski, Jim and Dexter Haven. 1980. Oyster Mortalities in
the Upper Rappahannock River and in the Virginia
Tributaries of the Lower Potomac - Their Association With
High River Discharge and LovT Salinity. SRAMSOE No. 241.
Virg in ia Inst itute of Marino Science, College of William
and Mary. August. Glauce.'"ter Point, Virginia. 12 pp.
191
-------
SAVAGE EIS DISTRIBUTION LIST
FEDERAL AGENCIES
Advisory Council on Historic Preservation
Council on Environmental Quality
Federal Emergency Management Agency
National Agricultural Lands Study
US Bureau of Prisons
US Department of Agriculture
Soil Conservation Service
US Department of the Army
Corps of Engineers
Baltimore District
US Department of Commerce
Office of Environmental Affairs
National Marine Fisheries Service
US Department of Defense
US Department of Energy
Office of the Secretary for the
Environment
US Department of Health and Human
Services
US Department of Housing and Urban
Development
US Department of Interior
Bureau of Outdoor Recreation
Fish and Wildlife Service
National Water Resource Analyses Group
Eastern Energy Land Use Team
National Park Service
US Department of Transportation
Federal Highway Administration
Marine Environmental Protection Division
US Department of the Treasury
US General Services Administration
Water Resources Council
MARYLAND STATE AGENCIES
Department of Agriculture
Department of Economic and Community
Development
Department of Health and Mental Hygiene
Air pollution control Commission
MARYLAND STATE AGENCIES (cont.)
Bureau of Air Quality and Noise Control
Office of Environmental Programs
Department of Natural Resources
Extension Service
Maryland Environmental Services
Maryland Forest Service
Maryland Geological Survey
Maryland Park Service
Tidewater Administration
Water Resources Administration
Department of Parks and Recreation
National Capital Park and Planning
Commission
Department of State Planning
State Clearinghouse
Department of Transportation
State Highway Administration
Maryland Council on the Economy,
Environment and Energy Production
Maryland Geological Survey
LOCAL AGENCIES
Anne Arundel County
County Administrator
Department of Public Works
Health Department
Office of Planning and Zoning
Soil Conservation Commission
Wildlife Administration
Calvert County
Board of Commissioners
County Administrator
County Planner
Department of Public Works
Health Department
Office of Land Use
Planning Commission
Sanitary commission
Charles County
Soil Conservation District
Howard County
Board of Commissioners
County Council
Department of Public Works
Health Department
Office of Lav/
Montgomery County
Office of Environmental Planning
Washington Suburban Sanitary Commission
193
-------
LOCAL AGENCIES (cont.)
ELECTED OFFICIALS (cont.)
St. Mary's County
Office of Planning and Zoning
REGIONAL AGENCIES
Interstate Commission on the Potomac
River Basin
Metropolitan Commission
Metropolitan Washington Council of
Governments
Regional Planning Council
Tri-County Council for Southern Maryland
ELECTED OFFICIALS
Honorable Harry R. Hughes
Office of the Governor
Honorable Charles MacMathias, Jr.
US Senate
Honorable Paul S. Sarbanes
US Senate
Honorable Beverly B. Byron
US Representative
Honorable Goodloe Edgar Byron
US Representative
Honorable Roy Dyson
US Representative
Honorable Marjorie Holt
US Representative
Honorable Clarence Dickinson Long
US Representative
Honorable Barbara Ann Mikulski
US Representative
Honorable Darren J. Mitchell
US Representative
Honorable Gladys Noon Spellman
US Representative
Honorable Newton Ivan Steers
us Representative
Honorable Aris T. Allen
Maryland Senate
Honorable John A. Cade
Maryland Senate
Honorable James Clarks, Jr.
Maryland Senate
Honorable Edward T. Conroy
Maryland Senate
Honorable Thomas V. Mike Miller,
Maryland Senate
Honorable H. Erie Schafer
Maryland Senate
Honorable James C. Simpson
Maryland Senate
Honorable Tyras S. Athey
Maryland Delegate
Honorable Torrey C. Brown
Maryland Delegate
Honorable Hugh Burgess
Maryland Delegate
Honorable Gerard F. Devlin
Maryland Delegate
Honorable Elner F. Hagner, Jr.
Maryland Delegate
Honorable 0. James Lighthizer
Maryland Delegate
Honorable Robert R. Neall
Maryland Delegate
Honorable Joan Pitkin
Maryland Delegate
Honorable John William Quade, Jr.
Maryland Delegate
Honorable Charles J. Ryan
Maryland Delegate
Honorable Patrick c. Scannello
Maryland Delegate
Honorable George T. Schmincke
Maryland Delegate
Honorable Elizabeth S. Smith
Maryland Delegate
Honorable Michael J. Sprague
Maryland Delegate
Honorable Gerald W. Winegrad
Maryland Delegate
Honorable John w. Wolfgang
Maryland Delegate
194
-------
LIBRARIES
MEDIA (cont.)
Annapolis Library
Brooklyn Parks Library
Calvert County Public Library
Charles County Public Library
Crofton Library
Howard County Library
Kuethe Library
Linthium Library
MD City Library
North County Library
Odenton Library
Riviera Beach Library
Severna Park Library
South County Library
MEDIA
Anne Arundel Times
Baltimore Sun
Bowie
Bowie Blade
Bowie News
College Park-The Prince George's Journal
Crofton Courier
Crofton Crier
Enterprise Newspapers
Evening Capital
Glen Burnie Maryland Gazette
Howard County News
Howard County Times & Columbia Flyer
Hyattsville Prince George's County
Sentinel
Hyattsville The New Prince George's Post
Laurel News Leader
Laurel Prince George's County News
Laurel Sentinel
Leonardtown-St. Mary's Beacon
Lexington Park Enterprise
New Carrollton Blade
News American
Post
Prince Frederick Calvert Independent
Prince Frederick Calvert Journal
Prince Frederick Recorder
Severna Park Village Voice
Sun
RADIO
TV
WBAL-TV
WBFF-TV
WDCA-TV
WETA-TV
WHMM=TV
WJZ-TV
WMAB-TV
WMAL-TV
WRC-TV
WTOP-TV
WTTG-TV
CITIZENS
WAYE-AM
WBAL-AM
VfBJC-FM
WBMD-AM
WFBR-AM
WFMD-AM
WISZ-AM
WITH-Ml
WKIK-AM
WLIF-AM
WLMD-AM
WMAL-AM
WMJS-FM
VJNAV-AM
WRC-AM
WSPH-FM
WTOP-AM
WTRI-AM
WYRE-AM
WZYO-AM
Ahern, Edwward C. Jr.
Allen, Eddie
Allen, Scott
Anderson, Jan
Arminger, Earl L.
Baer, William
Bayles, C. B.
Belt, Dorothy
Bender, Walter L.
Bishop, Lee
Bishop, Richard
Bishop, William
Blackburn, William R.
Boettcher, Evelyn, M.
Boyd, Richard
Breeder, Steven K.
Brennan, Robert E.
Britt, Clarence S.
Brooks, Ned
Brown, Charles
Brown, M.
Carrell, David
195
-------
CITIZENS
CITIZENS (cont.)
Christmas, John
Conrad, David
Crist, Howard
Crow, Tom
Digges, Mitchell
Dixon, R.
Dixon, William E.
Downing, Collins S.
Downing, Dent
Duvall, John
Engel, William T.
Evans, Diane R.
Farrell, John A.
Farrogit
Ferguson, Frank
Finney, Connie
Fleischaker, David
Foster, Delbert R.
Gaiser, William H.
Geis, Alfred D.
Giovanniello, Michael
Glick, Michael
Gluck, William
Gordon, Alan
Graham, James W.
Grope, Shirley
Gutman, James E.
Hardy, Margo
Hartman, Ronald
Hasfurther, William A.
Harvey, E.
Hedrick, James
Heinle, Don
Hucker, Pat
Hudson, Ted
Hyatt, Bernard S.
Jansson, Eric
Jeffrey, Edward
Johnston, W.D. , III
Jones, Martin R.
Karin, J.
Kerwin, Ed
Kintz, Sidney
Knutson, E. Lawrence
Kriebel, Paul W.
Lederman, Thor.ias
Lyding, John
Lynch, Mary
Mace, Tom
Mackeroy, H. C.
Marmon, Robert
Marti, Mr. & Mrs.
Maynes, John
Mcintosh, Ellen
Meaghes, Pat
Menke, Robert
Milhursky, Joseph
Mohler, Philip
Mountford, Kent
Mulford, Richard
Muntz, "William
Newborn, James S.
Nipparo, R. E.
Norden, Arnold
Pace, Michael
Pery, M.
Pickett, Merhle P.
Poe, Tom
Poberson, Thomas D.
Proul, Craig
Paum, Walter
Peeves, Merilyn
Piener, Michael
Ripley, R. Graydon
Robbins, Pete
Roberts, James B,
Roeder, Heinz
Rome, B.
Saunders, Vernon
Schulte, Jim
Shepherd, Edward 0.
Sherman, Ellen
Sullivan, Helen
Sullivan, Kevin
Swecker, Edward L.
Tacinelle, Gerald
Thanner, Lawrence J.
Tippitt, J. Royal, Jr.
Tullier, S.
Ulanawicz, Robert
Vagt, Mr. & Mrs.
Van Deusen, Marie
Walter, Harry
Ward, Wilbur, F., Jr.
Watson, Richard
Khirley, Laura A.
White, Joseph J.
Wilkerson, Oren R,
Winer, Jay
Winer, Simon
Wood, Betty Jane
Woodford, Waltern E., Jr.
Wroten, Charles G.
CITIZENS GROUPS
Allied Civic Group-Public Utilities &
Environment Committee
American the Beautiful Fund
Audubon Naturalist Society of the Central
American States, Inc.
Audubon Society
Baltimore Environmental Center, Inc.
Better Air Coalition
Center for Environmental & Estuarine
Studies
Chesapeake Audubon Society
196
-------
CITIZENS GROUPS (cont.)
Chesapeake Bay Seafood Asso.
Chesapeake Bay Foundation
Chesapeake Environmental Protection Asso.
Davidsonville Area Civic Asso.
Delmarva Advisory Council
Environmental Concern, Inc.
Environmental Policy Center
Friends of the Earth-Potomac Branch
Hopkins Civic Association
Izaak Walton League-MD Division
League of Women Voters
Maryland Chapter
National Capitol Area
Maryland Cold Water Coalition
Maryland Conservation Council
Maryland Environmental Trust
Baltimore County Chapter
Maryland Watermen's Asso., Inc.
National Parks and Conservation Asso.
Natural Resources Defense Council
Odenton Businessmen's Asso.
Patuxent Beach Community Asso.
Patuxent River Park
Potomac River Asso.
Potomac River Basin Advisory Committee
Prince George's Fish and Game Commission
Rachel Carson Trust for the Living
Environment
Resources for the Future, Inc.
Seneca Valley Citizen's Asso., Inc.
Sierra Club
Patuxent Chapter
Potomac Chapter
Society for a Better Environment
CITIZENS GROUPS (cont.)
Southeast Community Organization, Inc.
The Wildlife Society
Upper Chesapeake Watershed Asso.
Water Pollution Control Federation
Wilderness Society
OTHER
Betz, Converse, and Murdoch
Betz Environmental Engineers, Inc.
Camp, Dresser and McKee
Centrex Homes Corp.
CH2M Hill
Chesapeake Bay Center for Environmental
Studies
Collins & Downing, Sr.
Connell, Metcalf & Eddy Planning and
Architectural Engineering
David Volkert and Asso.
ESEI, inc.
Gannett, Fleming, Corddry and Carpenter,
Inc.
Howard Research & Development Corp.
International Research & Evaluation
K & M Development
Martin Marietta Laboratory
Metcalf & Eddy Engineers
O'Brien & Gere
Philadelphia Academy of Sciences
at Benedict
Potomac Electric Power Commission
University of Maryland - Inland
Environmental Lab
Water Quality Environmental Affairs
197
-------
Appendices
-------
APPENDIX A
ALTERNATIVES
-------
INFLUENT
SEWAGE
SLUDGE
EFFLUENT
SLUDGE
OXIDATION
SLUDGE TO DISPOSAL
PRELIMINARY
TREATMENT
SAND BEDS
CHLORINATION
LAGOON
CONTACT
STABILIZATION
(5MGD)
ACTIVATED
SLUDGE
(5 MGD)
FIGURE A-1
SAVAGE TREATMENT PLANT-EXISTING AFTER THIRD ADDITION
-------
SEWAGE
SLUDGE
INFLUENT
>
i
N>
BACKWASH
SUPERNATANT
SLUDGE
FLOW
TREATMENT
EQUALIZATION
PHOSPORUS
REMOVAL
NITRIFICATION
TREATMENT
I
ACTIVATED
9LUDGE
(15 MGD)
FILTRATION
CHLORINATION/
DECHLORINATION
POST
AERATION
SLUDGE TO
DISPOSAL
Alternative 1 includes the following
additional units to the existing plant
Flow Equalization
Primary sedimentation tanks
Activated sludge aeration tanks
Secondary clarification tanks
Nitrification aeration tanks
Nitrification clarification tanks
Phosphorus stripping tanks
Phosphorus reactor clarifiers
Flocculation basin
Filtration
Chlorination and dechlorination
Post aeration basin
Flotation thickeners
Aerobic digesters
Gravity thickeners
Sludge dewatering (vacuum filters)
DISCHARGE TO
L. PATUXENT
(BELOW FORT MEADE
RAW WATER INTAKE
STRUCTURE)
FIGURE A-2
ALTERNATIVE 1
-------
Table A-l. ALTERNATIVE 1.
Item Cost
° Upgrading and expansion of LPWQMC to
15 mgd of advanced wastewater treatment. $ 30,640,000
° Outfall with discharge below Fort Meade
raw water intake structure 2,500,000*
Subtotal 33,140,000
° Step III costs (Administrative, Legal,
Engineering and Contingencies) 11 ,630 ,000
Construction Cost 44,770,000
Present Worth of Construction Cost 40,260,000
° Annual treatment plant operation and
maintenance (o&M) costs 1,800,000
Present Worth of O&M 17,090,000
Present Worth of Salvage Value 2,590,000
Present Worth of Alternative 1 $ 54,760,000
*4/5 of outfall costs;
1/5 of cost paid by General Electric. For evaluation only?
outfall as built does not include these flows.
A-3
-------
SEWAGE
SLUDGE
INFLUENT
PRELIMINARY
TREATMENT
ACTIVATED
SLUDGE
(15 MGD)
PHOSPHORUS
REMOVAL
Alternative 2 includes the
following additional units to
the existing plant:
Flow equalization
Primary sedimentation tanks
Activated sludge aeration tanks
Secondary clarification tanks
Nitrification aeration tanks
Nitrification clarification tanks
Phosphorus stripping tanks
Phosphorus reactor clarifiers
Chlorination and dechlorination tanks
Flotation thickeners
Aerobic digester
Gravity thickeners
Sludge dewatering (vacuum filters)
Satellite post aeration basin
60 mgd capacity effluent pumping station
FLOW
EQUALIZATION
SUPERNATANT
SLUDGE
TREATMENT
SLUDGE TO
DISPOSAL
POST
AERATION
NITRIFICATION
CHLORINATION/
DECHLORINATION
DISCHARGE TO
THE PATAPSCO
FIGURE A-3
ALTERNATIVE 2
-------
Table A-2. Alternative 2.
Item Cost
° Upgrading and expansion of LPWQMC to
15 mgd of advanced wastewater treatment. $ 28,370,000
° Force main/outfall system and pump stations
with discharge to the Patapsco River. 6,750,000
Subtotal 35,120,000
° Step III costs (Administrative, Legal,
Engineering and Contingencies) 12 ,320 ,000
Construction cost 47,430,000
Present worth of construction costs 42,660,000
0 Annual treatment plant and pump stations O&M 1,830,000
Present worth of O&M 20,770,000
Present worth of salvage value 2,580,000
Present worth of Alternative 2 $ 60,850,000
A-5
-------
>
cr>
BACKWASH
ALUM
SLUDGE
TREATMENT
SUPERNATANT
SLUDGE TO
DISPOSAL
SLUDGE TO
DISPOSAL
DISCHARGE TO
L. PATUXENT
BELOW RAW
WATER INTAKE
SEWAGE
SLUDGE >
TREATMENT
POST
AERATION
CHLORINATION
FILTRATION
ACTIVATED
SLUDGE
(5 MGD)
PHOSPHORUS
REMOVAL
CHLORINATION;
DECHLORIN-
ATION
PRELIMINARY
TREATMENT
PRELIMINARY
TREATMENT
NITRIFICATION
ACTIVATED
SLUDGE
(10 MGD)
DISCHARGE TO
DEEP RUN
SLUDGE
FIGURE A-4
ALTERNATIVE 3A.1
-------
Table A-3. Alternative 3A.1.
Item Cost
° Upgrade LPWQMC to 10 mgd advanced
wastewater treatment $ 20,130,000
° Outfall with discharge below Fort Meade
raw water intake structure 1,790,000*
° New 5 mgd secondary WTP at Deep Run 10,540,000
° Force main/outfall system and pump station
to Deep Run plant 2 ,110 ,000
Subtotal 34,570,000
° Step III costs (Administrative, Legal,
Engineering and Contingencies) 12,120,000
0 Land for Deep Run Plant 30,000
Construction costs 46,720,000
Present worth of construction costs 42,020,000
° Annual O&M for LPWQMC and Deep Run plants
and pump station 1,820,000
Present worth of O&M 17,300,000
Present worth of salvage value 3,200,000
Present worth of Alternative 3A.1 S 56,120,000
($ 53,950,000)**
*3/4 of outfall costs;
1/4 of cost paid by General Electric. For evaluation only;
outfall as built does not include these flows.
**Present worth of alternative without outfall below raw water
intake structure.
A-7
-------
>
I
CD
BACKWASH
ALUM
SLUDGE
TREATMENT
SUPERNATANT
SLUDGE TO
DISPOSAL
DISCHARGE TO
L. PATUXENT
BELOW RAW
WATER INTAKE
CHLORINATION
SEWAGE
SLUDGE
PUMP
DISCHARGE TO
LAND APPLICATION
FIGURE A-5
POST
AERATION
AERATED
LAGOONS
(5 MGD)
FILTRATION
POLISHING/
HOLDING
POND
PHOSPHORUS
REMOVAL
CHLORINATIONJ
DECHLORIN-
ATION
PRELIMINARY
TREATMENT
PRELIMINARY
TREATMENT
NITRIFICATION
ACTIVATED
SLUDGE
(10 MGD)
DISCHARGE TO
LAND APPLICATION
SITES
FIGURE A-5
ALTERNATIVE 3A.2
-------
Table A-4. Alternative 3A.2.
Item
Cost
Upgrading LPWQMC to 10 mgd of advanced
wastewater treatment
Outfall with discharge below Fort Meade
raw water intake structure
New 5 mgd aerated lagoon at land application
site
Force main and pump stations to land
application site
Land application equipment
Subtotal
Step III costs (Administrative, Legal,
Engineering and Contingencies)
Land for application site and WTP
Construction cost
Present worth of construction cost
Annual O&M of LPWQMC, land application plant
and equipment and pump stations
Present worth of O&M
Present worth of salvage value
$ 20,130,000
1,790,000*
1,280,000
4,510,000
3,300,000
31,010,000
10,880,000
10,400,000
52,290,000
49,170,000
2,190,000
20,800,000
4,920,000
Present worth of Alternative 3A.2
$ 65,050,000
$(62,880,000)**
*3/4 of outfall costs;
1/4 paid by General Electric. For evaluation only; outfall as
built does not include these flows.
**Present worth of alternative without outfall below raw water
intake structures.
A-9
-------
SUPERNATANT
10 MGD
"1
INFLUENT
S MGD
SLUDGE
TREATMENT
ALUM
SLUDGE TO
DISPOSAL
PUMP
DISCHARGE TO
DEEP RUN
DISCHARGE TO
L. PAUXENT
OR
SEWAGE
DISCHARGE TO
POST
AERATION
POST
AERATION
PHOSPHORUS
REMOVAL
FILTRATION
ACTIVATED
SLUDGE
(10 MGD)
PRELIMINARY
TREATMENT
FLOW
EQUALIZATION
CONTACT
STABILIZATION
(5 MGD)
CHLORINATION
NITRIFICATION
CHLORINATION/
DECHLORINATION
LAND APPLICATION SLUDGE
SITE
FIGURE A-8
ALTERNATIVE 3B
-------
Table A-5. Alternative 3B.1
Item Cost
Upgrading and expansion of LPWQMC to 10 mgd
advanced and 5 mgd secondary wastewater
treatment $ 29,040,000
Outfall with discharge below Fort Meade raw
water intake structure 1,790,000"
Force main/outfall system and pump station to
Deep Run with post aeration basin. 2,460,000
Subtotal 33,290,000
Step III cost (Administrative, Legal,
Engineering and Contingencies) 11,670,000
Construction cost 44,960,000
Present worth of construction cost 41,610,000
Annual O&M of treatment plant and force main
system 1,626,000
Present worth of O&M 15,440,000
Present worth of salvage value 2,430,000
Present worth of Alternative 3B.1 $ 54,620,000
$(52,460,000)**
*3/4 of outfall costs;
1/4 paid by General Electric. For evaluation only; outfall as
built does not include these flows.
**Present worth of alternative without outfall below raw water
intake structure.
A-11
-------
Table A-6. Alternative 3B.2.
Item
Cost
Upgrading and expansion of LPWQMC to 10 mgd
advanced and 5 mgd secondary treatment
Outfall with discharge below Fort Meade raw
water intake structure
Force main/pump stations to land application
site
Land application equipment
Subtotal
Step ril coats (Administrative,, Legal,
Engineering and Contingencies)
Land for application site
Construction costs
Present worth of construction costs
Annual O&M of treatment plant, land application
equipment, and pump stations
Present worth of O&M
Present worth of salvage value
$ 23,040,000
1,790,000*
4 ,510,000
3,300,000
39.640,000
13,550,000
10,400,000
62,590 ,000
58,700 ,000
2,080,000
19,790,000
5,630,000
Present worth of Alternative 3B.2
$ 72,860,000
4$ 70,690,000)*
*3/4 of outfall costs;
1/4 paid by General Electric. For evaluation only* outfall as
built does not include these flovs,
'•Present worth of alternative without outfall below raw water
intake structures.
A-12
-------
PARTIAL
FLOW
EQUALIZ
ATION
AERATED
LAGOONS
(15 MGD)
INFLUENT
PRELIMINARY
TREATMENT
PUMP
POLISHING/
HOLDING
POND
CHLORINATION
DISCHARGE TO
LAND APPLICATION
FIGURE A-7
ALTERNATIVE 4
-------
Table A-7. Alternative 4.
Item Cost
° New Treatment Plant, Land Application Equipment
and Holding Pond $14,650,000
0 Force Main System to Application Sites* 6,350,000
° Pump Stations 6,850,000
Subtotal 27,850,000
0 Step III Costs 9,770,000
37,620,000
° Land for Application Site, Treatment Plant and
Holding Pond 30,150,000
Total 67.770,000
Present Worth 63,980,000
0 Annual O&M 1,384,000
° Present Worth of 06M 12,570,000
° Salvage Value 10,130,000
Total Present Worth $66,420,000
*The cost of the force main system is based only on conveying the
effluent to the sites identified in Figure II-2. The conveyance
costs to other sites necessary for treatment would increase this
figure; the extent of these costs cannot be determined until other
sites have been identified.
A-H
-------
APPENDIX B
HATER SUPPLY USERS
-------
appendix b
WATER SUPPLY USERS
Howard County Howard County depends completely upon neighboring jurisdictions for
public potable water supply. All water supplies to Howard County's
public potable water system currently come from the city of Balti-
more and the WSSC. The remainder of the county's water supply is
obtained from private wells and a few surface water sources. The
present average daily requirement for the county is approximately
12 mgd. About 9.03 mgd is supplied through public systems, which
serve 74% of the county's population. By the year 2000, the public
system is expected to serve 95% of the population with the city of
Baltimore providing 30.8 mgd, the WSSC 6.5 mgd, and groundwater
sources 5 mgd (Howard County, 1980 ). Both the city of Baltimore
and the WSSC intend to meet the future water supply needs of the
county through the year 2000 (Kretschmar, 1981; Shagogue, 1981).
Groundwater yields are generally very limited in the crystalline
rock formations which underlie Howard County. Yields are low, but
generally adequate to meet the needs of domestic and farm uses
(Dinqman, et al., 1954 ). The city of Baltimore and the WSSC have
adequate transmission and supply capabilities to meet existing
supply needs, and they intend to meet the future water supply needs
of Howard County. However, under peak hour or drought conditions,
user restrictions can be placed on Howard County by the suppliers.
The Washington Suburban Sanitary Commission (WSSC), a quasi-public
Montgomery and water and sewer agency in Montgomery and Prince George's Counties
PhrTnce George's is the principal consumer of raw water from the Patuxent River
Counties (Table II I —1). Twenty-five percent of the water it supplies to its
servicing area comes from the Patuxent River basin (U.S. Army Corps
of Engineers, 1979). The Patuxent River is regulated by two dams:
Brighton Dam, which impounds Triadelphia Reservoir, and T. Howard
Duckett Dam, which impounds Rocky Gorge Reservoir. Both dams were
constructed as water supply projects by the WSSC and control 132
square miles of drainage area. The gross storage capacities of the
reservoirs are 7.0 billion gallons (bg) for Triadelphia and 6.4 bg
for Rocky Gorge. The annual safe yield of the reservoirs has been
estimated at 42 mgd, based on low flows of the 1930s (Bi-County
Water Supply Task Force, 1978). Safe yield is defined as the con-
stant average daily withdrawal from combined streamflow and storage
during a period equivalent to the most severe drought on record,
with full storage assumed available at the beginning and end of the
drought. An annual average of 50 to 55 million gallons of water
are withdrawn daily by the WSSC from the two reservoirs (WSSC,
1974). These current withdrawal rates annually exceed safe yield
by 8-13 mgd. Although treated water used in the basin is returned
to the Patuxent through an estimated 60 wastewater discharges, the
exchange is not equal, with the difference (roughly 10-15 mgd)
representing a net loss to the Patuxent River (WSSC, 1974).
For the most part, the WSSC can meet projected water demands for
the counties in its servicing area through the year 2000 under nor-
mal operating conditions (Shagogue, 1981). Critical situations
occur during dry summer months when customer demand increases but
water supply is limited because of low river flows and constrained
intake facilities or when peak day output is less than peak day
demand. Under low flow and drought conditions, water use restric-
tions are implemented. There are presently no plans to increase
impoundments of the reservoirs within the Patuxent basin or in-
crease utilization of Patuxent waters by the WSSC (Shagogue, 1981).
In those areas of Montgomery and Prince George's Counties where
public water service is not available, potable water is provided by
private wells. When totaled, all groundwater supplies in the
B-l
-------
bi-county area account for a small percentage of each county's
water demand.
ial Pnnntv currently does not use the Patuxent River for
WoWilJl-a PurPo,Sa. ha, no intentions of osin, the
Patuxent or any of its tributaries as a future water supply source
(Moffet, 1981}.
Anne Arundel County relies almost entirely on .groundwater for its
water suply needs, except for the northernmost portion of the
w 7 Burnie Service Area) which is supplied partly with
water^ purchased ^om Baltimore City (Anne Arundel County, 1979)
The amount of water received from the city of Baltimore is minimal
Ta maximum of 0.37 mgd S and is generally used only during drought
DPriods (Moffet, 1981). The county has 78 mgd of purchase rights
in agreements with Baltimore City. The projected maximum day
demands for the year 2000 (as outlined in the county's most recent
water and sewerage plan) calls for groundwater sources to supply 48
mqd in add it ion to the 78 mgd of purchase rights contained in these
agreements. However, the county has recently decided to decrease
Us dependence on Baltimore water and strive for self sufficiency
by increasing the use of its groundwater resources.
According to studies conducted by the U.S. and Maryland Geological
Surveys, the county's future water supply demand can be easily met
from the three major water producing formations m the county: the
wLnthv the Patapsco and the Patuxent formations. U.S. Geologic
Survey (USGS) Circular 697, entitled "Water from the Coastal Plain
Aquifers in the Washington, D.C. Metropolitan Area and dated 1974,
computed the water supply potential of the Patuxent formation to be
8 0 mad, the Patapsco 50 mgd, and the Magothy 40 mgd. Previous
studies by USGS also Indicate that geologic and climatic conditions
favor the availability of groundwater in the county (Mack and
Richardson, 1962).
The tri-county region (Calvert, Charles and St. Mary's Counties)
receives virtually all °£ water supply from groundwater
sources. Favorable geological conditions have provided substan-
tial supplies of groundwater that appear to be adequate for any
foreseeable level o£ development for the region m the years ahead.
of the plentiful underground supply of potable water, none
of the counties within the tri-county area has plans to use the
Patuxent River as a water supply source. The capital costs of
desiring and building intake structures, underwater transmission
itextensive transmission mains and a complete water treatment
facility, Plus the high operating expenses of desal mization, rule
out using the Patuxent.
Calvert, Charles
and St. Mary's"
Counties
B-2
-------
APPENDIX C
PUBLIC HEALTH IMPACTS
-------
APPENDIX c.
PUBLIC HEALTH IMPACTS
Waterborne Diseases Warmblooded animals, man in particular, add a variety of intestinal
pathogens to water through fecal pollution. (Pathogens are
infectious agents capable of causing disease in a susceptible
host.) Waterborne disease incidents may be related to a number of
factors: (1) raw wastewater contamination of water supplies, (2)
inadequate treatment of a contaminated surface or groundwater
supply, (3) abuse of commonly accepted wastewater practices, (4)
contamination by untreated or partially treated wastewater applied
to food crops to be eaten raw, (5) inadvertent swallowing of large
amounts of water, or (6) exposure of open sores and other sensitive
areas during water contact recreational activities.
The most common pathogens include strains of Salmonella, Shigella,
Leptospira, enteropathogenic Escherichia coli, Pasteurella^ Vibrio 7
Mycobacterium, human enteric viruses, cysts of Endamoeba hTstoly-
t ica, and hookworm larvae. The following discussion briefly
reviews several common pathogenic microorganisms and the sickness
they may cause. Salmonella strains are found most frequently
(Mitchell, 1972). Salmonella typhi, typhoid, is specific for man
and does not occur in other animals. In humans, salmonellosis most
commonly occurs as an acute gastroenteritis with diarrhea and
cramps. Fever, nausea and vomiting are frequent additional
symptoms.
Shigellosis is the most commonly identified cause of acute diar-
rheal disease in the U.S. Symptoms may vary from a mild transitory
diarrhea to severe prostrating attacks accompanied by high tempera-
tures, vomiting and profuse bloody stools. Most shigellosis epi-
demics are food-borne or spread by person-to-person contact. A
significant number of epidemics, however, have resulted from poor
quality drinking water.
Leptospirosis causes acute infections involving the kidneys, liver
and central nervous system. It is transmitted to man by various
domestic animals, including cattle, swine, horses and dogs, as well
as animal pests. Leptospira may enter recreational streams and
lakes through direct urination of infected animals that gain access
to the water, or from drainage of adjacent livestock pasture land.
Enteropathogenic Escherichia coli frequently cause a gastroenteri-
tus characterized by a profuse watery diarrhea with little mucus
and no blood, nausea, prostrations and dehydration with a general
absence of fever. They are present in streams and lakes polluted
with warm-blooded animal feces, the occurrence being probably less
than 1% of the fecal coliform population (Mitchell, 1972).
Pseudomonas aeruginosa and Staphylococci aureus are two common
secondary pathogens that cause illness through skin contact. P.
aeruginosa is associated with eye and ear infections. It is
resistant to antibiotics and often invades individuals in debili-
tated states. The organism is ubiquitous and is known to be dis-
charged in the feces. Olivieri (1980) found P. aeruginosa to be
the most abundant pathogen in urban streams in Baltimore.
Although direct contact with infected persons is the most important
source of S. aureus, prolonged contact with water carrying concen-
trations of a wide variety of S. aureus strains could be an impor-
tant factor in the infection of cuts and abrasions. The organism
is responsible for a wide spectrum of clinical diseases. Boils,
carbuncles, abscesses and impetigo are common skin lesions
(Olivieri, 1980).
C-l
-------
Any human virus that is excreted in the feces may theoretically be
transmitted through water by fecal contamination. Enteroviruses
(oolio virus, cox sackie viruses, and ECHO viruses) adenoviruses,
and reoviruses have all been found in sewage and polluted rivers.
ThP aaent for infectious hepatitus remains unknown. However, in
the reported infectious hepatitus epidemics from 1895 to 1964 and
more recently, contaminated municipal supplies, wells and spring
water were indicted as the mode of transportation (Mitchell,
1972) .
information on reported waterborne disease in the United States
between 1961 and 1974 is summarized in Table C-l. The most
outbreaks of disease and greatest number of cases resulted from
qhiaella SP Typhoid fever outbreaks were reported half as often
T^r^TTTaella Sp., with about one-fifteenth the number of reported
^Hpoatitus virus A caused the greatest number of disease
outbreaks These reported waterborne disease outbreaks are likely
be onlv a fraction of the actual number of outbreaks, but were
not recognized or reported during that time period.
Table C-l. Summary Information on Reported Waterborne Disease in
the United States (Crites, et al., 1979).
Wastewater
Constituent
Resulting
Disease
Disease Incidents,
1961-1976
Reported Reported
No. of No. of
Outbreaks Cases
Reported
Untreated
Was tewater
Concentration
(No./100 ml)
indicator Organisms
Total coliforms
Fecal coliforms
NA
NA
NA
NA
NA
NA
109
108
Bacteria
Shigella sp.
Salmonella typhi
Other Salmonella sp.
Escherichia coll
Shigellosis 32 4,413 ND
Typhoid fever 18 326
Salmonellosis 11 16,743 600
4* 188 ND
10^ to 4x10
Virus
Not specified
Hepatitus virus A
Not specified NA
Hepatitus A 43
NA 700 to 1,900
1,254
Note: NA = not applicable
ND = no data
*None reported during 1971-1974.
Sources of Purees omicrobial" cVntam^nation^in the Patuxent Rive
l" he°g""e"nt plant. di.ch„ging to the
Rivpr PatUXe" been or are in the process of being upgraded to secondary
treatment, and have disinfection facilities.
C-2
-------
Urban and rural stormwater runoff are beginning to be considered
important contributors to microorganism concentrations in the
Patuxent River. Urban stormwater contributes pollutants propor-
tional to population density, new construction, street and vegeta-
tion litter, motor vehicle contaminants, fertilizer and animal
manure. Pathogenic microorganisms are consistently found in urban
stormwater, even in systems where storm and sanitary sewers are
separate; however, with the exception of the members of the genus
Shigella, there is little reason known today for extensive public
health concern in recreational waters receiving urban stormwater
(Olivieri, et al., 1977). The total coliform or fecal coliform
index of stormwater quality is very limited due to its uncertain
correlation to the occurrence of pathogenic bacteria and viruses.
Therefore when urban stormwater contributions to a body of water
are great, a coliform index is not useful as an indicator of poten-
tial health risks.
Rural nonpoint sources that contribute to the microbial pollution
of surface waters include runoff from land where landspreading of
either animal manures or sewage washes has occurred, or runoff from
land utilized by grazing animals. »In addition, stormwater runoff
transports fecal contamination from poultry and pig feeding pens,
cattle feedlots and, to a lesser degree, the fecal contributions
from wildlife. The kinds of potentially pathogenic organisms that
may originate from these sources can be enumerated. However, it is
virtually impossible to define with any degree of confidence the
actual disease hazards in light of existing epidemiological data
(Burge and Parr, 1980; Mitchell, 1972).
C-3
-------
APPENDIX D
AQUATIC BIOTA IMPACTS
-------
appendix d.
aquatic biota impacts
Finfish Studies Since the early 1960s the Patuxent River watershed has undergone
many changes. The Chalk Point power plant began using the estuary
as a cooling water supply in 1964. Sewage treatment plant dis-
charges have more than tripled in order to accommodate rapid urban-
ization, particularly in the Baltimore-Washington corridor. Use
patterns of the river have changed. The Patuxent estuary has his-
torically supported a relatively productive, but low diversity,
fish community. Species inhabiting the estuary, particularly those
that can survive in the transitional zone between fresh and salt
water, are physiologically adapted to handle both natural and man-
induced stress conditions. Thus local or regional changes in
environmental quality are not expected to rapidly change the
species composition or diversity of the fish communities (Mihursky,
e t al., 1980 ) .
Mihursky and McErlean (1971) and McErlean, et al., (1973, cited by
Mihursky and Boynton, 1978) noted substantial reductions in fish
diversity for the Patuxent system as compared to the 1962-67
period, but a more recent study by Mihursky, et al. (1980), shows a
reversal of that trend. Mihursky, et al., (1980), recently
completed a survey of both deep and shallow water fish communities
in the Patuxent estuary between Lower Marlboro and Brooms Island.
The survey was designed so that their data could be compared with
data from extensive surveys conducted in the same portion of the
estuary from 1962 through 1967 . Both sets of data were used to
examine detectable trends in the overall system since the 1960's.
Although water quality has changed considerably in terms of
nutrient levels, increased phytoplankton standing stocks and
productivity, dissolved oxygen levels and turbidity, downward
trends in fish species, numbers and diversity have not occurred in
the Patuxent estuary. Mihursky, et al., (1980) speculated that as
deeper zones of the estuary have been eliminated as productive fish
habitat during warmer seasons, the loss has been compensated by
increased productivity in shallower zones.
The dominant fish species captured at various depths at different
times of the year are summarized in Table D-l. White perch and
spot were the only commercially important fish species dominant in
these collections. Spot accounted for an insignificant portion of
the Patuxent commercial catch, while perch contributed the most
poundage of any finfish species in the last several years (Table
D-2) .
Six of the eight dominant species, white perch, hogchoker,
tidewater and Atlantic silversides, spottail shiner, and mummichog,
have a restricted or limited range within the estuary. Spot enter
the estuary in spring, and young-of-year bay anchovy are found in
the estuary during early summer; both species leave during late
fall (Mihursky, et al., 1979). Thus all dominant species are able
to survive in the estuary during mid-to-late summer, the period of
the worst water quality conditions.
Lukacovic (1981) provided a list of documented fish kills in the
estuary between 1965 and 1980. Out of a total of 20 fish kills, 12
were caused by Naval Ordinance Lab underwater explosions, two were
the result of commercial discards, two were attributed to the Chalk
Point power plant, two had unknown causes, one was caused by cold
temperature, and one was suspected of being caused by low dissolved
oxygen. Thus anaerobic conditions resulting from eutrophication
do
D-l
-------
Table D-l. Summary of the Dominant Fish Species Captured During Various Seasons With a Deep Trawl,
Shallow Trawl and Beach Seine Between Lower Marlboro and Brooms Island in the Patuxent
Estuary in 1978.
[Source: Mihursky, et al., 1980]
Deep Trawl
White
Perch
(Morone
ameri-
cana)
Hog-
choker Spot
(Trinectes (Leiostomus
Spottail
Shiner
(Notropis
hud-
Bay
Anchovy
Anchoa
Atlant ic
Silver-
side
(Menidia
Tidewater
Silverside
(Menidia )
Mummi-
chog
(Fundulus
hetero-
maculatus) xanthurus sonius) mitchelli) menidia) beryllina) clitus)
March
May
August
November
x
x
x
x
Shallow Trawl
March
May
August
November
x
x
x
x
x
Beach Seine
March
May
August
November
x
x
X
x
x
x
-------
Table D-2. Commercial Landings Statistics for Striped Bass, Menhaden, White Perch,
Catfish, Blue Crabs and Oysters in the Patuxent Estuary and Maryland
from 1975 through 1979.
[Sources; King, 1981; National Marine Fisheries Service, 1978-1980;
Mihursky and Boynton, 1978]
1975
1976
1977
1978
1979
Striped Bass (lbs/yr)
Patuxont Catch 58,823 25,352 19,607 7,378 14,265
Maryland Catch 2,896,800 1,897,100 1,814,800 1,265,400 946,313
% of Maryland Catch 2.0 1.3 1.1 0.6 1.5
Menhaden (lbs/yr)
Patuxont Catch 7,551 8,316 3,739 1,043 16,253
Maryland Catch 6,105,900 5,379,700 8,381,100 7,115,900 5,608,110
% of Maryland Catch 0.1 0.1 <0.1 <0.1 0.3
White Perch (lbs/yr)
Patuxent Catch 43,039 28,901 45,553 50,466 44,772
Maryland Catch 526,800 439,800 613,700 1,056,200 697,350
% of Maryland Catch 8.2 6.6 7.4 4.8 6.4
Catfish sp. (lbs/yr)
Patuxent Catch 36,185 19,138 11,312 7,073 14,888
Maryland Catch 264,500 246,800 284,300 355,700 579,845
% of Maryland Catch 13.7 7.7 4.0 2.0 2.6
Blue Crabs (lbs/yr)
Hard
Patuxent Catch
Maryland Catch
% of Maryland Catch
221,700
24,264,000
0.9
147,400
19,429,500
0.8
180,000
19,243,396
0.9
110,000
16,590,436
0.7
48,500
24,819,135
0.2
4,800
1,653,900
0.3
2,700
1,473,700
0.2
1,900
1,151,963
0.2
2,800
869,020
0.3
2,200
946,913
0.2
Sof t/Peeler
Patuxent Catch
Maryland Catch
% of Maryland Catch
Oysters (bushels/yr)
Patuxent Catch 97,591 66,823 45,054 86,266 63,636
Maryland Catch 2,440,990 2,292,927 2,045,310 2,276,576 2,100,204
% of Maryland Catch 4.0 2.9 2.2 3.8 3.0
D-3
-------
not appear to be a significant source of finfish kills in the
Patuxent estuary.
Tsai and Golembiewski (1979) studied changes in fish species diver-
fan indicator of community structure and health) between 1966
1,77 in the Patuxent in both the piedmont plateau and coastal
nV^in reaions." In the piedmont region diversity changed very
?ittle In the coastal plain region (where most of the sewage
u ' . ^ are. located) there was a significant reduction in
^ Lrmc '"hich
the - P the patuxent-Crofton outfall (which
droppe rom . reduced species diversity that had
^™r J \n IMs'biloS other plant outfalls ,Fort Hoade
nos 1 and ?, Maryland House of Correction, Maryland City, Parkway
and'Bowie) remained depressed in 1977. On the other hand, species
diversity increased from 1.91 to 2.8 below the Horsepen Wastewater
Treatment Plant (a ^tiary r^^^^corunUies^beTow tJe
and 1977, obvious
chanoes were noted in sections of the river downstream from the
city of Columbia and the Triadelphia Reservoir.
rAmmBrr,ial catch data are published regularly in a somewhat stan-
format The data may be used to estimate the percentage of
Maryland™3Annual landings' taken from the Patuxent and to illus-
trate which species are the most commercially important from year
to year.
Four of the most important commercial finfish in the Patuxent
Four or tne r striped bass, menhaden, white
estuary between i975 andI 1979& for thege four flnfish, as
perch and catfish an^ ovsters, are summarized in Table D-2. For
Welh Tish the table gives the total catch from the Patuxent
each fish, Maryland and the percentage of Maryland's
ratch contributed t!y the Patuxent. During the period examined,
only white perch, catfish and oysters from the Patuxent consistent-
ly contributed more than 2% of the Maryland commercial landings.
* - it is virtually impossible to interpret most of the
Unfortunately, it * Je^%atchy recSrds since there are no data con-
trends eY^de . of oeople engaged in various fisheries, effort,
"TtvDe aqe class composition of various catches, market prices,
gear type, 9 records, etc. (Mihursky and Boynton, 1978). Al-
though landings information clearly cannot be used alone to assess
the health of the Lower Patuxent, some trends in commercial fisher-
ies and their probable causes are discussed below.
?? .necies Of the 160 species of fish recorded in the
About 22 . ^ system are included in the commercial finfish catch
Patuxent Riv ypatuxent River (King, 1981; Mihursky and Boynton,
reported for Boynton (1978) examined commercial catch data
1978). Mihurs y harvests for almost all species were general-
r hiaher prior to 1960 than at present. Whether harvest declines
are rented to water quality or to a shift from the fishing occupa-
tion to other types of work is not known.
• -a K= = = (r-nrkfish) is probably the most important finfish in
in terms of both poundage and desirability Periodic
the Patuxent i i normal for striped bass populations and
fluctuations in numbers are norm^ ^ patuxent harvests between
lYnd°CiC979 were the lowest recorded over the past 20 years.
1976 and 1979 we ^ available. ) However, the Patuxent
(More recent dat llel the total catch for Maryland and suggest
catches generally paraxxei
D-4
-------
that no special features of the Patuxent strongly influence harvest
(Table 111-19) (King, 1981; Mihursky and Boynton, 1978).
Blue crabs play an important role in both commercial and recrea-
tional harvests in the Patuxent and in the Chesapeake Bay. Unfor-
tunately, incomplete data, the closing of some crabmeat picking
plants in the Patuxent area and changes in licensing laws over the
period of record make it impossible to speculate on relative stock
sizes through periods when yields were similar but water quality
conditions were probably quite different (Mihursky and Boynton,
1973).
Patuxent Oysters Oysters occur naturally throughout the lower 21.5 miles of the
Patuxent estuary. From 1963 through 1971, annual harvests from
Patuxent oyster beds ranged between 29,000 and 59,000 bushels and
generally did not parallel trends in Chesapeake Bay harvests. A
peak harvest of 243,000 bushels occurred in 1972-73, after which
harvests declined. Since 1971, growth in oyster harvests have been
due to an extensive seed oyster and shell planting program con-
ducted by the state of Maryland (Mihursky and Boynton, 1978).
Spat sets are a measure of natural oyster reproduction, and
seedings a measure of human oyster management. Spat are tiny
oyster larvae that have stopped swimming, glued themselves in place
on a piece of old shell or hard bottom and begun to grow their own
shell. Seed oysters are young oysters grown in hatcheries or
fertile areas and then planted on oyster bars. Spat and seed
oysters added together represent the number of new oysters entering
the community each year (Fincham, 1979b).
Although the decline in oysters is sometimes blamed on tropical
storm Agnes, a series of poor spat sets since the early 1970s re-
main the one major reason for predicting harvest slumps during the
coming years. Spat sets on natural cultch around the bay have
dropped drastically since 1968, running nearly 72% below the
average sets of the previous 27 years. Fortunately, oyster seeding
works, and human management makes a measurable difference to the
oyster harvest. The Maryland oyster fishery is therefore no longer
a wild fishery, responding only to natural cycles, environmental
damage, and overfishing. Since 1970, the oyster fishery has been a
managed fishery that responds significantly to aquaculture
(Fincham, 1979b).
Several points were made about the status of the Patuxent River
oyster fishery during the Maryland Oyster Spat Survey in the fall
of 1979 (Krantz and Webster, 1980). Among the points made was the
demonstration that the upper river oyster bars are below population
levels for profitable economic harvest. Oysters on several bars
closed by the health department are dying of old age, and oysters
in deepwater above the present patent tong line are also dying
before they enter the harvest. Several upstream oyster bars,
especially above Brooms Island, suffer from water quality problems
(Krantz and Webster, 1980).
Reopening of oyster beds in Maryland is based on ambient water
quality, but, as a supplement, oysters are sampled extensively for
bacteria, viruses, pesticides and heavy metals. Oyster closures
occur almost exclusively because of high bacterial or viral counts
in ambient water; no closures have been attributed to high concen-
trations of toxic substances or pesticides. Most closures are the
result of large storms that cause sewage treatment plant bypasses
and increased runoff (Garreis, 1981).
D-5
-------
T n,oH r 1 osures which occur mostly in creeks tributary to the
Patuxent are caused by such local problems as tailing septic
Pat f„f' " agricultural practices and point source discharges,
systems, poor g tributary streams usually remain closed, the
ofLS \»S gained open «ost of the ti.e since
March of 1977 (Garreis, 1981).
1 „ = nnf a source of closures in downstream
t^ibutaWrTes " In addition, it is not possible to state whether
tributaries. j- t-HP result of sewaae treatment plant
discharqe^1during unusual circumstances such as bypassing during
discharges auri y runoff. It is therefore very
Stvriv°rthat°mthe0nLPWQMC discharge contributes significantly to
shenfish closures except possibly in the case of complete
bypassing during severe tropical storms.
a mainr concern of watermen in the southern counties is the
Salinity A con^<'L £ freshwater flow into the estuary as a result
increaS1^ treatment plants. The expansion at the LPWQMC
of expanding ble controversy over whether the proposed addi-
has caused consid salt/freshwater interface suffi-
ciently downs'tream to cause significant oyster mortalities.
The s,Un. p«t of the
estuary. Fresh while denser, saline water enters at the
plants) enters UP tidally averaged basis, the denser bay
mouth of the estuary. On a J fresh water, which is
moving ^ov^fstream^ The surface and bottom waters are not complete-
ly mixed.
r-hP^oeake Bay intrude 35 to 50 miles (56 to 80
Saline waters estuary depending on the amount of freshwater
km) into the P^uxent estuary V and wind conditions, and the
entering the.e^"a^u^e basin. Only one of these four factors,
freshwater flow" can be changed by expanding the LPWQMC.
months, so it is necessary to consider
Saltwater 1°"eahwater inflows. Day-to-day changes are so
l0"?i Pthat only after several weeks of low or high freshwater in-
floi wUl the movement of saline water be apparent.
u flows aenerally reduce the saline portion of the
High freshwa^ freshwater flows permit salt water to intrude
river, and ^ Salinity influences the distribution and sur-
£ort?"„f°P™nv estu«?lie oVanis.,, particularly such sedentary
vival of manv' ish that cannot move away from an undesirable
organisms as ,sh® Various ranges of salinity are associated with
change in aquatic communities. During most of the year,
zones of dlstinCt ^as three salinity zones—mesohaline (5.0 to
the Patuxent est^J (f) 5 to 5#0 ppt) and tidal fresh (0 to 0.5
18.0 ppt), olig°l1li portion of the Patuxent estuary supports most
ppt). The mes°^Jin/isreries and therefore has a higher economic
of the commercial tistieries
value than the other two zones.
• 1. _j mndp 1 can help predict the extent of saline
A salinity intru varying freshwater flow conditions. Such
water intru1slomnn,pU^erare dually either time-varying models or
mathematical mod d modelsj they can be one- or two dimen-
steady-state tidal *3 inciuded as one dimension of a model,
sional. Length r ^ either depth (when stratification is
The second . ^he estuary is very broad). Although two-
strong) or wld\h (4arying models give the best insight into a
dimensional, time'v* x ^ estuary, they are time consuming and
dynamic environment sucn
Prediction of
Saline Water
Intrusion
costly
D-6
-------
The most accurate model available to predict saline water intrusion
is the MIT-TSIM (Transient Salinity Intrusion Model), a one-
dimensional, longitudinal variable area model of unsteady tidal
hydrodynamics and salinity. It can be designed to predict the
salinity at short time intervals (15 minutes) with high resolution
(one-mile intervals along the length of the estuary). Unfortunate-
ly, this MIT-TSIM model has not been calibrated and verified for
the Patuxent estuary.
Specialized mathematical models that consider tidal averages rather
than simulating short-term variations can save expense and effort.
To evaluate the effect of salinity fluctuation on the organisms in
the estuary, the steady-state, tidal-averaged models can still pro-
vide a reasonable prediction. These models can be further sub-
divided into "well-mixed" and "stratified" categories. For the
partially stratified Patuxent estuary, a one-dimensional, two-
layer, steady-state model has been developed and calibrated by
HydroQual, Inc. (1981). This model was written to depict existing
conditions using input data for which measurements can be made at a
reasonable expenditure of cost and manpower. The following dis-
cussion of salinity changes is based on the results of HydroQual's
model.
High and low freshwater flows are the two extremes at which the
LPWQMC expansion will affect the saline water intrusion. During
periods of high freshwater flow, the LPWQMC 5 mgd incremental dis-
charge, which is less than 2% of the mean annual freshwater flow at
the USGS Bowie Station, will have a negligible effect on salinity
distribution. During low freshwater flow periods, however, a 5 mgd
incremental discharge may reduce salinity enough to affect the life
in the estuary.
A careful examination of flow records for the past three years
shows that freshwater flow less than 100 cfs at USGS Bowie Station
occurred 16 days, 9 days and 7 days in water years of 1978, 1979
and 1980, respectively. During water year 1978, the minimum mean
daily discharge was 63 cfs; during water years 1979 and 1980, the
minimum mean daily discharges were 96 cfs and 93 cfs, respectively.
Thus, it can be assumed the average minimum freshwater flow at
USGS Bowie Station is about 100 cfs.
HydroQual calibrated its model with field data collected on June
21, August 23 and October 18, 1978. The flows on those dates were
200 cfs, 115 cfs and 100 cfs, respectively. The results are shown
in Figure D-l. Table D-3 shows the salinities at selected oyster
bars during different freshwater flows. Salinities are much lower
at flows of 200 cfs than at 100 cfs at any of the given locations.
At the most upstream state-chartered oyster bar, known as Farmers,
the salinity decreased by 2.0 ppt due to an increase in flows from
100 to 115 cfs. Thus, it is reasonable to expect a 1.3 ppt
decrease in salinity for a 10 cfs increase in freshwater flow when
river flow is at 100 cfs. The same approach applied to an 85 cfs
increase (from 115 to 200 cfs) reduces salinity by 4.2 ppt. This
is equivalent to a 0.49 ppt decrease in salinity for each increase
of 10 cfs at flows of 115 cfs. Salinity reduction for each addi-
tional 10 cfs of flow becomes smaller as the river flow increases.
For this reason it follows that, at any river mile the salinity
decrease associated with an incremental increase in flows at a
river flow of 200 cfs will always be less than that at 115 cfs.
Table D-4 summarizes the rates of salinity decrease at selected
oyster bars during two separate flows.
D-7
-------
LEGEND
20
WRA DATA
HYDROQUAL CAUBRATION CURVE
100 cfs
E8EI ESTMATE
HIGH STRESS ZONE
X
;X-y.XlXy.X;X;XX'
SSS&x*
.v.;
40
20
50
30
10
60
0
MILES ABOVE DRUM POINT
FIGURE D-1
OBSERVED AND ESTIMATED SALINITY DISTRIBUTIONS AT DIFFERENT FRESHWATER
DISCHARGES AT USGS GAGING STATION NEAR BOWIE, MD.
(SOURCE: HYDROQUAL. INC. AND
ESEf)
-------
Table D-3. Salinity Predictions at Different Freshwater Flows
in the Patuxent Estuary Near Bowie, Maryland
Location Salinity (ppt)
River
Q* =
Q* =
Q* =
Oyster Bar
Mile
100 cfs
115 cfs
200 cfs
Farmers
26. 3
10.0
8.0
3.8
Teague
24.0
12.0
9.0
4.8
Holland Point
21.7
13.5
9.0
7.0
Kitts Marsh
18.0
15.3
10.8
8.4
Jacks Marsh
16.3
16.0
11.0
9.3
Jacks Bay
14.2
17.0
11.0
10.0
*River flows measured at USGS Bowie (Maryland) Station.
Table D-4. The Calculated Maximum Rate of Salinity Decrease from
Two
Discharge
Volumes in the !
Patuxent
Estuary.
Location
Salinity
Decrease
River
Q =
Q =
Oyster Bar
Mile
100 cfs
200 cf
Farmers
26.3
1.3 ppt/10
cfs
<0.49 ppt/10
cfs
Teague
24.0
2.0 ppt/10
cfs
<0.49 ppt/10
cfs
Holland Point
21.7
3.0 ppt/10
cfs
<0.23 ppt/10
cfs
Kitts Marsh
18.0
3.0 ppt/10
cfs
<0.23 ppt/10
cfs
Jacks Marsh
16.3
3.3 ppt/10
cfs
<0.20 ppt/10
cfs
Jacks Bay
14.2
4.0 ppt/10
cfs
<0.11 ppt/10
cfs
D-9
-------
= of Tables D-2 and D-3 shows that upstream oyster
C,lT,\Tealul%ct °o: Ser salinities during periods of high flow
All ^s> thin low flow (100 cfs). At high flow, each incremental
floS increase of 10 cfs would decrease salinity no nore than 0.5
1 ~ a„r«lnt between Farmers and Jacks Bay oyster bars. During
?P fintsalinity conditions are much more favorable for upstream
low flow, sal _ y incremental flow increase of 10 cfs can
oyster beds, although an ^ ^ jacks Ray oygter bar> Furth^r_
reduce salmi y ,inity decrease is smallest upstream and gradu-
a -axim- raw of "Unity decrease
ally increase g redaction then diminishes as the river becomes
wider and more saline bay waters at the estuary mouth reduce the
effects of increased freshwater flow,
of the maximum rate of salinity decrease is
In summary, th }; freshwater flow and hydrodynamics and morpho-
dependent on up - ' ^QW f2ow conditions, the location of
logy of the es ua y. u it decrease moves upward; on the other
«' and the decrease in the marginal effect of salinity depression
menon and the d c in-^paee explain why the rate of salinity
as fteshwater J qreater between Farmers and Jacks Bay during flows
ofC100Scfs, yet becomes smaller between the same two points during
flows of 200 cfs.
. B t0ierate reduced salinity during winter months when
Oysters can t le physiological activities. During summer,
cold water slows their prtysicu g ^ ^ ^ ^ gusceptible to 1. The KydroQual model did not have
during summer mo freshwater discharges greater than 200 cfs,
salmity profiles extrapolated for 300 and 400 cfs based
TL froU MEZ, «£,
SL.r.tive', and .STl ua.lTve.a,,,, -U1 «
than those estimated.
-n k1(> n 6 shows unacceptable (5 ppt), high stress (5-7 ppt] and
Table D-d shows, *'init aones based on river flow at various
acceptable Zu~ river Zone designations were established for the
puiSseaofncomparing flow conditions and should not be considered
absolute,
ctuauo-u ww •
nvrr bars and landmarks are along the
Table D-7 shows where th y itions to tUe salinity figures in
river. By comparing th ^ bottom is not suitable for
Table D-6, it can De s Farmers, the most upstream charted
oyster set above Chalk poi. ^ locate<3 above chalk Point,
oyster bar, is the only cnar
of mo cfs, all charted oyster bars are well
Under flow conditions J". lty range. An additional 5 mgd flow
within the accept® ^ LPWQMC during a flow of 100 cfs would
(equal to 7.75 cts)
D-10
-------
Table D-5. Patuxent River Discharge Near Bowie, Maryland
Monthly Mean Discharge (cfs)
Annual
Mean
Water
Year*
Oct.
Nov.
Dec.
Jan.
Feb.
Mar.
Apr.
May
June
July
Aug.
Sept.
Discharge
( cfs)
1978
221
314
748
1316
359
854
373
884
234
298
293
130
506
1979
110
202
348
1290
1323
817
524
461
612
220
532
1358
637
1980
1093
459
385
497
263
694
806
607
308
210
157
107
472
Table
D-6 .
Number of Days with
than 300 cfs and 400
the Patuxent
cf s.
River
Discharge Near :
Bowie,
Maryland, Greater
Water
Year*
Oct.
Nov.
Dec.
Jan.
Feb. Mar. Apr.
May June
July
Aug.
Sept.
Number
of Days
with
Flow
in Excess of
300
cfs
1978
4
12
18
26
18
28
19
28 4
4
9
1
1979
0
1
10
31
12
31
27
21 17
4
21
24
1980
30
11
21
24
9
26
28
31 19
3
1
0
Number
of Days
with
Flow
in Excess of
400
cfs
1978
0
7
13
23
2
23
13
10 1
4
8
1
1979
0
1
8
30
9
31
20
10 10
2
18
24
1980
21
13
13
13
1
18
27
31 7
2
0
0
*The
from
water year always begins in
October 1977 to September
October and
1978.
ends
in September
; i •'
e., water year 1978 ran
D-ll
-------
Table D-7. Spatial Relationship Between Selected River Miles,
Oyster Bars and Landmarks
River
Mile Oyster Bar Landmark
Upper Patuxent
26.3 Farmers
25.0
24.0 Teague
21.7 Holland Point
21.0
19.0
18.0 Kitts Marsh
16.3 Jacks Marsh
16.0
Middle Patuxent
14.2 Jacks Bay
12.0
10.0
Table D-8. Selected Discharge Rates and Associated Salinity Zones
Described in Terms of River Miles.
River
Flow
(cf s)
Unacceptable
Salinity
(<5 ppt)
High Stress
Zone
(5-7 ppt)
Acceptable
Salinity
(>7 ppt)
100
above 32.0 miles
32.0 - 30.0
miles
below 30.0
miles
200
above 24.0 miles
24.0 - 21.0
miles
below 21.0
miles
300
above 20.0 miles
20.0 - 14.0
miles
below 14.0
miles
400
above 14.5 miles
14.5 - 9.0
miles
below 9.0
miles
-v. freest decrease in salinity of the four flows examined,
cause the larg ld remain within acceptable levels for
Sr»rra«rvfv,rii"H ch.rt.a oyst«
Persistent flows at 2jK)^^cfs ^would shift the oysterPtba*2
salinity downS"®a , Sheridan Point would be in the high stress
between Chalk Poin* „ell within the unacceptable zone. A
zone. Farmers bar would be w l^i^ ^ ^ __ mgd expansion at the
7.75 cfs ^crease /nncl-^i£icant at a flow of 200 cfs (see Table
LPWQMC would be insignitleant
D-3) .
kvi> n further downstream at persistent
The salt wedge wo ^ charted oyster bars would be exposed to
flows of 300 cfs. About 10 ch.bar3 W()ala r9maln ln the
unacceptable salinitieis, expansion at the LPWQMC would
highly stresff|L icant in terms of decreased salinity. The
become even less s g persistent flows of 400 cfs. Nine
same pattern foil ^ fche high stregs zone, whiie 28 charted
Chalk Point
Long Point
Sheridan Point
Queen Tree Landing
Broomes Island
Sotterly Point
D-12
-------
These predictions of salinity based on HydroQual's model are con-
servative, however, and actual salinities will be higher than the
predictions. The further downstream the salt wedge moves, the
greater the acreage of oyster bars affected by salinity changes.
As the river widens, and there is more river bottom available for
oyster bars, the average acreage per oyster bar becomes greater.
Information on upper Patuxent oyster bars published by Krantz
(1977) and Krantz and Webster (1980) is summarized in Table D-9.
Although the data are insufficient to draw conclusions, salinity
does not appear to be a major factor in oyster survival or health
in the upper Patuxent. The complete mortality of oysters in the
samples taken at Teagues bar could have been related to salinity.
However, samples without live oysters in 1977 and a very small per-
centage of living oysters in 1979 taken from the deep portion of
Gatton bar, coupled with the presence of blackened shells, suggest
anaerobic conditions.
Upstream oyster bars, especially above Brooms Island, suffer from
water quality problems. There has been virtually no spat fall in
the upper Patuxent River for 15 years. The harsh winters of 1977
and 1978 also caused the oyster bars to experience severe mortal-
ity. Restoration of upstream bars may not be biologically feasible
or economically important due to poor water quality conditions
(Krantz and Webster, 1980). Decreased salinities could be an addi-
tional aggravating factor in the demise of the Patuxent oyster.
The results of this investigation show that natural high flows
over prolonged periods may cause a significant downstream movement
of the salt wedge. However, the proposed 5 mgd expansion at the
LPWQMC will not reduce salinity enough to impact charted oyster
bars.
D-13
-------
Table D-9.
River
Composition of Oyster Bar Samples Taken From Selected Bars.
Composition of Oyster Bar Sample
Salinity
Temp.
% Mark-
Spat/
Mile
Oyster Bar
(PPt)
<°C)
etable
Small
Shell
Bushel
Comments
26.3
Teagues
2.5
21.0
All oysters dead
21.7
Holland Point
3.7
21.1
12
0
83
0
Recessive growth
in 80%.
21.0
Buzzard island
5.6
21.0
11
0
88
0
Gonads present in 50%.
en.o:
(Prison Point)
(14.1)
(19.8)
(50)
(2)
(45)
(0)
16.0
Thomas
7.3
21.4
10
0
85
0
Mussels heavy
and dying.
15.0
Jacks Bay
8.7
21.2
55
0
40
Mussels heavy,
poor condition.
12.5
Brooms Island
9.7
21.4
40
3
52
0
Oysters open easily.
(12.5)
(Brooms Island)
(14.4)
(19.8)
(15)
(1)
(80)
(0)
12.0
Gatton - deep
10.1
21.5
6
0
92
0
Shell black and
50% buried.
(12.0)
(Gatton - deep)
(14.4)
(20.0)
No live
oysters
at 28 feet.
Sources: Numbers in parentheses taken from oyster bar survey conducted on October 7, 1977 (Krantz, 1977].
Numbers taken from oyster bar survey conducted on October 5, 1979 (Krantz and Webster, 1980).
-------
APPENDIX E
ENDANGERED SPECIES LIST
-------
appendix b.
federally listed endangered species in the patuxent river basin
Common Name
Scientific Name
Shortnose sturgeon Acipenser brevirostrum
Bald eagle
Haiaeetas leucocephalus
American peregrine Falco peregrinus anatum
falcon
Arctic peregrine Falcon peregrinus
falcon tundrius
Kirtland's warbler Dendroica kirtlandii
Eastern cougar
Felis concolor cougar
Distribution
Atlantic coastal
rivers
Entire state
Entire state
Entire state
migratory - no
nesting
Entire state -
occasional
migrant
Entire state -
probbly extinct.
E-l
-------
APPENDIX F
NUTRIENT CONTROL STRATEGY
FOR THE
PATUXENT RIVER BASIN
January 14, 1982
Office of Environmental Programs
Maryland Department of Health and Mental Hygiene
-------
STATEMENT OF POLICY The state's strategy for the Patuxent River consists of four parts:
a point source control strategy, a nonpoint source control strate-
gy, a water quality monitoring and research strategy and an en-
forcement strategy. All four parts incorporate recommendations
developed by group consensus December 2-4, 1981 during an intensive
work session, called a charrette, involving diverse representatives
of government and interest groups. The policies set forth in this
nutrient control strategy and the charrette recommendations not
therein incorporated will be addressed in the Draft 208 Water
Quality Management Plan for the Patuxent River Basin to be open for
public comment in early spring 1982.
The policies embodied in this strategy should be implemented over
the next five years, which is referred to as "the first phase,"
though implementation is heavily dependent upon the resources made
available to the appropriate state and local agencies, and upon
active cooperation by the basin's residents. During that five
years and the ensuing two years continuing intensive monitoring and
research will measure the strategy's effect in water quality
improvement and expand our knowledge of the river system. Modifi-
cations to the strategy will be initiated through that time period
to ensure the best attainable water quality improvement and maxi-
mization of our effort toward that goal.
The essential parameters for water quality improvement considered
in the nutrient control strategy are dissolved oxygen and turbid-
ity. Chlorophyll a levels are also considered an important indi-
cator of water quality. Inasmuch as a direct cause-and-effeet
relationship between phosphorus and nitrogen loadings and the above
water quality parameters is currently incompletely defined, the
goals set forth in this policy are expressed in terms of daily
pound loading reductions.
The phosphorus loading reduction goal is expressed as a riverwide
maximum daily loading of 420 pounds. This will be achieved through
the phosphorus control element of the point source strategy.
The daily nitrogen loading reduction goal is to remove 4,000 pounds
of nitrogen from the riverwide loadings. Of this overall goal,
2,000 pounds will be removed by means of point source effluent
limitations and by land treatment of effluent. The second 2,000
pounds will be removed by nonpoint source controls.
Listed briefly in the following text are the essential points of
this nutrient control strategy (full details are discussed in later
sections).
point Source The important points of the point source strategy's four elements
Strategy are s
1. All facilities greater than 0.5 mgd (see Figure 1) must meet
1.0 mg/1 phosphorus effluent limits and plan for possible 0.3
mg/1 phosphorus limits. All dischargers will be evaluated over
time and included in any consideration to modify the strategy.
2. Specific facilities will incorporate conventional nitrogen
removal to 3.0 mg/1 or land treatment. All facilities will
plan for possible 3.0 mg/1 nitrogen limits and their "201"
facilities plans will analyze options for achieving 3.0 mg/1
nitrogen.
3. The "201" facilities process will make specific decisions for
each individual plant.
F-l
-------
NORTH
SAVAGE
MO HOU SC Of CORRECTION
0.80 (Abandoned)
FORT meade l a Z
MARYLAND CI'IY
PARKWAY
BOwiE-SELAIR
RT. 30 BRIDGE
RM.60
RM.50
W£ stern branch
11.9 (23.7)
RM.40
LOWER
MARLBORO
RIVER MILE 35
RM.30
BENEDICT
CHESAPEAKE
BAY
RM.O
4 -
Waste water Flow in Million Gallons per Day (MGD)
19SO Annual Average Flow (Projected Year 2000 Flow)
FIGURE 1
LOCATION OF SEWAGE TREATMENT PLANT DISCHARGES
-------
Nonpoint Source
Strategy
4. It is the intent of this strategy that land treatment is to be
the preferred treatment alternative and is to be seriously
evaluated during the "201" facilities planning process.
Nonpoint sources (NPS) of water pollution contribute a significant
portion of the total pollutant load (including sediment and
nutrients) to the Patuxent River system. NPS originate on urban,
suburban and agricultural lands in the basin, with agriculture
believed to contribute the largest portion of the total. State and
local agencies must cooperate intensively over the next several
years and receive considerable cooperation from the general public,
if there is to be a significant reduction in NPS sediment and nut-
rient loads to the Patuxent River. Below are some highlights of
the NPS strategy for the basin.
1. Overall NPS
Planning and
Control
A standing NPS Technical Committee of the Patuxent Commission
should be estab lished, for the purpose of detailing and coordi-
nating the implementation of this NPS strategy. Key state agen-
cies, the seven counties, the Soil Conservation Districts, the
scientific community and EPA each would have representatives on
this committee.
The Office of Environmental Programs (OEP) will commit funds to the
development and maintenance of a computerized model for the entire
basin. OEP will provide the principal staff support for this
effort, but will coordinate throughout the process with the Techni-
cal Committee. Eventually, the model will serve to test alterna-
tive policies and development scenarios for their water quality
benefits to the Patuxent.
2. Agricultural A Patuxent Agricultural Task Force should be established, compris-
NPS ing representatives of the Soil Conservation Service and the Soil
Conservation Districts (SCDs) working in the basin, as well as
representatives of key state agencies. The Task Force will coordi-
nate the implementation of the provisions for agricultural NPS con-
trol presented in this strategy document.
Local SCDs should be strengthened by means of additional funding
from the corresponding county governments in those cases where
present SCD staff levels cannot properly assist local farmers in
planning and installing pollution controls.
OEP will work with other agencies to establish a new, state-level
cost-share program to help farmers with installation of NPS pollu-
tion controls. Initially, at least, OEP expects the new program to
place special emphasis on farms in the Patuxent Basin.
Technical assistance and cost-share funds will be directed first to
the "agricultural critical areas" selected by the SCDs pursuant to
the state's "208" program for agriculture. The Agricultural Task
Force will be asked to identify additional areas, if any, which
have a high potential for exporting nitrogen to the Patuxent
system.
3. Urban/Suburban OEP will work with the NPS Technical Committee to help the local
NPS governments in the Patuxent Basin strengthen their existing storm-
water management programs. Successful local programs will be high-
lighted and OEP will work with the Technical Committee to communi-
cate new technical and institutional information about stormwater
controls to local officials.
OEP is calling on each jurisdiction in the basin to develop, ade-
quately staff and fully implement programs for effective stormwater
management on all new development and public property and all new
F-3
-------
or rebuilt roads in the Patuxent watershed. These local programs
must explicitly address the water quality, as well as quantity,
benefits of stormwater controls.
Honitoring and
Research
Enforcement
BACKGROUND
Ins t i tut iona1
Problems
Technical Problems
The NPS strategy presents details for each of these
recommendations. It concludes with brief sections on NPS pollution
from construction sites, surface mines, septic systems and boating
in the Patuxent Basin.
Intensive, comprehensive riverwide monitoring and continuing
research will be conducted during the first phase and the ensuing
two years.
The responsibilities of sewage treatment facility operation and
maintenance control and NPDES permit enforcement will be conducted
by OEP consistent with this strategy.
The diverse uses of the Patuxent River, including water supply,
recreation and fishing, have led to recognition of this system by
many as a valuable resource and to a strong commitment by Maryland
to achieve high water quality goals for the river. The State
Legislature has passed laws designating the Patuxent River as a
scenic river, creating a River Basin Comm is sion and, in partic ular,
requiring planning for nutrient control. The Governor has a
special interest in environmental protection of this river and is
monitoring the progress of this protection. There are also active
groups of citizens, local government officials and scientists whose
efforts have proven invaluable in the development of this strategy.
The State will continue working with all of these groups during
implementation.
During the past decade, there has been increasing concern in many
quarters that the Patuxent River—particularly its estuarine
portion—is deteriorating in water quality and fisheries productiv-
ity. The alarm has been sounded by citizens who live near, use and
love the river and by the scientists and governmental officials who
study it and attempt to manage its resources. Though these groups
all held improved Patuxent water quality as their overall goal, a
consensus on the proper course of action could not be achieved.
Therefore, poor water quality conditions continued unabated.
By 1981, the lack of a finalized state policy on nutrient control
was preventing the completion of the 208 Water Quality Management
Plan for the Patuxent River Basin, which had faced repeated delays.
At the same time, the state faced a court-imposed deadline for
adopting its nutrient control strategy for the Patuxent. In the
hope that a consensus could be reached through an intense bargain-
ing session where all interests were represented, a conflict
resolution meeting, called a charrette, was held December 2—4, 1981
to develop a consensus which would provide the basis for the final
nutrient control strategy.
The overall water quality goal adopted during the charrette calls
for a return to the Patuxent water quality of the 1950's before the
major stresses began appearing in the basin.
The water quality concern most often expressed by the citizens is
that the turbidity of the estuary has increased steadily over the
years. This may reduce the bioligical viability of the estuary and
definitely makes the river less enjoyable to many for fishing and
swimming. Watermen have reported that the river's oyster harvests
are declining and that "bad water" fouls fishing pots (wire-mesh
traps) and kills the animals trapped in the pots. Others complain
F-4
-------
about declining fish landings, although they recognize that there
seem to be similar trends occurring in recent years throughout the
Chesapeake Bay system.
To these concerns, the scientists and government officials add
their own about chlorophyll a and dissolved oxygen (D.O.) levels in
the estuary. Chlorophyll £~is a relative measure of algae concen-
tration in the water. (A certain level of algae is natural and
essential to the river's ecological health.) The Patuxent estuary
has shown an historical trend of decreasing D.O. levels in the
bottom waters of the lower estuary and increasing concentration of
chlorophyll a, particularly in the upper, free-flowing portion of
the river. While elevated algae levels actually increase oxygen
levels in the sunlit layers of the water, dead algal cells which
settle to the bottom exert a substantial oxygen demand as they
decompose.
Cognizant of these undesirable trends in the Patuxent, the
charrette participants chose to measure progress in the return to
water quality levels of the 1950's in terms of D.O. and turbidity.
These two parameters are not only viewed as the root cause of many
Patuxent problems, but they are also linked, in an incompletely
defined, complex relationship, to nutrient loadings to the river.
The charrette recommendations call for a minimum D.O. of 5 mg/1 in
upper layer waters upriver from Sheridan Point (river mile 20). In
the deep waters of that river stretch, a 2 mg/1 D.O. minimum is the
goal. Turbidity levels should allow a minimum of 1.5 to 2 meters
secchi disc visibility at Sheridan Point also. Though the
charrette produced no recommendations for acceptable chlorophyll a
levels, this parameter remains an important means of measuring
progress toward improved water quality.
In addition, those attending the charrette reached a consensus for
specific nutrient inputs to the entire Patuxent watershed based on
their feeling for the river's assimilative capacity. This consen-
sus was expressed as recommended goals. The phosphorus loading
goal is expressed as a 420 pound-per-day limit for point sources
riverwide. The nitrogen loading goal was also addressed in a daily
load limit of 1,250 pounds from point sources but only for the
period of April 1 through September 30. (This strategy has
extended the control period through October 15 to achieve consis-
tency with new NPDES permitting requirements for ammonia nitrifi-
cation. ) The burden of achieving the first phase nitrogen
reduction of 4,000 pounds per day was divided evenly between point
source and nonpoint source loadings. (See the point source
strategy for details.)
SUMMARY OF WATER Over recent decades, water quality in the Patuxent River estuary
QUALITY ANALYSIS has exhibited a steady decline, as evidenced by high chlorophyll a
levels in the upper Patuxent above river mile 35 and low dissolved
oxygen in the bottom waters of the lower estuary below river mile
35. A review of historical water quality data indicates that
increases in point source loads are a contributing factor to these
water quality problems. At the same time, increasing nonpoint
source loads from farms, towns and suburbs must also be considered
contributory. A preliminary analysis indicates that on an average
basis, in a typical year, up to 50% of the total nitrogen load to
the river and about 70% of the total phosphorus load comes from
point sources. It can also be postulated that the excessive growth
of phytoplankton (plant material in the water column) ultimately
adds a significant amount of organic material to the bottom sedi-
ments in the lower estuary and contributes to D.O. deficits. it
appears that what is needed is a combination of actions which will
F-5
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reduce total nutrient loads to the river from both point and non-
point sources. Point-source nutrient removal will reduce phyto-
plankton production and correspondingly reduce bottom sediment
oxygen demand over time, resulting in some increase in lower-layer
dissolved oxygen levels. Point-source controls will also reduce
the amounts of nutrients transported directly to areas experiencing
D.O. stress during high flow periods. Selective application of
nonpoint source controls throughout the basin may yield additional
improvement in chlorophyll a, turbidity and D.O. levels.
HydroQual, Inc., nationally recognized water quality experts under
contract with the State and EPA, calibrated and verified a steady-
state water quality model capable of projecting water quality in
the Patuxent which would result from various levels of nitrogen and
phosphorus removal. Estimates of nutrient loads from both point
and nonpoint sources were incorporated in their analyses. The
characteristics of this type of model produces simulations which
are most accurate in the free-flowing portions of the Patuxent
above river mile 35. The dynamics of the lower river diminish con-
fidence in the model's predictive abilities for the estuarine
portion below river mile 35.
Model analyses indicated that above river mile 35, chlorophyll a
concentrations exceeding 100 ug/1 in the summer and dissolved
oxygen levels nearing saturation are directly related to high
primary productivity. (See Figures 2 and 3.) (Primary productivity
is the production of plant material from available nutrients and
sunlight.) Furthermore, these high primary-productivity levels
result from a surplus of available nutrients. Downstream below
river mile 35, chlorophyll a levels of approximately 20 ug/1 and
low dissolved oxygen of less than 5 mg/1 in bottom waters result
principally from exchange with Chespeake Bay water, release of
nutrients from sediments, sediment oxygen demand and upstream con-
tributions of nutrients.
Model projections indicate that high chlorophyll a levels will
result under present and year 2000 wastewater flow conditions with
no nutrient removal. (See Figures 2 and 4.) Cost aside, model
analysis indicates a comparable reduction in chlorophyll a levels
if effluent concentrations are limited to either 1.0 mg7l phos-
phorus (P) or 3.0 mg/1 nitrogen (N) at present flows. The situa-
tion shifts somewhat, as projected flows increase to the year
2000.
The general consensus of the scientific community seems to be that
the limiting nutrient above river mile 35 is phosphorus (based on
the N/P ratio of 16/1). Consistent with this belief, the model
also indicates that P removal can greatly suppress chlorophyll a
levels in the upper river at projected year 2000 flows.
However, the determination of a limiting nutrient in the lower
river below river mile 35 is more dynamic. In general, during
summer conditions nitrogen is often the limiting nutrient, while
the estuary is more typically phosphorus-limited during other
seasons. The modeling results shown in Figures 2 and 4 indicate
that nutrient control will have lesser beneficial effect on chloro-
phyll a concentrations in the lower estuary than in the upper half
of the-estuary.
It must be emphasized, nonetheless, that the greatest benefit to
water quality in the estuary will occur when D.O. is improved below
river mile 35, in the lower estuary where D.O. problems are
greatest. (See Figure 3.) Secondly, reductions in chlorophyll a,
indicating water quality improvement, in the lower estuary will
F-6
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n LJL i .i: I
f.' .% i
PRESENT PHOSPHORUS TREATMENT
:20
M C u E l
BOTTOM / \'
N'OOCL ' \
c 0 5C 4C JO L'O 10
EFFLUENT Nr 5.0 m g /
EFFLUENT P = ! 0 mq/
120
I
120
ErFlUETJT N = 3.0 mg /
EFFLUENT P= 0.1 mg/1 6 0.3mg/l
120
100
—
100
—
•—
—
—
c
8C
—
90
—
-4m.
"o
60
—
Ir~\
J
60
—
A
r \
/ ""V4
r— P 1 c. J m (J / i
-J
"X
4 0
—
40
—
20
0
'»/ 1
i ; i : i i i i-r-n
20
0
~T 1
1 1
\
1 mg/l X V
s > ~
1 i I 1 ! 1 1 ^ 1
60 to <;o 20 >o
WILES ABOVE DRUM POINT
60 50 30 20 10
MILES above DRUM POINT
FIGURE 2
CHLOROPHYLL 'a' PROJECTIONS
(SUMMER FLOW - PRESENT WASTEWATER FLOWS)
F-7
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PRESENT TREATMENT
M
_ PRESENT WASTEWATER FLOW
YEAR 2000 WASTEWATER FLOW
12
TOP
MODEL
10
8
6
BOTTOM
MODE L-
2
O
t
60
60 30 20 10
MILES ABOVE DRUM POINT
0
50
50
40 30 20 .0
MILES A9QVE DRUM POINT
0
EFFLUENT P = 0.3 mg/
PRESENT WASTEWATER FLOW
_ YEAR 2000 WASTEWATER FLOW
CP
_ J
50
MILES ABOVE DRUM POINT
60
0
50
40 30 20 10
MILES ABOVE DRUM POINT
CO
FIGURE 3
D.O. PROJECTIONS-LOW ESTUARY STRATIFICATION
( SUMMER FLOW - PRESENT WASTEWATER FLOW
AND YEAR 2000 WASTEWATER FLOW )
F-8
-------
PRESENT NITROGEN TREATMENT
PRESENT PHOSPHORUS TREATMENT
TOP
MODEL
HOT TOM
MODEL
i-Jl
1. 1...1 I i I I ,1
120
60 ¦ 50 40 30 20 10
60 50 40
EFFLUENT N= 5.0mg/l
EFFLUENT P= 1.0 mg /
cr>
i
x
"o
120
o«
X
—
—
f
—
1 S\
—
ft
\
\\
V
—
/!
V
I
i i j i i r
ao
30 20
EFFLUENT N = 3.0 mg/.l
50 40 JO 20 10
MILES ABOVE DRUM POINT
60 50 aq 30 20 10 0
EFFLUENT P= O.lmg/l a 0.3 mg / I
P-0.3mq/l
50 40 JO 20 10
MILES ABOVE DRUM POINT
FIGURE 4
CHLOROPHYLL V PROJECTIONS
(SUMMER FLOW-YEAR EOOO WASTEWATER FLOW)
F-9
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occur only if nutrient loads to the upper estuary are reduced. In
terms of total biomass or organic load, a small reduction of
chlorophyll a concentration in the relatively broad and deep lower
estuary is equivalent to a much larger reduction of concentration
in the upper estuary. This is accounted for primarily by the great
difference in their respective volumes of water. Even though
Figure 2 shows that chlorophyll a concentrations generally decrease
as one moves downstream, the downstream biomass is relatively
greater than upstream. Therefore, any basinwide nutrient control
strategy which reduces lower estuary chlorophyll a levels should
also enhance water quality in upstream segments of the river.
The effects of land treatment as a method of nutrient control were
evaluated in the model projections performed by HydroQual, Inc.
Figure 5 shows the results of running the model for five different
assumptions. The graphs indicate various levels of projected
chlorophyll a suppression in the upper estuary while they show
almost no significant difference in chlorophyll a levels in the
lower estuary which result, respectively, from chemical phosphorus
removal and from land treatment.
Dissolved oxygen projections for present and year 2000 wastewater
flows (see Figure 6) indicate that dissolved oxygen levels asso-
ciated with upstream chlorophyll a peaks are always greater than
5.0 mg/1. There are, however, diurnal fluctuations of approximate-
ly 5 mg/1 indicated by the projections associated with algal photo-
synthesis and respiration. Projections of bottom-layer dissolved
oxygen levels indicate that the lower portion (below river mile 35)
of the Patuxent River estuary is sensitive to the degree of verti-
cal stratification. (See Figure 7.) An increase in the degree of
vertical stratification (i.e., a decrease in vertical mixing of the
waters) results in dissolved oxygen levels of less than 5.0 mg/1,
even with high levels of nutrient removal and a thirty percent
reduction in sediment oxygen demand.
POINT SOURCE The State has determined that reduction of algal biomass as
STRATEGY measured by chlorophyll a concentration in the lower Patuxent
estuary can be the principal means of achieving its goal of
improving overall water quality in the estuary. Chlorophyll a
reduction should produce lower turbidity and help improve dissolved
oxygen concentration in the bottom waters of the lower estuary.
(See previous discussion.) The analysis completed by HydroQual,
Inc. has strongly indicated that phosphorus controls for point
sources should produce substantial decreases in chlorophyll a con-
centrations in the phosphorus-limited upper estuary. However, the
reduced sensitivity of the model produced results that are incon-
clusive in the lower estuary although an analysis of monitoring
data has shown algal productivity to be either phosophorus or
nitrogen limited depending on seasonal conditions. It was, none-
theless, a consensus of the charrette that a reduction of both
phosphorus and nitrogen loadings to the estuary will yield water
quality improvements. Listed below are the essential points in the
elements of point source strategy. Then each element is detailed
in the subsequent discussions.
Elements of the 1. All surface water discharges to the Patuxent and its tribu-
Point Source taries of treated sewage effluent flows greater than 0.5 mgd (see
Strategy Figure 1) will be required to meet a maximum total phosphorus con-
centration of 1.0 mg/1 monthly average. This limitation is con-
sistent with the goal to limit total point source phosphorus
loading to 420 pounds. These dischargers are also required to plan
for the possible future addition of processes necessary to obtain a
0.3 mg/1 maximum total phosphorus concentration. All dischargers
F-10
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P fl'-jtNT THEATMENT
WITH L&NO APPLICATION OF 5Q
WITHOUT tANO
AVPwIC ArtON
lOC
TOP
MODEL
30
** AG
€0
60
o
-J
4C
U
20:
IG
0
50
20
10
50
20
50
40
JO
60
EFFLUENT 0.3 wq/l
120
120
WITH LAUD APPLJCA7J0.N OF 9 mqtf
WITHOUT LftND APPLICATION
100
~ 8C|
80,
> ec
-J
5 "c
2C
40
30
20
ao
60
60
*0
50
EFFLUENT P= 0.3 m?/)
120
WITHOUT LAUD APPLICATION
WITH LAND APPLICATION OF 50mv0
¦VILES ABOVE DRUM POiNT
50
MtLES ASQVE OHUM POINT
60
•>o
l c
FIGURE 5
CHL a' PROJECTIONS-EFFECT OF LAND APPLfCATiON
(SUMMER FLOW-YEAR 2000 WASTEWATER FLOW)
F~n
-------
PRESENT TREATMENT
rr
f-
UJ
X
O
O
UJ
10
C.l
o
SURFACE
MAX
BOTTOM
->n 20 10
MILES ABOVE DRUM POINT
50 jo 20 in
MILES ABOVE DRUM POINT
TOTAL P= 0.3 mg /
11
14
12
—
CP
A
p
/ \ U A X
— 10
/ \ /
10
— i— MAX.
LlJ
/
w\\ /
CO !)
/ /
e
— //
>-
/v.
y\ //
X
° 6
: ^
6
/ W
C J
UJ
/
— MINI.\\ /
4
_ \ /
O
CO
V)
2
—
Q
—
0
i I I I I i 1 i i i i 1 i
0
1 1 1 1 1 1 1 1 1 1 1 1 |
jO 50 40 JO 20 10 0
60 50 40 30 20 10 0
MILES ABOVE DRUM POINT
MILES ABOVE DRUM POINT
FIGURE 6
MAXIMUM AND MINIMUM DISSOLVED OXYGEN PROJECTIONS
(SUMMER FLOW-YEAR 2000 WASTEWATER FLOW)
F-12
-------
PRESENT TREATMENT
14
12
10
cp 8
o
o
LOW STRATIFICATION
: A-a
U w
¦> V '
\
~~ /
r top
/ MODEL
— /
Z*"'
/
— BOTTOM /
_ MODEL—'
\ <
1 1 1 1 1 1 1 1
1 I 1 1 1
60 i>0 ''0 50 20 10 0
MILES ABOVE DRUM POINT
MODERATE STRATIFICATION
50 40 50 20 10 0
MILES ABOVE DRUM POINT
EFFLUENT P = 0.3 mg/ I
LOW STRATIFICATION
MODERATE STRATIFICATION
t>0 40 50 20 10 0
MILES ABOVE DRUM POINT
60 50 40 50 ?0 10 0
MILES ABOVE DRUM POINT
FIGURE 7
D.O. PROJECTIONS-LOW AND MODERATE ESTUARY STRATIFICATION
(SUMMER.FLOW-YEAR 2000 WASTEWATER FLOW)
F-13
-------
to the Patuxent will be evaluated over time and included in any
future consideration to modify this strategy.
2. It was a consensus of the charrette participants to achieve a
2,000 pound per day nitrogen reduction for point sources based on
1981 levels. To this end, specific sewage treatment facilities
will incorporate nitrogen removal either by advanced conventional
treatment to achieve a maximum total nitrogen concentration of 3.0
mq/1 monthly average or by land treatment. All dischargers greater
than .5 mgd are required to include the possible future addition of
processes to meet 3.0 mg/1 nitrogen limits in their planning. All
"201" facilities plans for these dischargers will analyze all
reasonable options for achieving total nitrogen of 3.0 mg/1 in the
future, while achieving all effluent limits in their present and
foreseeable discharge permits.
3. All decisions on specific treatment plants, including their
exact future capa city and their methods of treatment, will be made
during the "201" facilities planning for each individual plant. It
is beyond the scope of this strategy and of the Patuxent River
Basin Water Quality Management Plan to make such decisions concern-
ing individual plants.
4. All "201" facilities plans for plants in the Patuxent River
Basin will be required to give serious evaluation to land treatment
as an alternative for meeting present and anticipated future dis-
charge limits. Under federal and state law, EPA and OEP give
preferential consideration and extra funding to land treatment as a
treatment alternative. Furthermore, it is the intent of this
strategy that land treatment is the preferred option and continued
surface discharges by sewage treatment plants will be permitted
only after exhaustive analysis has ruled out the land treatment
options.
Phosphorus One important recommendation set forth by the charrette is based on
Reduction the concept of maximum assimilative capacity of a river system. In
the case of phosphorus loadings to the Patuxent, a maximum total
loading of 420 pounds/day from point sources was proposed as a
goal. Though future analysis to substantiate the river's true
assimilative range may revise this figure, it is nonetheless an
achievable goal. If all the major point sources in the Patuxent
contributing .5 mgd or greater discharge effluent with a maximum
phosphorus concentration of 1.0 mg/1, the river could accept
approximately 50 mgd of such effluent without exceeding the total
pound limitation. (At the present time, major facilities discharge
effluent with phosphorus concentrations in the 4 to 8 mg/1 range.)
Beyond this goal, the rationale for the 1.0 mg/1 total effluent
phosphorus limitation is based on engineering, economic and
environmental (water quality) considerations of the state's two
main objectives in the Patuxent River estuary:
1. Reduction of total algal biomass as measured by chlorophyll a
concentration. This excessive primary growth is in part
responsible for high turbidity and is linked to dissolved
oxygen deficits in certain areas of the estuary.
2. Improvement of dissolved oxygen levels in the bottom water of
the lower estuary. Point source phosphorus loadings contribute
to the problem.
Phytoplankton biomass production will become suppressed when an
essential nutrient has become limiting. This suppression of
phytoplankton production is the goal of any nutrient-removal
F-14
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strategy. In most cases, such a strategy is implemented by
reducing a single, selected nutrient from all significant point
sources in the watershed in question. EPA policy has been to fund
with "201" construction grants the degree of treatment demonstrated
to be necessary with adequate documentation, i.e., water quality
modeling.
In this case, HydroQual's modeling indicates that advanced phos-
phorus removal has the greatest potential for reduction of chloro-
phyll a in the upper estuary, above river mile 35. The general
consensus of the scientific community that this river segment is
phosphorus limited supports these model results.
Below river mile 35, the model indicates a minimal effect on
chlorophyll a levels when employing various levels of phosphorus or
nitrogen removal, or land treatment. This situation could be
accounted for by model insensitivity or by the possibility that
lower estuary nutrient inputs other than upstream point sources
have much greater influence. However, one can infer that a
decrease in algal biomass in the upper estuary will have a positive
water quality effect on nutrient enrichment of the lower estuary.
Analysis of monitoring data has shown the lower estuary to be
phosphorus-limited during certain conditions. Therefore, reduced
nutrient transport and deposition from upstream sources should have
positive effects on lower estuary water quality.
The degree of phosphorus removal to be required is determined by
balancing the water quality improvement to the river against
economic constraints. The zero cost option of no action is
environmentally unacceptable. The state of the art option of
limiting effluent phosphorus concentrations to 0.1 mg/1, though
technically possible, is substantially more expensive than the 0.3
mg/1 limit, which, according to the HydroQual model, would yield
similar water quality benefits. Therefore, the stricter limit's
substantial additional costs cannot be justified by its relatively
small incremental benefit to the river.
Furthermore, the incremental improvement of water quality by moving
from a 1.0 mg/1 P limit to 0.3 mg/1 is not projected to be substan-
tial until year 2000 flows are approached. Given the large
incremental increase in capital outlay, operation and maintenance
cost and an ever-increasing sludge management problem that would be
unavoidable with the more stringent control, the state feels only
1.0 mg/1 P effluent concentration limits are justifiable as a
requirement at this time. Further monitoring and analysis will
eventually show when more stringent phosphorus controls may be
warranted.
on another aspect of Element 1, the question may be raised as to
why the state is excusing the treatment plants with effluent flows
less than .5 mgd from the phosphorus-removal policy. The total
present flows of sewage treatment plants (STPs) subject to this
policy amount to approximately 36 mgd. The sum of all the present
flows from the numerous small STPs discharging to the Patuxent
total only about 1.5 mgd. (It must be noted that most STP effluent
flows vary significantly due to rainfall levels, condition of the
collector system, etc. and subsequently all flow figures are neces-
sarily averages.) The policy, therefore, encompasses about 96% of
the current flows.
Significantly, most future growth in the basin is expected to occur
in the areas served by the larger plants, although some new small
dischargers may bcome into existence. Therefore, we expect the
policy to apply to an even greater percentage of the total sewage
F-15
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flows as time passes. In the meantime; all treatment plants will
be subiect to the same enforcement policies for compliance with the
limits in their state/NPDES discharge permits. All dischargers
will also be included in consideration of future strategy modifi-
cations' in the event that proliferation of small dischargers or
other unforeseen occurrences would dictate a strategy change to
protect Patuxent water quality.
„ , . • „ Th = consensus of the charrette that nitrogen loadings are
NjL^aen_Reductxon infjee(j contributory to the low dissolved oxygen concentrations
found in the bottom waters of the lower estuary, below river mile
TS This seems to be supported by monitoring data which has shown
thit the" lower estuary tends to be nitrogen limited during warmer
months. Though, at the present time, our knowledge of the lower
estuarv's nutrient dynamics is incomplete, we must assume that a
reduction of nitrogen loadings, including those from point sources,
can only serve to improve water quality in the nitrogen limited
parts of the Patuxent.
The concept of a river system's maximum assimilative capacity
esooused during the charrette was also applied to nitrogen loadings
in the Patuxent. The ultimate goal is for the total point source
nitrogen load not exceed to 1,250 pounds per day average for April
1 throuqh October 15. (The charrette-recommended time frame was
extended from September 30 to achieve consistency with the new
NPDES permitting requirement for ammonia nitrification.) However,
acknowledging that such a limit cannot be achieved in the near
future the charrette recommendations set forth several first phase
aoals ' In the case of point sources, the average daily nitrogen
load should be reduced by a minimum of 2,000 pounds based on the
1981 average daily load during the period of April 1 through
October 15.
Since there is a lack of comprehensive nitrogen data available from
sewage treatment plants, a precise accounting of the 1981 average
daily load is difficult to obtain. However, based upon the avail-
able measurements and estimated loadings, where total nitrogen data
?s not available, the 1981 average daily load for total nitrogen is
estimated to be approximately 5,900 pounds per day. Therefore, the
first phase goal for the average daily nitrogen loading from point
sources is about 3,900 pounds.
The charrette participants agreed that the first phase nitrogen
reduction goal, as well as the other first phase goals, should be
completed in approximately five years. They also recommended that
these ^iTtrogen loading reductions should be accomplished by land
treatment to the extent possible. It was felt that land treatment
offered numerous benefits in addition to nitrogen reduction and
that land treatment should be an integral part of the strategy.
For the purpose of this point source strategy, land treatment and
conventional phosphorus and nitrogen removal are considered to per-
form to equally satisfactory levels. Therefore, when land treat-
ment is utilized, other phosphorus or nitrogen removal processes
are not required (see land treatment discussion). Should further
research and evaluation over the course of the first phase show
that a modification of this strategy would be beneficial to the
achievement of the overall water quality goals for the Patuxent,
the necessary changes will be incorporated.
Unlike phosphorus removal technology, the difficulty and expense of
nitrogen removal using conventional treatment and the paucity of
n i"?," lotions for land treatment prevent the state from
imposing a maximum allowable nitrogen limit for the effluents of
all major STP discharges to the Patuxent at this time. Instead,
F-16
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the particulars of nitrogen removal lend themselves to installation
at a few chosen facilities in order to meet the pound loading goal
for all point sources. To this end, a number of options have been
proposed and some commitment made for nitrogen removal at specific
sewage treatment facilities currently undergoing major upgrading
and 201 facilities planning. The options as outlined in the
following text represent the best means now available to obtain the
loading reduction goals. During the course of the first phase, as
more information is gathered in the facilities planning process,
the options may change somewhat. Nonetheless, the best attainable
option to achieve the strategy's water quality goals will be
instituted.
Whichever control option will finally be instituted, it must
account for two components of the total nitrogen loading reduction.
First the 2,000-pound reduction from 1981 load levels must be
incorporated. Second, over the course of the five years allowed
for completion of this initial phase, additional sewage flows
resulting from expected growth will produce incrmental amounts of
nitrogen loadings beyond 1981 levels. This growth-induced addi-
tional nitrogen loading must also be removed to meet the first
phase goal. To achieve the first phase loading goal of 3,900
pounds daily loading maximum, an anticipated total of approximately
2,600 pounds must be reduced from the projected 1987 loadings. To
achieve this nitrogen loading goal, the following facilities will
institute some combination of these necessary actions to reduce
total nitrogen in their discharge during the first phase:
1. Washington Suburban Sanitary Commission (WSSC) has a nitrogen
loading reduction goal of approximately 2,500 pounds per day.
The WSSC-operated sewage treatment facilities at Western Branch
and Parkway will use whichever combination of land treatment
(preferred) and/or conventional nitrogen removal processes that
can best attain their goal. A small steering committee of
about 6 members including a WSSC chairperson and representa-
tives of OEP, Anne Arundel, Howard and the southern Maryland
counties will review and provide input to the 201 facilities
planning process for these facilities.
2. Anne Arundel County-operated sewage treatment facilities at
Maryland City (existing design capacity—.8 mgd) and at
Patuxent (existing design capacity—4.0 ragd) will use some
combination of land treatment (preferred) and/or conventional
nitrogen removal processes to maintain a maximum 3.0 mg/1
nitrogen effluent concentration for all future flows beyond
their existing design capacity. Based on current growth
projections, this contribution to the first phase nitrogen
reduction amounts to approximately 30 pounds-per-day.
3. Solomons Island sewage treatment plant now proposed in St.
Mary's County will incorporate some combination of land
treatment (preferred) and/or conventional nitrogen removal
processes to maintain a maximum 3.0 mg/1 nitrogen effluent
concentration for all anticipated flows. Based on current flow
projections, this contribution to the first phase nitrogen
reducts amounts to approximately 30 pounds-per-day.
Some sewage treatment facilities that are incorporating alterna-
tives in order to reach the strategy's nitrogen reduction goals may
find that some portion of their project is not federally fundable.
In these cases, all other funding sources, including state, local,
etc., will be explored and utilized in the most advantageous manner
to allow achievement of the nitrogen reduction goals.
F-17
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In addition to the first phase goals for nitrogen load limitations,
the state recognizes that new data and new analytical methods may
become available in the years ahead, which may change our under-
standing of so complex a system as the Patuxent estuary. In view
of our incomplete understanding of the Patuxent's nutrient budgets,
it is conceivable that greater nitrogen loading reductions could be
proven necessary to reach our water quality goals. Therefore, the
possibility that nitrogen removal may be deemed necessary should be
planned for and incorporated into the facilities planning process
for all treatment plants larger than .5 mgd. All facilities plans
for the larger sewage plants will be required to consider only
those treatment schemes and processes for the near term which are
amenable to the subsequent addition of nitrogen removal processes
capable of meeting a 3.0 mg/1 nitrogen concentration limit.
Facilities Planning Thorough evaluation of the alternative treatment schemes for each
sewage treatment plant is highly dependent on local conditions,
including topography, floodplains, site constraints, soil types and
existing treatment works. The "Step 1" facilities planning process
is intended to allow investigation of the environmental,
engineering, and social impacts of alternative collection and
treatment proposals for each sewer service area. Facilities plans
are intended to identify the most cost-effective and
technologically sound means of collecting and conveying sewage and
of treating it to levels specified in each plant's permit.
Moreover, the Federal Clean Water Act mandates a high degree of
public involvement in the facilities planning process for each
plant and service area.
This strategy applies only to the problems of nutrient-algae inter-
action in the Patuxent. It does not specify the limits for the
other parameters which must be controlled by the treatment plants.
These include such materials as BOD, suspended solids, bacteria and
chlorine residual. The full set of effluent limits for each plant
will be specified by the state (OEP) in the plant's NPDES/state
discharge permit.
This strategy and the respective permits will become embodied in
the Patuxent River Basin "208" Water Quality Management Plan. It
is expected that, as facilities planning proceeds and is completed,
the selected scheme for each treatment plant will be added to sub-
sequent editions of the Patuxent 208 Plan.
Land Treatment "Land treatment" of sewage effluent has been promoted by many as a
way of better protecting the Patuxent River from the adverse
impacts of direct surface discharge of sewage plant effluents, even
by plants equipped for nutrient removal. The term land treatment
includes a variety of techniques, including overland flow, rapid
infiltration and spray irrigation. All three systems generally
take effluent treated to approximately secondary levels as input
and employ natural aerobic-bacterial and chemical processes to
provide further treatment, including some measure of nutrient
removal.
Overland Flow—effluent flows down an impervious slope as a thin
film to allow ample contact with air. The effleunt is collected at
the bottom of the slope. This is the least land- and capital-
intensive land treatment option.
Rapid Infiltration—effluent is allowed to percolate through a pre-
pared soil or sand bed and the leachate is either collected by sub-
surface drains for discharge elsewhere or is allowed to percolate
downward into groundwaters.
F-18
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Spray Irrigation—effluent is sprayed over woodland or agricultural
fields, and treatment occurs in the upper soil layers. Water not
diverted by transpiration and nutrients not captured by the pro-
cesses of the upper soil layers percolate into the water table.
This option is the most land-intensive, due to (maximum) allowable
percolation rates and buffer zone requirements.
Though levels of phosphorus and nitrogen removal vary somewhat with
each method and with each individual site, approximate removal
levels are 90% P and 60% N. The remaining nutrients generally
reach groundwater and by that means may ultimately reach surface
water.
Where land with acceptable topography and soils is available in
large enough parcels and at reasonable cost, land treatment appears
to offer decided advantages. All forms of land treatment provide
some level of nutrient removal, which serves as a major beneficial
consideration in light of this strategy. These phosphorus and
nitrogen removal capabilities can allow land treatment to play an
important role in the Patuxent River Basin. Other "advanced treat-
ment" benefits of land treatment include some level of BOD removal
and pathogen neutralization.
Other advantages include preservation of cropland, woods, or other
"open space"; reclamation of nutrients in a usable form; treatment
reliability and energy savings; local groundwater recharge, with
possible beneficial impacts on base streamflow; and added protect-
ion of surface waters against many pollutants and virtually all
bacteria and viruses.
Congress has specifically mandated consideration of land treatment,
among other alternatives, during 201 facilities planning. Further-
more, both the state and EPA give increased grant assistance to a
grantee if land treatment or other innovative treatment methods are
selected. State policy encourages the use of land treatment in the
Patuxent River Basin, wherever 201 planning shows it to be feasible
and reasonably cost-effective.
Furthermore, it was a consensus of the charrette that its nitrogen
removal goals, "To the extent possible, ...be accomplished by land
treatment." The charrette recommendations went on to encourage
financial incentives and regulatory flexibility to further aid
implementation of the land treatment technology. One motivation of
some charrette participants was the belief that water quality can
be enhanced where direct discharges are avoided or curtailed. In
this case, land treatment as a "groundwater discharge" is the only
alternative that can meet the challenge.
Finally, it is the intent of this strategy that land treatment is
the preferred effluent treatment alternative. Though instances may
exist where discharges to the surface waters of the Patuxent are
proven to be the best alternative, an exhaustive analysis of the
land treatment options must clearly show land treatment to be less
desirable in that specific case. The lack of federal funding for
the land treatment portion of a project may not be considered suf-
ficient cause to select a surface discharge alternative. Other
state and local funding sources may be sufficient to maintain the
viability of a land treatment alternative.
F-19
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Nonpoint sources of water pollution (NPS) contribute a significant
portion of the total pollutant load to the Patuxent River system.
In a typical year, on an annual average basis, NPS are believed by
some Patuxent experts to contribute from 50% to 60% of the total
nitrogen entering the system and about 30% of the total phosphorus.
In a wet year, they may contribute as much as 70% of the N and 40%
of the P.
While the present document focuses on nutrient control for the
Patuxent, it should be stressed that NPS are responsible for a wide
range of pollutants. NPS contribute significant amounts of sedi-
ment to the Patuxent estuary and its tributaries. Sediment adds
turbidity in addition to algae-bascd turbidity and serves as a
transport/storage mechanism for phosphorus, oil compounds, some
pesticides and other toxics. In addition, NPS contribute BOD and
bacterial loadings to the Patuxent system. Reduction of sediment
loads will help reduce nutrient transport/storage in the estuary;
sediment controls will be maintained as a corollary objective of
the Patuxent nutrient strategy.
Control of NPS nutrient loads to the Patuxent presents more of a
challenge to State and local governments than control of point
sources, because most "Best Management Practices" for the reduction
of NPS loads are applied and maintained by individual property
owners (developers, farmers, etc.). This means that meaningful
change will come about only if a variety of state and local agen-
cies can be drawn into the process, and if they in turn can moti-
vate the public to act.
A mechanism for achieving the agency coordination and involvement
is proposed below.
The charrette adopted a recommendation for NPS controls which says,
in part- "...initiate appropriate management practices basinwide to
reduce the average pound load of nitrogen during the period April 1
to September 30 by 20%, which is approximately 2,000 pounds per day
for an average year." The science of quantifying the generation
and transport of NPS pollutants is still in its infancy. Measuring
the collective progress towards this specific goal will be diffi-
cult to do with any accuracy. OEP believes that the best approach
is to initiate a wide range of actions to improve NPS loads, even
while conducting studies to better quantify them. It is essential
to maintain the momentum towards restoring the river which was
established by the charrette process. At the same time, it will be
desirable to determine which activities and which watersheds are
contributing the most of each pollutant of concern, so that efforts
can be directed where they will yield the best results.
ofate and local governments must commit themselves to supporting
areatlv increased efforts on NPS controls throughout the Patuxent
River Basin. In the following sections, OEP is recommending
actions which it believes will reduce nutrient and sediment
load inqs to the Patuxent system and will provide tangible water
quality benefits. OEP feels strongly that the implementation of
new or improved controls must not await, for example, the adoption
of the definitive policy plan for the river or the development of a
verified, basinwide NPS pollutant model, as desirable as each might
be.
. p=,fvi*pnt Commission includes representatives of most of the
Actions Proposed h departments and all seven counties in the river
forjg™rall NPS Therefore, U haT the potential to serve as the forum for
SlEFol9 policy-level coordination on the implementation of a NPS strategy
for the basin.
F-20
NONPOINT SOURCE
STRATEGY
Introduction
-------
A standing Technical Committee of the Patuxent Commission should be
established. It would include key staff members from OEP, DSP,
DNR, DAg and from each county in the basin; one or two scientific
experts on the Patuxent; one or two representatives of the basin's
SCDs and the SCS; and one staff member from EPA. The principal
charge to the Technical Committee would be to develop, under OEP's
leadership, a NPS control program based on a computer model of NPS
pollution generation and transport in the Patuxent River Basin.
The committee would review proposals for research and monitoring on
the river, help in the sharing of technical information and practi-
cal experience about NPS controls and monitor all phases of the h'PS
model's development and subsequent application. It would report to
the Commission upon request or when significant progress has been
made or policy issues have arisen.
OEP will commit funds presently available to it under Section 208
of the Federal Clean Water Act to the development and maintenance
of a computerized nonpoint source model of the entire Patuxent
Basin. Such a model has been used with much success to establish a
comprehensive approach to NPS control in the watershed of the Occo-
quan Reservoir in Northern Virginia. The Patuxent model will simu-
late (a) the basin's hydrologic response to different types of
storms and in different parts of the basin and (b) the transport of
pollutants off the land and through the surface waters to the
Patuxent estuary. OEP will provide principal staff support for the
development and maintenance of the model, but will consult fre-
quently with the Technical Committee during the development period
and afterwards, when the model is used to investigate selected land
use options and policy options for the basin. The Occoquan model
has proven valuable as a tool for the local governments to evaluate
such options.
Agricultural NPS Of the 582,379 acres in the Patuxent River Basin, approximately
196,000 (33.6%) are in croplands 276,570 (47.4%) are in woods and
80,878 (13.9%) are urban (State Soil Conservation Committee, 1979).
Research on NPS has shown that forested areas export relatively low
nutrient loads, so cropland in the basin is assumed to be the land
use contributing the majority of the NPS loads to the Patuxent
system. Croplands export sediment, nitrogen and phosphorus (among
other pollutants); barnyards, feedlots and pastures contribute N,
P, bacti and BOD. Farm animal populations are relatively small in
proportion to the total agricultural land in the basin.
Under Maryland law, except for cases involving gross pollution of
surface or groundwaters, farmers are not subject to regulatory
pollution control programs. Although there already is much infor-
mation available about agricultural Best Management Practices,
their application on farms is wholly based on farmers' voluntary
cooperation. What's more, the Soil Conservation Service (SCS) and
the local soil conservation districts (SCDs)—the principal sources
of technical assistance to farmers—do not operate at the direction
of either state or county government. Por these reasons, county or
state officials can do little, acting alone, to bring about reduc-
tions in the agricultural NPS loads to the Patuxent.
For the Patuxent Basin, OEP will rely on a combination of applied
research on the water quality impacts of agricultural BMPs,
strengthening of local SCDs and multi-agency programs to promote
pollution control activities by farmers. These efforts are
dependent on the work of the State Soil Conservation Committee
(sscc), the Agricultural Stabilization and Conservation Service
(ASCS), the SCS and the local SCDs in the river basin. OEP is
asking the seven county governments in the Patuxent Basin to
increase their financial support for their respective SCDs. And
F-21
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OEP intends to work with other agencies to seek new sources of
funding for agricultural cost-sharing.
A variety of federal programs have made grants to local agencies
(ASCS/SCD) in Maryland for the purpose of documenting the water
quality impacts of intensive Best Management Practices (BMPs)
application (for sediment and animal wastes) on selected water-
sheds. Such projects are underway in Carroll, Baltimore and Howard
Counties; the lattermost of these involves the Cattail Branch
watershed, a part of the Patuxent Basin. OEP will carry out the
water quality monitoring for the Carroll County (Double Pipe Creek)
project, as well as simultaneous sampling in other parts of the
Monocacy Basin. In addition, the agency is funding a study of
contamination (with nitrates) of groundwater on the Eastern Shore.
OEP staff will keep informed about the results of this and similar
applied research on agricultural BMP effectiveness, and will use
this knowledge to help the SSCC, the SCDs and state enforcement
personnel to strengthen their programs for reducing agricultural
NPS pollution in Maryland.
Under the state's "208" Plan for agriculture, the SSCC had lead
responsibility for identifying priority areas in which the poten-
tial for water pollution from agriculture is great. Local SCDs
across the state received funding to map in detail their local
"critical areas." Since the mapping was completed, most SCDs have
worked actively to promote the development of voluntary "Soil Con-
servation and Water Quality Plans" by farmers in the respective
critical areas. In support of this program, OEP maintains regular
representation on the SSCC and is working actively with the SSCC to
identify and overcome obstacles to the implementation of the
program.
The SCDs in the Patuxent have chosen and mapped their "critical
areas." The main criterion for the prioritization of these criti-
cal areas was the potential for sediment pollution to enter water-
ways. A total of 84,570 acres in the Patuxent Basin (in five
counties) have been designated as having potential "critical con-
ditions." (The Montgomery and St. Mary's SCDs chose critical areas
outside the Patuxent Basin.)
OEP believes that the control of sediment from farmland in the
basin can contribute significantly to the reduction of sediment and
phosphorus loads to the Patuxent system. For this reason, OEP
recommends that the available technical assistance and cost-share
funds in the basin be directed towards the installation of sediment
BMPs on farms (especially croplands) in the selected critical
areas. At the same time, reduction of NPS nitrogen loads to the
river by the 2,000 pounds per day specified by the charrette also
will depend heavily on load reductions from farmland. OEP recom-
mends that a basinwide agricultural task force be convened (see
below) and that it identify the extent to which farming activities
with a high potential for nitrogen export lie outside the selected
critical areas. Subsequently, such areas would receive special
attention for application of BMPs effective for nitrogen removal.
There already exists a sizeable body of knowledge about agricul-
tural BMPs, their cost and their effectiveness for controlling
erosion. However, economic considerations often keep this know-
ledge from being applied on many Maryland farms. At the present
time, the SSCC (with assistance from OEP) is conducting a survey to
investigate the extent to which manpower and budget limitations
prevent the local SCDs (both within and outside the Patuxent Basin)
from providing sufficient technical aid to farmers. (These limi-
tations will be aggravated by recent and proposed further cuts in
F-22
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federal funding of the SCS in Maryland, because SCS personnel work
side-by-side with SCD personnel in most counties.)
Where the results of the SSCC resource/workload survey demonstrate
that work demands or funding limitations are preventing a SCD in
the Patuxent Basin from providing needed technical assistance to
local farmers, OEP will expect the corresponding county government
to give additional funds to the SCD sufficient for one additional
full-time staff member to work with the local agricultural com-
munity .
The other major economic constraint on agricultural BMP installa-
tion is the "cost-share money" available to farmers. While not all
BMPs are costly, those which involve structural changes (diver-
sions, waterways, etc.) and major changes in tillage practices are.
The principal source of cost-share funds to farmers has been the
ASCS, a branch of the U.S. Department of Agriculture. The funds
available in any one county in a given year have always been
limited and USDA presently is considering further cutbacks. This
is a problem statewide, not just in the Patuxent watershed. For
these reasons, OEP will propose the establishment of a new, state-
level cost-share program to help farmers across the state, with
special emphasis on the Patuxent Basin.
Much experience and expertise exists among the SCD and SCS person-
nel in the basin's seven counties. To promote the exchange of in-
formation among these people and to delve into issues and report
progress on the implementation of the Patuxent nutrient control
strategy, OEP will ask the SSCC to convene a Patuxent Agricultural
Task Force, comprising the chairman (or his designee) of each SCD,
plus selected District Managers, District Conservationists and ASCS
personnel. The Task Force would review the existing selected agri-
cultural critical areas, nominate possible additional high-nitrogen
farm areas, designate particularly effective BMPs for use in the
basin and prioritize the application of SCD/SCS resources and ASCS
(and other) cost-share funds to agricultural funds in the river
basin.
Lastly, as an aid to further prioritization of the efforts to
install bmps, OEP will investigate the possibility of documenting
the relative NPS loads of the major sub-watersheds of the Patuxent
which drain farming areas. Such data would help the SCDs in their
efforts to persuade farmers to implement agricultural BMPs.
Urban/Suburban NPS Research conducted in the past decade has suggested that the
'(non-construction) impacts of urbani zation on streams and rivers can be devastating,
in terms of altered flow regimes, increased pollutant loads and
overall degradation of the stream as a habitat. Fortunately, there
is a small, but growing, body of research and practical experience
which shows that rigorous application of good site layout/
utilization and of selected structural measures can virtually
eliminate these adverse effects of development. Of the nonpoint
contribution of nutrients, field studies in the Occoquan River
Basin in Virginia show that urban land uses contributed more
nitrogen and phosphorus to the receiving waters than any rural
agricultural land use, with the exception of cropland. Not only
are urban areas significant contributors of nutrients to the water
body, but sediment loadings to the stream are often increased as a
result of stormwater runoff. Sediment, aside from being a
pollutant in itself, also serves to transport nutrients to the
receiving waters.
In light of the growing concern for urban storm runoff (USR) and
its effects on water quality, the state's strategy for urban NPS
F-23
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rests on (1) a continuing review of the evolving body of knowledge
relating to the mitigation of the water impacts of USR, (2) an
investigation of the legal, institutional and economic aspects of
establishing effective stormwater management programs at the state
and local levels, and (3) a program of "technology transfer" for
the purpose of sharing this knowledge with concerned citizens,
local officials and other state agency officials in Maryland. OEP
will apply this strategy first in the Patuxent Basin.
Under EPA's National Urban Runoff Program (NURP), a sorely-needed
body of data on the extent and nature of the pollution resulting
from USR and on the pollutant-removal effectiveness (and cost—
effectiveness) of a wide range of BMPs for urban stormwater will be
established. Simultaneously, similar research is being carried out
under other programs. If sufficient funds are available, the state
will support further research into the impacts of urbanization on
various surface waters. OEP staff will keep informed in depth on
the status and the findings of such research efforts.
At the same time, OEP staff will investigate the existing programs
for stormwater management in such areas as Montgomery County, Mary-
land; Fairfax County, Virginia; New Castle County, Delaware; and
Baltimore County, Maryland. Water quality benefits and other
stream-habitat benefits of such programs will be documented. The
laws and regulations, institutional arrangements and funding
mechanisms which seem most effective will be identified. Under the
auspices of the Technical Committee of the Patuxent Commission,
resources being applied by local governments to stormwater manage-
ment in the Patuxent River Basin will be reviewed. A similar
review subsequently will be made for other parts of Maryland.
Once the above information has been gathered, OEP, WRA, and other
state agencies will begin a comprehensive program for sharing this
knowledge with interested citizens and with appropriate local and
state officials. Brochures, slide talks, annotated bibliographies,
literature reviews and handbooks will be developed to this end.
The state will organize and sponsor a number of regional workshops
for local and state government employees at which the impacts of
USR and the advantages and disadvantages of specific BMPs can be
discussed. All of these efforts will be directed towards strength-
ening the stormwater management programs of the local governments
and the state agencies. In view of the state's particular concern
over the Patuxent River Basin, these efforts will be directed first
towards the units of government having jurisdiction in that basin.
Lastly, an important accomplishment of the charrette was the stated
commitment by represented local officials to take an active role in
controlling the impacts of nonpoint source pollution. OEP inter-
prets this to mean that each jurisdiction in the Patuxent River
Basin shall develop, adequately staff and fully implement programs
for effective stormwater management on all new development, public
property and new or rebuilt roads in the basin. Some jurisdictions
have stormwater management programs which deal primarily with
volume controls; it is the intention of this strategy that special
attention be paid to quality as well as quantity considerations.
Exemplary stormwater management legislation was enacted by Mont-
gomery County in 1980. The bill requires that a stormwater manage-
ment plan be submitted with applications for new subdivisions and
approved before a building permit will be issued. In lieu of sub-
mitting such a plan, a developer may elect to pay a fee in accord-
ance with a set fee schedule, or grant an easement or dedicate land
to the county to be used for the purposes of stormwater management.
The county expressly states that one of the purposes of the
F-24
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legislation is to "assist in the attainment and maintenance of
water quality standards." The other counties in the basin should
consider adopting some of these features.
The state will work closely with the jurisdictions within the basin
to develop or improve their respective stormwater management
programs no later than July 1983. In promoting the goals and
policies described in this urban/suburban nonpoint source strategy,
OEP intends to work in close cooperation with DSP, DNR and local
agencies. The Technical Committee, referred to earlier in the non-
point source strategy, could serve as an ideal forum for such co-
operative activities.
Sediment and Ero- Disturbance of land surfaces for construction-related activities
sion Control NPS~ can be a seri ous source of pollution, unless adequate controls are
developed and implemented. For this reason, state law and regula-
tions require sediment and erosion control measures for construc-
tion activities in general, as well as for timber-harvesting
operations and surface-mining activities.
Under the existing statewide program, each county or municipality
must adopt grading and building ordinances necessary to carry out
the sediment control program. Such ordinances require that a
person receive a grading or building permit before any clearing,
construction or development may begin. One requirement for
receiving such a permit is that the developer submit an Erosion and
Sediment Control Plan, which must be approved by the local Soil
Conservation District (SCD) before the county or town can issue the
permit.
The Water Resources Administration (WRA) has the lead responsibi-
lity for ensuring that local sediment and erosion control programs
are operating effectively. Each program is reviewed by WRA once
every three years for the purpose of determining overall field
application and effectiveness. Of the programs reviewed in the
Patuxent Basin, three were found to be "acceptable" and two
programs were determined to be "unacceptable." WRA has forwarded
recommendations to each county suggesting improvements in their
respective programs. The remaining two programs are in different
stages of review. WRA is evaluating sediment and erosion control
programs being implemented at state-owned construction sites,
especially those of the Departments of Transportation and General
Services. The results of this evaluation will be available by
February 1982.
OEP has entered an agreement with WRA, which basically states that
the two agencies will work cooperatively in implementing and
enforcing sediment and erosion control programs. OEP is respon-
sible for "sediment as a pollutant" (after it has entered a water-
way), and will notify WRA of any apparent sediment and erosion con-
trol plan violations which are observed.
Several local SCDs (including those in the Patuxent) have reported
to OEP that manpower needed to adequately review sediment and
erosion control plans is severely limited. Prince Georges SCD has
started charging developers a fee for plan review, as means of aug-
menting present plan review staff. The SSCC resources/workload
survey described under "Agricultural NPS" should serve to identify
other instances in which sediment control plan review is hindered
by manpower limitations. OEP will support all efforts by the SCDs
to obtain the staffing levels they need to meet all the demands
placed upon them.
F-25
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Surface Mininq NPS The surface mining of minerals (sand and gravel operations) can be
serious source of sediment pollution resulting from the disturb-
ance of land surfaces, which, in addition, frequently produces
large quantities of unusable materials. If the disturbed areas are
not protected properly from erosion during and after mining
operations, and if mining wastes are not properly handled, surface
mining can have detrimental effects on water quality.
The Maryland Surface Mining Act of 1975 was established to mitigate
the effects of this previously unregulated industry. The Surface
Mining Division of the WRA says today (1981) that the industry as a
whole is complying with the provisions of the Surface Mining Act
and that active mining sites do not represent a significant non-
point source problem. It should be remembered that the program has
been in place only a few years; thus, evaluation of its short-
comings, if any, is difficult. A before-and-after comparison of
the impacts on water quality of the implementation of the Surface
Mining Act has not been performed.
The Surface Mining Division of the WRA is in the process of
prioritizing abandoned mines, based on the degree of environmental
degradation, for the purpose of funding future reclamation
projects.
The Waste Management Administration at OEP is working with WRA and
other agencies to establish a demonstration project involving the
use of sewage plant sludge to reclaim abandoned surface mines.
A technical study of the effects of the sand and gravel industry on
water quality in the Patuxent River Basin has been completed by the
Office of Environmental Programs. A site-by-site assessment has
been made of most industrial NPDES discharge permittees in the
Patuxent River Basin to ascertain the water quality impacts of
their discharges. Preliminary investigations indicate that surface
mining operations do not contribute significantly to water quality
degradation in the Patuxent.
The extent of nutrient loading in the Patuxent River Basin from
£_ilinq septic systems is unknown, although it is believed to be
minor in most areas. There is widely scattered occurrence of
improperly sited and poorly maintained systems. County Water and
Sewerage Plans have documented septic failures due to small lots,
high water tables, poor percolation, and steep slopes. If it is
determined that these problems contribute significantly to the
Patuxent nutrient loads, a work program to correct them, involving
the state and local health departments, will be included in the
Patuxent Water Quality Management Plan.
Boating Related NPS There has been a growing concern that the sewage generated by
Boating Reia recreational and commercial boats operating m shellfish waters
poses a potential danger for the spread of disease. Several
studies conducted outside the Patuxent Basin by the state over the
two years have documented the extent of this problem. Areas
that combine large concentrations of boats with poorly flushed
waters are subject to high fecal coliform counts. These indicate
the presence of a potential health hazard.
In the Patuxent Basin, around Solomons Island, there are a number
of large marinas whose combined capacities total approximately
1 500 slips. Many of these marinas are located in creeks with
restricted openings and limited flushing capability. Boating
sewage can contribute to elevated bacteria levels and to oxygen
depletion in these creeks, and where shellfish are involved,
boating sewage may represent a potential health hazard.
Failing Septic
Systems
F-26
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OEP has developed draft regulations entitled "Sanitary and Sewage
Facilities at Marinas." These regulations were reviewed extensive-
ly by the boating public and marina owners, and the comments
received have been used to develop amendments to the regulations.
These will be reintroduced after EPA completes revisions to its
regulations concerning Marine Sanitation Devices. Further public
hearings will then be held after a review by the Joint Standinq
Committee on Administrative, Executive and Legislative Review of
the General Assembly.
WATER QUALITY MONI- Continuing research and monitoring is an essential component and an
TORING AND RESEARCH integral part of the Patuxent nutrient control strategy. The
STRATEGY participants of the char rette also recognized this need with their
consensus on a specific recommendation which in part called for
reports to be given to the Patuxent River Commission. Their other
recommendations are integrated into the monitoring and research
strategy presented here under the headings of monitoring, research,
funding and administration.
Monitoring The only mechanism to evaluate the effectiveness of a nutrient
control strategy is to support an intensive, comprehensive, river-
wide data collection program. This will allow for future well-
informed strategy modifications to further improve water quality.
The charrette recommendations call specifically for a continuous
program consisting of a network of water quality monitoring
stations throughout the tidal and nontidal portions of the river.
During the initial five years of the nutrient control strategy's
institution, the first phase controls will be put in place with a
concurrent data collection effort. Over the next two years, a more
intensive monitoring effort will determine the effectiveness of the
first phase controls. Decisions to modify the strategy or specific
controls will be based on this information and new research
results.
Research All research in the Patuxent Basin should be coordinated with the
above monitor ing work and every effort to obtain research appli-
cable to the basin should be made. The HydroQual water quality
analysis and comments from the Patuxent Technical Advisory Group
have pointed out areas of research which the state will pursue.
One area of concern is the spatial and temporal distribution of
zooplankton and phytoplankton communities. This data would help
define phytoplankton growth rates and zooplankton grazing rates and
quantify the significance of nitrogen-fixing species of algae.
These parameters have a strong impact on the resulting levels of
dissolved oxygen. Furthermore, species-composition data will help
to enhance the predictive capabilities of the model. The state has
received EPA funding for a study to address these concerns. The
study was initiated in the spring of 1981 by the Philadelphia
Academy of Natural Sciences in conjunction with studies already
performed for the EPA Chesapeake Bay Program.
At present, little is understood concerning the relationship
between the Patuxent estuary and the Chesapeake Bay. It has been
suggested that the Bay may have an important influence in the lower
estuary but substantiation of this has not been possible thus far.
Given the continuing problem of D.O. deficits in the bottom water
of the lower estuary, it is necessary that the Bay's influence on
the estuary is quantified before it can be known if the Patuxent
River Basin controls can have a successful impact or if the lower
estuary's condition is part of a less-controllable baywide trend.
Another area of research interest is obtaining additional measure-
ments of sediment oxygen demand and the rates of sediment nutrient
F-27
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Funding and
Administration
ENFORCEMENT
STRATEGY
release. As was discussed earlier, these two factors are signifi-
cant contributors to water quality conditions in the lower Patuxent
estuary The model input for these parameters is currently limited
to measurements around the Chalk Point Power Plant. More measure-
ments of these parameters would refine the modeling of interactions
between the bottom sediments and the water column. This data would
also improve the predictive capabilities of the model. The state
of Maryland is currently pursuing a joint venture with the U.S.
Geological Survey to conduct these studies.
Since nonpoint sources are significant contributors of nutrients to
the patuxent River, this is also a high priority for research. The
U S EPA Chesapeake Bay Program has monitored the nonpoint source
contributions from five small watersheds in the Patuxent. This
work should help characterize nonpoint source loads from agricul-
tural and forestland runoff in the basin. This data, combined with
other available data for urban runoff, will allow computer modeling
of the effects of nonpoint sources of pollution on the Patuxent
estuary EPA and the state are currently reviewing available non-
point source models to find one suitable for this purpose.
Studies of the nutrient exchanges in and around tidal marshes and
collection of more hydrodynamic measurements to further define the
degree of vertical stratification are also in the long-range
research plan. The state will also maintain and expand the mathe-
matical modeling capability of OEP for use in planning and assess-
ment of water management in the basin.
A funding mechanism to be developed by the Patuxent Commission will
provide for the monitoring and research program through
contributions from the state and the seven counties on the river.
Federal funding sources will also be pursued for various portions
of the program. Not only do all the jurisdictions within the basin
have an interest in improved water quality, but also a financial
stake in the administration of controls. Considering that the
research funding needs in the Patuxent Basin will be in the range
of $200 000-$300,000 for the initial phase, it is in their best
interests to be a partner to the monitoring and research that will
allow verification and revision of the overall strategy and
controls.
The OEP will establish a peer review group of scientists to period-
ically review work being done and recommend further research and
data collection for the Patuxent. This should ensure unbiased in-
put for the decision-making process and provide a fresh perspective
for problem solving.
Enforcement of regulations governing sewage treatment facility
ooeration is the responsibility of the Sewerage Division of the
Inspection and Compliance Program of OEP's Water Management Admini-
stration. This Division has two major responsibilities: (1) an
ooeration and maintenance control activity, and (2) carrying out
enforcement actions against violators of NPDES/State Municipal Dis-
charge Permits. These two activities are integrated to insure a
unified approach to point source control.
OEP has described its existing procedures and policies for sewage
control by means of an enforcement strategy document. This
strategy will be applied uniformly to all sewage discharges in the
Patuxent River Basin—large and small. Each will be expected to
meet the requirements of its discharge permit; when it does not, a
variety of voluntary remedial measures and, these failing, legal
measures will be applied.
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Once the required point source control technologies are in place at
major Patuxent facilities, the Division of Sewerage will assure
compliance with the inspections, effluent quality monitoring,
self-reporting requirements, flow monitoring and, if necessary,
appropriate compliance with legal actions.
Site inspections are carried out by field engineers approximately
twelve times per year. State effluent monitoring includes a
monthly sample of chemical analysis (i.e. BOD5, nitrogen, phos-
phorus) as required by state law and biweekly bacteriological
samples. Operators are required to maintain daily operating
reports and submit them to the state monthly. Daily self—
monitoring reports of effluent quality are also required to be sub-
mitted quarterly. Information obtained from all of these sources
is used to determine available treatment capacity through the
state's flow-monitoring program.
The above programs are intended to provide the state with enough
information to spot potential problems and work with the operating
agency to correct them. If voluntary compliance is not obtained,
the state will proceed with Administrative Orders, Consent Orders
and, if necessary, court action.
F-29
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