FINAL
Environmental Impact Statement
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LLUTIONA CONTROL PLANT
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COLUM
Pre pared ^By
ENVIRONMENTAL PROTECTION AGENCY
MIDDLE ATLANTIC
MAY 1974
3EZ
Re: 3MGS-FS-DC-I
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FRONTISPIECE
Final Clarifiers
EXISTING WATER POLLUTION CONTROL
FACILITIES, DISTRICT OF COLUMBIA
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&
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FINAL ENVIRONMENTAL IMPACT STATEMENT
DISTRICT OF COLUMBIA WATER POLLUTION CONTROL PLANT
(Expansion and Upgrading)
Prepared Pursuant to Section 102(2)(c)
of the National Environmental Policy Act of 1969
ENVIRONMENTAL PROTECTION AGENCY
REGION III
Philadelphia, Pennsylvania
"Hay,"11974
U.S. ERA. Region III
itegional Canter for Environmental
I ,ai.ion
1650 Arch S'.-.reat (3PM52)
Philadelphia, Fa 19103
roved by
Iteniel J. Sriyder//1"]
Regional Administrator
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SUMMARY SHEET
District of Columbia Water Pollution Control Plant
(Expansion and Upgrading)
) Draft
(x) Final Environmental Impact Statement
ENVIRONMENTAL PROTECTION AGENCY
REGION III
Philadelphia, Pennsylvania
Type of action: ( x ) Administrative
( ) Legislative
Description of action: The proposal would expand from 240 million gallons
per day (mgd) to 309 mgd and upgrade (from secondary to tertiary treatment)
the existing District of Columbia Water Pollution Control Facilities. On-
site disposal of undigested plant sludge by incineration is planned, with
the ash residue transported to approved sanitary landfills for ultimate
disposal. The areas to be serviced by these facilities include Washington,
D. C. proper and suburban portions of Maryland and Virginia.
Beneficial Environmental Impacts:
(1) Significant water quality improvements in the Potomac estuary.
(2) Long-term enhancement of Dyke Marsh once the restoration project is
completed by the National Park Service (NPS).
(3) Minimization of plant odor problems.
(4) Reduction in the probability of pathogenic organisms escaping into the
environment.
(5) Permanent removal of sludge stockpiles which presently produce runoff
problems, odors, and general unhealthy conditions.
Adverse Environmental Effects:
(1) Minimal effects on ambient air quality.
(2) Potential for spillage during fuel transfer and other unloading
operations.
(3) Minor long-term effects produced by the project include noise genera-
tion, aesthetic intrusion, and the potential for adverse land use
(4) Short-term effects during construction activities include:
(a) Increased turbidities during dredging and spoiling operations.
changes.
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(b) Fugitive dust emissions.
(c) Erosion and siltution caused by disturbed ureus fit the sLlo.
(d) Increased noise levels.
(e) Inconvenience to the surrounding communities.
Alternatives Considered:
a. Treatment
(1) No action.
(2) Retain capacity at 240 mgd but upgrade plant.
(3) Various combinations of (A) independent physical-chemical;
(b) biological treatment systems.
(4) South Tahoe Design
(5) Spray Irrigation (Muskegon Plan)
b. Sludge Disposal
(1) Ocean Disposal
(2) Land Disposal
(i) Pumping digested sludge to dry beds.
(ii) Pumping digested sludge to farmland for irrigation and
fertilizing.
(iii) Disposal of digested sludge in lagoons.
(iv) Disposal of partially dewatered digested sludge as a
soil conditioner or to a landfill.
(v) Disposal of flash-dried digested sludge as a soil
conditioner.
(vi) Pyrolysis.
c. Transportation of Equipment and Materials
(1) Highway
(2) Rail
(3) Waterway
Review and Comment Requests:
Comments were solicited from Federal, State and local agencies, private
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organizations, and individuals. Copies of all comments received will
be found in Appendix a. A list of those parties submitting formal
comments follows.
6. Date Draft Statement Made Available to CEQ and Public:
April 20, 1972
7. Date Final Statement Made Available to CEQ and Public:
May 1974
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COMMENTS RECEIVED ON DRAFT EIS
LIST OF FEDERAL. STATE AND LOCAL AGENCIES.
PRIVATE ORGANIZATIONS AND INDIVIDUALS
Blue Plains Sewage Treatment Plant, District of Columbia
FEDERAL
Capt. S. A. Wallace
U.S. Coast Guard
Chief, Marine Environmental
Protection Division
400 Seventh Street, S.W.
Was&ington, D.C. 20591
Mr. Graham T. Munkittrick
State Conservationist
U.S. Department of Agriculture
Soil Conservation Service
4321 Hartwick Road
College Park, Maryland 20740
tyllliam E. Murray
U.S. Department of Agriculture
Forest Service
Northeastern Area
State and Private Forestry
6816 Market Street
Upper Darby, Pennsylvania 19082
Mr. W. Lyon, Deputy Assistant
Office of the Secretary
Department of the Interior
Washington, D.C. 20240
Dr. Sidney Galler
Deputy Assistant Secretary for
Environmental Affairs
U.S. Department of Commerce
Washington, D.C. 20235
Mr. William E. Trieschman, Jr., Chief
Planning Division
Baltimore District
Corps of Engineers
P.O. Box 1715
Baltimore, Maryland 21203
Capt. E. W. Sapp
Director
Naval Research Laboratory
Washingt6n, D.C. 20390
Mr. Rod Kreger, Deputy Administrator
U.S. General Services Administration
Washington, D.C. 20405
Mr. L. E. DeCamp, Director
Standards Development & Implementation
Program
EPA
Washington, D.C. 20460
STATE AND LOCAL AGENCIES
John W. Epling
Executive Director
Northern Virginia Planning
District Commission
7309 Arlington Boulevard
Fall Church, Virginia 22042
Mr. Howard E. Chaney, Director
Environmental Health Services
Maryland Department of Health
and Mental Hygiene -
610 North Howard Street
Baltimore, Maryland 21401
Mr. Robert J. McLeod
General Manager and Chief Engineer
Washington Suburban Sanitary Commission
4017 Hamilton Street
Hyattsville, Maryland 20781
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STATE CLEARINGHOUSES
REGIONAL CLEARINGHOUSES
Mr. Edwin L. Powell, Jr.
Chief, State Clearinghouse
Maryland Department of State
Planning
301 West Preston Street
Baltimore, Maryland 21201
ATTN: Vladimir A. Wahbe
Secretary of
State Planning
Mr. Walter A. Scheiber, Exec. Director
Metropolitan Washington Council
for Governments
Metropolitan Clearinghouse for D.C.
1225 Connecticut Avenue, N.W.
Suite 201
Washington, D.C. 20036
STATE AND LOCAL
Mr. William C. McKinney, Director
District of Columbia Department
of Environmental Services
Presidential Building
415 -12th Street, N.W.
Washington, D.C. 20004
Mr. Charles H. Conrad.
Executive Director
National Capitol Planning Commiss
1325 "G" Street, N.W.
Deputy Mayor
District of Columbia Government
Washington, D.C. 20004
Executive Secretary
Advisory Council of Historic
Preservation
Washington, D.C. 20240
Washington, D.C. 20005
PRIVATE ORGANIZATIONS AND INDIVIDUALS
Mr. William Shands
Central Atlantic Environmental
Service
1717 Massachusetts Avenue, N.W.
Washington, D.C. 20036
Mr. T. R. Jones, Chairman
Citizens Council for a Clean
Potomac
P.O. Box 1972
Hheaton Station
Silver Springs, Maryland 20902
Mr. John S. Winder, Exec.
Director
Metropolitan Washington Coalition
for Clean Air, Inc.
1714 Massachusetts Avenue, N.W.
Washington, D.C. 20036
Mr. David Hawkins
National Resources Defense Council, Inc.
1710 N Street, N.W.
Washington, D.C. 20036
Mr. Alexander Zucker
Executive Director
National Academy of Science
National Academy of Engineering
Environmental Studies Board •
2101 Constitution Avenue
Washington, D.C. 20418
Mr. Louis S. Clapper
Conservation Director
National Wildlife Federation
1412 16th Street, N.W.
Washington, D.C. 20036
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TABLE OF CONTENTS
District of Columbia Water Pollution Control Plant Upgrading and Expansion
Section Description Pas>e
I Introduction -1-
II Description of the Proposed Action -11-
III Environmental Impact of the Proposed Action -20-
IV Adverse Impacts Which Cannot be Avoided -30-
Should the Proposal be Implemented
Alternatives to the Proposed Action -31-
VI Relationship Between Local Short-Term Uses -36-
of Man's Environment and the Maintenance and
Enhancement of Long-Term Productivity
VII Irreversible and Irretrievable Commitments -37-
of Resources WhichiWould be Involved in the
Proposed Action Should It be Implemented
VIII Problems and Objections -38-
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APPENDICES
Section Description Page
a Comments Received on Draft Version of Statement a-1 to a-104
b Draft Version of NPDES Permit and Related Material b-1 to b-26
c- Alternatives to the Proposed Action c-1 to c-33
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Preface to the Final Statement
An Environmental Impact Statement for the Blue Plains project was prepared by
the Regional Office and released in draft form on April 20, 1972. Comments
on the draft were received throughout the summer and fall of that year and
during the initial review of the comments it became evident that the most
serious objections to the project were aimed at the proposed sludge inciner-
ators. Construction of the solids processing building which was designed to
house the incinerators began in 1971 and was underway while the draft state-
ment was being reviewed. Also, prior to the beginning of the review period
the applicant had decided to adopt the biological nitrification-denitrifica-
tion system in favor of the two-stage lime precipitation treatment method.
This change was prompted by research results obtained at the EPA-DC pilot
plant. One effect of this decision to change processes was that additional
sludge handling capacity was required. The District requested an "increase
in scope" to accommodate the additional sludge processing equipment on
April 20, 1972. This request was subsequently conditionally approved on
November 3, S972, and accepted by the applicant on November 7, 1972, The ap-
proval condition is shown below.
"On behalf of the Government of the District of Columbia, I hereby accept the
increase in Federal assistance in the amount of $4,538,990, provided under
the Federal Water Pollution Control Act, as amended, for construction of the
sewage treatment facilities project designated C-ll-23, and reaffirm all of
the assurances applicable to the former grant offer in connection with this
project. In addition, the increase in project scope and grant is further sub-
ject to completion of a review required by the National Environmental Policy
Act of 1969, 42 U.S.C. 4321 et seq. The District hereby agrees to furnish
information and otherwise cooperate with EPA regional office staff in the NEPA
evaluation and further agrees that no additional costs or obligations for in-
cineration equipment will be incurred unless and until the Regional Adminis-
trator notifies the District in writing that the NEPA review has been satis-
factorily completed. The Regional Administrator may annul this increase if he
determines as a result of the NEPA review, that the project for which this
grant has been awarded is environmentally ttftsound."
On April 19, 1973, a highly technical and very serious critique of the pro-
posed incinerators was submitted to the Regional Office by the Natural Re-
sources Defense Council, Inc. The commenting period for the draft statement
was held open until the questions raised by NRDC could be resolved. The
Regional Office called on air pollution experts at EPA's National Environmen-
tal Research Center (NERC) in Research Triangle Park, North Carolina, to
study the health aspects of the incinerator emissions.
i
In June 1973 the NERC produced a report entitled "Evaluation of Potential
Mercury and Beryllium Emissions from Proposed Sludge Incinerators to be Lo-
cated at the Blue Plains Waste Treatment Facility in Washington, D. C." which
found that while the mercury and beryllium emissions "should not constitute
a threat to public health in the vicinity of the sewage treatment plant" that
there is a "lack of specific information concerning the composition of the
sludge and the fate of materials processed in sludge incinerators". Clearly,
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the Regional Office needs more information before it can allow the District
to proceed with the incineration equipment contract. However, it is also
clear that the longer construction of advanced wastewater treatment units
is deferred, the longer marginally treated wastewater effluents from Blue
Plains will continue to undermine attempts to achieve compliance with water
quality standards for the Upper Potomac Estuary. Therefore, the following
strategy has been developed and adopted as the Region's response to this
dilemma. We will continue to award grant support for those AWT units which
are not yet funded while continuing to defer approval on the incinerator
units until firmer conclusions concerning the effect of incinerator emis-
sions can be reached.
The District has recently requested an award of grant support for the con-
struction contracts listed below.
The three large contracts are expected to require 33 months for execution.
Also, they are scheduled to be awarded in a staged fashion, that is, they
are interdependent and cannot all begin at once. Another aspect is that ex-
perience has shown an interval of four to six months is required to advertise
for bids, open and evaluate the bids, and to award the contracts. This bid-
ding process cannot begin until after the award of grant support has been
made. An examination of the overall project timetable clearly shows that if
the schedule set forth in the draft NPDES permit (see Appendix b) is to be
met, grant support must be made available for these four contracts before the
end of June.
Once the contracts discussed above have been funded, there will be only one
major contract not funded. The final contract provides for advanced waste-
water treatment instrumentation and it is estimated:to include $9,000,000 worth
of work. The contract is presently in the design stage and the design work
is scheduled for completion by January 1975. There are also several minor
contracts which are not yet funded. These contracts include such work as
landscaping, final paving, additions to the supply building, etc.
Dne predictable consequence of the funding program described in the above
paragraphs is that as these AWT units are constructed and become operational,
quantities of sludge produced by the plant will increase. Since sludge dis-
posal at Blue Plains is already a volatile subject, would not the additional
sludge produced by the denitrification and filtration facilities aggravate
in already chronic problem? One way of answering this question is with
figures taken from a table entitled "sludge quantities" which was published
Contract Title
Estimated Amount
Denitrification Reactors
Denitrification Sedimentation
Multi-Media Filters
Additions to Pump Station No. 2
$26,200,000
27,100,000
13,000,000
4,000,000
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in a paper"'- developed by the design engineers. The figures are shown
below and the table's format has been modified to differentiate between
funded and unfunded contracts.
Source Quantity
(l,000#/day, dry basis)
Funded Contracts Primary 359
Secondary 395
(includes first
step phosphorus
removal)
Nitrification 38
Unfunded Contracts
Denitrification 31
(includes second
step phosphorus
removal)
Filtration 39
Total 862
Thus, the unfunded contracts provide facilities which produce only Q%
(I®. ) of the total sludge - a relatively Slight increase.
862
While the calculations and conclusions presented above are correct,
a muchjnore positive approach would involve facing up to the sludge dis-
posal problem and that is what the Regional Office p'lans to do. During
meetings with officials of the District's Department of Environmental
Services, it was agreed that this Agency would assume the responsibility
for further invesTigating the health aspects of the incinerator emissions
since the results of the investigation would probably have nationwide ram-
Tfications. The "District official's" in turn agreed to investigate alterna-
tives to incineration and the following paragraphs describe those alterna»
tives which are Being given'"serious consideration.
1. Flash Drying - Fortifying
The District, Maryland Environmental Service, and Organic Recycling, Inc.
are parties to an agreement which provides for Organic Recycling, Inc.
to build and operate a patented flash dryer demonstration facility at
Blue Plains. The Maryland Environmental Service and the District will
1. Design of advanced wastewater treatment facilities for District of
Columbia Blue Plains Water Pollution Control Plant. George K. Tozer
and Donald E. Schwinn, Metcalf & Eddy, Inc., Boston, Mass. October, 1973.
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pay Organic Recycling, Inc. a treatment charge for each ton of sludge
the facility processes. Organic Recycling, Inc. expects this fee
plus revenues derived from sale of the end product will enable the
venture to return a profit.
The heart of Organic Recycling's process is a high rate toroidal
(doughnut) shaped flash dryer whose configuration causes combustion
turbulances to selectively classify sludge particles and to allow the
dried sludge fraction to leave the dryer. As the dried sludge is re-
moved, it can be enriched with controlled amounts of nitrogen, potassium,
and phosphorous so that the end product is a well balanced fertilizer
which would appeal to gardeners and nurserymen..
The demonstration unit began operation early in April and will
be run on a "shakedown" basis for a few weeks prior to full scale
operation. When operating at peak capacity the unit is expected to
convert 2h0 wet tons/day of either raw or digested sludge into approxi-
mately 60 tons /day of fortified organic fertilizer. While the manufacturer
reports that the flash dryer has been used for a number of years in
industrial applications with materials similar to sewage sludge, it must
be kept in mind that this unit is involved in a demonstration project
and cannot be adopted on a large scale until it has demonstrated con-
clusively its environmental,technical, and economic feasability.
Should the demonstration project yield favorable results, an ap-
propriate number of flash dryer units could be installed in the solids
processing building in lieu of incinerators. "A portion of the fuel re-
quirements for the dryers could be satisfied by utilizing the methane
gas produced'by the existing anaerobic digesters. It is likely "that" the
"service agreements described above would be revised to provide for out-
right purchase of the equipment.
2. Construct proposed incinerators and operate as dryers.
This particular alternative involves proceeding with the con-
structing of the multiple hearth incinerator units as described in the
draft Impact Statement and operating them as sludge dryers rather than
incinerators. The furnace designer reports this change could be
accomplished by redirecting the flow of air through the incinerator
units so that air flow is concurrent with sludge flow rather than counter-
current. This redirection could be accomplished by repositioning
components of the air supply ductwork and furnace hearth systems.
If the dryer mode of operation were adopted, the product would
be approximately 85O tons/day of sludge dried to 30% moisture content.
Theoretically, this product could be fortified and used as a fertilizer
just as the product from the flash dryer system that was previously
described can be converted to a fertiliser.' One further advantage of
this alternative is that a reduction in certain air pollutants is to
be expected. While detailed calculations concerning the expected re-
ductions are not yet available, it is logical to assume that the emissions
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attributable to thp combustion of sludge will "he eliminated, while
those attributable to the combustion of fuel will rema ¦>. Finally,
since this alternative requires the same facilities th* ¦ would be
required for incineration, no significant change in project financing,
scheduling, costs, etc. would be required.
The fuel requirements for this mode of operation are about the
same as for incineration and are reported to be 15,700,000 gallons of oil
per year. This figure is the result of a statistical analysis of sludge
flow and fuel requirements conducted by the furnace designer and is
lower than originally reported in the draft statement.
3. Composting
On March 30, 1973, a full .scale trial of the feasibility of
composting Blue Plains sludge by the Windrow Method was begun at a
site near Beltsville,Maryland. The project was sponsored jointly by
the U. S. Department of Agriculture's Agricultural Research Service
and the Maryland Environmental Service (MES). USDA provided land
for the composting operation and scientific supports while MES designed,
constructed, and operates the project.
The sludge was hauled from Blue Plains in enclosed concrete trucks
and mixed with wood chips at the compositing site. The wood chips
were added as a bulking agent to improve air flow to the aerobic
microorganisms which convert the sludge to compost. This biological
reaction also produces heat which elevates the temperature in the
compost windrow to a point which destroys most pathogenic (Disease
causing) organisms. After several weeks in the composting windrow,
the mixture of compost and wood chips is screened and the compost is
cured for at least 30 days in a storage pile. The cured compost is
then ready for incorporation into soil where it acts to improve aeration,
water retention^and other soil characteristics in addition to serving
as a low grade fertilizer.
While operation of the composting program has produced generally
favorable results, one period marked by odor complaints from neighbors
is said to have occurred during a interval in which the type of sludge
which was composted was switched from digested sludge to raw sludge.
This problem deserves further attention since Blue Plains lacks both
digester capacity and the land on which to build additional digester
capacity should it turn out that only digested sludges can be composted.
Other aspects deserving further consideration are enclosing the operation
to improve wet weather performance and the development of a controlled
aeration system.
One of the most obvious advantages of this alternative is that its
energy requirements are substantially below those of the alternatives
previously considered. At present, much of the energy input is used
to move the sludge from Blue Plains to the Beltsville site. This input
could be reduced by locating the composting site in the vicinity of
Plains, However, ne such site is presently available.
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4. Land Disposal and Reclamation
The District is presently disposing of the bulk of the sludge gen-
erated at Blue Plains by trucking it to a location in Montgomery County
and depositing it in trenches dug for that purpose. The trenching
technique is primarily a disposal method while the previous alternatives
are designed to produce a useful end product.
Another alternative that has been pursued on a limited scale in-
volves spreading the sludge on farmland. This method holds promise for
reclaiming marginal land but care must be exercised to avoid contamina-
tion of groundwater and nearby streams. This Agency is presently working
to develop policy which will govern loadings and permissible toxic metal
concentrations for sludges disposed of on land. While the policy is still
in the formative stage, it is clear at this point that some form of sta-
bilization such as digestion will be a required prerequisite for applica-
tion on the land. It will be difficult to assess the applicability of
this method as a long-term solution until Agency policy in this field is
firmly established.
5. Incineration
For the sake of completeness, we are pointing out the obvious fact
that one alternative open to the District would be to proceed with incin-
eration as described in the draft statement. Should the EPA studies pre-
viously mentioned find that incineration can be practiced without danger
to the public health, this may well be the soundest course of action.
Summary
Each of the alternatives listed on the above pages has advantages and
drawbacks associated with its implementation. At this point in time it
cannot be demonstrated that any one alternative is clearly superior to the
others although incineration appears to have the advantage of a long history
of reliable operation. Six months from now this situation should be reversed.
The Organic Recycling, Inc. flash dryer will have accumulated nearly six
months of operating records that will be available for analysis. EPA studies
on the effects of sludge incineration on public health should at least be ad-
vanced to the stage where some conclusions are possible. Agency guidance on
the subject of land disposal and reclamation with sewage sludges should be
available. Six months from now it will be necessary to decide which alterna-
tive will be adopted since some of the alternatives have not construction
times. Therefore, this office plans to release a supplement to this state-
ment in approximately six months. The supplement will report on recent de-
velopments connected with each of the sludge disposal alternatives, point to
the alternative selected for implementation at Blue Plains, and present a
discussion of the consequences of that selection.
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F inal
Environmental Impact Statement
(P.L. 91-190)
District o£ Columbia Water Pollution Control Plant
(Expansion and Upgrading)
I
INTRODUCTION
A. General Background
The primary cause of pollution in the upper Potomac estuary is
municipal wastewater discharges. This includes raw sewage re-
leased from overloaded sewer systems, sewage treatment plant
effluents, combined sewer overflows, and storm water. A listing
of prior District of Columbia sewerage systems and a detailed
description of existing water pollution control facilities is
presented in Appendix F of the draft statement. The amount of
watetf used for industrial processes is insignificant. Industrial
use consists primarily of cooling water used in power generation
facilities.
Applications have been received from the States of Maryland and
Virginia and from Washington, D. C., for Federal construction
grant funds to expand and upgrade the Blue Plains sewage treat-
ment facility. In order to evaluate the environmental impact
of the proposed treatment facility it is necessary to define the
problem and determine the sphere of influence of the treatment
facility. The sphere of influence includes the air affected by
emissions from the sludge incinerator, the reaches of the Potomac
estuary affected by the effluent discharge, and the service area
contributing wastewater to the Blue Plains facility.
The Blue Plains treatment plant is a regional facility; i.e., its
service area is not limited by governmental boundaries. While it
is owned and operated by the District of Columbia, it treats
wastewater from portions of Prince Georges and Montgomery Counties,
Maryland; wastewater from portions of Loudoun, Arlington, and
Fairfax Counties, Virginia; and wastewater from the Washington,
D. C. area. Currently the Blue Plains plant is treating between
75 and 80 percent of the total domestic wastewater generated in
the Washington Metropolitan area.
The breakdown of the existing flow of approximately 295 million
gallons per day (mgd) is as follows:
Washington Suburban Sanitary Commission 135 mgd
(Prince Georges and Montgomery Counties, Md.)
District of Columbia 143 mgd
Potomac Interceptor 10 mgd
Pimmit Run Interceptor
(Fairfax County, Va.)
7 mgd
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The Potomac River, from its headwaters on the eastern slope of
the Appalachian Mountains to the Fall Line above Washington,
D. C. is a freshwater river. Below the Fall Line the Potomac
is tidal for approximately 114 miles to the Chesapeake Bay.
Throughout this impact statement the tidal portion of the Po-
tomac River will be referred to as the Potomac estuary.
While this impact statement is primarily concerned with the
Blue Plains sewage treatment facility, the discharge from the
facility is an integral part of the total water quality manage-
ment plan which must be developed for the Potomac River Basin.
In June 1967 pursuant to the provisions of the Water Quality
Act of 1965, the District of Columbia adopted water quality
standards for its interstate waters. The water quality stan-
dards consist of (1) planned water uses; (2) quality criteria
designed to protect those uses; and (3) a plan for implementa-
tion and enforcement of the criteria. These standards were
submitted to the Secretary of the Interior on June 29, 1967.
The Secretary gave his full approval in January 1969, thus making
the District of Columbia's water quality standards Federal
standards.
The stated purpose of the District's standards is primarily
intended to provide improved recreational opportunities as a
result of water quality improvement. With the exception of the
criteria related to water contact recreation (swimming, etc.),
water quality objectives were to be realized in 1972. Water
quality to permit contact recreation was planned for 197 5 in
limited zones of the Potomac River and Rock Creek.
Dissatisfied with pollution control progress, the Secretary of
the Interior reconvened the third session of the conference on
the Matter of Pollution of the Interstate Waters of the Potomac
River and its tributaries in the Washington Metropolitan area
(Potomac Enforcement Conference) in April 1969. The conferees
represented the water pollution control agencies of Maryland,
Virginia, and the District of Columbia; the Interstate Commis-
sion on the Potomac River Basin; and the Department of the
Interior - Federal Water Quality Administration (now part of the
Environmental Protection Agency).
The Conference resulted in the^issuance of 15 recommendations to
"^enhance water quality of the Potomac estuary. The most signifi-
cant recommendation called for constructionoofaadvanced waste
treatment facilities.
In accordance with conference recommendations, the District
proceeded to implement its phased developed plan for the Blue
Plains site. This was to include reclamation of 51 acres of
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Potomac River mud flats for plant expansion to 419 mgd, the ex-
pected flow for the year 2000. However, subsequent Department
of the Interior opposition to the reclamation proposal made ap-
proval by the Federal Government unlikely. As a result, it was
necessary to abandon plans for full expansion of the plant to
4l9 mgd.
In recognition of this impasse, the conferees reached a compro-
mise set forth in a "Memorandum of Understanding" completed on
October 7, 1970 (see Appendix G of draft statement. The Memor-
andum called for the development of the Blue Plains site to
provide advanced waste treatment for J09 mgd by the end of 1977
and it recognized that an alternate regional plant (or plants)
would be'needed to treat flows above the 309 mgd limit. Thus
the size of Blue Plains was limited by physical constraints
rather than by the normal procedures of designing for a popula-
tion projection in the service area.
The "Memorandum of Understanding" agreed to an expansion of Blue
Plains to 309 mgd with the following breakdown of flows:
Washington Suburban Sanitary Commission 148 mgd
(Prince Georges and Montgomery Counties, Md.)
District of Columbia 135 mgd
Potomac Interceptor 18 mgd
Pimmit Run Interceptor 8 mgd
(Fairfax County, Va.)
309 mgd
As a result of the subsequent request from the Secretary of the
Interior, the District of Columbia agreed to advance the comple-
tion date of the Blue Plains treatment plant improvements to
December 1974 provided certain conditions were met, including
the availability of adequate Federal assistance in the form of
construction grants. This deadline will not be met, however,
and completion is again predicted for late 1977. For details
concerning the treatment plant completion schedule, please see
the draft NPDES permit reproduced as Appendix b of this document.
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B. Existing and Proposed Studies
1. Water Quality and Water Supply
In November 1969 a technical advisory committee was
established to determine the studies required to evaluate
water quality management needs of the upper Potomac Estuary.
In addition, the Assistant Secretary of the Interior requested
a study of the water supply potential of the upper Potomac
Estuary. Thus, a detailed water quality - water resources study
of the Potomac Estuary was undertaken by the Chesapeake Technical
Support Laboratory, In April 1971, a study, Water Resources -
Water Supply Study of the Potomac Estuary, Technical Report 35,
was completed by the Chesapeake Technical Support Laboratory,
Environmental Protection Agency, to provide technical information
for the Potomac River Enforcement Conference. A synopsis of
TR-35 is enclosed as Appendix E of the draft Environmental
Impact Statement.
For purposes of Conference discussion and investigation, the
Potomac Estuary was divided into three zones (1) upper zone -
beginning at Chain Bridge and extending southward to well below
Indian Head, Maryland; (2) middle zone - Indian Head to U. S.
Route 301 Bridge; and (3) lower zone - U. S. Route 301 Bridge
to Chesapeake Bay. (Please see Figure III-l which follows this
page. This figure has been reproduced from TR-35 and modified
to show the location of the Blue Plains Wastewater Treatment
Plant and Dyke Marsh.)
The study included: (1) an evaluation of pollution sources
including nutrients; (2) the development and refinement of
mathematical models to predict the effects of the various
pollutants on water quality; (3) the projection of water supply
needs and wastewater loadings; (4) an evaluation of the estuary
as a potential water supply source; (5) the determination of
the maximum pound loadings by zone for the various pollutants
under various flow conditions; (6) an investigation of alternative
waste treatment plans; and (7) an estimate of the cost of achiev-
ing wastewater quality standards.
To evaluate the effects of effluent discharge locations on the
water quality of the upper Potomac Estuary, the Water Resource -
Water Supply Study of the Potomac Estuary investigated three
basic alternative treatment systems. Two of the three alternatives
assumed that expansion at Blue Plains is not restricted. However,
this has since proved impractical because of the physical constraints
and ecological considerations at the Blue Plains location. The
third option, Alternative III, is similar to the proposals expressed
in the "Memorandum of Understanding" in that Blue Plains was
limited to a maximum capacity of 309 mgd. Additionally, it was
assumed the appropriate parties would provide another regional
plant or plants to accommodate the projected increases in
wastewater.
-4-
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/
')\
CHAIN BRIDGE-
N
\
\
/
/
BLUE PLAINS WASTEWATER/
TREATMENT PLANT
DYKE MARSH
UPPER REACH
INDIAN HEAD
-301 BRIDGE
MIDDLE REACH
LOWER REACH
\CHESAPEAKE
BAY
POTOMAC RIVER TIDAL SYSTEM
FIGURE III -1
-------
For the study purposes, it was assumed that increased waste-
water volumes would be treated at one or more of three proposed
locations: Upper Potomac (near Chain Bridge), Anacostia River
above the D. C. line and the existing Piscataway Treatment Plant.
Whether increased flows are treated at these locations or other
locations is not important. The important fact is that the
increased volumes will occur in the vicinity of the proposed
locations and the treated effluent discharged into the Potomac
Estuary.
Water quality simulations for establishing zonal pollution
loadings were made using the Dynamic Estuary Model developed by
Federal Water Quality Administration personnel and future waste-
water loadings formulated from the COG population projections.'
The maximum allowable ultimate oxygen demand (UOD)loadings
determined for the upper Potomac Estuary were derived using the
following criteria:
Temperature 29°C. (Centigrade scale)
Freshwater inflow to estuary
after water sttpply diversion.
Dissolved Oxygen (DO) in the
treated effluent.
300 cfs (cubic feet per second)
6 milligrams per liter (mg/1)
Dissolved Oxygen standard for
receiving water, average. 5 mg/1
Simulation of phosphorus (P) discharged into the Potomac Estuary
was made using a mathematical model with second-order reaction
kinetics. Allowable phosphorus loadings in pounds per day were
determined using the following criteria:
Average freshwater flow
into estuaty after water
supply diversion. 300 cfs
Average maximum phosphorous
in upper reach from Chain
Bridge, Washington, D. C. to
Indian Head, Md. 0.067 P&/1
Average maximum phosphorous
below Indian Head, Md. for
algal control. 0.03; mg/1
(A) The Metropolitan Washington Council of Governments (COG) is a
Federally-approved areawide planning organization for the Washington
Metropolitan Area. It is responsible for coordinating the Office
of Management and Budgetfs (0MB) A-95 review procedures in the
Metropolitan Area.
-5-
i
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Inorganic nitrogen was simulated using a mathematical model
which has been verified based on observed data. Allowable
nitrogen loadings in pounds per day were determined using the
following criteria:
Average freshwater flow
into estuary after water
supply diversion. 300 cfs
Average maximum inorganic
nitrogen in upper reach from
Chain Bridge to Broad Creek. 0.5 rng/1
Average maximum inorganic
nitrogen in upper reach from
Broad Creek to Indian Head. 0.4 mg/1
Average maximum inorganic
nitrogen in upper reach from
Indian Head to Smith Point. 0.3 mg/1
To facilitate the determination of wastewater loadings and
water supply requirements for the Metropolitan Area, popu-
lation projections were distributed over 13 service areas
using 1960-1970 population trends with consideration given to
land use potential and other attenuating factors.
Utilizing the population projections and waste flows at
existing treatment facilities, future wastewater trends were
developed for the 13 service area in the Washington Metropolitan
Area. Wastewater flows are summarized below:
Washington Metropolitan Area Washington, D. C.
Year Flow (mgd) Flow (mgd)
1970 325 252 *
1980 473 140
2000 861 160
2020 1,342 180
Since the District's allocation according to the "Memorandum
of Understanding" is limited to 135 mgd9 it is evident that
provisions will have to be made for additional capacity at
another location. The need for another regional facility (or
facilities) has been recognized in the "Memorandum of Under-
standing1.'. Recent plans envision relief treatment plants in
Montgomery County, Maryland and near the existing Piscataway
Treatment Plant.
* The wastewater flows shown for the District of Columbia for the
year 1970 represent the total flow to Blue Plains which includes
flow from Maryland and Virginia as well as the District proper.
Flows for 1980, 2000, and 2020 reflect wastewater from the District
only.
-6-
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The major source of freshwater inflow into the Potomac
Estuary is from the upper Potomac River Basin. In water
resource management, low flow frequencies are used to
determine assimilation and transport capacities of receiving
waters. The 7-day low flow with a recurrence interval of once
in 10 years (7-10 low flow) is the standard used by Maryland,
Virginia, and the Eistrict of Columbia to determine assimilative
capacity for water quality aspects. For the Potomac at Washington,
the 7-10 low flow is 954 cubic feet per second (cfs) or 616 mgd.
Water Resource -'Water Supply Study of the Potomac Estuary takes
into consideration the fact that the need for water supply is
projected to use all of the river flow during critical flow
conditions; therefore, a water quality management design flow of
300 cfs was used in determining the assimilative capacity of the
upper Potomac Estuary. It is stated in the report that a minimum
flow of 300 cfs will maintain an ecological balance arid preserve
aesthetic appearance in critical stream reaches during low flow
periods. This design flow is used throughout the report and in all
dicAssions within this environmental impact statement.
Water supply demands and per capita usage were obtained from the
major water suppliers in the metropolitan area and used as a
baseline for the water supply projections. Total projected water
requirements for the Washinton Metropolitan Area are listed below!
Year Water Demand
mgd (yearly average)
1969 370
1980 556
2000 1,009
2020 1,568
In addition to existing sources of water supply, it appears that
the District of Columbia's water supply and a major part of the
water supply for the Metropolitan Area in Maryland and Virginia
must come from the Potomac River. The water quality design flow
(7-10 low flow) for the Potomac at Washington, D. C. is 616 mgd;
therefore, it can readily be seen that the water supply require-
ment in 1980 is about equal to the critical 7 day low flow.
Additional provisions for water supply raust be undertaken.
The estuary can be used as a supplementary water supply source
if wastewater discharges and water supply withdrawals are
adequately treated. In addition to the EPA work on water quality,
close cooperation was maintained with the U'. S. Army Corps of
Engineers who were investigating water supply potential of the
upper Potomac Estuary as part of their Northeast Water Supply
Study (NEWS) for the Washington Metropolitan Area.
-7-
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House Document 91-343 (Potomac River Basin Report) prepared by
the U. S. Army Corps of Engineers evaluated the total water
resources of the Potomac River Basin including water supply
requirements to the year 2010.
The Federal Water Pollution Control Act Amendments of 1972, and
implementing regulations, provide a sound basis for developing
water strategies that are aimed at assessing the situations,
monitoring to continually keep abreast of water quality, estab-
lishing of a planning process to eliminate sources of pollution,
implementation of actions to physically abate pollution sources,
establishment of a legal framework through the National Pollu-
tant Discharge Elimination System, and enforcement actions upon
violation of the NPDES permit.
The water quality situation in the Potomac estuary has been ex-
tensively studied and is well documented in other papers. In
addition to the Potomac River Enforcement Conference Proceedings,
the "Memorandum of Understanding", and Technical Report 35,
there have been several recent developments armed at fulfilling
both the requirements of the 1972 Amendments and the needs of the
Washington Metropolitan Area.
In 1973 Maryland Environmental Services completed a draft, Potomac-
Metropolitan Area Basin Water Quality Management Plan in accordance
with Section 303(c) of the Federal Water Pollution Control Act
Amendments of 1972. This plan provides for a sewage treatment
plant in Montgomery County which will relieve Blue Plains of some
of the sewage generated in that area. The plan also provides for
expansion of the Pisctaway sewage treatment plant and an intercep-
tor from Blue Plains to Piscataway so that flows in excess of 309
mgd can be shunted to Piscataway for treatment. Through the concept
of a three plant operation the problems of overloading of Blue
Plains will be eliminated. Also, the increased degree of treatment
proposed at Blue Plains will insure that this facility will meet
the effluent limitations imposed upon it by the Potomac River En-
forcement Conference.
TR-35 notes that the water quality in the estuary is also signifi-
cantly affected by the quality of the water entering the estuary,
especially from the mainstream of the Potomac River. An additional
safeguard to the water quality of the estuary can be attained if
the concentration of background nutrients entering the estuary is
reduced. Provisions for analyzing the upper Potomac water quality
are being made through the development of waste load allocations
for point discharges in the free flowing portion of the Potomac
River and its estuaries. Monitoring systems are being planned
which will enable toe states to keep abreast of conditions that
affect the quality of water in the area and assist in analyzing
non-point pollution source.
-8-
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The Corps of Engineers is currently proposing construction
of an Emergency Pumping Station in the Potomac Estuary to bolster
the short-term water supply reliability in the Washington
Metropolitan Area. EPA commented on an Environmental Impact
Statement developed by the Corps for this facility and recommended
further investigation of this proposal.
The State of Virginia is currently studying the.Loudoun County
Area for the feasibility of constructing a regional sewage
treatment facility. The ramifications of this study are that
increased flows to Blue Plains may not be a reality if this
facility comes into existence.
A discharge permit for the Blue Plains facility is currently
being processed by this agency and should be issued in the near
future. A draft permit has been circulated, public hearings
have been held, and comments are now being reviewed for inclusion
in the final* permit. The proposed permit establishes schedules
that provide for staged improvements in effluent quality. These
schedules will supersede part of the Water Quality Standards
Implementation Plan. The proposed permit is included into this
statement as Appendix b.
-9-
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C. Land Use and Population Projections
As previously stated, the Metropolitan Washington Council of
Governments (COG) is the official metropolitan planning body for
the Washington Metropolitan area. As the metropolitan planning
agency, COG must direct its efforts to the metropolitan scale;
however, coordination of all local planning efforts must be as-
sured. In this effort COG works'with local planning agencies to
establish areawide policies for orderly development and use of
land resources.
The majority of the land area served by the Blue Plains plant is
considered to be a developed area rather than a growing one.
Loading limitations established in the "Memorandum of Understand-
ing" have essentially limited the Blue Plains service area to the
developed area currently sewered. Developing areas outside the
current Blue Plains service area will be required to use other
wastewater treatment facilities.
COG has projected growth of new communities along urban corridors
radiating out from the District of Columbia. Rural areas on the
fringe of the metropolitan area are presently capable of sustain-
ing further urbanization. This development will require addi-
tional regional facilities which will be substantially distant to
Blue Plains.
As noted earlier, population projections used in the Water Re-
source - Water Supply Study of the Potomac Estuary were furnished
by COG.* These projections were derived by use of the COG's
EMPIRIC Activity Allocation Model. This model consists of a set
of simultaneous linear equations that relate changes over time
in the distribution of regional population and employment to their
original distributions at some base year, their regionwide growth
over the forecast period, and the effects of public policy and in-
vestment decisions.
The base year information was compiled for COG by Hammer, Green,
Siler Associates (HGS). Although local population projections
were considered in the development of this information, it was
noted that none of these forecasts were mutually acceptable by
other agencies. Therefore, HGC Associates made an economic base
study for their projections.
The total population projections for the Virginia and Maryland
portions of the metropolitan area and the District of Columbia
are summarized below:
Year Population
1969 2,800,000
1980 4,000,000
2000,, 6,700,000^
2020 9,300,000
Population projections for the year 2020 were developed by EPA-Region
III rather than COG.
-10-
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Iboooq
wfcuin inaniiiiM bun
- Q0omo
Mmr-tYfo
DISTRICT OF COLUMBIA
WATER POLLUTION CONTROL PLANT
PLANT LAYOUT
Figure I
-------
DESCRIPTION OF THE PROPOSED ACTION
Proposed additional treatment units at the plant include a Raw Sewage
Pumping Station, Aerated Grit Chambers, Primary Clarifiers, Aeration
Basins, Secondary Clarifiers, Nitrification Reactor Tanks, Nitrifica-
tion Sedimentation Tanks, Denitrification Reactor Tanks, Nitrogen
Release Tanks, Denitrification Sedimentation Tanks, Effluent Pumps,
Multimedia Filters, Chlorine Contact Channels and Effluent Conduits to
the Potomac River. Sludge Processing Facilities include Flotation
Thickening Tanks, Sludge Blending Tanks, Vacuum Filters and Multiple
Hearth Incinerators (See Figure 1).
The proposed units, in conjunction with the existing facilities which
will be retained, are designed to provide complete treatment for an
annual average flow of 309 mgd. The units are designed to handle peak
flows up to a rate of 650 mgd. In addition, flows between 650 mgd and
939 mgd will receive grit removal, primary sedimentation^and chlorina-
tion in the excess flow facilities before being discharged directly to
the Potomac through the existing plant outfall. The excess flow facil-
ities are designed to provide primary treatment for flows emanating
during rainstorms from combined sewers in the District. These facili-
ties are expected to be used approximately 400 hours per year. Flows
in excess of 939 mgd will be stored within the sewer system until its
capacity is exhausted and then bypassed to the Potomac and Anacostia
Rivers at various upstream points. Bypassing would be expected approx-
imately 240 hours per year during more intense storms. The draft version
of the NPDES permit requires the District to operate the facility in such
a manner which will minimize discharges of excessive pollutants and calls
for the District to develop a monitoring program and to study abatement
measures for the combined system overflows.
Design flows are normally expressed in terms of daily quantities, i.e.,
309 mgd. Actual designs of Sewage Treatment Plants are based on the max-
imum rate that wastes may be expected to be received at a plant as the
flow rates vary during the day. The flow rates may be stated in various
units, such as cubic feet per second (cfs) or gallons per minute (gpm).
The following flow rates are equivalent:
Average Daily Flow 309 mgd
Peak Flow to Complete 650 mgd
Treatment
Excess Flow 289 mgd
Total Flow 939 mgd
It may be interesting to note that a flow of 309 mgd would take approx-
imately 3.8 seconds to fill an average-sized living room (12' x 18' x
8k').
480 cfs 214,000 gpm
1,000 cfs 450,000 gpm
450 cfs 200,000 gpm
1,460 cfs 650,000 gpm
-11-
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The facilities are being constructed with the aid of EPA grant funds
under several projects. Federal grants will total approximately $226
million of the estimated cost of $330 million. In ,'iddLLtou to tlio lil'A
contribution, the District of Columbia will contribute $51 million,
WSSC $26 million, the State of Maryland $25 million, Fairfax County,
Virginia, $1.4 million, and the Commonwealth of Virginia $1.2 million.
The D. C., Maryland and Virginia shares of the costs are allocated on
the basis of capacity assigned in the "Memorandum of Understanding".
(See Appendix G of draft statement).
Since the District can recover its capital investment for facilities
to handle the flows from the Potomac Interceptor under existing agree-
ments, these flows have been included as part of the District alloca-
tion of 153 mgd. Since the plant will provide treatment for wastes
emanating from two states and the District of Columbia, the cost of
Federal grant projects has been divided among the various state alloca-
tions. The projects and their current status is discussed below.
1. Raw Sewage Pumping and Conduits
Date of Grant
Eligible Cost Grant Amount Grant Offer Paid
$4,285,828 $1,854,440* 12/28/66 $1,854,440
additional $288,470 under the reimbursable provisions
Project No.
C-110020
•k
Eligible for an
of the FWPC Act.
Status: Construction Complete.
The project consisted of the construction of miscellaneous conduits and
raw sewage pumping facilities.
Construction of the Pump Station commenced in November 1967 and was comple-
ted in September 1970. Construction of the conduits began in July 1967
and was completed in January 1969.
Final inspection; of these facilities by EPA has been made. However, the
pumping units cannot be operated until the primary treatment facilities
being constructed under project C-110022, etc. (see below) are comple-
ted. The primary treatment facilities are to be complete by August 1,
1974.
2. Primary Treatment Facilities
Project No. Eligible Cost Grant Amount
Date of
Grant Offer
Grant
Payments
C-110022
C-240283
C-510351
$11,002,100
10,642,600
575,300
$6,051,150
10/27/70 $4,320,300
11/6/70 2,242,100
5/18/71 215,000
Eligible for $2,537,920 under reimbursable provisions of FWPC Act.
3,315,510
316,410
-12-
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Status: Under Construction.
The project consists of the construction of additional grit removal,
primary sedimentation and disinfection facilities. Major components
are twelve aerated grit chambers, twenty circular primary clarifiers,
chlorine contact tanks and miscellaneous appurtenances. The construc-
tion contract for the primary sedimentation basins and grit removal
facilities was awarded on May 6, 1971, and the work is nearly complete.
It is expected that these facilities will be operational by August 1,
1974. The construction contract for additional sludge dewatering facil-
ities was awarded on April 13, 1971, and the work is complete.
Plans and specifications for the chlorination facilities have not been
submitted to EPA for review.
3. Solids Handling Facilities
Project No.
C-110023
C-240296
C-510352
Eligible Cost
$23,555,100
22,785,300
1,231,600
Grant Amount
$12,955,300^
7,358,170
677,380
Date of
Grant Offer
5/20/71
5/20/71
5/20/71
Grant
Payments
$3,423,200
1,944,000
178,900
Eligible to receive $5,173,740 under reimbursable provisions of FWPC
Act.
Status: Under Construction.
Originally, the approved project consisted of the construction of eight
flotation thickening tanks, four sludge blending tanks, twenty vacuum
filters, six multiple hearth incinerators and miscellaneous appurte-
nances within the solids processing building. On that basis, grant sup-
port was awarded in May 1971 and the first construction contract, which
provided for the foundations of the solids processing building, was
signed in September 1971. The present status of the contract is that
the work is essentially complete. Another contract, which provides for
the solids processing building's superstructure, was awarded on September
20, 1972, and is presently approximately 85% complete.
On November 3, 1972, the scope of the project was increased to include
10 additional flotation thickening tanks, 10 additional vacuum filters,
and two additional multiple hearth incinerators at an estimated cost of
$11,618,000. These additional solids processing facilities were re-
quired as a consequence of the applicant's decision to adopt the bio-
chemical treatment process instead of two-stage lime precipitation pro-
cess. EPA approval of this increase in scope was expressly conditioned
on the satisfactory completion of the NEPA process begun by the draft
EIS and the applicant has been directed not to proceed with the incin-
erator unit contract until this Agency has completed its studies into
the feasibility of incineration and provided the applicant with written
notice to proceed.
-13-
i
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The applicant has advised this Agency that design of the incinerator
units is complete and that the plans and specifications for the con-
tract will be delivered to the Regional Office early in May. The in-
cinerator design will be reviewed with respect to its ability to satisfy
recently adopted emission requirements and in light of public health
issues surfaced during the NEPA review. The results of this review and
the subsequent Agency decision on the incinerator contract will be made
public in a "supplement" to this document.
4. Secondary Treatment Units
Project No. Eligible Cost Grant Amount
Date of
Grant Offer
Grant
Payments
C-110024
C-240299
C-510354
$18,569,900
17,963,100
971,000
$13,927,420
11,533,550*
728,250
Eligible to receive an additional $1,938,770.
9/28/71
10/7/71
10/7/71
$3,578,400
2,953,800
187,100
Status: Under Construction.
The project consists of the construction of two aeration basins, twelve
secondary sedimentation basins, additional aeration facilities, chemical
feed facilities and miscellaneous plant modifications and appurtenances
to increase secondary treatment capacity and to provide the initial step
in phosphorus removal.
The construction contract for initial chemical feed facilities was
awarded on February 29, 1972, and is complete. The contract which pro-
vides for alterations to the existing secondary treatment facilities is
approximately 97% complete. The contract which provides the additional
secondary treatment facilities is approximately 20% complete. A con-
tract award to provide for primary treatment flow metering facilities
was recently approved. A contract which provides instrumentation for
primary and secondary treatment facilities is in the design stage.
The various facilities described above will provide secondary treatment
and initial phosphorus removal and they are scheduled for completion by
January 1, 1976.
5. Excavation, Dredging, Dock and Substation Work
Project No. Eligible Cost Grant Amount
C-110026
C-240297
C-510353
$15,987,600
15,465,200
836,000
$8,793,180
8,505,860
459,800
Date of
Grant Offer
7/28/71
8/24/71
9/9/71
Grant
Payments
$6,095,900
5,415,600
257,500
Status: Under Construction.
-------
The approved project consists of dredging and construction of docking
facilities, mass excavation, and the construction and purchase of sub-
station facilities.
The dredging and dock construction contract for the amount of $4,376,175
was awarded on December 14, 1971, and is virtually complete. The excaw-
vation contract was awarded on February 14, 1972, and is essentially
100% complete. The substation work is underway and was reported to be
approximately 40% complete in late 1973.
6. Nitrification and Chlorination
Project No. Eligible Cost Grant Amount
C-110027
C-240309
C-510358
$47,151,200
45,610,400
2,465,400
$35,363,400
34,207,800
1,849,050
Date of
Grant Offer
6/28/73
6/29/73
6/29/73
Grant
Payments
-0-
-0-
-0-
Status: Under Construction.
The project consists of construction of 12 nitrification reactors, 28
nitrification sedimentation basins, the foundation of the multimedia
filter building (serves as chlorine contact tank), the secondary ef-
fluent conduit, chemical building, operations building, and landscaping.
Contract awards for the secondary effluent conduit and the chemical
building have been approved. Plans and specifications for the nitrifi-
cation sedimentation tanks and the multimedia filter foundation have
been reviewed and approved. The plans and specifications for the nitri-
fication reactors and the operations building are under review in the
Regional Office.
7. Denitrification and Filtration
Project No. Eligible Cost
C-110028
Md. No.-not assigned
Va. No.-not assigned
$47,109,300
45,086,100
2,437,100
Anticipated
Grant Amount
$35,331,970
33,814,570
1,827,820
Date of
Grant Offer
not made
not made
not made
Status: C-110028 is under review in the Regional Office.
The project consists of the construction of thirty-six multimedia fil-
ters, eight denitrification reactors, four nitrogen release tanks,
twenty-two denitrification sedimentation basins, AWT instrumentation,
additions to the main pumping station and some additional minor work.
Those facilities arc the final major treatment units in the system and
are scheduled for completion prior to January 1, 1978.
8. Miscellaneous Cleanup
A final project may be provided to cover cleanup operations and
-15-
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TABLE 1
PROJECTED RESIDUAL
POLLUTANTS FROM
DCWPC PLANT AFTER VARIOUS STEPS
IN THE PROCESS
(From EPA-D. C.
. Pilot Plant Results for Period July
1972-December 1972)
CHARACTERISTICS
SECONDARY
SEDIMENTATION
mg/1
NITRIFICATION
SEDIMENTATION
mg/1
DENITRIFICATION
SEDIMENTATION
mg/1
FINAL
EFFLUENT
mg/1
TOTAL LOADING
TO POTOMAC AT
309 mgd
lbs
STANDARD*
lbs
BOD, 5 Day
20
12.8
9.0
2.65
6,829
12,700
Phosphorus, Total
1.5
0.8
0.5
0.18
1+63
560
Nitrogen, Org
2:1
0.6
1.4
0. 74
1,906
—
nh3
13.4
0.9
0.4
0.36
927
—
N02 + N03
0.1
12.0
0.4
0.30
772
—
Total Nitrogen
16.2
13.5
2.2
1.40
3,605
6,130
**
Suspended Solids
20
15
15
3
7,730
18,100
PH
6.9 to 7.2
6-0 to 9.0
•k
Fecal Coliform
200/100 ml.
(30 day aver.)
200/100 ml.
(30 day aver.
NPDES Permit Requirements (See Appendix b).
Predicted results for these parameters are not taken from pilot plant data.
-------
other minor facilities not included in previous projects. If
necessary, its maximum eligible cost may approach $30,555,700 with
an EPA grant of up to $22,916,770.
The expanded facilities when completed are expected to reduce the
pollutants in the wastewater to the residuals listed in Table 1.
Upon completion of expansion, the annual operation and maintenance
costs are expected to approximate $24,046,000. Of this amount,
$9,409,000 may be attributed to primary and secondary treatment
and the remaining $14,637,000_to AWT facilities. These figures
include the cost of sludge handling and disposal. Approximately
500 employees will be required to properly operate and maintain
the facilities.
The existing facilities are operated by a staff of approximately
250 people. The average operation and maintenance cost for two
recent years was approximately $4.5 million.
When the expanded facilities are fully operational, approximately
431 tons of sludge per day are expected to be generated. The ton-
nage mentioned is on a dry weight solids basis. Annual operation
and maintenance costs for handling the sludge are expected to total
$7,652,000 of which just under half ($3,737,000) is attributable to
incineration costs.
During the plant's operational phase the following daily quantities
of chemicals are expected to be used in the processes:
Phosphorus removal - Either 290 tons of alum or 145 tons of ferric
chloride or a combination utilizing both of these chemicals.
Nitrogen removal - Approximately 86 tons of methanol, 58 tons of
lime and 1.3 tons of polymer.
Disinfection and odor control - Approximately 30 tons of chlorine.
Interim Treatment - As required by Section 10 of the Memorandum of
Understanding and the October 18, 1971, agreement with Fairfax
County and WSSC (Appendix G of draft EIS), the District has provided
interim treatment facilities which have reduced the BOD discharged
to the Potomac to below 100,000 lbs per day during certain recent
periods. Facilities to provide metal salt (alum or ferric chloride)
addition to the existing secondary treatment units are operational.
Some of the sludge produced during the construction period is being
disposed of by the Maryland Environmental Services at the Agricul-
tural Research Center at Beltsville, Maryland, where it is being
used in a research project to determine feasibility of sludge dis-
posal by the composting method.
-16-
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The District has contracted with a commercial firm to dry sludge
on site for sale as a fertilizer. This operation is about to
start up and has the potential, if successful, to alleviate the
sludge disposal problems experienced at Blue Plains.
Finally, some of the process sludge is also being used to develop
the agricultural potential of farmlands at various locations in
Prince George's and Montgomery Counties, Maryland.
For more information on the subject of sludge disposal alternatives,
please see the "Preface to the Final Statement" which is presented
on the pages following the Table of Contents.
-17-
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Other Projects Affected "by the Plant Expansion and Upgrading
A. C-110012; POTOMAC FORCE MAIN from the Potomac Pimping Station
at Theodore Roosevelt Bridge to Boiling AFB. The total eligible cost
is $5,593,700 and the approved grant $600,000. Construction is complete
and the facilities are operational . This is the last section necessary
for full operation of the Potomac Pumping Station.
B. C-110018; UPPER POTOMAC INTERCEPTOR RELIEF SEWER (UPIR) between
Foundry Branch and 31st Street in Georgetown. This is a continuation of
the Potomac Interceptor which serves portions of Fairfax and Loudoun
Counties, Virginia and Montgomery County, Maryland. Grants totaling $760,700
were initially approved on October 27, 1965 for a project having a current
estimated eligible cost of $3,086,000. Construction contracts have been
awarded on all sections of this project and the District recently reported
that- all the work is complete. Completion of this project resulted in
closing of the "Georgetown Gap".
C. C-110019; POTOMAC OUTFALL SEWER from Boiling AFB to the Blue
Plains site. The current grant of $758,7^0 was initially approved December 23,
1965, for a project having a current estimated eligible cost of $3,19*+,239.
The project appears to qualify for a supplemental grant of $838,380 under
the reimbursable provisions of PL-92-500. Construction is complete but
the facilities will not be operated until the primary treatment units pro-
vided for under C-110022 are completed. The primary treatment units should
be complete by August 1, 197^ •
D. C-110025; PORTLAND STREET OUTFALL RELIEF SEWER between the Poplar
Point Pump Station and the Potomac Outfall Relief Sewer. The grant offer
of $2,506,020 was approved May 3, 1971, based on the District's share of
the estimated eligible project cost of $1+,556 ,*+00. This grant offer was
subsequently withdrawn with the understanding that the project will be funded
with FY '75 funds.
E. C-2U0219; WSSC (INDIAN CREEK, PAINT BRANCH AND LITTLE PAINT BRANCH)
The project consists of approximately 39,285 lineal feet of intercepting
sewer.
Status: Under construction - approximately 80$ complete
F. C-21+0209; WSSC (ROCK CREEK - R0CKVILLE INTERCEPTOR)
The project consists of approximately l+,700 lineal feet of intercepting
sewer to serve the northeast section of Rockville. The project will allow
the abandonment of existing inadequate facilities which are presently
connected to the Cabin John System.
Initial Population
Design Population (year 2000)
Eligible Project Cost
Grant Amount
Date of Grant Offer
1+ ,360
U7,200
$1,099,000
$ 1+1*+,610
February 10, 1969
-18-
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DAMASCUS
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MARYLAND
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-------
Initial Population 6,250
Design Population 19,TOO
Eligible Project Cost $201,500
Grant Amount $ 20,800
Date of Grant Offer April 12, 1968
Status: Project is complete but final inspection has not been conducted.
G. C-5102U0; HERNDON, VIRGINIA
Interceptor sewers along Sugarland Run and Folly Lick Branch, which connect
to the Fairfax County system and thence to the Potomac Interceptor sewer.
Initial Population 5>000
Design Population (year 2000) 30,000
Eligible Project Cost $781,1+00
Grant Amount ^$257,850
Date of Grant Offer July , 1967
Status: Project is complete but final inpsection has not been conducted.
Grant Applications
In the draft Environmental Impact Statement, four grant applications
were described at this point. They were numbered as shown below.
1. WPC-Md-239 WSSC - Holly Springs
2. WPC-Md-2U0 WSSC - Northeast Branch and Sligo Creek Relief
sewers
3. WPC-Md-276 WSSC - Cabin John Creek
. WPC-Md-2l+9 Rockville
Each of these grant applications has been returned to the Maryland
Department of Health and Mental Hygiene since the projects were not
entered on the Maryland priority list.
One further Change in the situation with respect to grant applications
is that the Regional Office recently received and has begun reviewing an
application for the first section of the Anacostia Forcemain project. Ad-
dition information 6n that project is shown below.
A. C-2U0231-01 WSSC - Anacostia Forcemain
The project consists of the construction of approximately 21,000 l.f. of
108" dia. pressure sewer from the vicinity of Peace Cross along the East
Side on the Anacostia River to a point South of the Pennsylvania Railroad
Bridge over the Anacostia. The project is the first of a series of projects
that will result in Anacostia Basin sewage flows being conveyed to Piscataway
for treatment.
Initial population to be served 550,000
Design population 1,600,000
Estimated eligible project cost .s$10U85-,000
Estimated eligible (Jrant Amount $ 7,863,750
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III. ENVIRONMENTAL IMPACT OF THE PROPOSED ACTION
A. Water Resources & Water Quality
The Potomac Estuary is saline in the lower reach, brackish
in the middle reach, and fresh in the upper reach near Washington.
Variations in salinity and nutrient enrichment from wastewater discharges
have a pronounced effect on the biota of the estuary. Historical plant
life successions in the upper Potomac Estuary can be inferred from
several studies as noted in the Water Resource - Water Supply Study of
the Potomac Estuary. Of considerable significance is documentation in-
dicating that in 1952, vegetation in the reaches near the Washington
Metropolitan Area was virtually non-existent. In 1958 rooted aquatic
plants and blooms of the blue-green algae were reported in the upper
Potomac Estuary. Massive blue-green algal blooms, which are associated
with large phosphorus and nitrogen loading increases, have persisted since
the early 196o's. This problem is primarily attributable, on a proportional
basis, to present inadequately-treated sanitary discharges from Blue Plains
and other treatment plants in the area.
Biological observations during previous years indicate a succession
of more-dominant aquatic species as nutrient discharges increase. During
the summer season large populations of blue-green algae are prevalent in
the freshwater portion of the Estuary. The blue-green algae are not
readily used by the higher trophic forms and are often considered to be
a "dead end" of the normal food chain. As the algae respire, an additional
demand is placed on the dissolved oxygen in the Estuary, thus reducing the
assimilative capacity of the Estuary during critical flow and temperature
periods.
Mathematical model simulation of the dissolved oxygen budget for
the carbonaceous, nitrogenous, benthic, and algal oxygen demands indicate
that the nitrogenous demand is the greatest single cause of dissolved
oxygen deficit in the critical reach which includes the major wastewater
discharges and that algal growths exert the greatest demand on dissolved
oxygen from Piscataway to Indian Head, Maryland. The nutrient enrichment
and resultant eutrophication is primarily due to treatment plant discharges
supplemented to some extent by loading attributable to non point sources.
The most practical control measure is to reduce the level of nutrients dis-
charged from the concentrated point sources. Control of algal standing
crops will thus control the dissolved oxygen resources in the Estuary
for assimilation of the feasible minimum treated waste discharges. It will
also restrict the nuisance aquatic growths which create objectionable odors
and aesthetic problems in the Upper Estuary.
The upper reach of the Potomac Estuary received an approximate
average of 365-9 mgd of domestic wastewater during December, 1973. It is
estimated that the flow will increase to approximately 1+73 mgd by 1980.
The Blue Plains plant was receiving almost 80 percent of the
total domestic wastewater flow in the Upper Estuary and by 1980, is projected
to receive approximately 65 percent of the wastewater flow.
-20-
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It is the opinion of this Agency that advanced wastewater treatment
at Blue Plains will be essential in the enhancement of Potomac River
water quality by reducing BOD^'a'» nitrogea* , and phosphorous loadings
in the effluent from the Blue Plains plant in the future.
Completion of the current expansion and upgrading of the Blue
Plains facility will actually reduce the BOD^, nitrogen, and phosophorus
from approximately 1^5,500 lbs/day, 1*7,500 lbs/day5 and 17,200 lbs/day^'
to less than 12,700 lbs/day, 6,130 lbs/day, and 560 lbs/day, respectively,
as directed by the Potomac Enforcement Conference for the District of
Columbia. (Please see draft NPDES permit in Appendix b of this text for
a description of the scheduling and staging of this reduction in pollutant
discharge.) This reduction will enhance the dissolved oxygen content
in the Estuary by removing carbonaceous and nitrogenous oxygen demand and
reducing nuisance algal growth drastically,reducing the ambient nutrient
content. Thus, the project will have a beneficial impact on the aquatic
environment.of the Potomac Estuary.
The Potomac River is the major sources of water for the Washington
Metropolitan Area. A review of the projected water supply requirements
by the Metropolitan Washington Council of Governments and the U.S. Army
Corps? of Engineers indicates that total water supply needs may not be
available from the freshwater portion of the Potomac. The Corps has
proposed a combination of multipurpose reservoirs in the Potomac Basin;
however, it should not be assumed that all of the considered reservoirs
will be constructed.
Use of the Estuary for water supply is not a categorical question -
certain assumptions and judgments must be made. The Water Resource -
Water Supply Study of the Potomac Estuary, aided by data from a previous
study (which investigated the use of the Estuary as a water supply source,
primarily from the chloride intrusion aspect) concluded that the Estuary
was feasible as a water supply source. It was determined that discharge
of wastewater out of the Basin would considerably reduce the water supply
potential of the Estuary. The number of days that the Estuary could be
used for water supply depends on freshwater inflow and location of waste-
(a) BOD,- is defined as the quantity of oxygen utilized in the biochemical
oxidation of organic matter for five days and at a temperature of 20°C.,
expressed in parts per million (ppm), milligrams per liter (mg/l) or
pounds per day.
(b) Average for July-December, 1971
-21-
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water discharges, and diversion of wastewater to other basins or to land,
if spray irrigation disposal alternatives are found environmentally and
economically feasible in future years.
In May 1970, Maryland's Secretary of Health and Mental Hygiene
placed amoratorium on sewer connections in portions.of Prince George's
and Montgomery Counties. This has essentially halted new connections in
the sections of Anacostia and Cabin John Creek Watersheds which transport
wastewater to the Blue Plains sewage treatment facility.
This action creates artificially higher prices for residential
development land because of the decreased supply of approved connection
sites. Thus, housing becomes more expensive in one area and development
increase in areas not necessarily planned for immediate growth. Patterns
of growth are thus dictated by moratorium rather than by logical planning
sequence.
Completion of the Blue Plains wastewater treatment facility
will not automatically allow the moratoria to be lifted, however, it is
the first step in the direction. The alternate regional facilities
currently planned for Montgomery County, Maryland and Piscataway in Prince
George's County will be needed before the region's wastewater treatment
problems are over.
At this point the draft statement discussed the location of the
outfall conduit from the Blue Plains facility. Please see "Response to
Comments of Charles H. Conrad" in Appendix a of this document for the present
thinking with respect to the outfall conduit location.
Fuel oil will be brought to the plant by barge for use in the
sludge incinerators as well as in other heating units. Approximately
45,000 gpd will be required for incineration. The District has indicated
it plans to pump the oil to :Dn-site storage tanks. As in any installation
where oil is transferred, a possibility of spillage exists. The District
will be required to construct such facilities and to operate them in such
a manner so as to minimize this possibility. "The U. S. Coast Guard has
prepared regulations concerning preventioniof pollution at oil transfer
facilities. These regulations will be applied to the Blue Plains operation.
Should the barges be used for storage and oil transferred continuously from
them directly to the combustion units, the possibility of a barge breaking
loose from its moorings during a storm is increased. The possibility of
a line developing a leak during a period when the barge would be unmanned
would also exist. Should this alternate be selected, construction of a
completely enclosed slip should be required to prevent any oil which may
spill during the operation from reaching the River. Before final EPA
approval of the oil handling facilities is given the District will be
required to prepare and to submit an adequate spill prevention counter-
measure and control plan. For additional discussion of the oil transfer-
ring operation, please see "response to comments of Capt. S. A. Wallace,
U. S. Coast Guard in Appendix a.
-22-
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Chlorination of the plant effluent is "being provided for dis-
infection. The District has been chlorinating the effluent since 1955
and has observed no adverse impacts on the biota of the river.
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B. Effects of Plant Operation on Air Resources
Incinerator mass emissions (typically measured in tons per year) of
the major pollutants; oxides of nitrogen, particulates, and sulfur
dioxide show potential increases of each to be less than \ of one
percent of the current District of Columbia air pollution burden
for these pollutants. For the entire metropolitan area, the per-
centage increase will be reduced to approximately 1/10 of one per-
cent. Emissions of carbon monoxide and organic compounds will be
essentially zero. Trace amounts of toxic mercury and lead com-
pounds may also be added to the atmosphere with a negligible effect
on ambient air quality. Please see the response to the comments of
the National Resources Defense Council, Inc. in Appendix a for a
report on the public health aspects of furnace emissions and the
preface to this statement for a discussion of alternatives to
incineration.
The predicted effect of the emissions of oxides of nitrogen, partic-
ulates, and sulfur dioxide show that no meaningful degradation of air
quality will occur in the immediate vicinity, the city, or the metro-
politan area. Under unusual meteorological conditions, the quality
of ambient air may be degraded by small amounts to a level not ex-
ceeding 12^7° of national air quality standards - such degradation will
be restricted to local points generally within the confines of the
facility or in nearby non-residential areas east of the Potomac River.
The potential degradation at other locations rapidly falls off from
the predicted maximum sites. See June 1972 Statement of John S.
Winder, Metropolitan Washington Coalition for Clean Air, Inc. in Ap-
pendix a. Thus, from the viewpoint of both pollutant emissions and
air quality, the incinerator is expected to have a negligible adverse
impact. A detailed evaluation of the incinerator is presented in
Appendix C of the draft statement.
Odors from the existing plant have been a problem in the area for many
years. The adjacent Naval Research Laboratory has complained that
odors become intense and produce nausea. There is also claim that
structural finishes are damaged by the fumes. Complaints have also
been received from persons utilizing the Anacostia Freeway. See (1)
July 11, 1972, letter from Naval Research Laboratory, and (2) July 10,
.19.72,. memo from USDA Forest Service. Both found in Appendix a.
Portions of the wastewater received at the plant are conveyed as far
as 40 miles and may remain in the system as long as 30 hours. Conse-
quently, under warm weather conditions the sewage frequently becomes
septic before it reaches the plant. In passing through the treatment
processes hydrogen sulfide and other odorous gases may be released at
points where the wastewater is agitated.
Odors originate from the raw wastewater pumping station wet well, the
grit chambers, the primary settling basins and the aeration tanks as
-24-
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well as the sludge processing facilities, particularly the thick-
ening, elutriation, and vacuum filtration unit processes.
Since March 1969 the incoming sewage has been continuously pre-
chlorinated to reduce odors. Under the proposed expansion and
upgrading, facilities to control odors are included.
Prechlorination at the raw sewage pump station wet well and at
the influent to the primary clarifiers will be provided. Chlorine
prevents the release of hydrogen sulfide gas from the wastewater.
Capacity is being increased to provide a maximum dosage of 15 mg/1
at the design flow.
Exhaust gases from the raw sewage pump stations and the aerated
grit chambers will be deordorized by ozone treatment before ;_:being
discharged into the atmosphere.
The primary sedimentation tanks have been designed so as to allow
continuous sludge withdrawal which will alleviate odors caused by
sludge standing on the bottom of the tanks for a period of time.
The tanks may be covered in the future if this becomes necessary.
The exhaust gases would be treated by ozonation.
The gravity sludge thickeners, which will remain in use have been
covered. The flotation thickeners, sludge blending tanks, vacuum
filters and multiple hearth incinerators will all be housed in the
Solids Processing Building. The ventilation in this building is
arranged in such a way as to utilize the exhaust air and vacuum
pump discharges for incinerator combustion air. Any odors will be
destroyed in the incineration process itself or in the fume furnace
through which all exhaust gases are passed.
Upon completion of the proposed expansion, the incinerated ash will
be hauled directly from the solids handling building to an approved
landfill site for disposal. (See July 12, 1972, letter from Na-
tional Capital Planning Commission Appendix a).
Some concern exists as to the effects of organisms in the wastes
which may be discharged to the air by the activated sludge process.
However, conclusion number 3 on the following page suggests that
this concern is unwarranted.
Studies were conducted at the University of Cincinnati in 1968 on
"The Emission, Identification, and Fate of Bacteria, Airborne from
Activated Sludge and Extended Aeration Sewage Treatment Plants."
The largest plant used in the studies was 12 mgd. Pertinent con-
clusions reached in the report were:
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1. Under the worst conditions, contamination of the air in the
vicinity of the waste treatment plants extended 100 - 200
feet downwind of the aerators. These distances and beyond
should provide a safety factor. The minimum distance from
proposed aeration basins to the plant property line at Blue
Plains is approximately 150 feet along the Anacostia Freeway.
2. Approximately 300 total bacteria per cu. m. airborne at 50
feet downwind would result in an inhalation rate of 2 bac-
teria per minute. This was not considered to be a signifi-
cant hazard.
3. There is no epidemiological evidence to indicate the danger
to public health from sewage treatment plant aerosols.
4. The predominant genera in these aerosols were Klebsiella,
Escherichia and Aerobacter. Klebsiella are frequently impli-
cated in respiratory infections.
5. Important factors associated with the recovery of bacteria
at increased distances from the emitting source include wind
velocity and other climatic factors, the quality of the
sewage and the particle size.
The above study was limited to bacteria in its scope. We are un-
aware of any serious illnesses to STP operating personnel at Blue
Plains caused by or attributed to their day-to-day activities in
treating sewage.
Since no conclusive evidence has been presented concerning their
effects, it is felt that further research bust be conducted con-
cerning the public health effects of airborne pathogens from STPs.
Incinerator destruction of all pathogens in the sludge is assured
by the high temperatures and sludge residence time in the incinera-
tor. The combustion temperatures and durations to which the gas
stream is exposed both in the incinerator and afterburner provide
further assurance of pathogen destruction. Thus, neither the gaseous
effluent into the ambient air, nor the residue ash which is to be
disposed of in a sanitary landfill, offer a potential source of
any magnitude for contamination from living organisms.
C. Other Project-Related Environmental Effects
The primary source of noise in a plant of this type is the blowers
which supply air to the aeration basins. In the existing blower
building the blower room is insulated from the rest of the build-
ing to protect the employees. The sounds are also insulated from
the outside to reduce their levels to less than objectionable.
The additional blowers needed for the expanded facility will also
be insulated.
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A second source of noise at the plant is in the sludge handling
facilities. These facilities will all be housed in one building
and are being designed to reduce noise levels to within a safe
and comfortable range for operating personnel.
It is anticipated that the impact of noise from the plant during
operation will be negligible outside the plant property. Within
the various buildings precautions will be taken to reduce noise
to satisfactory levels. (See July 12, 1972, letter from National
Capital Planning Commission in Appendix a).
The visual impact of the plant from both the River and the Ana-
costia Freeway will be minor since most of the treatment units
are low profile tank structures. The one major building which
will be highly visible is the solids processing building which is
approximately 600 by 280 feet. A 300 foot section of the building
which houses the incinerator equipment will be 91 feet high with
4 stacks having heights of 114 feet above ground.
The building will be architecturally simple in design and in har-
mony with new architectural designs for this type of building in
the Washington area. The basic concrete facing panels encompass
the whole in clean, horizontal lines, and interrupted by the in-
troduction of vertical ribs in the entrance way, thereby elimina-
ting monotony. The entrance way and the vertical ribs will protect
shadows which will be continuously changing with the sun.
The building is located far enough from the waterline to be pro-
perly landscaped with grass, shrubbery and trees to blend with the
park strip along the Potomac River proposed by the National Capitol
Planning Commission. The District is cooperating with the Commis-
sion in their recommendations for the strip as well as other aesthe-
tic considerations.
The incinerator gases will be treated so as to make them invisible
when emitted from the stacks.
The project is not expected to have much impact in land use in the
Metropolitan Area since immediately upon completion the facilities
will be operated at nearly their design capacity. The development
of the service area is considered to be mature rather than devel-
oping. (See U. S. Department of the Interior letter of August 7,
1972, in Appendix a).
D. Short-Term Effects During Construction
It is anticipated that some siltation will occur during construc-
tion of the facilities. This is unavoidable but is and will con-
tinue to be minimized by construction procedures. (Appendices J
and K in draft statement).
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The various contractors are required to promptly provide temporary
measures to prevent erosion such as the construction of temporary
berms, dikes, dams,slope drains, and use of temporary mulches,
mats, seeding or other control devices. See Section 1-B of the
District of Columbia construction specifications, included in Ap-
pendix J of the draft statement. (See August 7, 1972, letter from
U. S. Department of the Interior in Appendix a).
A description of the proposed concrete batch plant was found in the
draft EIS at this point. The description has been dropped since
the on-site batch plant will not be utilized.
The treatment plant is expected to meet its present or a higher ef-
ficiency during the construction of the new facilities. Under a
current contract, facilities to provide alum or ferric chloride
feed to the existing aeration basins have been constructed. These
facilities are in operation and they have managed to present the
decrease in efficiency that may be expected as individual units are
taken out of service for modification.
EPA guidelines for Design, Operation and Maintenance of Waste Water
Treatment Facilities require that the existing plant maintain the
same degree of treatment during construction of new facilities, if
this is not feasible, a minimum of primary treatment and disinfec-
tion must be provided at all times. Bypassing of raw sewage during
the construction of the additions is not allowed unless it is abso-
lutely necessary such as inadequate treatment capacity in which case
it must be kept to an absolute minimum and receive prior approval
from EPA.
During construction of the new power substation and modification of
the existing substation, it may be necessary to shut down some of
the existing electrical facilities in order to connect new work to
them. The contractor will be required to minimize the number and
duration of shut downs, or outages. He will also be required to
work three shifts of eight hours each to minimize the duration of
any outages.
Some dust may be expected to result from construction activities.
However, since most construction will be below grade where the soil
is moist (continuous dewatering will be required), this is not ex-
pected to be a significant problem. The main access road around the
the plant site is paved and will reduce dust generation caused by
traffic movements. The contractors are required to provide and main-
tain temporary measures to control dust during construction. (See
Appendix J in draft statement).
Some minor siltation may have occurred during dredging operations.
It was caused by the disturbance of river bottom materials as they
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werelifted into scows and again as it was released by scows in the
Dyke Marsh restoration area. Siltation was minimized by use of a
clamshell bucket in lieu of hydraulic dredging which mixes the
spoil into a slurry and then returns the water solvent to the River.
The bottom dump scows drop the spoil in one or several large masses
which rapidly sink to the bottom with little breakup as would occur
if the spoils were removed by clamshell bucket or by hydraulic means.
EPA monitored the dredging operations continuously. Samples were
taken approximately once per week and tests have shown no adverse
effect on water quality from the operation. Also, no changes in
Benthic biota, attributable to spoil disposal, were observed. The
dredging operation is presently complete.
The dredged spoils were utilized at the Dyke Marsh area as part of
the National Park Service project to restore portions of the marsh
which were previously destroyed by commercial dredging for sand and
gravel. NPS plans to recreate a marsh environment. (Appendix A of
draft statement).
Heavy metals contained in the bottom sediments at Blue Plains were
not in soluble form and would not be expected to migrate and cause
environmental damage. The metals were generally more concentrated
at the surface than at deeper locations. Since some mixing of
dredged materials taken from various depths will occur, the metals
will be somewhat uniformly distributed in placement.
The dredged material will be placed in 20 to 40 feet deep holes at
the disposal site to fill them to a level approximately 8 feet below
the water surface. Clean landfill will be trucked into the site and
used' ta>complete the restoration. Any heavy metals in the dredged
spoils will be trapped under the fill and should they migrate to the
surface through saturated material, they will be sufficiently di-
luted so as to not be harmful.
During construction operations local noise levels are anticipated to
be higher than normal. Most of the construction will take place
below ground level and this will have a buffering effect on noise
levels beyond the site. Since the surrounding area is not residen-
tial in nature, night construction should not be particularly intru-
sive.
Some degree of general inconvenience will be experienced by the sur-
rounding area during the construction period. This impact cannot be
completely avoided but mitigative measures will be employed as dis-
cussed in various sections of this report.
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IV. ADVERSE IMPACTS WHICH CANNOT BE AVOIDED SHOULD THE PROPOSAL BE
IMPLEMENTED
During the construction and useful life of the project certain adverse
environmental effects are associated with the plant but are expected to be
minimized, insignificant, or temporary.
Dredging of the navigation channel from the main channel in the Potomac
to dockside was completed by use of clamshell bucket and scow in lieu of
more efficient and economical hydraulic techniques. Since extensive distur-
bance and high turbidities are associated with hydraulic dredging, the clam-
shell method was selected for this operation. Adverse consequences from
this project feature were minimal. These findings are documented in Appendix
A of the draft statement.
The negative effects of disposal of spoil material downstream in Dyke
Marsh was minimal and of a short-term nature. Use of bottom-dump scows re-
duced the dispersion characteristics of the dredgings. Since this operation
is integral to the National Park Service Restoration Plan, disposition of
this material at the designated site is considered to be a long-term intan-
gible benefit.
As presently planned, incineration of undigested sludge from future AWT
facilities may occur at adjacent multiple hearth furnaces. Although this
action will eliminate offensive odors and aesthetic impacts, an additional
burden will be placed on ambient air quality. As clearly demonstrated in
the previous section of this report and Appendix C of the draft statement,
the incinerators will be designed utilizing contemporary abatement techniques
and sophisticated equipment. The air quality impact of the incineration
features for the D. C. plant is expected to be negligible although it must be
conceded that these emissions are additive to the existing regional loadings.
The preface to this statement describes the alternatives to incineration that
are presently being evaluated.
The plant's aesthetic impact on the Potomac estuary has also been mini-
mized by incorporating certain architectural concepts into the design of the
structures (See rendering at the beginning of this report). Noise generated
from plant operation will be confined to the facilities and should not affect
nearby activities to any significant degree.
Short-term effects associated with construction activities and plant
operation are and will be minimized to the greatest extent possible by rigid
controls and a well-planned construction timetable. These impacts have been
considered in detail in the previous section. Also, planned measures to
mitigate these effects have been presented.
The action under consideration is not envisioned to jeopardize or con-
flict with the goals set forth in Section 101(b) of the National Environ-
mental Policy Act of 1969.
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V. ALTERNATIVES TO THE PROPOSED ACTIONS
At this point the draft statement went into considerable detail de-
scribing the various alternativen that had been conoiderod for the project.
Since very little comment was received on this section, pages 52 through 111
have been replaced by a chart which summarizes the tradeoffs associated
with each of the alternatives that was considered for the project. The
material which was previously presented at this point will now be found
in Appendix c.
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SUMMARY OF ALTERNATIVES
Description of
Alternative
Summary of Major
Adverse Effects
Summary of Major
Von It. ive Effects
No Action
B. Retain plant capacity
at 2l*0mgd and up-
grade to AWT.
Serious unacceptable
degradation of water
quality in the Potomac
Estuary would continue
to occur.
Since current flows
exceed 2U0mgd by a
significant amount
and since no relief
capacity is available,
a lengthly battle over
capacity rights would
probably ensue and
water quality would
remain poor until the
issue was resolved and
relief capacity was
constructed.
Temporary disruption
attributable to construct-
ion operations would not
occur.
Water quality would im-
prove with respect to
present conditions but
not to the degree called
for by the Potomac River
enforcement conference
since flows in excess of
2U0mgd would not receive
satisfactory treatment.
309 mgd AWT
1« Independent
physical-chemical
treatment, (two-
stage lime treat-
ment, filtration
ion exchange, car-
bon absorption)
2.Biological treat-
ment
a> Conventional
tertiary treatment v
system convention-
al primary-second-
ary treatment fol-
lowed by two stage
lime (or mineral
addition) filtration
and either ion ex-
change or breakpoint
chlorination for
nitrogen removal.
System is incompatible
with existing facili-
ties.
Two separate solids pro-
cessing systems are re-
quired if lime treatment
is utilized, Some sub-
alternatives unable to
consistently meet dis-
charge requirements.
Some subalternatives
would involve multilevel
construction.
System consistently pro-
duces high quality ef-
fluent since it is not
upset by occasional
"slugs" of toxic materials
in the influent wastewater.
Minimal amount of land is
required for this alter-
native.
Existing facilities become
integral part of system.
-32-
-------
b .Bio-Chemical treat-
ment System conven-
tional primary,
secondary treatment,
"biological nitrifi-
cation-denitrifica-
tion, filtration.
Limited amount of multi-
level construction re-
required.
System is susceptable to
upsets caused by slugs of
toxic material in in-
coming wastewaters.
South Tahoe Design
conventional primary,
secondary treatment
followed "by single
stage lime and
ammonia stripping,
filtration, carbon
adsorption.
Multiple furnace systems
are required for sludge
disposal.
Operational problems
encountered with strip-
ping towers.
Pilot scale results
suggest system unable
to meet discharge stan-
dards .
Existing facilities be-
come integral part of
system.
Only one type of sludge
disposal system is re-
quired.
Pilot scale plant results
indicate this system can
consistently meet dis-
charge requirements.
Spray Irrigation
(Muskegon Plan)
Conventional se-
condary effluent
sprayed over land.
Estimates indicate that
approximately 127 square
miles of land would be
required to treat 309
mgd. (Or an area twice
the size of the District
of Columbia.)
-Natural recycling of
organics, Nutrients,
and trace elements would
occur.
-Existing secondary
facilities would remain
in use.
-Eliminate incinerator
emissions.
-33-
-------
SUMMARY OF SUBALTERN ATIVES FOR SLUDGE DISPOSAL
Description of
Subalternative
Ocean Disposal
Land Disposal
Summary of Major
Adverse Effects
Environmentally unsound
and unlikely to win
regulatory agency
approval.
Generally requires
digestion—A process
which returns large
amounts of nutrients
to treatment process
and thereby inhibits
the attainment of ef-
fluent discharge stan-
dards for nutrients.
Summary of Major
Positive Effects
Possible fertilization of
marine environment at
dumping site.
Digester gas produced
would contain approxi-
mately 70% Methane
(Natural Gas) which could
be used as fuel.
Incineration
Emissions contribute
to degradation of air
quality.
minimal amount of re-
sidual material remains
for disposal.
Note: Please see the Preface to this statement for an expansion on the
topic of sludge disposal.
-34-
-------
SUMMARY OF ALTERNATIVE TRANSPORTATION MODES
Description of
Alternative
Highway-
Railway
"Waterway"
Summary of Major
Adverse Effects
-Additional traffic
will compound exist-
ing traffic problems.
-Probability of ac-
cident occuring is
highest of any mode.
-Low payload per de-
livery ratio.
-No grade separation
at Suitland Parkway
crossing
-Delivery could be
delayed due to low
water, severe floods,
etc.
Summary of Major
Positive Effects
-Minimal coordination
is necessary to arrange
delivery.
-Ability to deliver large
tonnage in a single de-
livery.
-Ability to deliver large
tonnage in a single de-
livery.
-35-
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VI. RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT
AND THE MAINTNEANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY
Upgrading and expansion of the secondary wastewater treatment facilities
to tertiary (AWT) is a significant step toward enhancing water quality of
the Potomac Estuary, which is one of the primary functions of the proposed
action. Once other sewage treatment plants along the Potomac upgrade the
quality of their effluent, future generations will reap the long-range
benefits of these improvements. Blue Plains AWT should not "be regarded
as an individual project, but rather as one vital link in the future
wastewater management plan for the Potomac Basin. To accrue the projected
environmental benefits of this 309 mgd facility, other area mimicipalities
must cumulatively follow suit or explore and utilize other alternative •
means of wastewater treatment than that which presently exists.
Selection of the proposed features for Blue Plains in no way precludes
other future treatment options for facilities riparian to the Potomac River.
Although it may be the opinion of some that tertiary wastewater treat-
ment and disposal of sludge by incineration only accomplishes a change from
one pollution form to another, the environmental benefits of significantly
improving Potomac River water when weighed in perspective against the en-
vironmental costs of a negligible effect on ambient air quality appears
to| easily justify this undertaking. It should also be reiterated here
that several Federal agencies, including EPA, are undertaking intensive
research investigations to determine the environmental and economic feasibility
of utilizing agricultural lands for the disposal of undigested sludge. If
these techniques prove to be viable, and do not pose an imminent danger to
the health, and welfare of the locale, disposal by incineration may be
utilized in future years as an alternative or backup method to land disposal.
However, the dire necessity to immediately upgrade and expand the
existing facilities is obvious and has been well documented throughout this
report. To postpone design and construction of this plant while waiting
for land disposal alternatives to become available is entirely unrealistic,
especially since a timeframe cannot be provided.
Since disposal of spoil materials at Dyke Marsh is complementing the
National Park Service's Restoration Plan, this action is considered to
enhance the state of the environment for future generations.
-36-
-------
VII. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES WHICH
WOULD BE INVOLVED IN THE PROPOSED ACTION SHOULD IT BE IMPLEMENTED
The planned steps to upgrade and expand existing facilities at
Blue Plains can be viewed as an irreversible resource commitment since
abandonment of this plant in future years appears to be unlikely. However,
it should also be noted that the existing site was devoted to this use
years ago when the original plant structures were installed.
If a major accidental spill occurs at the docking facilities during oil
transfer or other unloading operations,this could result in irreversible
damage to the Potomac Estuary. This impact has been recognized in Section
III of the report and implementation of the proposed Coast Guard pollution
prevention regulations (Appendix L of the draft statement)will further re-
duce the probability of this occurrence.
As asserted in the environmental impact section of this report and
documented in Appendix C of the draft statement, the project's effects on
ambient air quality has been evaluated as being insignificant. Therefore,
the air resources of the region are not considered to be irreversibly or
irretrievably affected should the expansion and upgrading program at Blue
Plains be undertaken.
The project's induced effects on land use changes and future develop-
ment in the Washington Metropolitan Area is expected to be minor since the
plant will operate close to design capacity when the AWT features are
placed on line.
As stated previously, the material dredged to secure dependable trans-
portation access to the site will be deposited downstream in Dyke Marsh
and is part of a master plan to re-establish wetlands that were previously
forfeited to sand and gravel operations.
The only other resource commitments associated with project imple-
mentation that are known to this office consist of the labor and various
fuels, chemicals, and other materials required to operate the plant
throughout its useful life.
-37-
l
-------
VIII. PROBLEMS AND OBJECTIONS
Listed below is a summary of problems and objections received to
date for the planned construction of the District of Columbia's Blue
Plains advanced waste treatment plant. Appendix M of the draft statement
presents pertinent correspondence and information received since EPA
commenced funding the expansion and upgrading of Blue Plains.
A. Those groups opposed to the Blue Plains Project:
1. Committee of 100 on the Federal City. It passed a resolution
stating that an environmental impact statement should be provided regarding
the effect of the proposed incinerator on ambient air quality of the Capitol
Region and requested a comprehensive analysis of alternative sludge disposal
systems, specifically the feasibility and practicability of a land, disposal
system for sewage sludge. This Committee feels that sludge incineration
will be a major air pollution problem because present technology does not'
offer proven or practical methods for the control of the sulphur arid nitroge
oxides produced by sludge incineration.
2. Metropolitan Washington Coalition for Clean Air, Inc. Mr. John
S. Winder, Jr., Executive Director stated that the proposed incinerator
operations may emit significant quanitities of nitrogen oxides and other
harmful pollutants. He expressed concern about the possible environmental
effects of the proposed sludge incinerators and urged a halt to construction
of the project pending completion of an environmental impact statement.
3. Naval Research Laboratory, Washington, D. C. The NRL stated
that the impact of 1000-2000 construction workers at Blue Plains would
create an intolerable traffic situation at its main gate and expressed con-
cern over the increase in sludge production. It requested that appropriate
action be taken in order that the Blue Plains plans include adequate facilities
for increased vehicular traffic and for reducing sludge and processing odors
below present levels.
b. Northern Virginia Conservation Council (Former Position)
Marian K. Agnew, former President of Council, stated that Blue Plains
AWT project will transfer the pollution problem from the water to the air.
She feels that the spray irrigation system is better than the physical-
chemical treatment and burning of sludge. During 1971» she spoke for the
Council before the Potomac Enforcement Conference favoring the recycling
of natural resources and the use of natural biological processes in preference
to elaborate, highly technological methods.
5- Environmental Defense Fund. Scott H. Lang, Washington Counsel,
has raised numerous questions with regard to incineration, dredging and
filling, advanced waste treatment, land contained systems, plant capacity
and interim treatment at Blue Plains. He has met with EPA on several occasions
to discuss these issues and has requested that an environmental impact state-
ment be prepared which covers all elements of the proposed expansion. EDF
has been particularly concerned that Blue Plains should be "considered within
the context of the total regionwide waste treatment strategy, not just a
solitary project".
-38-
-------
B. Proponents of the Blue Plains AWT Plant:
1. Northern Virginia Conservation Council (Current Position)
On January 12 anT^S7_1972T~the~^OM^^F~Directors—and the membership
respectfully, modified their positions of November 10, 1971. Upon reconsider-
ation, they endorsed the "proposals of the Conference to expand the capacity
of the District of Columbia's Blue Plains sevage treatment plant to 309 mgd
by December, 197**, and to upgrade it to advanced waste treatment, as partial
steps toward solution of the area's" problems. In addition, they requested
that EPA comply with NEPA and produce additional statements on effluent
quality, sludge removal, and incineration; and that all concerned agencies
study land contained systems with the Potomac River Basin.
2. Citizens Council for a Clean Potomac. The Council passed a
resolution on January l8, 1972, urging "the U. sT Congress and the political
jurisdictions in the Washington Metropolitan Area to continue the Blue Plains
expansion and upgrading program". They feel that the volume of wastewater
generated and the particular physical conditions in the area make consideration
of land disposal methods for Blue Plains impractical from both cost and
technological standpoints.
3. Groups that have testified at the Potomac Enforcement Conference
regarding the Blue Plains project are listed below. The record shows that
these groups have either endorsed or not objected to the report.
, a. League of Women Voters.
b. Canoe Cruisers Association of Washington, D. C.
c. Accokeek Foundation, Inc.
d. Cabin John Citizen's Association
e. Chesapeake Bay Foundation
f. National Wildlife Federation
g. Citizens Permanent Conference on the Potomac River Basin
-39-
-------
Appendix a
Response to Comments Received
on the Draft Statement
-------
Introduction to Appendix a
It was recommended that the EIS be split into two volumes « Volume
One would be designed to present the layman with the basic issues
and the second volume would present the detailed technical supporting
information. We have adopted this suggestion in our approach to
finalizing this impact statement. Considerable detailed supporting
information has been eliminated from the final draft and this document
should serve as a vehicle for conveying the basic issues to the layman
while those who are interested in the detailed technical foundation of
the project are directed to the draft statement and its appendices.
a-1
-------
Date
May 11, 1972
May 21, 1972
May 24, 1972
May 31, 1972
June 6, 1972
June 23, 1972
July 3, 1972
July 5, 1972
July 10, 1972
July 11, 1972
July 12, 1972
July 19, 1972
July 21, 1972
INDEX TO COMMENTS
Organization
National Academy of Sciences National
Academy of Engineering
Citizens Council for a Clean Potomac
f
National Wildlife Federation
S igned
Alexander Zucker
Executive Director
T. R. Jones, Chairman
Louis S. Clapper
Conservation Director
Washington Suburban Sanitary Commission Robert J. McLeod
General Manager
Northern Virginia Planning District
Commission
John W. Epling
Executive Director
U. S. Department of Commerce
Washington, D. C.
Sidney R. Galler
Deputy Assistant Secretary
for Environmental Affairs
U.S.D.A. Soil Conservation Service
Graham T. Munkittrick
State Conservationist
Metropolitan Washington Council of
Governments
Walter A. Scheiber
Executive Director
U.S.D.A. Forest Service
William E. Nurray
Assistant Director
U. S. Naval Research Laboratory
Captain Earle W. Sapp
Director
National Capital Planning Commission
Charles H. Conrad
Executive Director
U. S. Coast Guard
Captain S. A. Wallace
Chief, Marine Environ-
mental Protection Division
U. S. General Services Administration
Rod Kreger, Deputy
Administrator
August 4, 1972 Baltimore District - D. S. Army
Corps of Engineers
William E. Trieschman, Jr.
Chief, Planning Division
-------
I
INDEX TO COMMENTS
Date Organization Signed
August 7, 1972 U. S. Department of the Interior W. Lyon, Deputy Assistant
Secretary of the Interior
August 24, 1972 Maryland Department of State Planning Vladimir A. Wahbe, Secre-
tary of State Planning
November 7, 1972 Metropolitan Washington Coalition for John S. Winder, Jr.
Clean Air, Inc. Executive Director
National Resources Defense Council, David G. Hawkins
Inc.
Mayor and Town Council of Forrest Dr. James Comas,
Heights, Maryland Councilman
April 19, 1973
April 6, 1974
a-3
-------
NATIONAL ACADEMY OF SCIENCES NATIONAL ACADEMY OF ENGINEERING
Environmental Studies Board
8101 CONSTITUTION AVENUE
WASHINGTON, D. C. 20418
May 11, 1972
Dr. Edward W. Furia
Regional Administrator
U.S. Environmental Protection Agency
Region III
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Dr. Furia:
I am responding to your letter of May 8, 1972,
to Dr. Handler in which you ask for comments on the draft
Environmental Impact Statement for the "District of
Columbia Water Pollution Control Plant."
We very much appreciate your sending us this
document and we are impressed with the thoroughness with
which the evaluations have been made. The Academy, how-
ever, cannot comment in detail on the impact statement
because we do not have the resources to evaluate it care-
fully. A superficial evaluation would not be of service
to you nor represent a considered position of the Academy.
Sincerely
Executive Director
cc: Dr. Philip Handler
a-4
-------
ditiz£n± GounaiC j~o%a dL an ^Potomac
T. RAY JONES
'SOD 649-2439
P. O. BOX 1972 - WHEATON STATIOf>
SILVER SPRING. MARYLAND 20902
May 21, 1972
Mr Edward W Furia
Regional Administrator
Environmental Protection Agency-
Philadelphia, Pennsylvania 19106
Dear Mr. Puria«
The Citizens Council for a Clean Potomac, in its
meeting of May 16, 1972, unanimously approved a reso-
lution endorsing the draft Environmental Impact State-
ment P. L. 91-190 on the expansion and upgrading of
the District of Columbia Water Pollution Control Plant.
The Council recommends that the Agency proceed with
publication of the report in final form.
We appreciate the opportunity to review the
report in draft form and to make our views known to
you.
Sincerely,
T R HJones
Chairman
-------
(JitLzzm douncLL fox a CL an ^Potomac
P. O. BOX 1972 - WHEATON STATION
SILVER SPRING. MARYLAND 20902
RESOLUTION
WHEREAS, the Environmental Protection Agency, in
compliance with Section 102 (2) (c) of the National
Environmental Policy Act of 19^9, has issued a draft
environmental impact statement on the expansion and up-
grading of the District of Columbia water pollution
control plant;
WHEREAS, this statement evaluates the total en-
vironmental impact of the proposed action, and cons id-
!¦>
ers alternatives to treatment, sludge disposal and
transportation of equipment and materialsj
AND WHEREAS, the statement satisfactorily ans-
wers criticism of and objections to the proposed action}
NOW, THEREFORE, BE IT RESOLVED, that the Citizens
Council for a Clean Potomac endorses said draft
environmental impact statement and concurs in the
conclusion of this statement that the proposed action
is a significant step toward enhancement of the Potomac
Estuary and is a vital link in the future waste water
management plan for the Potomac River Basin.
APPROVED May l6, 1972
Lois Vermillion, Secretary
. RAY JONES
(OD 649-2439
a-6
-------
National Wildlife Federation
Mr. Edward W. Furia
Regional Administrator
U. S. Environmental Protection Agency
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Furia:
Reference is made to your letter of May 8, 1972, with the enclosed draft
environmental impact statement on the water pollution control plant in
the District.of Columbia.
We appreciate your consideration in providing us with a copy of the draft
environmental impact statement. Because of our limited personnel
resources, we are unable to provide meaningful comments on the draft
statement. However, I am confident that other conservation organizations
which are following this particular problem closely will respond with
constructive remarks.
Please be assured that we share your concern for protecting our natural
resources and will always do everything without our resource capabilities
to work toward the enhancement of the environment.
t12 16TH ST., N.W., WASHINGTON, D.C. 20036
Phone: 202-483-1550
May 24,1972
Sincerely,
Louis S. Clapper
Conservation Director
-------
COMMISSIONERS
FLOVD D PETERSON
Chairman
JOHANNA S NORRIS
Vice-Chairman
-RENCEL BROOKS
DAVID H ELLIOTT
CARTER C HUBBEl, JR
GEORGE W McRORY, JR
WASHINGTON SUBURBAN SANITARY COMMISSION
4017 Hamilton Street, Hyattsville, Maryland 20781
277-7700
May 31, 1972
Mr. Edward W. Furia
Regional Administrator
U. S. Environmental Protection Agency
Region III
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
robert j mcleoo
General Manager
ALFRED MACHIS
Director. Department of
Planning & Operations
JAMES A. STAPP
Director, Department of
Engineering &
Construction
Dear Mr. Furia;
This is in reply to your letter regarding 3MGS-IS-DC-1,
May 8, 1972. The following comments and editorial changes apply
to Draft Environmental Impact Statement P.L. 91-150, subject "District
of Columbia Water Pollution Control Plant (expansion and upgrading)",
dated April 1972:
General Comments:
The subject draft represents a massive effort which should
be appreciated by all organizations involved with the development of
similar Environmental Impact Statements. To WSSC it is an exemplary
guide and a useful source document. Our following comments and minor
editorial corrections in no way alter our respect for the fine work
expressed in this statement.
.. Page 12;
It is noticed that the water demand for 1980 as shown in the
table on page 12 is lower than that shown for 1980 on page E-7. Further,
the data in the maximum daily or the maximum monthly water supply needs
column shown on page E-7 would be a more realistic basis for comparison
with a 7-10 low flow than the needs based on the data in the yearly,
average column. If the water shortage problem has to be addressed, it
should be described forcefully.
Page 12;
Change line 14 to read "....equal to the critical 7 day low flo\«,"
Page 12:
After revised line 14, add:
"When viewed on a one-day low flow basis, even the
current supply-demand relationship becomes alarming.
For example, on September 10, 1966, the one-day low flow
at Washington, D. C. was 388 mgd. Water supply require-
ments were equal to this flow on July 3, 1969, and
exceeded it on July 15, 1971 (402 mgd) and July 17, 1971
(393 mgd)."
a-8
"Willing Water" — Symbol of Quality Service to the Suburban Maryland Area
-------
Mr. Edward W. Furia
May 31, 1972
Page 2
Page 12:
After line 18, add:
" adequately treated, although no permanent water
supply facility is programmed for construction and the
treatment problems may be insurmountable."
Page 13:
Delete lines 10 and 11.
Page 15:
Edit lines 13 and 14 to read:
" the units will be designed to handle flows '
Page 17:
Line 19:
Question accuracy of dollars for WSSC and others.
WSSC records show a total cost of $359.3 million instead
of $364.0 million and that the WSSC share is approximately
$34.4 million instead of $4.4 million.
Page 30:
Line 19:
Change last word to read "to".
Page 46:
Line 14:
Correct spelling of "efficiency".
Page 63:
Last line:
Correct "could b>"to read "could be".
Page 68:
Line 14:
Correct spelling of "phosphorus".
Verv^truly yours,
c
Robert g/ McLeod
General Manager
WAK-H
a-9
-------
Response to Comments of Robert J. McLeod
p. 12 While there is a slight discrepancy (556 mgd vs. 570 mgd) between the
text and the appendix, the text has been allowed to stand since the
value shown is in agreement with the body of Water Resource - Water
Supply Study of the Potomac Estuary. While the recommended comparison
would be more realistic, it recognized that a forceful discussion of
the water shortage problem is beyond the scope of this statement and
such a discussion will not be attempted. Readers seeking more infor-
mation on this subject are directed to more recent reports such as the
one produced by the Governor's Task Force.
p. 12 The suggested modification has been made.
p. 12 We are in agreement with the suggested revision but have not inserted
it into the text because it is dated and the water supply demand situa-
tion may have become even more serious than described.
p. 12 Discussion on page nine of this text points out that an emergency pump-
ing station may be constructed to utilize the stuary as a source of
supply for water treatment facilities.
p. 13 The draft text has been allowed to stand since the two regional plants
planned for Montgomery and Prince George's Counties will serve the de-r
veloping areas while Blue Plains will serve an established area.
p. 15 The sentence has been revised to incorporate the comment and to reflect
existing circumstances.
p. 17 The sentence has been corrected and revised to reflect the current
funding situation.
p. 30 This page has been completely revised so the comment is no longer
available.
p. 46 The sentence containing the error has been delted.
p. 63 The correction has been made.
p. 68 The correction has been made.
a-10
-------
lion. Jwnmie 11. Singleton, Chairman
Falls Church
Thomas M. Stanners, Vice-Chairman
Fairfax County
Shelley Krasnow, Treasurer
faxClly Planning District Commission
Northern Virginia
c
John W. Epling
Executive Director
COMMISSIONERS:
Hon. Richard J. Bennett
Uerndon
Hon. Melvin L. Bergheim
Alexandria
Hon. James E. Bradford, Jr.
Manassas
Anthony Clark
'rinci1 William County
Hon. A. George Cook III
Mcxandria
Hon. Roger J. Costello
Manassas Park
H. Hall Gibson
Arlington County
Hon. John Herrity
Fairfax Counlv
Shelley Krasnow
Fairfax City
William C LaBaugh,Jr.
Falls Church
Mrs Virginia Lampe
Arlington County
' im S. Leach
L. ioun Counlv
Hon. Ralph A. Mauller
Prince William County
Virginia E. McEnearney
Fairfax County
Hon. Audrey C. Moore
Fairfax County
Hon. Walter F. Murray
LccsburR
William E. O'Neill, Jr.
Alexandria
Hon. Rufus Phillips
Fan fax Counlv
James H Pickford
Fairfax CounU
Hon A. Leslie Phillips
Arlington Counlv
Charles F Robinson, Jr.
Fairfax Cnuntv
Hon James M. Scott
Fairfax Countv
Hon W. Rembert Simpson
Fan fax Citv
Hon Jimnne H. Singleton
Falls Church
Edwin R. Spann
Fairfax Countv
Thomas M. Stanners
Fairfax Countv
Hon. Neil M. Walp
\ .1
h., . Paul J Walstad
I.oudoun Countv
Hon. Joseph S. Wholey
•\i linnton Countv
• 7309 Arlington Blvd. • Falls Church, Virginia 22042 « 703-573-2210
June 6, 1972
Mr. Edward W. Furia
Regional Administrator
Environmental Protection Agency
Region I I I
Philadelphia, Pennsylvania
Dear Mr. Furia:
On May 12, 1972, the Northern Virginia Planning District Commis-
sion received the draft Environmental Impact Statement identified below.
This is to advise you that at its regular meeting of May 25, 1972,
the Commission decided to make no comment on this statement but to
express its appreciation for the opportunity to cooperate in the inter-
governmental review process.
I might point out as a matter of information, however, that the
Water Pollution Control Plant expansion and upgrading was discussed in
the Interim Water Quality Management Plan for the Northern Virginia
Planning District published in April of 1972. This interim plan was
endorsed by the Metropolitan Washington Council of Governments and the
Northern Virginia Planning District Commission. On May 15, 1972, the
Virginia State Water Control Board certified the interim plan.
Sincerely yours,
APPLICANT:
PROJECT:
CONTROL NUMBER:
STAFF CONTACT:
TELEPHONE NUMBER:
Jonn W. Epling
Executive Director
D. C. Department of Environmental Services
Draft Environmental Impact Statement
D. C. Water Pollution Control Plant
P. L. 91-190
Austan S. Librach
573-2210, Ext. 70
cc: D. C. Department of Environmental Services
ft£C EIV
jUN231972;
ed
a-11
Regional Intergovernmental Cooperation for Progress
-------
COMMENTS AND RECOMMENDATIONS
OF
REGIONAL CLEARINGHOUSE
Date: May 23, 1972
Clearinghouse or planning agency:
Name: Northern Virginia Planning District Commission
Address: Loehmann's Plaza, Suite 300
7309 Arlington Boulevard
Falls Church, Virginia 220'i2
Source of Authority for Establishment of Agency
Virginia Area Development Act and Virginia Project Notification and Review
System Procedures Guide for Local and Regional Agencies..
An application is to be made under Section 106 of the Clean Air Act of 1970
to the Air Pollution Control Office of the Environmental Protection Agency.
The estimated date the application will be filed: June 1 , 1972.
Applicant's Name: Air Quality Planning Committee of the
Metropolitan Washington Council of Governments
Address: 1225 Connecticut Avenue, N. W.
Washington, D. C. 20036
Geographic Location of Project: Washington S.M.S.A.
Project Description: Request for funding for three full-time staff positions
at COG to provide staff assistance to the Air Quality Planning Committee to
develop recommendations for revisions of the region's implementation plans
to assure attainment and maintenance of national primary ambient air quality
standards by 1975.
Clearinghouse Certification:
The project described above does ( ) does not (x)conflict with the
comprehensive plan developed or in process of development for the metropolitan
area in which it is located.
Comments and Recommendations:
No further comment. Coordination with local jurisdictions who are responsible
for implementation of air quality strategies should be emphasized.
TsTgni
Author
lure) John w. rpJA
ijzed Representative
C1 ear i nnhouse
a-12
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1
NORTHERN VIRGINIA PLANNING DISTRICT COMMISSION
.E SOLUTION NO. 72-89 DATE: May 25, 1972
PATRON: Neil M. Walp, Chairman
Natural and Environmental
Resources Committee
A-95 REVIEW OF REGIONAL PROJECTS
BY THE NATURAL & ENVIRONMENTAL
RESOURCES PLANNING DIVISION
WHEREAS, the Northern Virginia Planning District Commission
ias been advised by the Executive Director and the Director of the Division
»f Natural and Environmental Resources that the development of a work
irogram for submittal to the State Water Control Board by July 15, 1972 for
ilanning funds in the area of Water Quality Management Planning is an item
)f major importance; and,
WHEREAS, by Memorandum dated May 23, 1972: SUBJECT:
^-95 Review of Regional Projects, it is recommended that "No Comment"
etters be submitted in connection with two applications (one for three
ull time staff positions at COG and the other from the Government of the
District of Columbia, being an Environmental statement pertaining to a
jroject to update and expand the Blue Plains plant from 240 mgd to 309 mgd),
NOW THEREFORE BE IT RESOLVED THAT the Executive
Director be authorized to sign "No Comment" letters on the above two
projects, and where during the next sixty (60) days ending July 24, 1972,
10 substantial regional issue is raised, that the Executive Director be
authorized to prepare similar "No Comment" letters for the approval of
he Commission, upon the recommendation of the Natural and Environmental
Resources Planning Committee.
CERTIFICATION
The undersigned certifies that the foregoing
is a true and correct copy of a resolution
adopted at a legally convened meeting of th^
Northern Virginia Planning District Commissioi
held on May 25, 197^.
/?•?
'
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THE ASSISTANT SECRETARY OF COMMERCE
Washington, D.C. 20230
June 23, 1972
Mr. Edward W. Furia
Regional Administrator
U.S. Environmental Protection
Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Furia:
The draft environmental statement for the "District of
Columbia Water Pollution Control Plant (Expansion and Upgrad-
ing)," which accompanied your letter of May 8, 1972, has been
received by the Department of Commerce for review and comment.
The Department of Commerce has reviewed the draft environmental
statement and has the following comments to offer for your
consideration.
The draft environmental impact statement appears complete and
accurate in most respects, and in our opinion, the upgrading
of the Blue Plains sewage treatment facility should have a
beneficial effect on the commercial and sport fisheries in
the Potomac River. In recent years, there have been serious
soft-shell clam kills that were believed to be caused by oxjgen
depletion. If the oxygen content of the River is increased as
a result of upgrading the plant, summer kills of soft-shell
clams may be prevented.
Although the statement appears to treat most of the required
topics adequately, we feel it could be improved by additional
discussion or clarification of the following points.
It is stated on page 33 that th£ nitrogenous demand is the
greatest cause of dissolved oxygen deficit. On page 34, it is
stated that "Completion of the current expansion and upgrading
Df the Blue Plains facility will actually reduce the . . .
litrogen . . . from approximately . . . 47,500 lbs/day ... to
-------
NORTHERN VIRGINIA PLANNING DISTRICT COMMISSION
RE SOLUTION NO. 72-89 DATE: May 25, 1972
PATRON: Neil M. Walp, Chairman
Natural and Environmental
Resources Committee
A-95 REVIEW OF REGIONAL PROJECTS
BY THE NATURAL & ENVIRONMENTAL
RESOURCES PLANNING DIVISION
WHEREAS, the Northern Virginia Planning District Commission
nas been advised by the Executive Director and the Director of the Division
Df Natural and Environmental Resources that the development of a work
program for submittal to the State Water Control Board by July 15, 1972 for
planning funds in the area of Water Quality Management Planning is an item
~f major importance; and, •
WHEREAS, by Memorandum dated May 23, 1972: SUBJECT:
A-95 Review of Regional Projects', it is recommended that "No Comment"
Letters be submitted in connection with two applications (one for three
full time staff positions at COG and the other from the Government of the
District of Columbia, being an Environmental statement pertaining to a
project to update and expand the Blue Plains plant from 240 mgd to 309 mgd),
NOW THEREFORE BE IT RESOLVED THAT the Executive
Director be authorized to sign "No Comment" letters on the above two
projects, and where during the next sixty (60) days ending July 24, 1972,
no substantial regional issue is raised, that the Executive Director be
authorized to prepare similar "No Comment" letters for the approval of
:he Commission, upon the recommendation of the Natural and Environmental
Resources Planning Committee.
CERTIFICATION
The undersigned certifies that the foregoing
is a true and correct copy of a resolution
adopted at a legally convened meeting of thi
Northern Virginia Planning District Commis
held on May 25, 197^.
AO-
- cvj. Goii
a-13 Executive Assistant
-------
THE ASSISTANT SECRETARY OP COMMERCE
Washington, D.C. 20230
June 23, 1972
Mr. Edward W. Furia
Regional Administrator
U.S. Environmental Protection
Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Furia:
The draft environmental statement for the "District of
Columbia Water Pollution Control Plant (Expansion and Upgrad-
ing)," which accompanied your letter of May 8, 1972, has been
received by the Department of Commerce for review and comment.
The Department of Commerce has reviewed the draft environmental
statement and has the following comments to offer for your
consideration.
The draft environmental impact statement appears complete and
accurate in most respects, and in our opinion, the upgrading
of the Blue Plains sewage treatment facility should have a
beneficial effect on the commercial and sport fisheries in
the Potomac River. In recent years, there have been serious
soft-shell clam kills that were believed to be caused by oxjgen
depletion. If the oxygen content of the River is increased as
a result of upgrading the plant, summer kills of soft-shell
clams may be prevented.
Although the statement appears to treat most of the required
topics adequately, we feel it could be improved by additional
discussion or clarification of the following points.
It is stated on page 33 that the nitrogenous demand is the
greatest cause of dissolved oxygen deficit. On page 34, it is
stated that "Completion of the current expansion and upgrading
of the Blue Plains facility will actually reduce the . . .
nitrogen . . . from approximately . . . 47,500 lbs/day ... to
a-14
-------
less than 61,130 lbs/day ..." If these figures are correct,
greater oxygen depletion would result from the discharge of
additional nitrogenous waste. The figure listed on page 58
is 6,130 lbs/day, however, suggesting that the figure on page
34 should be 6,130 instead of 61,130 lbs/day.
The last paragraph on page 34 discusses the probability that
the Potomac will be unable to supply the future freshwater
needs for the Washington Metropolitan area, and the proposal
by the Corps of Engineers to construct multipurpose reservoirs
in the Potomac Basin. It would be desirable for the statement
to include a discussion of the impact on the Potomac Estuary
of increased utilization of freshwater inflow, as a result of
increased efficiency of pollution abatement, increased diver-
sion of freshwater flow from the Estuary, or a combination of
these and other factors. Specifically, discussion should be
included concerning the impact on estuarine and marine resources,
especially those of commercial or recreational importance,
caused by alterations in the salinity pattern that may result
from increased use of Potomac River or Potomac Estuary water
to satisfy future water supply needs of the area.
The last paragraph on page 37 states that the sewage effluent
has been chlorinated since 1955 and that no adverse effects
on River biota have been noted. On page 38, it is stated that
"Since the residual chlorine is expected to be in a different
chemical form when the new facilities are completed its effect
on the river biota is unknown." In view of the uncertainty
expressed here, we suggest that studies be conducted on the
effects of residual chlorine on the River biota in order to
provide a sound basis for an adequate assessment of the impact
of these chemicals on the biota.
We note that the meteorological assumptions used in appendix
C (pages 24 and 25) maximize the computed downwind concentra-
tions averaged over a one hour period. Consequently, provided
the assumed source terms are accurate, the predicated particu-
late and N0k concentrations are correct.
a-15
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- 3 -
We hope these comments will be of assistance to you in the
preparation of the final statement.
Sincerely,
Sidney R. Galler
Deputy Assistant Secretary
for Environmental Affairs
a-16
-------
Response to Comments of Sidney R. Galler
1. An error was made on p. 34 (of the draft statement) and the text has
since been corrected.
2. A discussion of the effect of wastewater treatment plant discharges on
Potomac River salinity is presented in Water Resource-WaterSupply Study
of the Potomac Estuary on page Xii-8. The study also presents informa-
tion on the commercial and recreational fisheries of the Potomac (pages
111-15 to 111-18). In fact, two of the study objectives were to project
water supply needs and wastewater loadings and to predict the effect of
these withdrawals and loadings on water quality in the Potomac. Another
study objective was to evaluate the consequences of utilizing the estuary
as a water supply source. In summary, the reader is referred to the
report cited above for further information on this topic.
3. This comment was referred to the Annapolis Field Office of EPA-Region III
for resolution and their response is shown below.
"Present effluent is high in organic nitrogen and ammonia content because
of inadequate treatment. Chlorination therefore has resulted in a higher
chloramine content, particularly due to the latter, which has low disin-
fectant value and requires higher chlorine dosage to insure an adequate
amount of free chlorine. With the high degree of treatment proposed,
chlorine dosage can be materially reduced with insignificant chloramines.
Residual chlorine can be low and the effects of the resulting hypochlorous
acid on the biota unmeasurable for a large treatment plant where propor-
tional feed is practiced. Even in a small plant with uniform chlorine
feed rate adjusted for maximum flow, residual chlorine is no threat to the
biota unless the volume of diluting water is small."
4. This comment simply confirms the accuracy of calculations made in Appendix
C of the draft statement.
a-17
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE - 1+321 Hartwick Road
College Park, Maryland 207^+0
July 3, 1972
Mr. Edward W. Furia
Regional Administrator
U. S. Environmental Protection Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Furia:
We have reviewed the Draft Environmental Impact Statement for the
District of Columbia Water Pollution Control Plant, dated April 1972,
and have the following comments:
1. We are pleased to see appropriate attention given to constructing
sediment control.
2. We concur in the problems raised concerning spray irrigation of
effluents. Many areas of Maryland including that portion east
of the Chesapeake Bay are characterized with soils with limita-
tions to this operation as described.
3. Our Maryland office having Soil Conservation Service responsibility
in the District of Columbia will be pleased to assist in any of
the proposals including in the statement for which we have expertise
such as soils, erosion control and irrigation water management.
We appreciate the opportunity to review this statement and trust our
comments are helpful.
Sincerelv.
Graham T. Munkittrick
State Conservationist
cc: K. E. Grant
T. C. Byerly
a-18
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metropolitan Washington
COUNCIL OF GOVERNMENTS
1225 Connecticut Avenue, N.W., Washington, D. C. 20036 223-6800
July 5, 1972
Mr. Edward W. Furia
Regional Administrator
U.S. Environmental Protection Agency
Region III
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
RE: COG No. 72-DC-W/S-5
EPA No. 3MGS-IS-DC-1
Draft Environmental Impact
Statement, D.C. Water Pollution
Control Plant Expansion
Dear Mr. Furia:
In accordance with the provisions of the National Environ-
mental Policy Act of 1969, and the procedures of Circular A-95,
the draft environmental impact statement for the project referenced
above was circulated to interested and affected parties (as
listed on Attachment A) for their review and comment.
The Council of Governments wishes to clarify the references
to,the population projections found on page 14 of the text. COG
furnished regional population projections for the years 1980
and 2000 only. Projections for the year 2020 were developed by
the Federal Water Quality Agency's Middle Atlantic Region.
(See Environmental Protection Agency Technical Report No. 35,
pp. IX-3).
These regional projections were based on the "low-estimate"
forecasts prepared for COG by Hammer, Greene, Siler Associates.
(See Hammer, Greene, Siler Associates, The Economy of Metropolitan
Washington, July, 1969). These "control totals" were then manually
distributed to the individual service areas on the basis of 196 0-
1968 population trends with consideration given to potential land
use and other factors.
The EMPIRIC Activity Allocation Model was not fully developed
at the time the distributions by jurisdiction were made. However,
COG is currently using the completed EMPIRIC Model to evaluate
alternative sets of regional policies which will then be the basis
of COG's recommended development policies plan for the Year 2000.
We anticipate that these recommendations will be available by the
end of 1972.
RECEIVED
1 'T72'
a-19
Fl" !'¦ f i
-------
Mr. Edward W. Furia
page 2
We have received comments (see enclosures) from several
agencies which address specific aspects of the draft statement.
(Attachment B contains a list of those responding.) In addition
to specific comments and questions upon the draft/ the Maryland-
National Capital Park and Planning Commission requested that COG
schedule a conference with the appropriate officials to permit
further discussion of the draft statement. However, because of
bhe closeness of the deadline for submitting comments, M-NCPPC
^ias withdrawn that request on the understanding that its concerns
:;an be addressed in the final statement. Since some of its
questions are directed to the Maryland Department of Environmental
Services and to the District of Columbia Department of Environmental
Services; we have transmitted a copy of M-NCPPC's comments to those
agencies with a request that they respond to M-NCPPC.
As the Metropolitan Planning Agency as well as the Metropolitan
Clearinghouse for the Washington area, we appreciate the opportunity
:o circulate and to comment on the draft environmental impact state-
nent for a project of such significance to the Washington Metro-
politan Area. If we may be of further assistance, please call.
Sincerely yours,
Walter A. Scheiber
Executive Director
7AS/par
Inclosures: Attachment A, List of Referrals Receiving Draft
Statement
Attachment B, List of Those Responding
Responses (5)
-------
ATTACHMENT A
DISTRIBUTION LIST
¦ION. WILLIAM C. CROSSMAN, JR., CHAIRMAN
Loudoun County Board of Supervisors
Mr. Philip Bolen, Executive Secretary
Loudoun County
TON. JOSEPH S. WHOLEY, CHAIRMAN
Arlington County Board
HON. WILLIAM S. HOOFNAC-LE, CHAIRMAN
Fairfax County Board of Supervisors
Administrative Response Staff
c/o Dr. George J. Kelley, County Executive
HON. JAMES P. GLEASON, COUNTY EXECUTIVE
VIontgomery County
HON. DICKRAN Y. HOVSEPIAN, PRESIDENT
Montgomery County Council
Mr. William H. Hussmann, Director
Montgomery County Office of Program
HON. WILLIAM W. GULLETT, COUNTY EXECUTIVE
Prince George 1s County
HON. WINFIELD M. KELLY, JR., CHAIRMAN
Prince George's County Council
Mr. Edward Chen, Planning Coordinator
Prince-George 1s County
HON. WALTER E. WASHINGTON,~MAYOR
District of Columbia
HON. JOHN A. NEVIUS, CHAIRMAN
District of Columbia City Council
Mr. Comer S. Coppic, Special Assistant
Office of Budget and Program Analysis
HON. MATTHEW J. MCCARTIN, MAYOR
Citv of Rockvil]e .
HON". CHARLES E. BEATLEY, JR., MAYOR
City of Alexandria
HON. LOUIS H. BLAIR, MAYOR
City of Falls Church
Mr. Horace M. Hallett, Director
Loudoun County Sanitation Authority
Mr. Floyd D. Peterson, Chairman
Washington Suburban Sanitary Commission
Mr. Fred C. Morin, Chairman
Fairfax County Water Authority
Col. William Prentiss, Engineer
Baltimore District, Corps of Engineers
Mr. James P. Alexander, Director
D.C. Department of Environmental Services
Mr. Paul V. Freese, Chairman
Regional Sanitary Advisory Board
Mr. James P. Corbalis, Chairman
Water Supply Committee, RSAB
Mr. Philip R. Hogue, Chairman
Maryland-National Capital Park and Planning Commission jjrArn
Mr. John P. Hev?itt, Executive Director ntCEr/ED
Maryland-National CapiLul Park and Planning Commission
Ms. Marilyn M. Pray, C^ief, General Planning Division JUL 1 2 1972'
Maryland-National Capital Park and Planning Commission
a-21
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-2-
Mr. Charles R. Burbach, A-95 Information Officer
Va. Division of State Planning and Community Affairs
Mr. Edwin L. Powell, Jr., Chief, State Clearinghouse
Maryland Department of State Planning
a-22
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ATTACHMENT B
Referral Responses:
Department of Environmental Services, District of Columbia
Office of Planning and Programming, Montgomery County, Maryland
Office of the County Executive, Prince George's County, Maryland
Maryland-National Capital Park and Planning Commission
Northern Virginia Planning District Commission
.a-23
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SJppt'r JtSsBrlfwrtf. ftffitrfgltutfi 201170
027-3000
CHIEF ADMINISTRATIVE OFFICER
June 8/ 1972
PRINCE GEORGE'S COUNTY GOVERNIiENT A-95 REVIEW COMMITTEE
TO: Walter A. Scheibe-r, Executive Director
Washington Metropolitan Council of Governments
FR0I1: Edward W. Chen £-2.
Planning Coordinator
SUBJECT: Project Notification Review for:
PROJECT* Environmental Impact Statement-D.C. Water Pollution
x " Control Plant Expansion
A-95 ID; 72-DC-W/S-5
APPLICANT: Environmental Protection Agency
DESCRIPTION• Environmental Impact Statement
PROJECT DISPOSITION:
The project referenced above was received by the Prince
George's County Planning Coordinator on Mav 16. 19 72
for review and comment under the A-9 5 procedures promulgated
by the Office of Management and Dudgct. The project was
subsequently referred to appropriate County departments for
review and comment, reflective of their functions and
responsibilities, prior to the County A-95 Review Committee
conference held June .1. 1972 to discuss
this project.
As a result of discussion at this conference, the County
Government:
1. Does not wish to comment on the above subject.
2. Wishes to make the following comments: (See attachment)
X 3. Has reviewed the project referenced above, finds it
in conformance with our policies, and recommends a
favorable Clearinghouse Review. Subject to following
comments:
O /.
-------
PRINCE GEORGE'S COUNTY GOVERNMENT
A-95 REVIEW COMMITTEE
Summary of Agency and Department Comments Concerning Summary
Notification for Environmental Impact Statement - D.C. Water Pol-
lution Control Plant Expansion. COG No. 72-DC-W/S-5
1. It is stated that the proposed sludge incineration would
contribute 1.9 percent of the particulate burden in the
Washington area. While this is termed a "very small"
effect, we feel that, such a contribution coming from a
single source is not small and may have an adverse environ-
mental impact.
2. Population projections used in the document and as supplied
by COG are based on H.G.S.A. "low projections" which reflect
1960-1970 trends. Due to limitations placed on sewage flows
to be accepted and treated at Blue Plains and the need to
locate additional treatment capacity at a plant or plants
to be located in the suburban jurisdictions as per the
October, 1970 Memorandum of Understanding, Prince George's
County has been reassessing its growth potential with the
view of limiting or further reducing future population
growth.
Further, the H.G.S.A. projections have never been accepted
by Prince George's County as the official County projections.
SI 3. The problems surrounding the disposal of 2 , 500,000 cubic
yards of earth and stockpiled sludge are barely mentioned
in the Environmental Impact Statement. Over 100,000 cubic
yards will go to "approved landfills" and the Oxon Run Golf
Course; no consideration is given to the impact of relocat-
ing this material. There are no landfills in Prince George's
County that accept sludge and we have not seen plans for the
Oxon Run Golf Course, Seeing that 2,500,000 yards of earth
and sludge are disposed of in an "approved" manner is ap-
parently a problem left to the jurisdiction receiving the
material.
4. The question of the disposal of sewage sludge during the Blue
Plains expansion (including the interim chemical precipitation
process) is not adequately dealt v/ith in the Statement. Reference
was made to an agreement made between D.C. and MES for land
disposal of digested and raw sewage sludge on State-owned land
in Prince George's County between now and the completion of
the sludge handling facilities at Blue Plains. No assessment
is made of the impact of the disposal of this sludge in Prince
George's County, nor is there an analysis of odor or traffic
problems which could result when MES actively begins to handle
the project.
a-25
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-2-
During local meetings with I<1ES the question of environ-
mental impact analysis was put forward by County representa-
tives. MZS stated that such an assessment would be included
in the EPA Statement on Blue Plains.
We find no reference in this report to interim sludge
handling or disposal. Such a section should be added to
the report or presented as an additional analysis supple-
menting the Environmental Impact Statement.
5. Miscellaneous Comments
Page 12:
It is noticed that the water demand for 1980 as shown in the
table cn page 12 is lower than that shown for 19 80 on page
E-7. Further, the data in the maximum daily or the maximum
monthly water supply needs column shown on page E-7 would be
a more realistic basis for comparison with a 7-10 low flow
than the needs based on the data in the yearly average
column. If the water shortage problem has to be addressed,
it should be described forcefully.
Page 12 :
Change line 14 to read "....equal to the critical 7 day low
flow."
Page 12:
After revised line 14, add:
"When viewed on a one-day low flow basis, even the current
supply-demand relationship becomes alarming. For example,
on September 10, 1966, the one-day low flow at Washington,
D.C. was 338 mgd. Water supply requirements were equal to
this flow on July 3, 1969, and exceeded it on July 15, 1971
(402 mgd) and July 17, 1971 (393 mgd)."
Page 12 :
After line 18, add:
" adequately treated, although no permanent water supply-
facility is programmed for construction and the treatment
problems may be insurmountable."
a-2b
-------
-3-
Page 13;
l
Delete lines 10 and 11.
Page 15:
Edit lines 13 and 14 to read:
" the units will be designed to handle flows....."
Page 17:
Line 19:
Question accuracy of dollars for WSSC and others.
WSSC records show a total cost of $359.3 million instead
of $364.0 million and that the WSSC share is approximately
$34.4 million instead of $4.4 million.
Page 30:
Line 19:
Change last word to read "to".
Page 46:
Line 14:
Correct spelling of "efficiency".
Page 63:
Last line:
Correct "could by" to read "could be".
Page 68:
Line 14:
Correct spelling of "phosphorus".
a-27
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metropolitan Washington
COUNCIL OF GOVERNMENTS
1225 Connecticut Avenue. N.W...Washington. D.
r^^xijrL^T-i
A-95 METROPOLITAN CLEARINGHOUSE MEMORANDUM
M J * 7 r!
TO: Mr. Warren Giauque May ^5, lfc7yVrpv * en rfr ¦
M-NCPPC '
8787 Georgia Avenue ^
Silver Spring, Maryland 20907 • »— ...
SUBJECT: PROJECT NOTIFICATION AND REVIEW FOR
project: Environmental impact Statement - D.C. cog no.: 72-DC-W/S-5
Water Pollution Control Plant Expansion
APPLICANT: Environmental Protection Agency
The project title, COG number, and the applicant's name should be used in all
future correspondence with COS concerning this proposed project.
PLEASE NOTE ACTION INDICATED BY CHECK MARK IN BOX BELOW OR ON REVERSE
PROJECT NOTIFICATION
~
J
The Project Notification for the project referenced ahove was received
on and has been referred to aDpropriate parties
(see attached list) for their review and comment. This review will be
conducted as expeditiously as possible.
"7/ A copy of the Project iTotification for the project referenced above is
enclosed for your review and comment, in accordance with CM3 Circular
A-95 Review reauiremer.ts. Your review should focus on the intended
application's compatibility with the plans, programs, and objectives of
your organization. You may indicate below your interest in and/or
comments
the
mments concerning the proposed project bv r&turnina this sheet to
e Metropolitan Clearinghouse by iVlAY 2 <'.) 197? •
This organization:
does not wish to cc~rient on the above project.
las further interest and/or cuestions concerning the above project
and wishes to confer with the applicant.
is interested in the above project and wishes to make the following
comments: (use attachment)
will submit corn-ents concerning the above project by .
desires an extension of time until for
further consideration of this project. (Subject to certain restraints
imposed bv the fCircular,.)
has rr".i fr/ei th~ ::r~ji\ct referenced above, finds it in
conforrr.ar.ee with o._ policies, recor c.onds a favorable
'letropol i t.an Cli.=. r muhouie icvi/w.
Signature £/$¦/
a/8j /
Organi zn t i on ^_M/ J.KC/--
ol irnhn • ConPt> • I- t«rf *x C • '.«*> • tiuJojo Ciu-nt. • t ouoijr • fringe (.iorj:c t • Prime County
\i, « i I i v • I urf.ix ( »;/ • J* i!l» h • t• KisUmIIi : 'I i i'*rk
-------
Ths Maryland - National Capital Park a no Planning Commission
UCIONAL AND MITKOrOUTAN DISTRICTS IN MONTCOMIRY AND PRIMCI CIOfiCTS COUNTIU, MAIYLAND
Reglonol Hoadquarlori Building MM4M
8787 Georgia Avonu«
Sllvar Spring, Maryland 20907
June 26, 1972
Mr. Walter A. Scheiber
Executive Director
Metropolitan Washington Council of Governments
1225 Conaec.ticut Avenue NW
Washington, DC 20036
Subject: A-95 Clearinghouse Referral
COG #72-DC-W/S-5
Draft Environmental Impact Statement
DC Water Control Plant Expansion
Dear Mr. Scheiber:
This agency has reviewed the subject draft statement,
and it is recommended that a conference with the applicant
be scheduled at an early date.
The draft statement, in our opinion, does not contain
sufficient information relative to the environmental impact
-of sludge disposal via a landfill located at Cheltenham,
nor the impact of transporting these large quantities of
sludge from Blue Plains to the landfill sites in 36 ton
trucks.
Our questions and concerns are more specifically
enumerated in the staff memorandum attached, and we request
the opportunity to further discuss these matters with the
appropriate EPA and MES representatives.
Very truly yours,
C. Warren Gi/luque
Regional Pl/nni ng( 0/fi cer
CWG:rt
CC: J. Sti 1 Iv/el 1 , SCS
J. Coulter, Uept. of Natural Resources (MES)
The Hon. W. Kelly, Jr.
The Hon. W. Gullett
Chai rman Hogue
Vice Chairman, Brennan
Executive Director, Hewitt
a-29
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<4
The Maryland - National Capital Park and Planning Commission
RECIONAL AND METROPOLITAN DISTRICTS IN MONTGOMERY AND MINCE GEORGE'S COUNTIES, MARYLAND
Regional Headquarters Building 377-3300
6600 Kenilworth Avenue Ana 801
Riverdale, Maryland 20840
PL-PG-20
June 16/ 1972
MEMORANDUM
€
TO: C. Warren Giauque, Regional Planning Officer
FROM: Jorge A. Valladares, Coordinator of Environmental Engineering
SUBJECT: COG #72-DC-W/S-5, Draft Environmental Impact Statement,
D.C. Water Pollution Control Plant Expansion ^
After thorough review of the above noted project, I find there are
still some major unresolved questions not addressed in the Draft.
First and foremost is the question regarding sludge, its treatment
(or lack thereof), and its disposal. Ostensibly, research is currently
being conducted at the U.S.D.A. in Beltsville to determine the feasibility
of land disposal of various types of sludge. However, even before the
results are known, the M.E.S. is proceeding with plans to dispose of
sludges at Cheltenham in Prince George's County. Nowhere in the Draft
docs it mention the types of sludges that M.E.S. has agreed to take both
before and after Blue Plains expansion, nor does it note where or how
the kludge will be disposed. It is imperative that it be made clear to
the general public and residents of Prince George's County just what is
occurring on this matter before it occurs. The County is responsible
for a fair share of the waste it has itseTf created, but there is serious
question that it should accept aLl the wastes. The types of wastes that
I allude to for the period of interim treatment and subsequently, after
completion of the plant expansion, includes, screening wastes, grit,
sludges from alum and other chemical additions, digested sludge, raw
sludge, etc.
2
Also, how is the sludge or sludges to be transported to the disposal
site? Are the roads adequate? Is it safe to transport and handle raw
sludge?^ How will the Beltsville research findings be used? Will any
effort be made to reclaim the large volume of chemicals used?
1 See page G24 of Draft, item #4.
2 See page 90 of Draft Statement.
a-30
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2
3
One of the alternatives noted on page 94 of the Draft included
pumping of digested sludge to drying beds. It was abandoned since
n acres of covered area would be needed and a "vast open area is
not available", yet the federal government owns "vast open area"
between the Capital Beltway and Blue Plains in the vicinity of Oxon
Cove. The immediate question is why should the residents of Prince
George's County be asked to support the entire sludge burden when
there are other open lands. (Even this federal property is mostly
located in P.G. County.)
Other items of concern include the use of COG population pro-
jections which have consistently been rejected by local authorities
and; the still prevalent practice of bypassing the treatment plant
approximately 10 days per year diiring more intense storms. What
will be the total cost of the treatment method selected in terms of
capital costs and operation and maintenance costs in relation to the
population served?
Will all sludges be incinerated in the future or only biological
sludges? What will be done with chemical sludges? Will they be re-
used?
Further, this Commission has been working for several years on
development of a P.L. 566 program in the Piscataway basin which in-
cludes an impoundment adjacent to Boys Village at the M.E.S. disposal
site and another larger one downstream. Water contact recreation is
one of the uses. Will this sludge disposal allow for water contact
•ecreation in tributary watercourses? The development of these lakes
involves many millions of federal and local monies and should be
looked into at this stage of planning. Assurances by the M.E.S. are
not sufficient to dispel concern over leaching problems.
On page 114 of the Draft are listed the irreversible and irre-
trievable commitments of recourses.
What about the final disposition of land at Cheltenham? Certainly
its use as a sludge landfill seriously limits any other use of the
site. This should be noted in section VII of the Draft.
It is my opinion that these matters ought to be brought out in
the open and discussed now. Even if there are logical and sound reasons
for handling the sludges as proposed, it should all be a part of the
impact statement.
JAV:cmc
a-31
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Response to Comments of Walter A. Scheiber
Covering Letter - A footnote has been added to the final text which explains
that the population projections for the year 2020 were developed in-house and
not supplied by COG.
Prince George's County A-95 Review Committee
1. The review committee's comment concerning sludge incinerator particulate
emissions was referred to members of the regional staff who had prepared
the air pollution sections of the draft EIS. Their response was to the
effect that the issue was addressed in sufficient detail on pages C-l,
C-32, and C-33 of the draft statement. For convenience several excerpts
of these pages are quoted below.
From page C-32, "It has been determined that the incineration process will
result in.various forms of environmental degradation. By every measure of
acceptability - federal standard, local regulation, guideline, or engi-
neering judgment - the degradation has fallen within acceptable limits,"
and, "The mass emissions of the major pollutants (NOx, particulates, and
S02) were also related to air.quality. The results show no meaningful
degradation can be predicted for the immediate vicinity, the City, or the
Metropolitan Area."
2. Should Prince George's County take steps to reduce future population
growth, this action would not appreciably effect the proposed project
since present flows at Blue Plains are not far from the 309 mgd design
level. If Prince George's County growth were constrained, it would, of
course, have a marked effect on the capacity of' the proposed regional
plant at Piscataway.
3. The stockpiled sludge and excess excavation have since been disposed of
by hauling to the Oxen Cove area, to Andrews Air Force Base, and also to
the vicinity of the junction of 1-29-5 with 1-495. Since the excavation
contractor was able to obtain the necessary County permits to conduct
this operation, we assume the County concerns mentioned in the comment
were later satisfied.
4. Subsequent to this comment, the Maryland Environmental Service and the
U.S.D.A. Agricultural Research Service have constructed and are now op-
erating a joint research and demonstration project that is investigating
the feasability of the composting method of sludge treatment with sludge
from Blue Plains. An environmental impact statement (which addressed
the potential for odor and traffic problems) describing the project was
prepared by the Agricultural Research Service and circulated in draft
form on December 7, 1972. The statement was released in final form on
November 20, 1973.
a-32
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5. Identical comments were received from the Washington Suburban Sanitary
Commission in their letter of May 31, 1972. Please see "Response to
Comments of Robert J. McLeod" in this appendix.
The Maryland-National Capital Park and Planning Commission
Paragraph 1 and 2 - Please see response to item number 4 above.
3. The sludge digestion process, if utilized, would produce a supernatant
which is highly concentrated in terms of nutrient levels. This super-
natant would have to receive extensive treatment if the strict nutrient
discharge limits proposed for Blue Plains are to be met. This treatment
could be accomplished only if space for additional tankage was available
at the Blue Plains site. Thus, this alternative has been dropped from
serious consideration since space for both additional treatment tankage
and for the sludge drying beds is not available.
The project, as currently proposed, does not involve utilizing land in
Prince George's County for a wastewater treatment plant site.
4. The COG population projections used in the statement were taken from ear-
lier Federal Reports (such as Technical Report No. 35) and accepted for
the sake of uniformity.
Bypassing of combined flows does occur in the District's system but the
NPDES permit included in Appendix b directs the District to "operate the
treatment works (including treatment plant and sewer system) to minimize
the total quantity of pollutant discharge for the parameters identified
in the permit."
The capital cost of the expansion and upgrading program is currently es-
timated at between 330 and 360 million dollars. The draft statement re-
ported the operation and maintenance costs are estimated to amount to
$24,046,000 per year. The population associated with the 309 mgd annual
average figure is 2,227,000 (from Development Plan for the Water Pollution
Control Plant with Implementation Program for 1969-197?, Metcalf and Eddy,
Engineers — Boston, Massachusetts. February 1969).
5. The applicant proposes to use a three-stage biological treatment system
to meet the discharge requirements. This system will produce mainly bio-
logical sludges which will be conditioned, dewatered, and incinerated.
This treatment system does not produce any appreciable quantity of chemi-
cal sludge.
Paragraph 6 and 7 - Since the proposal to dispose of sludge at Cheltenham was
not implemented, these comments are no longer applicable.
a-33
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United States Department of Agriculture
FOREST SERVICE
Northeastern Area - State & Private Forestry
6816 Market Street, Upper Darby, Pa. 19082
REPLY TO: 1940
July 10, 1972
subject: Draft Environmental Statement, District of Columbia
Water Pollution Control Plant
TO: Mr. Edward W. Furia, Regional Administrator
U.S. Environmental Protection Agency, Region III
6th & Walnut Streets
Phila., Pa. 19106
We have reviewed the draft environmental statement for plans to expand
and upgrade the existing Water Pollution Control Plant in the District
of Columbia.
One feature of the operation of the Water Pollution Control Plant that
would have an adverse impact on vegetation is the incineration of sludge.
According to tables in the statement, only 200 tons of sulfur dioxide
and 200 tons of oxides of nitrogen will be produced every year -- this
is a negligible amount even if it is concentrated in the immediate area.
Chlorine is to be applied at the raw sewage pump station wet well,
secondary treatment process and as treatment of excess flow (P40, P70,
PB2). There isn't any comment on the effect of this chlorine on
vegetation - prevailing winds, amount of vegetation in the area,
concentration of chlorine gas at different distances from the treatments.
We .appreciate the opportunity to comment on this draft statement and
r of the final statement when it is published.
Assistant Director
Environmental Protection & Improvement
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Response to Comment of William E. Murray
1. In response to Mr. Murray's comment regarding the effects of chlorine on
vegetation, the District reports that, "No adverse effects have been ob-
served on the existing shrubbery and lawns in the area to date. No com-
plaints have been received about noticeable chlorine gas odors at the
plant or in the vicinity of the plant".
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NAVAL RESEARCH LABORATORY
WASHINGTON. D.C. 20390
IN REPLY REFER TO;
001 -1 8:SLC:blm
11 JUL 1972
Mr. Edward W. Furia
Regional Administrator
U.S. Environmental Protection Agency
Region III
6th & Walnut Street
Philadelphia, Pennsylvania 19106
Dear Mr. Furia:
The Naval Research Laboratory (NRL) has received a copy of the
draft Environmental Impact Statement on the expansion and upgrading
of the District of Columbia Water Pollution Control Plant.
As an immediate neighbor of the Water Pollution Control Plant, NRL
has a strong interest in the establishment and maintenance of a
healthful and non-obnoxious environment for personnel who live and
work on its grounds. NRL also has a strong interest in revitalizing
the Potomac River. NRL is therefore in favor of the concept of
improving the operations of the Plant.
Our review of the draft Environmental Impact Statement makes it
clear that NRL is not in a position to analyze and evaluate the conclusions
as to the scope of facilities required and the specific processes
proposed for installation at the Plant. We do, however, have a
number of comments based on our previous experience with the Plant,
bearing on some of the more obvious aspects of the potential impact
of the expanded Plant on NRL.
a. Full prechlorination in present operation was not begun until
March 1969, and then only after continued protests from NRL. We
therefore urge that the plans for prechlorination be specific to require
full treatment of the wastewater at all times with accompanying
continuous monitoring.
b. In several instances the plans for new installations call for some
means of controlling odor formation, without reference to backfitting
such systems on similar devices in the present Plant. In all such cases
the provision for doming and skimming of sedimentation tanks should be
a-36
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extended to include the present tanks. Similarly, ozonation, if effective,
should be applied to all appropriate stages of the process, such as the
pumping station, sedimentation tanks and the grit removal area.
c. Plans for use of ozone should include provision for monitoring
the net contribution of ozone to the environment by the ozone generators,
and the effect of such ozone release during critical air pollution episodes.
d. Conflicting decisions already made on methods for deodorizing,
packaging and transporting the undigested sludge during the construction
period leave a situation in which the responsibilities of the Water
Pollution Control Plant, the Maryland Environmental Services and the
contractor seem at times to overlap and at times to leave a time gap
(such as the period between the end of 1973 and the date the incinerators
are to be in operation). This should be resolved to provide safe and
non-obnoxious handling of the undigested sludge.
e. Positive efforts should continue toward solving the problem of
highway traffic congestion caused by construction and sludge handling
operations.
f. Operational breakdowns have occurred in the past for lack of
manpower and funds. Substantial and continued emphasis should be
put on the requirement for adequate staffing and funding of the ongoing
operation and maintenance of the Plant, to avoid such breakdowns in
the future.
g. Perhaps most important of all is the requirement for the
Environmental Protection Agency to monitor the operation of the Plant
and enforce its standards with respect to the effect of the Plant's
effluents on its surroundings.
NRL fully realizes the ultimate advantages to the entire community of
upgrading the Water Pollution Control Plant, and the resultant enhance-
ment of water quality in the Potomac estuary. Fronting on the Potomac
as much as on Interstate 295, NRL has special reason to appreciate the
aesthetic as well as the utilitarian properties of a great river. f Although
we cannot comment on the specific processes proposed in this plan,
our obligation to provide wholesome working conditions for our staff
and our experience with current Plant operations over recent years
generates a deep interest on the part of NRL in the improvement of the
Plant's capability.
Sincerely your
Copy to:
CHESNAVFACENGCOM
Earl8 IV. Sav;.>
uo?l
a-37 L.'.rocior
2
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Response to Comments of Captain Earle W. Sapp
a. In response to this comment, the District points out that "prechlorina-
tion will be used whenever the hydrogen sulfide range reaches the odor
threshold. This practice will conserve chlorine which is presently in
short supply.
b. The applicant reports out that the "existing primary and secondary sed-
imentation facilities will be refurbished with new equipment as necessary
to bring them in line with new equipment being incorporated in the new
facilities."
c. The District reports that, "Ozone usage in grit chambers is estimated as:
1.7 lb./day/10,000 cfm. x 100,000 cfm. = 17 lb./day. Contact time esti-
mated as 5 seconds in summer and 10 seconds in winter. Resulting ozona-
tion will not be detectable and is considered not to be hazardous."
d. A considerable amount of sludge has been successfully transferred to the
joint U.S.D.A. Agricultural Research Service-Maryland Environmental Ser-
vice composting site at Beltsville since this comment was written. The
only serious accident occurred when a sludge hauling truck shutoff valve
vibrated open causing some sludge to spill on the Beltway. A gasoline
tanker which was following the sludge hauling truck overturned and its
load was spilled near the highway.
The sludge hauling vehicles were modified concrete trucks that were com-
pletely closed to reduce odor emissions. The sludge was treated with an
odor masking chemical that minimized odor production.
In May 1973 a serious odor problem developed in the vicinity of the Blue
Plains STP. This problem occurred because the contents of the existing
plant's digesters were transferred to the excavation for the AWT facili-
ties for temporary storage. This transfer was necessary because a slug
of toxic material (probably copper, chromium, or zinc) had entered the
digesters and was inhibiting the anaerobic digester organisms. The di-
gesters were refilled with non-toxic sludge and brought back on line.
This problem will not reoccur once the expansion and upgrading project is
complete because the new plant will include an incinerator that will burn
raw (non-digested) sludge.
e. The information contained in Appendix c of this document describes the
fact that the project is no longer on the "accelerated" construction
schedule that was envisioned at the time the draft statement was prepared.
Consequently, the work force will be smaller and material and equipment
deliveries will be at a slower rate. Less traffic congestion will be the
end result.
f&g.The Federal grant offers associated with this project are conditioned in
such a manner as to require the applicant to develop a plan to adequately
operate and maintain the treatment plant. The plan will be reviewed by
the EPA Regional Office and final payment of Federal grant funds will not
a-38
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be made until the plan is found to be satisfactory. After the project
is complete and placed in operation, it will be periodically inspected
by the Regional Office's Operation and Maintenance Staff to insure safe
and efficient practices have been adopted. Also, the Regional Office's
NPDES permit program staff will be monitoring the operation of the plant
both during construction and after its completion.
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NATIONAL CAPITAL PLANNING COMMISSION
WASHINGTON, D.C. 20576
[N REPLY REFER TO:
ICPC File No. MP k3 JUL 1 2 1972
Mr. Edward W. Furia
Regional Administrator
U.S. Environmental Protection
Agency, Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
re: Draft Environmental Statement,
District of Columbia (Blue Plains)
Water Pollution Control Plant
Dear Mr. Furia:
We appreciate the opportunity to comment on the Draft Environmental State-
ment for the District of Columbia (Blue Plains) Water Pollution Control
Plant Expansion and Upgrading which you transmitted to the Commission for
review and comment.
The Commission has taken a number of actions since 1969 on the Water Pollu-
tion Control Plant Master Plan and site and building plans submitted by
the District of Columbia Government for individual projects included in the
Master Plan. On May 5, 1969» the Commission approved a preliminary Master
Plan proposing the expansion of the plant capacity to Ul9 mgd. However,
because of objections to the size of the landfill necessary for the U19 mgd
capacity, the District Government reduced the proposed capacity to 309 mgd
through the Memorandum of Understanding on Washington Metropolitan Regional
Water Pollution Control Plant, executed in October 1970, a copy of which is
included in the EPA Draft Environmental Statement.
On February kt 1971» the Commission approved revised Development Concepts
for the Water Pollution Control Plant based on the 309 mgd capacity, and
the following month, on March U, 1971» the Commission approved a revised
Preliminary Master Plan based on this capacity. At that time, the Commis-
sion also approved final site and building plans for the Additional
Primary Treatment Facilities which are now under construction. The Com-
mission subsequently approved preliminary site and building plans for the
Solids Processing Facility on May 6, 1971.
On August 5, 1971> the Commission approved further revisions to the re-
vised Preliminary Master Plan relating to the location of the Docking
Facility and the configuration of the waterfront park along the Potomac
River. The Commission also approved the final site and building plans
for the Solids Processing Facility on this date. Preliminary site and
building plans for the Docking Facility were approved by the Commission
on September 2, 1971» and the final plans for this facility were approved
the following month, on October 7, 1971.
a-40
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The Commission again approved revisions to the Preliminary Master Plan on
June 29i 1972. These revisions included a new site and configuration for
the Multi-Media Filtration Facility and changes in the layout of the
tertiary treatment facilities. The preliminary site and Wilding plans
for the Multi-Media Filtration Facility were also approved on this date.
In each of its actions on the revised Preliminary Master Plan and on the
individual projects within the plant, the Commission has reviewed the
Environmental Statement and the appropriate supplements prepared by the
District of Columbia Government and included as Appendix I in the EPA
Draft Environmental Statement. A supplement to the District Government's
Environmental Statement covering the impact of the Multi-Media Filtration
Facility, which was not prepared in time for inclusion in the EPA Draft
Environmental Statement, was provided for the Commission's June 29, 1972
review of that project.
On the basis of a staff review and analysis of the Draft Environmental
Statement, we offer the following comments and suggestions for considera-
tion in the preparation of the Final Impact Statement:
C l/^ection III on Environmental Impact advises that the Environmental
Protection Agency will make the final determination and recommendation
regarding the location of the plant effluent outfall. The Final Statement
could be strengthened by including not only a description of the definitive
location but also the reason(s) for the selected location. If the location
has not been fixed at the time of the Final Statement, it would be helpful
to include some discussion and comparison of the effects of locating the
outfall in the turning basin and directly in the ship channel. ,
, 2. Section III states that incinerated ash will be'hauled directly from
tnfc-salids handling building to an approved landfill^site. The Final State-
ment could be strengthened by identifying the landfill site, the mode of
transportation of the ash to the site and the steps to be taken to insure
that there will be no adverse effects resulting from the hauling and the
landfill.
; 3. Section III includes a general discussion of the impact of noise
iSl the -plant operation, particularly in the blower buildings and sludge
handling facility and concludes that noise levels within and surrounding
these facilities will be reduced to "less than objectionable" and "a safe
and comfortable range." This discussion could be expanded to include
greater detail regarding the actual expected noise levels and the extent
to which the noise impact would be reduced in these facilities, in the sur-
rounding area within the plant, and in adjacent sites including the Naval
Research Laboratory. The Final Statement could also include information
available with regard to the nature of the environmental health impact of
such noise levels on the employees within these facilities.
U. Section III states that trace amounts of toxic mercury and lead
compounds may be added to the atmosphere with a negligible effect on am-
bient air quality. The discussion of impact of the incinerator emissions
on air quality also notes that any degradation of the quality of ambient
air would be restricted to nearby non-residential areas. Although the area
a-4l
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lurrounding the plant is generally non-residential, the District Government
Loes have two existing residential institutions, D.C. Village and Jr. Village,
.n the immediate vicinity of the Plant, east of the Anacostia Freeway. Jr.
rillage for children is being phased out, but the District Government cur-
¦ently proposes to build a new Childrens Receiving Heme in the same general
irea. In view of the increasing documentation on the potential health hazards
>f metals in the air, it would be helpful for the Final Statement to provide
my available information on potential health impacts as they may affect
;hese existing and proposed nearby institutions. This discussion could be
trengthened by including information on the effect of the prevailing winds
in the anticipated impact of the emissions on air quality in these nearby
j:eas.
5 he Supplement to the District Government's Environmental Statement
ovei the Solids Processing Facility, included in Appendix I, states that
he plant effluent temperature is estimated to rise approximately 2°F. in the
'verall treatment process. The Final Statement might include information
in the intact of this increase in temperature on the aquatic animal and plant
Ife in the vicinity of the outfall.
e appreciate the opportunity to comment on the Draft Environmental State-
lent and look forward to the receipt of the Final Statement.
Iharles H. Conrad
Sincerely yours,
¦Charles H. Conrad
Executive Director
a-42
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Response to Comments of Charles H. Conrad
1. The outfall location is presently tentatively established as the turning
basin. It is reported that vigorous current action exists in that vicin-
ity which should contribute to rapid mixing of the effluent with the es-
tuary waters. However, should water quality measurements taken after the
AWT facilities become operational indicate that the effluent is not ade-
quately diffused, steps will be taken to install an extension of the outfall
to the main channel of the river.
2. In response to this comment, the applicant reports that, "Incinerated ash
will be hauled by Either rail or enclosed trucks, or both, to the regional
landfill in Lorton, Virginia".
3. In response to this comment, the District has submitted the results of a
noise survey of the sewage treatment plant that analyzes the sound levels
at the existing facility. The report recommends specif inactions to reduce
noise and the applicant advises that these recommendations have been im-
plemented at the existing plant and will be followed in the design of the
expanded fiacility. The Noise Survey Report has been included in the text
at this poiitt.
\
During the construction phase, noise will be produced by construction
equipment, delivery trucks, etc. Should the volume of noise endanger the
health and safety of workmen employed at the site, the provisions of the
Williams-Steiger Occupational Safety and Health Act of 1970 (OSHA) require
that appropriate corrective action be taken.
4. A detailed investigation of the potential for adverse public health ef-
fects due to the incinerator emissions was conducted in response to the
comments of the Natural Resources Defense Council, Inc. (See "Response to
Comments of David G. Hawkins", this appendix). While the investigation
found that the emissions, "should not constitute a threat to public
health in the vicinity of the sewage treatment plant" it also pointed to
the need for further investigation of this problem. As the results of
these further investigations become available, they will be compiled and
released as a supplement to this final impact statement. Should these
studies find that incineration is not acceptable because of public health
considerations, one of the alternate sludge disposal techniques described
in the preface to this statement will be adopted.
5. In response to this comment, the applicant replies, "During the most cri-
tical months of June, July, and August the temperature of the wastewater
is several degrees cooler than the river water temperatures, and there-
fore, the estimated 2 F rise in wastewater effluent should have no adverse
effect on the animal and plant life in the vicinity of the outfall".
a-43
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60 Mr !!on Street
Cambridge, Mass. 02138
Telephone (617) 491-1850
Bolt Beranek and Newman Inc.
15 March 1972
Metcalf & Eddy
Statler Building
Boston, Massachusetts 02116
Attn: Mr. George K. Tozer
Subject: Noise Survey of Sewage Treatment, Plant
District of Columbia
BBN Job No. 138741
Gentlemen:
On. 8 March 1972 a series of noise ana vioration measurements
were conducted in the existing blower -building of the District
of Columbia Sewage Treatment Plant to determine appropriate
measures for reducing the interior noise levels. Included
in this brief letter report are the main results of these
measurements and our principle conclusions.
The essential results of the noise level measurements are
shown in Fig. 1. In this figure the sound pressure levels
(SPL's) in decibels are given for each octave band covering
the audio frequency range. As can be seen in every location,
the highest sound level was found to occur in the 1000 Hz
(CPS) octave, which covers the range of 700-1400 Hz. The
sound in this band is strongly dominated by a tone, or a siren
Like sound. Analysis of tape recordings made at the site
show that the tone frequency is about 1200 IIz.
Combining this tonal data with information obtained from the
slower manufacturer, Cooper-Bessemer, it is now clear that the
tone at 1200 Hz, which is clearly the annoying sound, is due
to the blowers. The two stage centrifugal blowers, Type RF2S,
and rated at 1750 HP, are driven at a speed of about 3600 RPM,
60 RPS. As it has been found that each compressor stage
las 20 blades, it is seen that the blade passage frequency is
L200 Hz (60 RPS x 20 blades)f and thus the tone is clearly
jenerated by the blowers.
RECEIVED
fcPR 261973
— ¦ — mfb
¦MlTjaif a mi t:;c.
/
-------
Metealf & Eddy
15 March 1972
Page 2
Recommendations
From the results in Fig. 1, plus other measurements close to
the pipes and blowers, and vibration measurements on the pipes,
it is clear that the sound at 1200 Hz is radiated principally
from the piping. Also in particular the sound is radiated
from the flexible expansion joints at the intake and discharge
flanges just beneath the blowers. At these joints, we found
the highest SPL, namely about 130 dB at 1200 Hz.
To reduce the sound at 1200 Hz, it is quite clear that the
most effective measure would be to provide a noise control
wrapping for the blower system pipes, fncl*uding the expansion
joints just below the blowers. The piping that is radiating
the highest levels appears to be the discharge pipe between
the blower and the cone valve system, and then the discharge
piping in the cross corridor. However, the intake pipe is
also radiating at 1200 Hz and shorild also be treated. Thirdly,
even the compressor housings on the blower are radiating to
some extent. It is, however, believed that the SPL in the
blower room and the control room at 1200 Hz is primarily
controlled by the radiation from the expansion joints and
the piping in the basement. Thus, wrapping the basement
piping and the expansion joint should reduce the noise in the
blower room by a significant degree before the sound radiated
-directly from the blower becomes controlling.
Finally, in regard to the piping, the mufflers in the intake
and discharge piping can do a reasonably good job of reducing
the sound transmitted in the air. However, the pipe v/all also
carries the sound and the energy in this path can by-pass
the muffler and couple back into the air path. Thus, to
enhance the performance of such mufflers, it might be useful
to provide a resilient break in the pipe wall before and after
the muffler. If this cannot be done, it is perhaps preferable
in a new system to omit the discharge mufflers and just provide
pipe wrapping. However, in the intake system, the muffler in
the present installation is probably doing some good, as there
is no extensive piping after the muffler.
Based on the data in Fig. 1, it would be desirable to reduce
the SPL at 1200 Hz by the order of 30 dB in the basement,
20 dB in the corridors, and 10 dB in the blower room, as well
as 10 dB in the control room. If the 30 dB reduction is achieved
in the basement, it is expected that the 10 dB reduction would
also be achieved in the blower and control rooms. To accomplish
a-45
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Metcalf & Eddy
15 March 1972
Page 3
this reduction, the pipe wrapping should consist of several
inches of glass fiber, and an outer impervious wrapping.
The glass fiber should be between 2 and 4 in. thick, and the
outer cover should weigh close to 1 lb/sq.ft. However, the
thickness and fiber size of the glass fiber can influence
the requirements for the outer cover. Another possibility
is to use one form of wrapping for the piping nearest the
blower, and a less expensive wrapping in the corridor.
For the discharge pipe between the blower and the cone valve,
and for the intake pipe between the blower and the intake
muffler, it is suggested that you consider using a 3 in.
thick wrapping of Owen Corning Tyoe 70 2, and a leaded asbestos
cloth, Type 8266 (wt. 1.25 psf), as made by the Thermoid
Division of H. K. Porter.Co. in Charlotte, N.C. For the
remaining piping, the outer wrapping could be a less expen-
sive cloth, and possibly the glass fiber thickness could be
reduced to 2 in.
Please let us know if you have any questions on this letter
report, or if we can be of further assistance.
Sincerely,
BOLT BERANEK AND NEWMAN INC.
Robert M. Hoover
RMH/jpk
Enclosure: Fig. 1
ai46
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DEPARTMENT OF TRANSPORTATION
UNITED STATES COAST GUARD
US coast guard (WEP-2/73)
400 SEVENTH Stdeet sW.
WASHINGTON. D C. MX* 20590
PHONE: 202-426-9573
mailing ADDRESS:
* 5922/19
19 JUL 1972
Mr. Edward W. Furia
Regional Administrator
Environmental Protection Agency
6th & Walnut Sts.
Philadelphia, Pennsylvania 19106
Dear Mr. Furia:
We have reviewed the draft environmental impact statement for the
Water Pollution Control Plant in the District of Columbia and have
the following comment to offer.
Although the proposed regulations for oil transfer facilities will
pertain only to the area in which the actual transfer is taking place,
and not to adjoining tank farms, we would like to recommend that pro-
vision be made for placing dikes around each of the storage tanks to
insure that any accidental leakage from the tanks is contained.
Thank you for the opportunity to review this environmental statement.
Sincerely,
/ S. A. WALLACE
Captain, U. S. Coast Guard
Chief, Marine Environmental
Protection Division
By direction of the Commandant
a-48
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Response to Comments of Captain S. A. Wallace
In response to this recommendation, the applicant reports that suitable dikes
will be provided to contain any accidental leakage that may occur.
a-49
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UNITED STATES OF AMERICA
GENERAL SERVICES ADMINISTRATION
Washington, d.c. awos
Mr. Edward W. Furia
Regional Administrator
Region III
U.S. Environmental Protection Agency
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Furia:
A.s requested in your recent letter, the General Services
Administration has reviewed the draft environmental impact
statement in conjunction with plans to expand and upgrade the
existing Water Pollution Control Plant in the District of Columbia.
On page 24, under the item "Interim Treatment, " there is the
statement that consideration is being given to the addition of
metal salt (alum or ferric chloride) to the existing secondary
treatment units. It may be of interest that results of similar
activities at our Pentagon Sewage Treatment Plant lead us to
strongly recommend this consideration. By feeding 400 to 500
pounds per day of liquid ferric chloride along with a polymer, we
were able to reduce the phosphate content of our effluent from
30 parts per million to one-half part per million. As an interim
treatment, this procedure has much benefit in reducing nutrient
content.
Our review of this draft environmental statement discloses no
problems of concern to this agency.
Sincerely,
KOD KREGER
Deputy Administrator
a-50
Keep Freedom in Your Future With U.S. Savings Bonds
-------
BALTIMORE DISTRICT. CORPS OF ENOINKKRB
P.O. BOX 17IB
BALTIMORE. MARYLAND 21ZOS
DEPARTMENT OF THE ARMY
NABPL-E
4 August 1972
1.
I.
3.
Mr. Edward W. Furia
Regional Administrator
Region III
U.S. Environmental Protection Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Furia:
In reply to your letter of 8 May 1972, we have reviewed the draft environmental
impact statement in conjunction with plans to expand and upgrade the existing
Water Pollution Control Plant in the District of Columbia. Our comments are
submitted in accordance with provisions contained in the National Environmental
Policy Act of 1969 (Public Law 91-190).
It is desirable that the potential for flooding at the site be considered and
the resulting consequences if the site or a portion of the facilities are
flooded. The plant should remain in operation during high water if possible
and damages avoided or minimized including resulting pollution of the Potomac
River due to untreated sewage. By-passing flow from combined storm sewer and
sewage pipelines should also be avoided if possible. The elevations of the
100-year and 50-year flood frequency in the vicinity of the site are 13.2 feet
above msl and 10.8 feet above msl, respectively.
A map of the general area would be beneficial to show the three reaches referred
to on page 6 of the EIS, to show the relationship of the Blue Plains site to
Dykes Marsh, and to provide a better understanding of the site in relation
to the surrounding area. Figure 1 on page 16 is of poor quality. The earth
berm shown on Figure 1 should be identified and its purpose explained in the
text.
The relationship of the water demands, wastewater flows, and population projec-
tions between the Washington Metropolitan Area and the Blue Plains Service Area
as given on pages 6 through 14 could be better explained to avoid the possibil-
ity of confusion to the reader. A clearer explanation of the need for other
additional regional wastewater treatment facilities would also aid the reader.
a-51
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NABPL-E
Mr. Edward W. Furia
4 August 1972
A map showing the sewer lines discussed on pages 26 and 2 7 would enable a better
understanding of the effect of the plant expansion and upgrading on that system.
On page 33, the EIS says that "eutrophication created by excessive discharges
of nitrogen can only be controlled by reducing the level of nutrients discharged
from domestic wastewater treatment facilities in the upper Potomac Estuary."
Nutrients are most likely also introduced from agricultural sources and from
storm sewer runoff causing eutrophication.
On page 34, there is a conflict in the values for nitrogen which indicate a
reduction from 47,500 lbs/day to 61,130 lbs/day.
A Department of the Army permit will be required for any extension of the out-
fall conduit into the main navigation channel which is mentioned as a possibil-
ity for the future on page 36.
Genus names given on page 42 should be underlined which is a generally accepted
practice in professional writings.
There is no section "C" between pages 76 and 80. The EIS is either labeled
wrong or a section has been omitted.
The discussion on the use of the area north and west of Washington for land
disposal should be expanded rather than merely saying on page 84 that they were
not considered practical because of pumping through or around the city. This
alternative location for land disposal could be further developed and its
advantages and disadvantages discussed.
Also, on page 84, the areas in Prince George's and Anne Arundel Counties could
be preserved for future land disposal. The potential this has as an alternative
could be presented.
The potential use of areas in Virginia for land disposal and the impact of
using those areas should be considered and discussed as an alternative rather
than not considering at all as stated on page 84.
The EIS refers to pumping raw sewage on page 88, paragraph 2, and discusses
its disadvantages. The sewage could receive secondary treatment prior to trans^-
mission to the land disposal area rather than secondary treatment at the land
disposal site.
2
a-52
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NABPL-E
Mr. Edward W. Furia
4 August 1972
On page 89, the effects of increased flows in local streams would also be to
add to low flows which would be an advantage.
Pumping to farm land for land disposal as discussed on page 95 appears to have
been abandoned without investigating if arrangements could be agreed on to
cross the State line.
On page 102, the possibility of obtaining permission to install a parallel
railroad line through the military base does not appear to have been investigated
In Appendix D, there is no identification of whose design criteria for spray
irrigation is included in the appendix.
Further data on how often barges will operate due to the facilities and addi-
tional information on safeguards against spills during operations associated
with barging would be beneficial.
These comments are offered as suggestions to aid your office in preparing a
comprehensive and detailed final EIS. As requested, the Council on Environ-
mental Quality has been furnished copies of this correspondence.
Sincerely yours,
WILLIAM E. TRIESCHMAN, Jr
WILLIAM E. TRIESCHMAN, Jr.
Chief, Planning Division
3
a-53
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Response to Comments of William E. Trieschman, Jr.
1. In response to this comment, the applicant reports that the potential
of flooding was considered in the design of the facility and that the
"Site will not be subject to flooding even under 100 year storm
frequencies." Also, the "plant site experienced no flooding problems
during storm Agnes in 1972." Critical treatment units are above the
referred to elevations.
With respect to bypassing, the NPDES permit found in Appendix b of
this statement is designed to require the District to operate the
sewerage system in such a manner as to "Minimize the discharge of
pollutants to the river and to maximize the achievement of water
quality objectives."
2. A map entitled Potomac River Tidal System has been reproduced from
T.R.35, modified to show the location of the Blue Plains Wastewater
Treatment Plant and Dyke Marsh, and inserted following Page 4 of
this statement. Also, Figure 1 has been revised and the reference
to the Earth Berm has been eliminated.
3. The material that was presented on Pages 6 through 14 has been revised
and updated to reflect present conditions. The role of Alternate
Regional Facilities at Piscataway and in Montgomery County are briefly
described in this text. For more information on this subject, the
reader should consult the "Regional Sanitary Facilities - Potomac
Drainage Areas" prepared by the Maryland Environmental Service.
4. Most of the discussion on these pages was devoted to the so-called
"Georgetown Gap" which has since been eliminated. Therefore, a map
showing the various sewer lines discussed in the draft would serve
no useful purpose. A map showing the location of the Potomac Interceptor
and the District's Project "C" has been substituted instead.
5. Section III B.l of this document has been revised to include information
which describes the fact that waste load allocation studies are being
conducted on the free flowing segments of the Potomac to determine
background nutrient concentrations. These studies will provide data
which will be used to draw conclusions concerning the impact of non p°in£
Sources on the Potomac.
3. The text has been corrected.
7. The applicant is believed to be aware of this requirement,,
30 The text has been corrected.
3. Section "C" (Other types of treatment considered) began on Page 58 of
the draft statement and extended through Page 80.
a-54
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Response to Comments of William E. Trieschman, Jr.
10. Several studies made since the date of the comment have examined the
feasibility of land disposal in areas adjacent to Washington and
recommended in favor of conventional advanced wastewater treatment
facilities instead. Selected studies are listed below.
1. "Wastewater Treatment Study - Montgomery County, Md."
By CI^M-Hill Engineers
November 1972
2. "Lower Potomac Basin Wastewater Facilities Study"
By Bechtell, Inc.
November 1972
11. The second of the studies listed above considered land disposal in
Prince George's County but recommended a system based on conventional
advanced wastewater treatment.
12. The response to comments Number 10 and 11 are also applicable to this
comment.
13. While it is quite true that the transmission of secondary effluents
is a possibility and it is also true that a rupture in a conduit
carrying secondary effluent would not be as serious as a break in a
line carrying raw sewage, the material presented on Page 88 of the
draft statement has been included in the final text because land
disposal sites located north or northwest of the metropolitan area
(as suggested in Comment No. 10) would probably receive raw sewage
from nearby Montgomery County rather than secondary effluents which
would be pumped all the way from Blue Plains.
14. The draft statement listed the "Advantages", "Disadvantages" and
"Unknowns" associated with spray irrigation (Pages 86-90 of draft
statement). The effect of increased flows on local streams was
addressed in "Unknowns" precisely because the effect could be either
adverse or positive, depending on circumstances associated with the
specific stream in question.
15. Potential jurisdictional obstacles were only one of the problems
associated with this alternative. Please see "Summary of Sub-
Alternatives for Sludge Disposal" which is found in Section V of
this text for the major disadvantage of this method.
16. The potential for right-of-way acquisition problems was only one of
the drawbacks associated with this transportation mode. Please see
Section V of this statement for the major disadvantage of this mode.
2
a-55
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Response to Comments of William E. Trieschman, Jr.
17. The "Tentative Design Criteria for Spray Irrigation for the Disposal
of Sewage Effluents Which Have Received Secondary Treatment" were
developed by the Commonwealth of Virginia's Department of Health.
Line Number 3 on Page No. 85 of the draft statement pointed out that
the design criteria were developed by- the State of Virginia.
18. The District reports that "It is proposed that chemicals for treat-
ment purposes and fuel oil may be received by barge. Rail facilities
will also be available for receiving chemicals. The frequency of
barges arriving and departing from the site will greatly dependent
on the results of competitive bidding which would determine whether
or not the materials are brought in by barge or by rail. All barging
operations will be conducted in accordance with the latest applicable
Coast Guard regulations."
Also, the District reported that "the contemplated design features to
safeguard the storage, handling, etc. of treatment chemicals will con-
sist of the following:
a. 'To prevent overflows, etc. during transfer of chemicals to the
Chemical Building, a system of freeboard, alarms, plus automatic
overflow in an enclosed gravity pipeline to an underground storage
tank outside of the building'.
b. - 'To capture spills, leakages, etc. from pipelines and tanks a
system of curbs, sumps, and pumps to send chemicals to the under-
ground storage tank outside of the building'.
c. 'Such collected overflows, spills, leakages, etc. could then be
pumped from the underground tank either back into the system, or
if conditions warrant, removed by tank truck for disposal else-
where 1.
3
a-56
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I
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
ER-72/535 AU6 7 1972
Dear Mr. Furia:
In response to your letter of May 8, 1972, we have reviewed the
draft environmental statement on the proposed expansion and up-
grading of the Water Pollution Control Plant in the District of
Columbia and offer the following comments.
General Comments
The effects of fill construction at the Oxon Cove site may be
negligible until work approaches the water's edge. At that time,
wave action and flood tides will cause erosion and subsequent
sediment action downstream unless bulkheads are constructed.
Whether or not bulkheading is planned was not made clear in the
description of the Oxon Cove work.
With regard to spoil disposal at Dyke Marsh, any necking down of
a river causes two reactions: (1) channel and edge scouring and
(2) back pressure upstream. In effect, this is what created the
original Dyke Marsh. During the future marsh development period,
which includes plant root development and the completion of secondary
consolidation, ordinary and extreme high water levels may be expected
to wash away a portion of the marsh edges, causing long-range siltation.
This effect will be duplicated by continued washing of the proposed
spoil areas adjacent to the Blue Plains site and the river channel.
The plant will be designed for 309 mgd, and it should adequately
treat that amount of sewage. The adequacy of adjacent existing,
upgraded, or new plant facilities is highly questionable if it is
based on the criteria established in the report. The report indicates
that by 1980 the Metropolitan Area will increase waste flows by
45 percent, and Washington, D.C. , alone by only 4 percent; by the
year 2000, the area waste flow will increase 204 percent, and Urban
Washington only 14 percent; and by the year 2020, the area increase
will be 413 percent and Urban Washington only 28 percent. The
reasoning given for such minimal expansion in Urban Washington is
that the city has fully expanded. A fallacy in thinking is that
60 percent of Washington now consists of two-story single-family
dwellings which are presently being replaced by eight-story multiple-
family dwellings. Vertical expansion is far from complete. Because
of this, the Blue Plains plant, physically limited in size, could be
inadequate at 309 mgd.
a-57
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The water quality design flow, 7-day - 10-year flow, will be
616 mgd. In the 20-year period from 1980 to 2000, the water
demand on the Potomac River will increase from 556 to 1,009 mgd.
Upon plant completion, the design flow for full treatment will be
309 mgd in 1977.
Hydraulically, plant units will be designed to handle flows of
' 650 mgd. During rains or heavy storms, the input therefore will
receive degraded treatment to a point of grit removal only. This
is expected to occur approximately 400 hours per year. Flows in
excess of 939 mgd will either become septic during the holding
period within the sewerage system or else be discharged raw in the
upstream Potomac and Anacostia Rivers. This is expected to occur
for a period totaling 240 hours every year, or 10 full days. Water
quality standards during these periods will be additionally degraded
by the retention dams to be constructed at points above the Potomac
Estuary which are to control the river design flow to 616 mgd.
Therefore, for a period of 640 hours, a flow totaling 630 mgd of
partially treated and/or raw sewage will enter the upper Potomac,
14 mgd in excess of the future design flow.
The major weakness is a lack of certainty as to how the sludge
incinerators will perform. The elaborate calculations on percentage
increase of air pollutants are meaningless, since they are based
only on estimates of the quantities of materials in furnace effluents
Another unresolved problem is the effect of dredging upon water
quality and aquatic organisms. A third uncertainty is the efficiency
-and operational maintenance of the newly developed and unproven
denitrification process.
The applicant should determine the probable effect of the heat load
on the river water temperature under the worst conditions anticipated
such as minimum flow at times of maximum seasonal ambient water
temperature. The results determined should then be evaluated in
terms of State and Federal standards. The estimated increase of
2°F in the effluent from the subcooler may represent a sizeable heat
load in view of the 309 mgd design specifications for the plant,
Specific Comments
Page 34, paragraph 2. The figure given for reduced nitrogen,
61,130 lbs/day, is apparently a typographical error, if it is to
agree with line 2 of the paragraph.
2
a-58
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Page A-2, paragraph 3. The sentence should read, "...restricted
to areas deeper than eight feet."
Page A-4, paragraph 2. The discussion in this paragraph should
be revised to reflect the National Capitol Parks amendment to
dumping permits, which defines maximum amounts of heavy metals
that will be accepted as fill at the Dyke Marsh area of the
George Washington Memorial Parkway.
The final environmental statement should reflect compliance with
" the Historic Preservation Act of 1966 by indicating consultation
with the National Register of Historic Places.
We appreciate the opportunity to review this statement.
Mr. Edward W. Furia
Regional Administrator
U.S. Environmental Protection Agency
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Deputy Assistant
Sincerely yours,
Secretary of the In
3
a-59
RECEIVED
.H 1972'
MFB
-------
Response to Comments of W. Lyon
1. During fill construction, stone rip-rap was placed in that portion of
the fill susceptible to wave action. Also, sewage sludge was available
for application to seeded areas; therefore, vegetation quickly became
established and minimized erosion. Finally, silt collection basins
were constructed to contain the sediment load carried by the plant
storm drainage system.
2. This comment is difficult to interpret. If it is an objection to
dredged spoil disposal at Dyke Marsh, Appendix A of the draft statement
addressed that subject in considerable detail and reported (in the
summary on Page A-6) that "Tests have disclosed no adverse effect on
water quality from spoil disposal." If it is an objection to fill
construction at the Blue Plains site, it is addressed in Response No. 1
above. Finally, if it is directed to the disposal of stockpiled sludge
and excess excavation, a substantial portion of this material was
subsequently disposed of on land owned by the Department's National Park
Service and located quite a distance from the river.
3. Recent wastewater planning for the Maryland portion of the metropolitan
area has recognized that the 309 MGD design capacity of Blue Plains is
inadequate to serve the area's future needs and design work is underway
for a relief facility to be located in Montgomery County, Maryland.
Another relief facility is planned for the Piscataway, Maryland vicinity.
The plans also propose a transmission facility connecting the Anacostia
drainage area to Blue Plains and to Piscataway. Ultimately, the Maryland
side of the Potomac in the Washington area will be served by three
regional, connected treatment plants: Montgomery County - Blue Plains -
Piscataway.
4. Section I-B of this text has been updated and it points out that serious
consideration is presently being given to constructing facilities that
will tap estuary water as a supplemental source of water supply.
5. With respect to the contention that: "For a period of 640 hours, a flow
totaling 630 MGD of partially treated and/or raw sewage will enter the
Potomac", the reader is directed to the draft NPDES permit found in
Appendix b of this text which will establish effluent quality requirements
for the plant discharge. Once the expansion and upgrading project is
complete (by January 1, 1978), the discharge is limited to 12,700 lbs/day
of BOD^, 18,100 lbs/day of suspended solids, 560 lbs/day of total
phosphorus, and 6,130 lbs/day of total nitrogen during any consecutive
30-day period. Furthermore, the permit requires that "Short-term flows
at a rate of up to 650 million gallons per day (MGD) or 2,460,000 cubic
meters per day shall receive complete treatment." Finally, with respect
to the combined sewer system, the applicant is required by the permit to
a-60
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Response to Comments on W. Lyon
operate the treatment plant and sewerage system in such a manner as to
minimize the total quantity of pollutants discharged and eventually to
develop long-range solutions to eliminate or abate pollution discharges
from the system.
6. Please see "Response to Comments of David G. Hawkins" in this appendix
for a detailed discussion of this topic.
7. Appendix A of the draft statement addressed the subject of dredging and
spoil disposal and described the precautions taken to minimize adverse
impacts by selecting equipment that would produce minimal disruption
to the environment. The summary found on Page A-6 of that appendix
indicated that water quality measurements were taken at Dyke Marsh,
Blue Plains, and in the Potomac across from the marsh and that no
adverse effects were found.
Table I (see Page 16) has been revised to include the results of the
EPA-DC Pilot Plant operation in place of projections made by the designer.
During the period from July to December 1972, the concentration of total
nitrogen averaged 1.40 mg/1 in the pilot plant effluent. This concentra-
tion is well below the 2.39 mg/1 concentration that can be calculated
from the NPDES permit limitations of 6,130 lbs/day and 309 MGD.
8. Please see "Response to Comments of Charles H. Conrad", No. 5
9. An error was made and the text has since been corrected.
.0, 11. These comments are noted but it is felt that there is no need to include
Appendix A of the draft statement with this final statement merely to
make the suggested relatively minor revisions.
12. Copies of this final statement are being directed to the District of
Columbia's State Liaison Officer on Historical Preservation and to the
Advisory Council on Historic Preservation. However, no Historical
Register Properties are believed to be affected by this project.
a-61
2
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MARVIN MANDEL
GOVERNOR
MARYLAND
Department of State Planning
301 WEST PRESTON STREET
BALTIMORE. MARYLAND 21201
TELEPHONE 301-3B3-245!
August 2lt, 1972
VLADIMIR A WAHBE
SECRETARY OF STATE PLANNING
EDWIN L. POWELL, JR.
DEPUTY SECRETARY
Mr. Edward W. Furio
Regional Administrator
U. S. Environmental Protection Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
SUBJECT: ENVIRONMENTAL IMPACT STATEMENT REVIEW
Applicant: Environmental Protection Agency
Projects District of Columbia Water Pollution Control Plant -
Expansion and Upgrading
State Clearinghouse Control Number: 72-5-181;
State Clearinghouse Contact: Edwin L„ Powell, Jr. (383-2U67)
Dear Mr. Furio:
The State Clearinghouse has reviewed the above noted Environmental Impact Statements
In accordance with the procedures established by the Office of i-lanagement and
Budget Circular A-95, the State Clearinghouse received comments (copies attached)
from the following:
Department of Health and Mental Hygiene: the Division of Water Supply and
Sewerage found the statement acceptable and reiterated approval of the project*
The Bureau of Air Quality Control recommended approval and noted that incinerator
emission controls are satisfactory.
Department of Natural Resources: evidenced approval by stating that the
improvement to the treatment facility is a top priority goal in the effort to
improve water quality in the upper Potomac estuary.
IOur staff suggested that the statement should address the implicit adverse
. environmental effect of the project on water quality in other .Maryland water
courses if the Federal share 01 Maryland's portion of the financing is taken from
those Federal funds normally allotted to Maryland for water quality control projects.
This negative impact will be avoided if the Federal share of the State's funding
is allocated from discretionary funds, thus permitting the continued funding of
other projects designed to improve water quality throughout the State0
a-62
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2
We hope that these comments will assist you in the preparation of your final
statement and look forward to continued cooperation with your agency in the
Clearinghouse review of the complete project presentation.
Enclosures
cct W* DfcLean Bingley
Jean J® Schueneman
Anthony Abar
Larry Fogelson
Walter Scheiber
Sincerely,
Hiti
Vladimir Wahbe
RECEIVED
SEP-51972'
MFB
a-63
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DEPARTMENT OF HEALTH AND MENTAL HYGIENE
Neil Solomon, M.D., Ph D., Secretory
ENVIRONMENTAL HEALTH ADMINISTRATION
610 N. HOWARD STREET
BALTIMORE, MARYLAND 21201
Areo Code 301
383
-2763
June 9, 1972
Mr. Edwin L. Powell, Jr.
Deputy Secretary-
Maryland Department of State Planning
301 West Preston Street
Baltimore, Maryland 2120}.
RE1 Water Pollution Improvements
Dear Mr. Powell1 District of Columbia
We have your letter of May 16 attaching a draft of the
Environmental Impact Statement prepared by the Environmental
Protection Agency concerning the Blue Plains Water Pollution
Control Plants The summaiy sheets shown on Pages i through
iii are in agreement with the comments we have previously
made and you will recall that my memorandum of October l£>
1971, included as sheet M27 of this document, clearly indicated
our approval to the project.
It is, therefore, our judgment that the Environmental Impact
Statement adequately fulfills the legal requirements for the
preparation of the Statement and is acceptable to this office*
Very truly yours,
uj. nvX.w 7^,rj
W. McLean Bingley, P. E.
Chief, Division of Water and Sewerage
WMeLR:ib
| ......,
j . „ ii, C d i V E D
; JUN 1 3 1972
a-64
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STATE OF MARYLAND —DEPARTMENT OF HEALTH AND MENTAL HYGIENE
Washington D.C. Health Dept.
Air Pollution Division
Mr, Edwin L. Powell, Jr.^Chiegrom Jean J. Schueneman,Director Hnfrw May 31 > 1972
State Clearinghouse Bureau of Air Quality
5^|kjAr» Water Pollution Plant Improvements - D.C.; Control Ng« 72-5-l8li
The Bureau of Air Quality Control is satisfied with the plans for the Blue
Plains sludge incinerator. Emissions are being controlled as much as technically
feasible and should pose no health hazard. We recommend approval of the project.
a-oo
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. w.:i'ate mm
. .1 mL, ^ « I V E lJ
23 1972
'.: '"en i
f
Date: August 21, 197?
Knryland Department of State Planning
State Office Building
301 VJest Preston Street
Baltimore, Maryland 21201
SUBJECT: PROJECT SUtHlAP.Y HOTI^ICATICN REVI'-'V;
Applicant: Environmental Protection Agency
Project: Water Pollution Control Plant Improvements
State Cle-:rin.rhcusc Co:itrol dumber: 72-5-1814.
D a C ,
CHECK ONE
1« This agency coes not have an interest in the ahove project.
2. The above rroiect is consistent vith this afencvrs plar>!; or
objectives and vie recommend approval of the proicct. •
This aponcv has further interest in and/or Questions concerning the
above project and wishes to confer irith th.p anolicvnt.
Cur interest or cucstio.in are shown on enclosed atU\chrront.
ll. This agency noes not holievc a conference is neco.'isnrv, hut wishes to
make favorable rr onnlifyinr consents shewn on enclosed attachment. XXX
Signature - . l' '/'/?/¦ ^V- ''
Title Chief. Planning & Evaluatic
^ency Dept0 of Natural Resources
-------
E$ D. COULTER JOSEPH H. MANNING
secretary STATE OF MARYLAND obputyokcrstarv
DEPARTMENT OF NATURAL RESOURCES
STATE OFFICE BUILDING
ANNAPOLIS 21401
August 21, 1972
COMMENTS OF THE DEPARTMENT OF NATURAL RESOURCES ON PROJECT #72-5-181*.
Water Pollution Control Plant Improvements - D.C.
The Department of Natural Resources wishes the proposed
improvements of the Water Pollution Control Facilities to proceed
as quickly as possible#
The expansion and upgrading of the District of Columbia
Water Pollution Control Plant at Blue Plains is an essential
element in the ongoing effort to improve the water quality of
the upper Potomac estuary®
This treatment plant now receives considerable flow from
Montgomery and Prince George's Counties in Maryland, and since
the Potomac River supports valuable natural resources of direct
and indirect value to the State, improvement of treatment at this
plant is viewed by Maryland as a top priority goal9
a-67
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Response to Comments of Vladimir Wahbe
1. The Federal Water Pollution Control Act was amended in October of 1972
to provide that Federal Construction Grant Funds be allocated to the
States on the basis of their "Need" for wastewater treatment facilities
as measured in a joint Federal-State "Needs" survey. Maryland's share
of Blue Plains was entered as a "Need" in the survey so it would seem
that the construction grant funds should be taken from the normal
State allotment. The 1972 ammendments also provide that funds which
are not used by a State within one year after the end of the fiscal
year for which they were appropriated shall be realloted among all
the other States which have used their full allotment. Therefore,
there is no possibility of a "Discretionary" appropriation as suggested
in the comment.
a-68
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METROPOLITAN WASHINGTON COALITION FOR CLEAN AIR, INC.
1714 MASSACHUSETTS AVENUE, N.W.. WASHINGTON, D.C. 20038 (202) 785-2444
November 7> 1972
Mr. Robert J. Blanco
Environmental Impacts Statements Branch
EPA - Region III
6th & Walnut Street
Philadelphia, Pennsylvania 19106
Dear Mr. Blanco:
I have been informed that you never received the MWCCA
comments on the Blue Plains treatment plant 102 Statement.
Enclosed is a copy of said statement -which was endorsed and
sent to the Region III office by Scott Lang, Environmental
Defense Fund.
I hope you will be able to discover why this statement never
reached you.
Thank you for your attention.
JSW/sh
Enclosure:
a-69
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Metropolitan Washington coalition for clean air, inc.
1714 MASSACHUSETTS AVENUE, N.W., WASHINGTON, D.C. 20030 (202) 785-2444
STATEMENT OF JOHN S. WINDER, JR., EXECUTIVE DIRECTOR
METROPOLITAN WASHINGTON COALITION FOR CLEAN AIR
RE: DISTRICT OF COLUMBIA WATER POLLUTION CONTROL PLANT
(DRAFT ENVIRONMENTAL IMPACT STATEMENT)
BEFORE: U.S. ENVIRONMENTAL PROTECTION AGENCY
June 1972
These comments are directed at those portions of the above-
cited Draft Environmental Impact Statement which relate to the
impact of the proposed facility on the air resources in the
National Capital Interstate Air Quality Control Region, (partic-
ularly page 38 — U2 -- "Effects of Plant Operation on Air Resources;
^.nd pages C 1 - C 40 -- Appendix C - "Sludge Incineration").
(1) The Impact Statement "Summary Sheet (p.i) included the
following statement: "Adverse Environmental Effects: (l) Negligible
effect-s on ambient air quality." This statement is highly cate-
gorical, unsupported, and, in fact, open to question by the data
cited in the Statement. The Statement, for example, states that
the incineration process will create the following major air
pollutants: N0X -- 198 tons/year; SO2 -- 206 tons/year. It is
inaccurate to suggest that an impact of this magnitude is "negligibl
(2) The air pollutants will have a particularly adverse effect
on the high concentration of persons in the three facilities
immediately adjacent to the proposed facility -- D.C. Village, U.S.
Naval Research Laboratory, and the Anacostia Freeway.
-------
MWCCA
E.P.A.
Blue Plains
June 1972
page 2
(3) This large concentration of emissions is inconsistent
with and in violation of the District of Columbia Air Quality-
Implementation Plan, adopted pursuant to the Federal Clean Air
Act of 1970. In general, these emissions will violate the non-
degredation policy embodied in the Clean Air Act, supported by the
EPA Implementat ion..Plan Guidelines, and required by the recent
Federal Court decision in Sierra Club et al¦ v. Ruckelshaus.
In particular, the increased emissions from this facility will
make increasingly difficult, if not impossible, the attainment of
the Federal ambient air quality standards for N0X -- (0.05 ppm).
Data compiled from the District of Columbia CAMP station for a period
from May 21 through December 13, 1970 and from January 1+ through
March ll+, 1971 indicated an arithmetic mean concentration of N0X
of 0.05U ppm -- currently exceeding the federal standard.
(U) The wind patterns for the District of Columbia indicate
that during the warmer months the prevailing winds are southerly
and southwesterly -- which will carry the pollutants over the most
heavily* populated, low income area of the District. It is also
during this time of year that the formation of photochemical smog,
which is increased by the addition of N0X, is most prevalent.
(5) It is undisputed that the automobile traffic on the
Anacostia Freeway is a substantial source of N0X; and during the
warmer months these pollutants will mix with the N0X concentrations
a-71
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MWCCA
E.P.A.
Blue Plains
June 1972
page 3
caused by the proposed facility to create a more intense and
harmful "burden on the residents north of the facility.
(6) IN CONCLUSION, it is clear that additional controls of
air pollutants from this proposed facility must "be required. A
cbmmitment must be made for not only the application of the maximum
existing control technology but also the periodic application of
future advances in control technology.
-------
Response to Comments of John S. Windner, Jr.
In response to these comments, the Staff which prepared Appendix C replied:
1. "That our conclusion of a negligible effect on ambient air quality is
'highly categorical, unsupported, and in fact, open to question1 is
false. A thorough analysis was performed, and its results (on pps. C24,
C25*) support our contention of an acceptably minimal impact."
2. "D.C. Village, the U.S. Naval Research Laboratory, and a portion of
the Anacostia Freeway all are within the distances for which ambient
air concentrations of pollutants from the incinerator were calculated
(pps. C24, C25*). These indicate that concentrations at the above
facilities will increase only slightly because of incinerator emissions."
3. 4, and 5:
"Although strategies for attainment of the ambient N0X standard
in Washington, D.C. have not been fully defined yet, it is anticipated
that the standard will be attained within the time constraints allowed."
6. "This proposed facility will already employ controls at the limits of
present technology (p. C33*). The recommendation that '...additional
controls ... must be required' thus cannot be acted upon."
a-73
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Natural Resources Defense Council, Inc.
s
171U ,\ STKi.r.1. NW
Washington. D C 20036
202 783-5710
Palo Alio Ojjtct
J HAMILTON AVENUE
] O ALTO. CALIF 9(101
415 .127-10X0
April 19, 1973
NOW YOKK. N.Y. 10036
212 869-0150
Nw York Offict
15 WEST 44.1, STREET
Mr. William D. Ruckelshaus
Administrator
Environmental Protection Agency
Room 120 0
Waterside Hall Building
401 M Street, S. W.
LJU> -^/CJ
fir/? "/>'
, !yua
Washington, D. C. 2046 0
Dear Mr. Ruckelshaus:
I am writing on behalf of the Natural Resources Defense
Council, the Metropolitan Washington Coalition for Clean Air,
the Montgomery Environmental Coalition, the Prince Georges
Environment Coalition, and the Center for Environmental
Strategy regarding EPA's Draft Environmental Impact Statement
(EIS) on the Blue Plains Sewage Treatment Plant. ("District
of Columbia Water Pollution Control Plant", Draft Environ-
mental Impact Statement, Environmental Protection Agency,
Middle Atlantic Region, April 1972.)
In our view the Draft EIS is wholly inadequate in its
discu-ssion of the environmental impact of emissions to the
air resulting from incineration of sludge at the plant. The
inadequacies in the statement are of such magnitude that
we urge EPA to prepare a new draft statement to provide a
reasonable basis for comprehensive comment and criticism.
The draft statement does not adequately treat the sub-
ject of total emissions of sulfur oxides, sulfates, sulfuric
acid aerosols, lead, mercury, beryllium, asbestos, and other
toxic elements from the plant's incinerators. Documents re-
lating to these pollutants, released by EPA since the publica-
tion of the draft EIS, demonstrate the need for a complete
reassessment of the safety of operating a large scale sludge
incinerator such as that proposed for Blue Tlains. I am
attaching a preliminary analysis of the nature of the hazards
posed by such pollutants in the context of the Blue Plains
project. This analysis was prepared by James L. Repacc, a
scientific consultant who is very familiar with problems of
sludge incineration.
a-74
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.Sul-fur' Oxides , Sulfates ,• Sulfuric Acid Aerosols*.
The draft statement discusses potential sulfur oxides
emissions from the Blue Plains incinerators but offers no
discussion of sulfates or sulfuric acid aerosols. This is
a major shortcoming of the EJS, resulting in a severe under-
estimation of the potential public health impact of the in-
cinerators. Recent EPA studies state that suspended sulfates
and sulfuric acid aerosols may pose significantly greater
health hazards than SO2 alone.^ Particularly noteworthy is
the statement in EPA's Summary Report on Suspended Sulfates
and Sulfuric Acid Aerosols that EPA investigators feel that
there is "unequivocal evidence that the levels of suspended
sulfates necessary to cause adverse health effects were one
to two orders of magnitude lower than the levels of sulfur
dioxide or total suspended particulates."2 The Blue Plains
project must be reassessed to determine the levels of sulfates
and sulfuric acid aerosols which can be expected from the in-
cinerators .
With respect to S02 emissions the draft statement should
not confine itself to an assessment of whether present pri-
mary and secondary standards will be met. There is increas-
ing recognition that the present standards are not adequate
to protect public health and welfare. For example, a recent
EPA meno on the subject states "we observe increased deaths
at levels even below existing national primary short-term
(24-hour) standards. Other acute health hazards, such as
aggravation of asthma and of cardio-pulmonary symptoms in
chronically ill subjects, have now been demonstrated at
these low exposure levels. Excess mortality occurs whether
we examine SO2 alone, or the product of SO2 and particulates."^
The secondary standards are also under review by EPA and will
be proposed in a more stringent form. EPA cannot ignore the
fact that the Blue Plains facility will be in operation for
a score of years or more and that all evidence indicates that
S02 and particulate standards will have to be established at
more stringent levels during that time to protect public health
and welfare. The project must be analyzed for its consistency
— U,S. EPA, National Environmental Research Center, Summary
Report on Suspended Sulfates and Sulfuric Acid Aerosols, Draft,
December 1972, See CHESS studies cited at page 71, notes 2-6.
2/
— lil* a*- 6(5 •
3/
— Memorandum: "Evidence for Change in Significant I-Iarm Levels,"
from Carl M. Shy, M.D., to Michael James, OGC, Oct. 30, 1972.
a-75
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-a. « i -j, -i. -i- -a- L-t i: u • J VU U V — .LOJLfiU ^
rrJ.Jc J
April I'J , V)i:
0
with anticipated adverse effects associated vn t) i its L-'miasions.
Another defect of the EIS relative to P07 and particulate
emissions is its failure to assess the ;iealth~hazard.c> associated
with incinerator operation at tines when the stack rer'oval
systems are inoperative. "EPA engineers estimate that SC>2
flue gas cleaning devices will be inoperative for scheduled
maintenance at least two weeks per year and Jr'ci -unscheduled
repair an additional 10% of the time."'1 VJill the plant in-
cinerators be operative during these periods? If not, how
will disposal of sludge be handled? These questions must
be answered.
Lead and Mercury.
As Mr; Repace notes in his analysis, the draft EIS relies
without justification on levels of lead and mercury purportedly
characteristic of primary sludge generated at the Lorton,
Virginia sewage treatment facility, while the critical in-
formation is, of course, the level of these elements in the
activated sludge at Blue Plains. Since the sludge at Blue
Plains is the product of a much more urbanized environment
than that associated with Lorton it is not reasonable to
assume that these contaminants will be at the same level in
Blue Plains sludge as in Lorton sludge. Moreover, EPA's
report on Sewage Sludge Incineration states that as a general
matter activated sludge (as at Blue Plains) will include more
of such contaminants than primary sludge (as at Lorton).
EPA has recently promulgated a national emission standard
for mercury (38 Fed. Reg. 8831, April 6, 1973). As Mr. Repace's
analysis indicates the standard of 2,300 grams of mercury
emitted per 24-hour period will be violated by the Blue
Plains sludge incinerators even when operating at average
load. The fact that EPA's mercury regulations by their terms
do not apply to sewage sludge incinerators is not controlling
since EPA has determined that an emission limitation of 2,300
grams per day by a source is necessary to prevent ambient con-
centrations of mercury from reaching levels hazardous to health.
The Clean Air Act requires hazardous pollutant emission stan-
dards to apply to all sources capable of violating the emission
limitation required by the standard.
y U.S. EPA, Staff Paper, Intermittent Control Systems,
April 1973 at Tab. 2, p. 1.
a-76
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Mr. William D, Ruckelshaus Page 4
April 19, 1973
Beryllium.
Mr. Repace1s analysis also demonstrates that the recently
promulgated national emission standard for beryllium (38 Fed.
Reg. 8830, April 6, 1973), will be violated by the Blue Plains
incinerators when operating at average load, The Draft EIS
offers no discussion whatsoever of beryllium emissions from
the incinerators.
Asbestos.
Since the draft EIS fails to discuss asbestos emissions
from the incinerators we do not have an adequate basis for
commenting on the specific hazard posed by Blue Plains with
respect to this pollutant. Mr. Repace's analysis simply
offers the observation that asbestos is likely to be present
in Blue Plains sludge and is not likely to be prevented from
being emitted to the air. The EIS must be redrafted to dis-
cuss this question.
In summary, we urge you to consult EPA's own recent work
on the air pollutants discussed above and undertake a complete
reevaluation of the proposed sludge incineration component
of the proposed Blue Plains project. This reevaluation is
essential if EPA is to ensure that the health of persons
near the project will not be jeopardized. It is our position
that this reevaluation must include a comprehensive chemical
analysis of Blue Plains activated sludge and must be accom-
panied by the preparation of a new draft EIS, which provides
a thorouc/h discussion of the results of this analysis.
We would appreciate the courtesy of an early reply to
the points raised in this letter.
cc: Robert Sansom
Jchn Quarles
Daniel Snyder, Region III
Sheldon Meyers
DGII/scr
Sincerely
/\
/ ;
David G. Hawkins
a-77
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PRELiniUARY ASSESSMENT 0? THE
BLUE PLAINS SEWAGE. TREATMENT PLANT
DRAFT ENVIRONMENTAL IMPACT STATEMENT
I have read the Environmental Impact Statement"^ dated
April 19 72, on the sludge incinerator under construction at
Blue Plainsi Since the publication^ of emission standards
for asbestos, beryllium and mercury, and in. light of the
EPA Task Force document on Sewage Sludge Incineration,^ I
must express my grave reservations as to the adequacy of
Blue Plains Impact Statement in particular, as to the safety
of sludge incineration in general, and as to the adequacy
5f national air quality standards in protecting human health.
1. The Blue Plains facility is being designed to handle
an average flow of 309 million gallons per day (MGD) in
1975 with a peak capacity of 65 0 MGD.^ The average flow
through the plant during 19724 was 2 83 MGD, and the month
of June averaged 297 MGD. Moreover, the population in the
area served by the plant is expected to increase by 30% by
1980.1 It seems clear, therefore, that there is a probability,
increasing with time, that the plant will be operated at
naximum capacity just to handle the average flow.
i. The incinerator emissions of SO2 , NOx, and particulates
^resented in the Impact Statement are based only on average
¦hroughput rates for sludge in the incinerators. If all eight
Incinerators at Blue Plains were to be operated at maximum
lesign throughput (a probable occurrence) the emissions of
lir pollutants from the incinerators would be 52% higher than
>resented in the Impact Statement.
!. It is planned that the incinerators and their afterburners
'ill operate using #2 distillate fuel oil, which is used for
ibme heating, and which is to contain 0.5% Sulfur by 1975.
n view of newspaper reports of the scarcity of fuel^ and of
ossible political decisions to suspend the requirement that
2 fuel oil be limited to 0.5%S^ it is probable that the sludge
ncinerators would be restricted to higher sulfur content fuel
il, or even to coal/ which might double or triple the SO2
utput of the incinerators.
Since the sludge will be burned at approximately 75%
oisture, and since sludge contains appreciable concentra-^
ibns of manganese and iron, which are catalysts for the
nidation of S02 to SO3, the SO2 in the incinerator emissions
,iy be. largely converted to sulfuric acid, which has been
a-78
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-2-
7
shown to be as much as four times as irritant as SO? .
Therefore, an estimate of the health impact of the iilue
Plains incinerator should probably be based upon Ii^SO^ ,
rather than SO2. Moreover, sulfates hav.c been shown to be
jp to 20 times more irritant than S02;^ in addition there
Ls a particle si^e effect; all of which indicates that
atmospheric levels of SCb and their implications to human
wealth should be assessed in terms of the potential formation
3f more irritant factors.
>. Mercury and lead. Estimates of the concentration of
nercury and lead in the sludge were based on primary sludge
samples taken from Lorton, Va. No evidence was presented
:o indicate that Lorton sludge was representative of Blue
Jlains sludge. V-fhy was not activated Blue Plains sludge
malyzed? According to the task force document on sludge
.ncineration^ mercury may be present in domestic activated
iludge to a concentration of 2Qj.fj/g dried sludge. (Table VI,
). 64). If we apply this figure to the Blue Plains Incinera-
tors, based on average throughput, the mercury output could
>e expected to be 8600 g/day as compared to 2300 g/d.ay which
s the maximum allowable for a mercury smelter.^ This would
-------
;ngStrok wide fibrils by "2000 angstroms .in length.; these can
mly be detected by electron microscopy. Since the water
crubbers to be used at Blue Plains are very inefficient
or submicron particles these fibrils would have a high pro-
ability of escaping capture. Since sludge incinerators
re in use all over the country it appears that an immediate
nvestigation is in order. On this count alone, it would
ppear that sludge incineration is most unwise;--
, Beryllium. National standards have been promulgated
fpr beryllium which limit emissions to not more than 10g/day.^
According to the task force report on sludge incineration,
bepyllium may be present in activated sludge to 4/tg/g. Based
on average throughput in the Blue Plains incinerator, 10.32 g
of beryllium per day would be emitted, which is in excess
of the legal maximum. However, if the incinerators were
operated at maximum capacity, this limit would be exceeded
by 52%. Again, on this point alone, sludge incineration at
$lue Plains would be condemned.
8. All of the above emissions would be additive to existing
body burdens, and to existing sources of pollutants in the
area of the incinerators. For example, *"*>35 ,000 cars/day
pass the plant site on Route 295. There are 900 overflights
a day by aircraft serving National Airport. A neighboring
PEPCO power plant burns -^3090 gallons of oil/hr. All this
will be in addition to the emissions of the Blue Plains in-
cinerators. I have calculated that the incinerators will
emit as much as 10-^ subraicron particles per minute. During
a moderate air stagnation a neighbor of the plant may inhale
up to 10^ of these particulates per day in the pressence of
NOx and SC>2. NOx tends to f ac.ili Lata deposition of particles
in the lower respiratory tract, SO;; retards lung clearance,
and submicron particles can penetrate to the alveolic and are
up to 100 times more irritant than micron sized particles.
9. There may be as many as 10,000 people who live or work
within a 1,000 meter radius of this incinerator. In view
of the extreme hazards posed by the emissions of the incin-
erator already mentioned above, especially as the dose per kg
of body weight might be a factor of 100 times greater for
infants and fetuses, it seems incomprehensible that sludge
incineration can be seriously contemplated as a method of
disposal.
In addition to the. above considerations there are a
number of other toxic-*-^ substances found in sludge:
¦silicon dioxide, manganese, copper, zinc, barium, chromium,
a-80
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-4-
boron,cadmium, antimony, arsenic, nickel, and lead. Boron
and lead, like mercury, are cumulative poisons. Nickel,
chromium, arseniclike beryllium, are associated with car-'
cinogenesi.s. Cadmium, antimony, manganese, and silicon
dioxide are highly toxic inhalation hazards. Emission factors
for compounds must therefore be determined and the very real
probability of synergy rtiust be considered.
10. In summary, the Blue Plains sludge incinerator poses
extremely grave environmental hazards which I believe have
not been adequately identified or discussed by the draft
environmental impact statement.
James L. Repace
a-81
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References
1. "District of Columbia Water Pollution Control Plant",
Draft Environmental Impact Statement, Environmental
Protection Agency, Middle Atlantic Region, April 1972.
2. 38 Federal Register, 8820, Friday, April ¦&-, 1973.
3. "Sewage Sludge Incineration", PB 211 323 (EPA-Ra-72-040),
August 1972, distributed by the National Technical
Information Service.
4. Quarterly Report on Interim Treatment Results in the
D.C. Sewerage System, June 1972, Water Resources Manage-"
ment Administration, District of Columbia.
5. Washington Star, March 8, 1973, p. Al.
6. Washington Post, April 3, 1973, p. A2, "Administration
Weights Delaying Air Cleanup."
7. "Aerosols Formed by Oxidation of SO2", M. Amdur, Arch.
Env. Health 23_, Dec. 1971, p. 460.
8. "Asbestos Air Pollution," I. Selikoff et al. Arch. Env.
Health 2_5, July 1972 , p. 1.
9. "Toxicity of Long-Term Exposure to Oxides of Sulfur",
T.R. Lewis, et al., Arch. Env. Health 25_, Jan. 1973, p. 16.
10. Dangerous Properties of Industrial Materials, N.I. Sax,
Reinhold, N.Y., 1957.
a-82
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Response to Comments of David G. Hawkins
The comments made by Mr. Hawkins in his letter generally overlap and expand
on the "preliminary Assessment df the Blue Plains Treatment Plant Draft En-
vironmental Impact Statement: prepared by James L. Repace. Therefore, the
response to both the letter and the assessment has been integrated and pre-
sented in a topic-by-topic fashion on the following pages.
Sulfur Compounds
In response to comments which claim that sulfur compounds will be converted
to sulphuric acid, the incinerator designer reports that he questions "the
statement that the SO^ will be 'largely converted to sulfuric acid1 since
iron and manganese compounds are relatively poor catalysts and the short
exposure to high temperatures in this combustion train should give low oxi-
dation rates of SO^. The degree of oxidation suggested in the comment
is of questionable validity without further substantiating evidence".
EPA reviewers agreed that sulfate emissions would be minimal. Their response
is reproduced below.
"There is little information available on the sulfate content of the particu-
lates emitted from sludge incinerators. However, the (relatively) small
amount of fuel required, its low sulfur content, and a high degree of particu-
late control will serve to minimize such emissions. As for health effects,
EPA publication AP-111 (p.V) states that 'although sulfuric acid is known to
be a much greater irritant than SC>2 to man, the combined effect of particle
size and concentration of sulfuric acid mist on exposed human subjects is
still undetermined, 'and'.... little is known of the actual atmospheric con-
centrations and chemical forms present under varying meteorological conditions
and of the toxicologic significance of this group of compounds under different
ecological conditions'. There are at present no air quality standards for
sulfateso"
Reliability
The incinerator designer has developed the following response in rebuttal to
criticisms concerning operational dependability of the incinerators:
"The discussion criticizes the draft EIS for 'failure to assess the health
hazards associated with incinerator operation at times when the stack removal
systems are inoperative' and then refers to an estimated period of two weeks
per year for scheduled maintenance plus an additional 10% of the time for un-
scheduled repair.
"The entire incinerator plant design was developed to provide a separate flue
gas cleaning system for each sludge furnace to provide a one-on-one arrange-
ment and preclude the operation of a furnace when its associated flue gas
cleaning equipment was inoperative or malfunctioning. The control system is
a-83
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arranged to automatically take a furnace out of operation if the flue gas
cleaning equipment or other critical components of the combustion train
malfunction. As is stated in the draft EIS no operating by-pass flue exists
in the design to prevent even manual override operation if the equipment
malfunctions.
"The District's decision to install eight furnaces even now that the plant
is not planned for expansion beyond the present 309 mgd flow rate results in
one total furnace alignment complete with the flue gas cleaning equipment
being always available on stand-by even during periods of 3-day peak opera-
tion with the larger quantities of sludge anticipated from the advanced
waste treatment process. Conversely, when the sludge production rates are
lower than the annual average production rates, additional furnace capacity
is available for back-up and system operating flexibility if an unscheduled
outage occurs on an operating unit.
"The individual furnaces were selected with reserve capacity beyond the max-
imum 3-day peak loading rate and the auxiliary equipment, including the flue
gas cleaning devices, were sized to offer the necessary operating safety
even under a possible increase in the sludge feed rate beyond the listed max-
imum range.
"While the above items have added to the installation cost of the project,
they were considered necessary to provide the degree of environmental pro-
tection required in a modern incinerator facility and we believe satisfy the
objections set forth in this comment."
Mercury and Beryllium
The question of the potential for public health hazards due to mercury and
beryllium emissions from the incinerators was referred to the Agency's Na-
tional Environmental Research Center in Research Triangle Park, North Carolina.
IJPA scientists reviewed the situation and developed an analysis which concluded
that "the foregoing calculations for mercury (and beryllium) under existing
conditions show that the emissions from the proposed Blue Plains waste treat-
ment facility are not expected to cause hazardous ambient concentrations to
occur". While several "work case assumptions" were made during the analysis
which tend to provide factors of safety, the researchers also pointed out
that there is a "lack of specific information concerning the composition of
the sludge and the fate of material processed in sludge incinerators". There-
fore, this Agency proposes to hold open the discussion period on the topic of
incineration until a comprehensive and conclusive investigation can be com-
pleted. The appLicant has been cautioned not to proceed with the installation
of the incinerators until explicit authorization is supplied him by this
Agency. Furthermore, it is our understanding that the applicant has nearly
completed an investigation of alternatives to incineration. The findings of
this investigation coupled with guidance from the National Environmental
Research Center in North Carolina should provide this Agency with the data
necessary to make an unbiased decision with respect to the fate of the pro-
posal to incinerate sludge at Blue Plains. Please see the preface to this
statement for further discussion on this topic.
I
a-84
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The EPA analysis referred to above is included in the final statement following
the next page.
Lead
Appendix C (page c-37) of the draft EIS contained an estimate of lead emis-
sions from the incinerators which was based on the lead content of particles
collected from the Lorton, Virginia, incinerator. However, additional infor-
mation has become available since the draft statement was prepared. Dr. R. L.
Chaney recently supplied EPA Headquarters personnel with information which in-
cluded a table entitled "Toxic Metal Content of Washington Area Wastewater
Treatment Plants". This table reported the lead content of Blue Plains di-
gested (raw sludge presumably would be lower) sludge as 540 mg/kg dry sludge.
This concentration can be used to calculate the incinerator emission if certain
calculations made in the EPA report discussed £^°ve^res§fThe rePort
adopts a maximum throughput rate of 1,069,000 , ' and a scrubber
efficiency of 98.9%. This information is used in the following calculation.
s ,1,069,000 lbs. dry solidsw, Arir,\
(540 mg.Pb/kg. solids)( ? f ^ 1 )(l-.989) — 6.35#Pb/day
The 6.35#Pb./day is a negligible emission. It is noteworthy that this amount
is far below the 26#Pb/day calculated for the Piscataway installation. At
the present time there are no standards for the emission of lead from sta-
tionary sources.
Asbestos
In response to comments which suggest that asbestos is likely to be present
in the incinerated sludge, EPA Technical Staff believe that, "The Blue
Plains sludge incinerator is not anticipated to be a significant source of
asbestos emissions. At any rate, the use of a 40" W.G. scrubber allows the
incinerator to meet the asbestos emission standard promulated by EPA on
April 6, 1973 - which includes regulations controlling emissions during
construction and demolition,"
Incinerator Operating Rates
Repace Comments No. 1 and 2 contend that population growth in the service
area will eventually compel the treatment plant operators to process
sludges at maximum design rates rather than at average rates. This
comment fails to consider the fact that alternate regional facilities are
presently planned for two locations in Montgomery and Prince George's
Counties. Construction of these facilities will enable the Blue Plains
Plant to process sludge at average rates as described in the draft state-
ment. For a description of the incinerators system's reserve capacity,
please see the incinerator designer's response under the topic of "Relia-
bility".
a-85
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Fuel Sulphur Content
In response to Repace Qomment No. 3, EPA staff reports, "It is highly
unlikely that fuel with a higher sulfur content would be allowed for use
in this incinerator, unless Federal ambient air quality standards for SO^
have earlier been attained in the Districts
Health Effects
In response to Repace Comments No. 8, 9 and 10, EPA technical staff reports
that, "Unfortunately, the state of the technology is such that there are no
environmental indices keyed to the total assault on the human body attribut-
able to the simultaneous presence of all potential pollutants. Thus the
issue raised here is not unique to Blue Plains, but could indeed be fairly
raised on any construction of a potential source of pollution."
As previously stated, this Agency plans to hold open the commenting period
on sludge incineration in expectation that the results of ongoing research
will become available to answer some of the serious questions which simply
cannot be answered at this point in time.
-------
Evaluation of Potential Mercury and Beryllium Emissions
from Proposed Sludge Incinerator to be Located
at the Blue Plains Waste Treatment Facility
in Washington, D. C.
ENVIRONMENTAL PROTECTION AGENCY
Emission Standards and Engineering Division
Research Triangle Park, North Carolina 27711
June 1973
a-87
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Evaluation of Mercury and Beryllium Emissions
at the Blue Plains Incinerator Located
in Washington, D. C.
Background
The existing Blue Plains waste treatment facility is operating at
a rate of 280 million gallons per day (mgd) of raw sewage. The sludge
disposal processes currently being used at the existing facility consist
of thickening, anaerobic digestion (bacterial decomposition), elutriation
and dewatering followed by stockpiling of the digested sludge. The new
system being constructed is designed to treat 309 mgd of raw sewage.
The system consists of primary sedimentation, modified aeration with
chemical addition for phosphorous removal, and nitrification and denitri-
fication followed by filtration. The sludges from these processes will
be disposed of raw by thickening, dewatering, and incineration. Another
method of sludge disposal that is being investigated as an alternative to
incineration is composting. The details of this method are not known,
however, the operator of the waste treatment plant indicates that a decision
concerning the use cf this alternative will be made within two months. If
this alternative 13 used, the incinerators at the site will be used as
sludge driers. The management of Blue Plains indicate that the old facility
will be retired when the new facility starts up.
The incineration of the sludge will be accomplished by eight 24-foot
diameter, 12 hearth, multiple hearth furnaces each having a maximum
capacity of 6900 lbs/hr of dry solids. Five to seven furnaces will normally
be on line with at least one furnace used as a standby. The average
capacity of each furnace will be 5200 lbs/hr of dry solids. The sludge
is incinerated with the aid of auxiliary fuel at a temperature of 1700°F.
a-88
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- 2 -
The furnace gases are cooled from 700°F to 180°F in an evaporative
cooler, then passed through a venturi scrubber, which is maintained
at 40 inches of water (wc) pressure drop. The furnace gases at
about 180°F then enter a sub-cooler, a fan, and a fume furnace.
The fume furnace is maintained at 1500°F by burning auxiliary fuel.
The gases cool to 520°F and are exhausted to the atmosphere through
a 5-foot diameter, 110-foot stack. The gas velocity will be 1800
fpm. The furnace gas flow rate with average excess air of 75 percent
is 36,700 CFM at stack conditions and 18,300 SCFM dry for each furnace.
The total effluent would be 260,000 ACFM or 130,000 SCFM with seven
furnaces in operation. The total particulate collection efficiency
of the control system is quoted at approximately 99.8 percent but for
reasons stated below it may be only 98.9 percent.
The contractor and operator have stated that the average burning
rate on an annual basis will be 862,000 lbs/day of dry sludge and
the maximum five-day average will be 1,069,000 lbs/day.
Assessment of Particulate Control
The 40 inch wc venturi scrubber should provide better control of
particulates than is now being employed at any U. S. sludge incinerator
However, the facility is much larger than any existing sludge facility
such that particulate emissions also will be greater. The scrubber
should collect beryllium but probably won't have any appreciable effect
on mercury vapor. It is reasonable to expect that the collection
efficiency of beryllium will be the same as for total particulate.
In a multiple hearth incinerator, most of the ash is discharged
from the bottom hearth. Only about 10 percent of the ash is carried
out with exhaust gases from the top hearth. Under these conditions,
a-89
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particulate concentrations in the gas stream to the scrubber are about
0.9 grain per dry standard cubic foot (gr/dscf). This value would be
expected to vary with sludge composition and with particle size of the
ash.
Although the scrubber should provide extremely good collection,
we have reservations that it can achieve 99.8 percent efficiency. As
stated above, the average concentration of particulates exiting from
multiple hearth incinerators is 0.9 gr/dscf. To achieve 99.8 percent
particulate removal would require an exit concentration of 0.002 gr/
dscf. While this level may be achieved, we feel that a concentration
of 0.01 gr/dscf is more reasonable to expect on a day-to-day basis.
Under these assumptions, the scrubber efficiency would be 98.9 percent.
At a concentration of 0.01 gr/dscf, 11 lbs/hr or 264 lbs/day of
particulate will be released from the facility. In the case of
beryllium, it is reasonable to add a safety factor and assume that
as much as 30 percent of the beryllium is carried to the scrubber
with the stack gases.
Incineration of Tail Gases
It is indicated that exhaust gases from the scrubber will be
incinerated at 1500°F apparently to destroy odorous compounds and
carcinogens. Based on the information available, it might be
advantageous both from the standpoint of fuel economy and pollution
control as well, to place the afterburner upstream of the scrubber.
Under the latter arrangement, the temperature increment in the
afterburner would be only 800°F (1500°-700°) rather than 1320°F
(1500°-130°). Assuming that gases from the incinerator do not contain
more than about 50 percent moisture, the arrangement should improve
a-90
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- 4 -
fuel econon\y. Besides costs, the latter configuration would have the
advantage of allowing a cooler and drier exhaust stream which could
be more readily treated for removal of toxic materials if the need
should arise. The supplementary control schemes suggested later 1n
this report would be more effective and more flexible at ambient
temperatures than at 500°F.
Beryllium Emissions
Concentrations of beryllium in sewage sludge samples are not precisely
known because they have been generally below the level of detection of the
analytical methods used. According to data obtained by EPA during the
investigation of this industry for new source performance standards
(Section 111 of the Clean Air Act), the beryllium content of sludge is
below 4 ppm on a dry basis. The concentration of beryllium in raw
sewage sludge from Blue Plains is not available.
In order to evaluate the emissions of beryllium from the sludge,
the following assumptions are made:
1. Tiit L'nryllium content of the raw sludge to be incinerated
at Blue Plains is 4 dry hasis.
2. Thirty percent of the beryllium that enters in the sludge
will leave in the furnace combustion gases with 70 percent
being retained in the bottom ash.
3. The control system will remove beryllium particulate
with the same efficiency as for gross particulate
(98.9 percent).
Using these assumptions, the following is calculated:
Daily Beryllium Emissions = (4 x 10"®)(1,069,000)(.011)(0.30)(454)
=6.4 g/day
Using these very conservative assumptions, the estimated beryllium
a-9i
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- 5 -
emissions are less than the 10 g/day standard that was derived for
NESHAPS. The meteorological assumptions and stack conditions used
to calculate the 10 g/day emission limit for NESHAPS are much more
restrictive than the meteorological conditions that exist at Blue
Plains.
Another method of calculating beryllium emissions can be used.
In Table 10 of the EPA Task Force report, all seven of the beryllium
analyses of particulates from sludge incinerators were 1.0 ppm or
less. The estimated total particulate emission rate from the Blue
Plains furnaces as indicated earlier will be 264 lbs/day. Using
this rate and beryllium concentration in the particulate matter give
a beryllium emission rate of 0.12 gram/day.
Using the same conservative meteorological conditions that exis
at Blue Plains that are explained later for mercury, an emission of
710 g/24-hour period would be required to cause the NESHAP ambient
3
guideline level of 0.01 yg/m to be exceeded for a 30-day average,
rt the Blue Plains facility would emit 6.4 grams of beryllium per d<
3
the 30-day average beryllium concentration would be 0.00009 yg/m .
Mercury Emissions
Data obtained by EPA during investigations of sewage sludge
incinerators and the Blue Plains facility indicate that emissions
of mercury will not pose a threat to public health.
Data taken from the EPA Task Force report on Sewage Sludge
Incineration show that mercury concentrations of sludge ranged from
3.0 ppm to 5.5 ppm. Mercury analysis of Blue Plains digested sludg
by Dr. Chapey of the Department of Agriculture in Washington, D. C.
a-92
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indicates a concentration of 3.6 ppm. Dr. Farrell of EPA's Water
Programs in Cincinnati, Ohio, indicated through a telephone conversation
that the mercury content of digested sludge on a dry solids basis is
probably a conservative concentration because:
1. Approximately 50 percent of the raw sludge solids
is decomposed into gases.
2. Most of the mercury that enters the digesters remains
with the undigested solids. Only small amounts leave
in the water and decomposition gases.
Assuming the above, the concentration of 3.6 ppm of mercury in raw
sludge to the incinerators may be high by a factor of two and lesser
concentrations probably will be experienced.
Dr. Chaney has also stated that analysis of raw samples of primary,
secondary, and mixed sludges have ranged- from 0.5 to 15 ppm from analyses
made at several laboratories employing various techniques of mercury
analysis. He indicated, however, that these analyses were not reliable
in his opinion because of sample, laboratory, and analytical variations.
To compute the maximum emissions of mercury from the Blue Plains
incinerator, the following worst-case assumptions were made:
1. The total weight of mercury that enters with the raw sludae will be
emitted to the atmosphere "in stack gases. (In actual .Dractice, however,
some mercury is adsorbed on particulate matter which
will be removed by the venturi scrubber.)
2. The plant is operated at its maximum 5-day incineration
rate of 1,069,000 lbs/day of dry solids. (The average
rate is anticipated to be 862,000 lbs/day of dry solids.)
Under the above assumptions, the mercury emissions can be calculated
to be:
a-93
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Maximum Daily Mercury Emissions = (3.6 x 10 ^)(1,069,000)(454)
= 1750 g/day
The mercury emission from the incinerators is less than the 2300 g/day
emission limit that was set for primary mercury extraction plants and
mercury cell chlor-alkali plants on the basis of dispersion calculations
assuming effective emission heights at near ground level and a maximum
ambient concentration of 1.0 yg/m (30-day average). To evaluate the
hazard that would exist a-t the Blue Plains incinerators, the meteorology
and.emission release conditions at the facility must be considered.
The emission rate that would cause 1.0 yg/m to be exceeded can
be calculated by using the meteorological equations used to calculate
the 2300 g/day emission for ground level.
Calculation Method
The calculation method used is based on that given in the back-
ground report (APTD-0753)J It assumes that:
1. A source emits at a constant rate.
2. Wind direction frequency is the maximum percentage
occurrence of wind flow from one of sixteen 22.5-degree
sectors during any 30-day period.
3. Wind flow is random from all directions within a sector
during a 30-day period. Correspondingly, the effluent
is uniformly distributed horizontally within a sector.
The equation in the form used to estimate maximum allowable daily emission
is:
'Background Information - Proposed National Emission Standards for
Hazardous Air Pollutants: Asbestos, Beryllium, Mercury", EPA, APTD-0753,
Decemhpr 1971, nn. 23-28.
a_Q4
-------
-'8 -
8.64 2u ' Xjujx u0zX _ x,na)( u„2x
16F exp [-1/2 ( £ )2] F exp [-1/2 ( £ )2]
z z
= maximum allowable daily emission, g/day
3
= maximum 30-day average concentration, pg/m
= representative average wind speed, m/sec
= vertical dispersion term as function of stability
and distance, m
= distance downwind, m
= maximum frequency of wind direction from a
22.5-degree sector, %
= effective stack height, m
Meteorological Assumptions
There are three principal meteorological parameters for which
representative values are selected. These parameters are:
1. Average wind speed, U.
2. Average atmospheric stability, which determines values of the
vertical dispersion term, a .
3. Maximum frequency of wind direction from any one sector, F.
An examination of the monthly meteorological data for the Washington,
D. C. area for a recent five-year period indicates that the following
conditions represent the worst dispersion condition that would be expected
to occur during a 30-day period.
Average Atmospheric Stability C
Average Wind Speed 2 meters/sec
Maximum Wind Direction Frequency 30 percent
where: "max
^Snax
U
az
x
F
a-95
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- 9 -
3
Calculation: For mercury - xm*v = 1*0 w9/m
fUCL/l
Qm). = (4-23H1 )(2)(70)(1200) = 70.700 g/day
(Hg) (30)(.33S)
[Q„x =710 g/day]
(Be)
Note: Maximum concentration occurs at about 1.2 kilometers from
the plant. Values for plume rise were calculated using a method described
by Briggs^ and the effective stack height is calculated to be 104 meters.
As can be seen from the calculations above, the emissions of mercury
could be substantially greater than 2300 grams before the ambient mercury
3
concentration of 1.0 yg/m would be exceeded. Under certain conditions,
aerodynamic down wash may cause short-term ground level concentration to
exceed 1.0 yg/m but these conditions are expected to occur a small
proportion of the time and will often be confined within the plant's
boundary lines.
The expected maximum concentration of mercury that would occur under
the above conditions is:
xmax = (1750)(30)(.335) = 0.025 pg/m3
Hg (4^23^2) (70) (1200)
Exmax = (6.4)(30)(.335) - 0.00009 ug/m3]
Be (4-23)(2)(70)(1200)
The foregoing calculations for mercury (and beryllium) under existing
conditions show that the emissions from the proposed Blue Plains waste
Draft Environmental Impact statement P. L. 91-190, District of Columbia
Water Pollution Control Plant (expansion and upgrading), EPA, April 1972,
Appendix C - Sludge Incineration.
a-96
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- 10 -
treatment facility are not expected to cause hazardous ambient
:oncentrations to occur.
Planned EPA Testing at Blue Plains
Although there appears to be little likelihood of hazardous
concentrations of mercury and beryllium emissions from the Blue
Plains incinerator facility, EPA has been ready for several months
to test the emissions of the incinerator exhaust gases of the Blue
Plains pilot plant. Equipment and personnel problems have caused
a delay in this testing program. Currently, EPA has initiated a
short-term program to analyze several samples of a formulation of
raw sludge which will be incinerated at the new facility. Initial
data from this short-term sampling program is expected within 4 to
6 weeks. This data will enable a better assessment to be made.
Control Technology
No technology is available to remove mercury and/or beryllium
from the raw sludge prior to incineration.
In addition to venturi scrubbers, technology is available at
significant cost to remove residual particulates, including beryllium,
from stack gases. Fabric filters or HEPA absolute filters could be
installed for this purpose. In such instances, it would be desirable
to pretreat the gases by: (1) cooling to ambient temperature, (2)
remove remaining mist, and (3) reheating the gases 20° or 30°F to
lower humidity. The installation of fabric filters downstream of
the scrubbers would cost $250,000 in capital expenditure and $75,000
in annualized costs. Costs would be greater if the baghouse were to
be used to treat hot gases. Such baghouses would have little effect
on mercury vapors in the gas stream regardless of the gas temperature.
a-97
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- 11 -
The installation of HEPA filters might require less capital expense
but the operating cost could be much greater depending on the replace-
ment rate.
Technology to remove mercury from the stack gases is available,
but the cost is great, and its removal efficiency has not been
commercially established. The only feasible control method for such
application is adsorption with molecular sieves or chemically
impregnated activated carbon. The vendor of the molecular sieve
system guarantees only that mercury concentrations in stack gases
3
will not exceed 500 yg/m . The concentrations of mercury at stack
3
conditions can be calculated to be 165 yg/m ; therefore, a molecular
sieve control system would not be applicable in this situation.
Although not proven on a commercial scale, it is generally accepted
that an impregnated activated carbon system can remove about 90 percent
of the vaporous mercury in the gas stream. The blinding effect of
residual particulates has not been evaluated. Using this carbon
system to remove mercury, costs and emissions can be calculated.
Costs for such a system have been developed for control of mercury
emissions from chlor-alkali plants and can be used to roughly estimate
the cost of a system necessary to treat the incinerator gases.
Assumptions:
1. Install a separate system for each incinerator (7 total).
2. 1075 ACFM gas stream can be treated with activated
carbon at a capital cost of $132,000.
3. Each incinerator has a gas flow rate of 36,000 ACFM.
4. Estimate the cost of the equipment by use of the six-
tenths rule.
a-98
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- 12 -
Calculation of Capital Cost:
Capital Cost (7 incinerators) = ,36,000/6 (132,000)(7)
1 1075 ;
= $7.7 million
The annualized operating cost is estimated to be 30 percent of
the capital cost or $2.3 million. Assuming 90 percent control, the
mercury concentration in effluent gases would be reduced from 165
3 3
ijg/m to 17 pg/m , and from 1750 g/day to 175 g/day.
a-99
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OFFICE OF
THE MAYOR AND TOWN COUNCIL
FOREST HEIGHTS. MARYLAND
20021
ApriI 6, 1974
i
Mr. R. Blanco
Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Blanco:
In response to the Piscataway Environmental Impact Statement, I wish
to express the concern of the residents of the Town of Forest Heights as to the
technical accuracy and the many deficiencies of the statement. The Town of
Forest Heights is located approximately 7 miles from the Piscataway Plant and
approximately one mile from the Blue Plains Sewage Treatment Plant. Being
physically close to Blue Plains and having sludge dumped next to our town, we
are aware of the problems and odors connected with sewage treatment and sludge
handling. The remarks on the Piscataway EIS also pertain to the Blue Plains EIS
as both statements are incomplete or inadequate in many overlapping areas.
The residents of Forest Heights are users and neighbors of the sewage;
>ystem and have a sincere interest in its working efficiency. Careful planning
should not be neglected for whjt might be a quick solution to the sludge disposal
problem. Irreversible commitments, especially with regard to the sludge incin-
erator system, should not take place until a pilot system has been carefully
studied and data on its operation documented. What is initially stated as a
negligible effect on the ambient air quality from sludge incineration is found to
be a very serious health and pollution problem after reading the published infor-
mation on existing systems.
The Piscataway and Blue Plains Environmental Impact Statements are
in severe need of editing and data documentation. There are many technically
misleading statements, e.g., the \-~b% average increase in the pollution level
from the Blue Plains incinerators over 100 square miles is not valid as it is
coming from a point source. Local increases in pollution, such as in Forest
Heights or the Oxon Hill area, should be given. Noticeably absent in the incin-
erator discussions are details on: lr scrubber efficiency with respect to particla
size and the correlation of particle size with health aspects; 2, temperature
inversion effects; 3, plume dynamics; 4, the health hazards of toxic metals,
e.g., Hg, Be, Cd, Pd and As. It is requested that the sludge incineration aspects
at Piscataway and Blue Plains be given serious technical attention. Also, it.Ms..^
requested that the areas above be addressed and added to the forthco/ni ng'.. -Impa'e-t^v
statements on Piscataway and Blue Plains.
-------
Mr. R. Blanco - 2
\pri I 6, 1974
There are inconsistencies in the EPA's statement concerning sludge
incineration. In the EPA publication No. PB2II323, Sewage Sludge Incineration,
It is stated on page 89 by Dr. Shy, Deputy Director, Division of Health Effects
Research, concerning toxic metals that, "... are likely to represent a true
health hazard, especially if sewage sludge incinerators proliferate in urban areas."
Also, on page 56 of the same EPA report with regard to sludge incineration, "The
chemistry of the potentially hazardous substances in sludge should be investi-
gated by literature study and experimentation so that predictions can be made
of their behavior upon incineration." Cited also are information needs to
determine the fate of toxic metals, pesticides, and other hazardous materials.
In contrast to the above statements, without supporting scientific
evidence or data documentation, it is stated on page 94 of the Piscataway EIS
with regard to sludge incineration that, "In addition, it has proven to be a
reliable process which can handle various types of sludges. All the other
processes considered have not proven to be either reliable, economical, or able
to treat various types of sludges." It is requested that scientific proof be
presented to establish the validity of the above statements.
Another disturbing comment by the EPA was observed in the Fact Sheet
on the Piscataway EIS distributed on March 7, 1974, at the Public Hearing at
Oxon Hill, Maryland. Under Air Quality, page 2, it is stated, "Studies by EPA
show no appreciable degradation to ambient air quality rcsuliing from incinerators
t Piscataway." In the same section, "Research into the range and toxicity of
^articulates and heavy metals is continuing at EPA." The health hazards should
be established prior to stating that there is no degradation of air quality from
incineration. Documented data is again needed so there will be a basis for EPA's
cred ib iIi ty.
There are available reports, for example the EPA report No. 430/9-73-006,
Survey of Facilities Using Land Application of Wastewater, on alternate systems
for sludge disposal. Composting and land based systems have been successfully
used. More attention should be given to such recycling methods, as opposed to
Incineration which is expensive and represents a health hazard. It is also
important to consider the Vander Jagt amendment to the Federal Water Pollution
Control Act in which is is stated that the ultimate disposal of sludge should be
in a manner that will not result in environmentaI hazards. The recycling of waste
is nationaI policy.
In the Federal Code of Regulations (#40), the purpose and function of
the EPA is defined. The Environmental Protection Agency was created to permit
coordinated and effective governmental action to assure tne prolection of the
environment by abating and controlling pollution on a systematic basis. The
endorcement by the EPA of sludge incinerators while the health aspects have not
been verified is not in keeping with its charter.
It is contradictory statements, such as those above concerning
cinerators, that add to the increasing concern as to the accuracy and integrity
o the EPA reports.
a-101
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Mr. R. Blanco - 3
April 6, 1974
Acknowledgment of the receipt of this statement and Its incorporation
Into the forthcoming Piscataway EIS would be greatly appreciated.
Sincerely,
Please send reply to:
Forest Heights Community Center
108 Arapahoe Drive
Forest Heights, Maryland 20021
cc: Russell Train, Administrator
Environmental Protection Agency
Dr. James Comas, Councilman
a-102
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RESPONSE TO COMMENTS DR. JAMES COMAS
The letter states that, "Being physically close to Blue Plains and
having sludge dumped next to our town, we are aware of the problems
and ordors connected with sewage treatment and sludge handling".
Odor problems are not an intrinsic characteristic of properly
designed and operated wastewater treatment systems. Rather they are
indicative of an overloaded or poorly operated facility. As pre-
viously reported, a serious odor problem developed in the Blue
Plains vicinity during May and June of 1973. This problem was traced
to toxic amounts of heavy metals which were inhibiting the growth
of anaerobic organisms in the sludge digesters. Attempts were
made to neutralize the heavy metal influx but they were not successful
and finally the digester contents were emptied into the AWT excavation
so that the digester operation could be resumed utilizing uncontaminated
sludge. The contaminated sludge caused a serious odor problem which
resulted in many complaints. Had the upgrading and expansion project
been complete, this incident would not have occured since raw sludge
will be dewatered and fed directly to the incinerators without prior
digestion.
This comment recommends a pilot system for the incinerator operation.
The material presented below was developed by the incinerator designer
to outline the procedure used in determining the sludge characteristics.
"The sludge characteristics used in our design and in the emission
characteristics we transmitted by letter dated February 22, 1972, to
Mr. Paul Freese of the District were for District sludge sampled at
the Blue Plains facility. The samples were collected by the DES staff
and test data reported on October 20, 19^9, by Crobaugh Laboratories
of Cleveland, Ohio, The analysis of the sludge was transmitted to us
by Mr. John Zelinski, Chief, D. C. Water Pollution Control Division
by letter dated October 2k, 1969- The ultimate analysis we used was
essentially the average of six laboratory samples reported in that data.
Outlet predictions were based on equipment operating efficiencies con-
sidered to be reasonable and the basic stoichiometry of the combustion
reaction.
While we recognize that the final D.C. sludge will only be ex-
perienced after the plant renovation has been completed, we believe
that the information used is realistic as proven by comparison' with
sludge characteristics from other locations using the treatment processes
being installed at the Blue Plains facility. Obviously, the only
accurate method for determining the characteristics of the exhaust gas
emission is to burn the actual sludge from the advanced treatment pro-
cess in an incinerator that is a duplicate of those designed for Blue
Plains with the control system developed for that specific facility.
a-103
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This is, of course, a practical impossibility and our prediction
of emission characteristics as set forth in the previously" men-
tioned letter of February 22, 1972 is in our opinion, still valid
for the items covered". (These predictions were used in the
draft statement.)
The immediately preceeding pages contain an EPA Report entitled,
"Evaluation of Potential Mercury and Beryllium Emissions from
proposed sludge incinerators to be located at the Blue Plains
waste treatment facility in Washington, D.C." The report assesses
the particulate control devices and makes a conservative assumption
with respect to scrubber effiency. The report makes several "Worst
case assumptions" and then goes on to calculate the maximum concentra-
tions of pollutants and their distance from the plant. After dis-
cussing the potential for plume downwash to cause short-term intervals
of relatively high pollutant concentration near the plant, the report
concludes that "The foregoing calculations for Mercury (and Beryllium)
under existing conditions show that the emissions from the proposed
Blue Plains waste treatment facility are not expected to cause hazardous
ambient concentrations to occur". The EPA scientists who developed
the report also point out that there is a "Lack of specific information
concerning the composition of the sludge and the fate of materials
processed in sludge incinerators". It is in recognition of this need
for further definitive information that the Agency has decided to
hold open the comment period on the topic of incineration until
further studies are complete.
a-104
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Appendix b
National Pollutant Discharge Elimination System Permit
(Draft Version)
-------
Introduction to Appendix b
[his appendix contains a draft version of the National Pollutant Discharge
Elimination System (NPDES) Permit. A public hearing on the subject of the
proposed Blue Plains permit was held in Washington, D. C. on March 28, 1974.
Testimony was taken from local government officials and representatives of
environmental groups. The District of Columbia presented testimony which
suggested this Agency consider changes in the following aspects of the
draft permit:
1. Planning, management and reporting schedules.
2. Sludge disposal problems associated with satisfying the permit conditions.
3. Nitrogen removal standards.
These suggestions are presently being given serious consideration by the
Regional Office's Permit Program Staff and subsequent decisions will be re-
flected in the final version of the permit which should be available in the
near future.
-------
Application HO. DC0021199
Effective Date
Expiration Date
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
DISCHARGE PERMIT
In compliance with the provisions of the Federal Water Pollution
Control Act, as amended, (33 U.S.C. s 1251 et. seq.) (hereinafter
referred to as "the Act"), the
District of Columbia, Department of Environmental Services
(hereinafter referred to as "the permittee")
is authorized by U.S. Environmental Protection Agency, Region III
(hereinafter referred to as "the permitting authority")
to discharge from point sources with discharge serial numbers
001 through 060 (See attachment A for listing
and location of sources) to the Potomac River
and its tributaries
in accordance with the attached general and special conditions contained
herein.
Daniel J. Snyder, III
Regional Administrator
Date
-------
Application No. DC0021199
SPECIAL CONDITIONS
1(a) EFFLUENT LIMITATIONS - INITIAL
Beginning on the effective date of this permit and lasting
through December 31, 1975, the permittee is authorized to
discharge from point sources 001 and 002 which shall be
limited by the permittee as specified below:
A. For any 12 consecutive month period, the average quantity
of effluent discharge shall not exceed 299 million gallons
per day (mgd) or 1,131,700 cubic meters per day. A 12
consecutive month average is used to account for seasonal
variations in the flow. Therefore, historical flow data
pre-dating permit issuance will be used initially to
determine average flows.
B. The quality of effluent shall be limited at all times
as follows:
Average
Average Effluent Concentrations Effluent Loadings
Parameter
30 Consecutive
Day Period
7 Consecutive
Day Period
30 Conse<
Day Per:
lbs/day
:utive
Lod
Kg/day
Biochemical Oxygen
Demand (5-day)
40 mg/1
40 mg/1
100,000
45,360
Suspended Solids
40 mg/1
40 mg/1
100,000
45,360
pH
within limits of 6.0 to 9.0
at all times
Total Phosphorus
5.0 mg/1
5.0 mg/1
12,500
5,670
Provide Continuous Disinfection
Page 2 of 26
-------
Application No. DC0021199
L(b) EFFLUENT LIMITATIONS - INTERIM I
Beginning on January 1, 1976, and lasting through March 31, 1977,
the permittee is authorized to discharge from point source 002
which shall be limited by the permittee as specified below:
A. For any 12 consecutive month period the average quantity of
effluent discharged shall not exceed 309 million gallons
per day (mgd) or 1,169,500 cubic meters per day. A 12
consecutive month average is used to account for seasonal
variations in the flow. Therefore, flow data from the
Initial permit period (1(a)) will be used to determine
average flows.
B. Short tern flows at a rate of up to 480 million gallons
per day (mgd) or 1,817,000 cubic meters per day shall
receive complete treatment.
C. The quality of effluent shall be limited at all times
as follows:
Average
Average Effluent Concentrations Effluent Loadings
Parameter
30 Consecutive
Day Period
7 Consecutive
Day Period
30 Conse
Day Per
lbs/day
cutive
iod
Kg/day
Biochemical Oxygen
Demand (5-day)
30 mg/1
35 mg/1
77,400
34,800
Suspended Solids
30 mg/1
35 mg/1
77,400
34,800
pH
within limits of 6.0 to 9.0
at all times
Total Phosphorus
3.0 mg/1
3.0 mg/1
7,700
3,500
Provide Continuous Disinfection
Page 3 of 26
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Application No. DC0021199
1(c) EFFLUENT LIMITATIONS - INTERIM II
Beginning on April 1, 1977, and lasting through December 31, 1977,
the permittee is authorized to discharge from point source 002
which shall be limited by the permittee as specified below:
A. For any 12 consecutive month period the average quantity
of effluent discharged from the wastewater treatment
facility shall not exceed 309 million gallons per day
(mgd) or 1,169,500 cubic meters per day. A 12
consecutive month average is used to account for seasonal
variations in the flow. Therefore, flow data from the
Interim I permit period (1(b)) will be used to determine
average flows.
B. Short term flows at a rate of up to 650 million gallons
per day (mgd) or 2,460,000 cubic meters per day shall
receive complete treatment.
C. The quality of effluent shall be limited at all times
as follows:
Average
Average Effluent Concentrations Effluent Loadings
Parameter
30 Consecutive
Day Period
7 Consecutive
Day Period
30 Conse
Day Per
lbs/day
cutive
iod
Kg/day
Biochemical Oxygen
Demand (5-day)
20 mg/1
20 mg/1
51,600
23,400
Suspended Solids
20 mg/1
20 mg/1
51,600
23,400
Fecal Coliform
200/100 ml
400/100 ml
pH
within limits of 6.0 to 9.0
at all times
Total Phosphorus
1.5 mg/1
1.5 mg/1
3,870
1,760
Total Kjeldahl
Nitrogen
5.0 mg/1
5.0 mg/1
12,900
5,850
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Application No. DC0021199
1(d) EFFLUENT LIMITATIONS - FINAL
Beginning on January 1, 1978, and lasting through January 1, 1979,
the permittee is authorized to discharge from point source 002
which shall be limited as specified below:
A. For any 12 consecutive month period the quantity of effluent
discharge from the wastewater treatment facility shall not
exceed 309 million gallons per day (mgd) or 1,169,500 cubic
meters per day. A 12 consecutive month average is used to
account for seasonal variations in the flow. Therefore,
flow data from the Interim I and Interim II periods (1(b))
and (1(c)) will be used to determine average flows.
B. Short term flows at a rate of up to 650 million gallons
per day (mgd) or 2,460,000 cubic meters per day shall
receive complete treatment.
C. The quality of effluent shall be limited at all times
as follows:
Average
Average Effluent Concentrations Effluent Loadings
Parameter
30 Consecutive
Day Period
7 Consecutive
Day Period
30 Conse
Day Pe
lbs/day
cutive
riod
Kg/day
Biochemical Oxygen
Demand (5-day)
5.0 mg/1
5.0 mg/1
12,700
5,760
Suspended Solids
7.0 mg/1
7.0 mg/1
18,100
8,200
Fecal Coliform
200/100 ml
400/100 ml
PH
within limits of 6.0 to 9.0
at all times
Total Phosphorus
0.22 mg/1
0.22 mg/1
560
250
Total Nitrogen
2.4 mg/1
2.4 mg/1
6,130
2,780
Dissolved Oxygen
Not less than 5.0 mg/1
at all times
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Application No. DC0021199
2. SCHEDULE OF COMPLIANCE FOR EFFLUENT LIMITATIONS
The permittee shall achieve compliance with the preceding effluent
limitations based on the following construction and operational
schedule:
a. Initiate construction of nitrification units of advanced waste
treatment facilities by March 31, 1974.
b. Report construction progress as of June 30, 1974, and quarterly
thereafter until complete. Progress reports shall be submitted
to the permitting authority and postmarked no later than 14 days after
the last day of each quarter.
c. Complete construction of the expanded primary facilities by
August 1, 1974.
d. Complete construction of expanded secondary treatment units and
achieve compliance with Effluent Limitations Interim I as
stipulated in Special Conditions Item 1(b) by January 1, 1976.
e. Complete construction of nitrification units and achieve compliance
with Effluent Limitations - Interim II as stipulated in Special
Conditions Item 1(c) by April 1, 1977.
f. Complete construction of denitrification units and related advanced
treatment facilities and attain operational compliance with
Effluent Limitations - Final as stipulated in Special Conditions
Item 1(d) by January 1, 1978.
The permittee shall submit to the permitting authority a written notice
of compliance or non-compliance with each of the above scheduled dates,
postmarked no later than 14 days following each elapsed date.
3. FACILITY OPERATION AND QUALITY CONTROL
All waste collection, control, treatment and disposal facilities shall
be operated in a manner consistent with the following:
a. At all times, all facilities shall be operated as efficiently as
possible and in a manner which will minimize upsets and discharges
of excessive pollutants.
b. The permittee shall provide an adequate operating staff which is
duly qualified to carry out the operation, maintenance and testing
functions required to insure compliance with the conditions of
this permit.
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Application No. DC0021199
c. Maintenance of treatment facilities that results in degradation of
effluent quality shall be implemented in such a manner that the
effluent limitations are not violated.
4. SELF-MONITORING AND REPORTING REQUIREMENTS
A. The permittee shall effectively monitor the operation and efficiency
of all treatment and control facilities and the quantity and quality
of the discharge. Monitoring data required by this permit shall be
summarized on an average monthly basis. Reports of these monthly values
are to be submitted quarterly. Quarterly reports will be required
for periods beginning on the first day of December, March, June, and
September. Duplicate original copies of the discharge monitoring
report form (to be furnished by the permitting authority) properly
completed and signed, must be submitted within 28 days after the
end of each quarterly report period to the Regional Administrator
at the following address:
Environmental Protection Agency
Region III
Curtis Building
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
The monitoring reports submitted shall be based on the
following parameters and testing frequencies:
POINT SOURCES 001 AND 002
Effluent
Characteristics
Minimum Frequency Sample Type
of Analysis
5-day BOD
Daily
Daily
Daily
Composite
Composite
Composite
Composite
Suspended Solids
Total Phosphorus
Nitrogen Series
Weekly*
(NH NO NO &TKN)
pH J
Flow
Temperature
Dissolved Oxygen
Zinc
Mercury
Copper
Chromium
Nickel
Oil and Grease
Fecal Coliform
Daily
Daily
Daily
Daily
Monthly**
Monthly**
Monthly**
Monthly**
Monthly**
Monthly**
Daily
Recording
Composite
Composite
Composite
Composite
Composite
Composite
Grab
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Application No. DC0021199
* The nitrogen series shall be performed daily after
April 1, 1977.
** For all monthly composites, a portion of each daily
composite shall be composited for seven (7) consecutive
days to make up the sample.
B. Minimum and maximum values shall represent the results of a 24-hour
day. In some situations, this may be the result of a single
analysis while in others, it may be the average of analysis of
three 8-hour composite samples.
C. Sampling and Analysis Methods
Test procedures for analysis of pollutants shall conform to
regulations published pursuant to Section 304(g) of the Act under
which such procedures may be required. These regulations (40 CFR
Part 136) were published on October 16, 1973.
5. RECORDING
The permittee shall record for all samples the date and time of
sampling, the sampling method used, the date analyses were performed,
the identity of the analysts, and the results of all required
analyses and measurements.
All sampling and analytical records mentioned in the preceding
paragraph shall be retained for a minimum of three years. The
permittee shall also retain all original recordings for any
continuous monitoring instrumentation, and any calibration and
maintenance records, for a minimum of three years. These periods
will be extended during the course of any unresolved litigation,
or when so requested by the Regional Administrator.
6. SOLIDS DISPOSAL
Collected screenings, slurries, sludges, and other solids shall
be disposed of in such a manner as to prevent entry of those
wastes (or runoff from the wastes) into navigable waters or their
tributaries.
7. SYSTEM OVERFLOWS
Approximately 35% of the total area of the District of Columbia is
served by combined sewers which carry sanitary sewage and stormwater.
The permittee shall be required to treat varying portions of the
combined wastewater flow in accordance with EPA policy concerning
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Application No. DC0021199
operation of systems with combined sewers. The fact that the
permittee shall be required to treat combined flows at the
treatment plant will likely cause the quantity of flow discharged
by the plant to exceed the discharge limitations (flow quantity)
set by this permit. Upon approval of the preliminary report and
interim operational plan specified in this section of the permit,
the quantity of combined flow that will be treated will be more
accurately defined and adjustments to the discharge limitation
(flow quantity) will be made accordingly. Inasmuch as the user
allocations are based on the present discharge limitations (flow
quantity), a reallocation of the flows may be required by the
permittee. The following two-phase program shall be implemented
to: (1) provide for optimum operation of the present system, and;
(2) accurately define the extent of the combined sewer problem
and seek long-range alternatives with respect to attainment of
water quality standards.
A. Operation of the System with Combined Sewers
The permittee shall operate the treatment works (including
treatment plant and sewer system) to minimize the total quantity
of pollutant discharge for the parameters identified in the permit
during overflow conditions. The following shall be required to
achieve optimum operation of the treatment works with respect to
system overflow:
(1) A preliminary report must be submitted by the permittee to
the permitting authority within three months of the date
of permit issuance. The preliminary report must contain
the maximum treatable flow rates for the treatment plant for
each separate calendar month. The maximum treatable flow
rates for the treatment plant, or any complete unit process,
must at least be equal to one of the following:
a. the maximum hydraulic flow rate for the sewage treatment
plant (or the maximum hydraulic flow for partial
treatment), or;
b. the flow rate based on historic records or theoretic
determinations, that would cause a treatment plant
upset such that other permit conditions could not be
achieved, or in lieu of the above;
c. a detailed plan of operation which can show from existing
data that implementation of such a plan will provide a
total system discharge of pollutants which is less than
that occurring if the maximum flow rate specified above
was used for wet weather operation.
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Application No. DC0021199
The preliminary report shall specify procedures for maximum
utilization of the existing primary treatment facilities when the
new primary facilities become operational by August 1, 1974. The
preliminary report, upon approval by the permitting authority,
will establish the flow rates for each separate calendar month
that can be treated in each unit operation at the treatment plant
prior to a combined sewer discharge, if such a flow rate can be
hydraulically delivered to the plant.
The permittee shall periodically update the preliminary report
to take into consideration the addition of new treatment facilities
as construction of the expanded plant progresses. Modifications
to the wet weather operating procedures to further minimize the
total system pollutant discharge shall be proposed three months
prior to the start-up of the expanded secondary treatment facilities,
the nitrification facilities and the denitrification/filtration
facilities and be implemented, upon approval by the permitting
authority, when each of these facilities become operational.
An interim operational plan must be submitted by the permittee to
the permitting authority within two and a half years of the date
of permit issuance. The interim operational plan must address
the coordinated operation of the sewage treatment plant and the
contributing sewer systems.
The plan shall include, if applicable, a section on the number,
location, types and kinds of regulators and their respective
operating history, maintenance program and performance efficiency.
The operational plan shall minimize the total system discharge of
pollutants. In addition to defining the maximum treatment plant
flow capacity, the plan must contain operational procedures which
will provide for utilization of at least 80 percent of the available
capacity of interceptors and trunk lines (prior to causing flooding
or surging conditions) upstream of any control device, pump
station, or regulator, that can be so controlled, prior to any
combined sewer discharge. If such control capabilities are not
available, the plan must contain operational procedures which
provide for the maximum use of storage prior to any combined
sewer discharge. The operational plan should contain the
calculated or estimated storage capacities of the sewer system
upstream from all control devices, pump stations, regulators, or
combined sewer discharges. An operational method to determine if
the upstream storage capacity was utilized prior to any event
discharge from interceptors and trunk lines must be submitted with
the operational plan.
The interim operation plan, upon approval by the permitting
authority, will establish the procedures that must be implemented
prior to any combined sewer discharge.
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Application No. DC0021199
Monitoring and Long-Range Planning
Point sources 003 through 060 are overflows currently resulting when
the hydraulic flow capacity of the system has been exceeded (see
Attachment A for a listing of these point sources). As soon as possible
after January 1, 1976, but no later than January 1, 1977, wet weather
flows in excess of 480 mgd shall receive at least primary treatment
with disinfection. After April 1, 1977, wet weather flows in excess
of a rate of 650 mgd shall receive at least primary treatment with
adequate disinfection. These discharge points may be utilized for
wet weather overflows or bypasses to the extent specified by the
approved preliminary report and interim operational plan. No dry
weather overflows are permitted after August 1, 1974. For all
wet weather overflows, the permittee is required to take the following
actions:
(1) Implement a monitoring program prior to November 1, 1974,
to determine the frequency, duration and volume of flow and
the quantity of wastes discharged (average and maximum kilograms
per day) from these point sources. Effluent quantities
determined should include five-day BOD, suspended solids,
total nitrogen, and phosphorus. A plan for implementing
this monitoring program must be submitted to the permitting
authority for approval by April 1, 1974.
(2) Institute a survey and study to develop an abatement program
to eliminate or significantly reduce pollution from these
sources so as to maximize the achievement of the required
water quality standards. The study must include the
consideration of alternative solutions, associated costs, and a
schedule of implementation. A report on the results of this
study shall be presented to the permitting authority not
later than January 1, 1975, with an interim status report
due not later than July 1, 1974. upon final approval by the
permitting authority, the plan presented in the report shall
be implemented according to the approved schedule of
implementation.
EFFLUENT LIMIATIONS ON POLLUTANTS ATTRIBUTABLE TO INDUSTRIAL USERS
A. Not later than 365 days following issuance of this permit, the
permittee shall have promulgated an enforceable industrial waste
ordinance. This ordinance should allow the permittee to enforce all
pre-treatment requirements necessary to ensure compliance with
the terms and conditions of this permit, as well as to ensure
compliance by all major contributing industries* with the
pre-treatment standards and any other applicable requirements
Page 11 of 26
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Application No. DC0021199
promulgated pursuant to Section 307 of the Act. A copy of this
ordinance is to be submitted for approval by the permitting
authority, such approval being an enforceable provision of this
NPDES permit. This ordinance shall require each major contributing
industry to submit to the permittee periodic notice (at intervals
not to exceed 9 months) regarding specific actions taken to achieve
full compliance with the requirements of Section 307.
The permittee shall submit to the permitting authority a report
summarizing the progress of all known major contributing industries
subject to the requirements stated above towards full compliance
with such requirements. Such reports shall be included with the
first and third quarterly reports required under Section 4.A. of
this permit and shall include at least the following information:
(1) A narrative summary of actions taken by the permittee to
develop, promulgate and enforce the local industrial waste
ordinance and thereby ensure that all major contributing
industries comply with the requirements of Section 307.
(2) The number of major contributing industries using the
treatment works, divided into Standard Industrial Classification
group categories.
(3) The number of major contributing industries in full compliance
with the requirements of Section 307, or not subject to these
requirements (e.g., discharge only compatible pollutants).
(4) A list identifying by name those major contributing industries
presently in violation of the requirements of Section 307.
These semi-annual reports must be filed with the permitting
authority within 28 days after the end of the first and third
quarter as a part of the self-monitoring report required by
Section 4.A. of this permit for each year until compliance is
achieved. Thereafter, submission will be required should a
major contributing industry reverts to violating the requirements
stated above.
Immediately upon issuance of this permit, the permittee shall establish
and implement a procedure to obtain from all major contributing
industries specific information on the quality and quantity of
effluents introduced by such industrial users. This information
shall be reported to the permitting authority on a quarterly basis
beginning within 180 days of permit issuance. Quarterly reports
reflecting no change from the previous quarter may simply relate
this fact, without submitting repetitive data.
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Application No. DC0021199
Based on the information regarding industrial inputs reported by
the permittee pursuant to the preceding paragraph, the permittee
will be notified by the permitting authority of the availability
of industrial effluent guidelines on which to calculate allowable
inputs of incompatible pollutants based on BPT for each industry
group. Copies of guidelines will be made available upon request.
Not later than 120 days following receipt of this information,
the permittee shall submit to the permitting authority calculations
reflecting allowable inputs from each major contributing industry.
The permittee shall also require all such major contributing
industries to implement necessary pre-treatment requirements (as
provided for in 40 CFR Part 128), providing the permitting
authority with notification of specific actions taken in this
regard. At that time, the permit may be amended to reflect the
municipal facility's effluent requirements for incompatible
pollutants.
A major contributing industry is one that: (a) has a flow
of 50,000 gallons or more per average workday; (b) has a flow
greater than five percent of the flow carried by the municipal
system receiving the waste; (c) has in its waste a toxic
pollutant in toxic amounts as defined in standards issued under
Section 307(a) of the Act; or (d) has significant impact,
either singly or in combination with other contributing
industries, on the treatment works or the quality of its effluent.
9. PLANNING AND MANAGEMENT ACTIONS
Since August 22, 1957, the Federal Government has held various progress
meetings of the Potomac River Enforcement Conference in an attempt
to eliminate the pollution of the Potomac River in the Washington,
D.C. Metropolitan Area. In October 1970, the participants of the
Enforcement Conference adopted a memorandum of understanding which,
in part, established the capacity of the Blue Plains plant at 309
mgd and allocated the flows to the plant among the user jurisdictions.
The principal signatories of this agreement were the District of
Columbia, the Washington Suburban Sanitary Commission; and Fairfax
County, Virginia.
Also associated with the Enforcement Conferences, the District of
Columbia, the Washington Suburban Sanitary Commission and Fairfax
County, Virginia agreed to an interim treatment program for the
Blue Plains facility. This agreement was accepted and adopted by
the Conference on November 11, 1971. The Maryland Department of
Health and Mental Hygiene, the Maryland Department of Natural Resources,
and the Virginia State Water Control Board concurred in this agreement.
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Application No. DC0021199
The agreement, in part, set out the following requirements:
(a) Reduce the total BOD pollutant load to the Potomac River
from the D.C. Sewerage system to approximately 100,000
lbs per day of BOD or less.
(b) Establish flow allocations into the Blue Plains facility
through 1975.
Based on these two Enforcement Conference agreements, flow
allocations were as follows:
Page 14 of 26
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D .C.
WSSC (Pot. Int.)
Va. (Pot. Int.)
WSSC (excld.
Pot. Int.)
Va. (excld.
Pot. Int.)
1969
Base
115
4
10
105
6
"240
Annual
6-yr.
Increase
3.3333
0.1667
0.3333
5.6667
0.3333
9.8333
1970
118.33
4.17
10.33
110.67
6.33
249.83
1971
121.67
4.33
10.67
116.33
6.67
259.67
1972
125.00
4.50
11.00
122.00
7.00
269.50
Application No. DC0021199
1973 1974 1975
128.33
4.67
11.33
127.67
7.33
131.67
4.83
11.67
133.33
7.67
135.00
5.00
12.00
139.00
Ultimate
Plant
Flow
135.00
5.33
12.67
148.00
8.00 8.00
279.33 289.17 299.00 309.00
Thus the total allocations by user jurisdiction, were as follows:
D .C.
WSSC
Va.
1970
118.33
114.84
16.66
249.83
1971
121.67
120.66
17.34
259.67
1972
125.00
126.50
18.00
269.50
1973
128.33
132.35
18.66
279.33
1974
131.67
138.16
19.34
289.17
1975
135.00
144.00
20.00
299.00
Ultimate
Plant
Flow
135.00
153.33
20.67
309.00
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Application No. DC0021199
Should there be a violation of any conditions of the permit, the
Environmental Protection Agency has the authority under Section 402(h)
of the Federal Water Pollution Control Act Amendments of 1972 to
proceed in a court of competent jurisdiction to restrict or prohibit
the introduction of any pollutant into the Blue Plains plant by a
source not utilizing such treatment works prior to the finding that such
condition was violated. It is intended that, in the event of a permit
violation, this provision will be implemented by the permitting
authority.
In order for the Blue Plains facility to adequately meet its effluent
requirements stipulated in this permit, the following specific
planning and management actions shall be undertaken:
(1) The District of Columbia Department of Environmental Services, in
consultation with the user jurisdictions to the Blue Plains
treatment system, shall develop a schedule of new extensions,
connections and hook-ups of new sources (e.g., dwelling units) to
the waste treatment system over the duration of the permit. A
copy of this schedule or schedules, along with a statement of
concurrence (or nonconcurrence) from the local governments, shall
be provided to the States of Maryland and Virginia and to the
permitting authority by June 1, 1974. Thereafter, a monthly
report should be submitted to the states, the permitting authority
and the various local agencies tracking the rate of actual
hook-ups, connections and extensions against the agreed-upon
schedule.
(2) The permittee shall undertake a overall program of public
accountability, including quarterly summary reports to inform
all users of the sanitary system and local government officials
and the general public of the extent of actual compliance with
permit requirements and conditions. Reports shall be provided
to at least the following:
Maryland:
Secretary, Maryland Department of Health and Mental Hygiene
Secretary, Maryland Department of Natural Resources
Chairman, Washington Suburban Sanitary Commission
Office of the Executive, Montgomery County
Office of the Executive, Prince George's County
Virginia:
Chairman, Virginia Water Control Board
Chairman, Fairfax County Board of Supervisors
Director of Public Works, Town of Vienna
Airport Manager, Dulles Airport
Loudoun County Sanitation Authority
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Application No. DC0021199
Other Jurisdictions and Agencies;
Maintenance Branch, U.S. Naval Research Center
Chief of Maintenance, National Parks Service
Director, Interstate Commission on the Potomac River Basin
Director, Metropolitan Washington Council of Governments
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Application No. DC0021199
;eneral conditions
L. All discharges authorized herein shall be consistent with the terms
and conditions of this permit. The discharge of any pollutant more
frequently than, or at a level in excess of, that identified and
authorized by this permit shall constitute a violation of the
terms and conditions of this permit. Such a violation may result
in the imposition of civil and/or criminal penalties as provided
for in Section 309 of the Act. Facility modifications, additions,
and/or expansions that increase the plant capacity must be
reported to the permitting authority and this permit then modified
or re-issued to reflect such changes. The permittee shall provide
notice to the authorizing permitting official of the following:
(a) Any new introduction of pollutants into the treatment works
from a source which would be a new source as defined in
Section 306 of the Act if such source were discharging
pollutants;
(b) Except as to such categories and classes of point sources
or discharges specified by the Administrator, any new
introduction of pollutants into the treatment works from
a source which would be subject to Section 301 of the Act
if such source were discharging pollutants; and
(c) Any substantial change in volume or character of pollutants
being introduced into the treatment works by a source
introducing pollutants into such works at the time of
issuance of the permit.
The notice shall include:
(1) The quality and quantity of the discharge to be introduced
into the system, and
(2) The anticipated impact of such change in the quality or
quantity of the effluent to be discharged from the permitted
facility.
2. After notice and opportunity for a hearing, this permit may be modified,
suspended, or revoked in whole or in part during its term for cause
including, but not limited to, the following:
(a) violation of any terms or conditions of this permit;
(b) obtaining this permit by misrepresentation or failure to
disclose fully all relevant facts; or,
(c) a change in any condition that requires either a temporary
or permanent reduction or elimination of the permitted
discharge.
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Application No. DC0021199
3. The schedule of compliance in this permit may, upon request of the
applicant, and after public notice, be revised or modified by the
permitting authority, if it is found that good and valid cause exists
for such revision.
4. Notwithstanding 2 above, if a toxic effluent standard or prohibition
(including any schedule of compliance specified in such effluent
standard or prohibition) is established under Section 307(a) of the
Act for a toxic pollutant which is present in the discharge authorized
herein and such standard or prohibition is more stringent than any
limitation upon such pollutant in this permit; or if this permit
contains no limitations on such pollutants, this permit shall be
revised or modified in accordance with the toxic effluent standard or
prohibition and the permittee shall be notified.
5. Under no circumstances shall the permittee allow introduction of the
following wastes into the waste treatment system:
(a) Wastes which create a fire or explosion hazard in the treatment
works.
(b) Wastes which will cause corrosive structural damage to treatment
works.
(c) Solid or viscous substances in amounts which cause obstructions to
the flow in sewers or interference with the proper operation of
the treatment works.
(d) Wastewaters at a flow rate and/or pollutant discharge rate which
is excessive over relatively short time periods so as to cause a
loss of treatment efficiency.
6. The permittee shall allow the head of the state water pollution control
agency, the Regional Administrator, and/or their authorized representatives,
upon the presentation of credentials:
(a) to enter upon the permittee's premises where an effluent source
is located or in which any records are required to be kept under
the terms and conditions of this permit;
(b) to have access to and copy at reasonable times any records required
to be kept under the terms and conditions of this permit;
(c) to inspect at reasonable times any monitoring equipment or
monitoring method required in this permit; or,
(d) to sample at reasonable times any discharge of pollutants.
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Application No. DC0021199
The issuance of this permit does not convey any property rights in
either real or personal property, or any exclusive privileges, nor
does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, state, or local laws
or regulations.
Except for data determined to be confidential under Section 308 of the
Act, all monitoring reports required by this permit shall be available
for public inspection at the offices of the head of the state water
pollution control agency and the Regional Administrator. Knowingly
making any false statement on any such report may result in the
imposition of criminal penalties as provided for in Section 309
of the Act.
The diversion or bypass of any discharge from the treatment works by
the permittee is prohibited, except: (1) where unavoidable to
prevent loss of life or severe property damage; or, (2) where excessive
storm drainage or runoff would damage any facilities necessary for
compliance with the terms and conditions of this permit. The permittee
shall notify the permitting authority in writing of each such diversion
or bypass in accordance with the procedure specified below for reporting
non-consistency compliance. The permittee shall within 30 days after
such incident submit to the permitting authority for approval a plan
to prevent recurrence of such incidents.
. If for any reason the permittee does not comply with or will be unable
to comply with any effluent limitation specified in this permit, or should
any unusual or extraordinary discharge of wastes occur from the facilities
herein permittee shall immediately notify the Regional Administrator
and appropriate state agency by telephone and provide the same authorities
with the following information in writing within five days of such
notification:
(a) A description of the non-complying discharge including its impact
upon the receiving waters.
(b) Cause of non-compliance.
(c) Anticipated time the condition of non-compliance is expected to
continue, or if such condition has been corrected, the duration
of the period of non-compliance.
(d) Steps taken by the permittee to reduce and eliminate the non-complying
discharge.
(e) Steps to be taken by the permittee to prevent recurrence of the
condition of non-compliance.
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Application. No. DC0021199
11. Permittee shall take all reasonable steps to minimize any adverse
impact to navigable waters resulting from non-compliance with any
effluent limitation specified in this permit. The permittee will
also provide accelerated or additional monitoring as necessary to
determine the nature and impact of the non-complying discharge.
12. The permittee shall require any industrial user of the permitted
facility to provide pre-treatment as required under Section 307, and
to provide any records, reports or information related to any
pre-treatment or new source performance standards as required by
Section 306 of the Act. Any industrial user of the permitted facility
shall be required by the permittee to prepare and submit to the
permitting authority periodic notices of progress toward full
compliance with the requirements of Section 307 of the Act. Such
notices shall be submitted at intervals not to exceed 9 months or
as required elsewhere in this permit.
13. The permittee is responsible for maintaining adequate safeguards to
prevent the discharge of untreated or inadequately treated wastes
during electrical power failure either by means of alternate power
sources, standby generators or retention of inadequately treated
effluent. Should the treatment works not include the above
capabilities at the time of permit issuance, the permittee must
furnish within 90 days a program, including an implementation
schedule for their installation to the permitting authority for
their approval. The set program shall include all the necessary
steps to correct the deficiency.
14. Except as provided in permit condition 9 on bypassing, nothing in
this permit shall be construed to relieve the permittee from civil
or criminal penalties for non-compliance.
15. Nothing in this permit shall be construed to preclude the institution
of any legal action nor relieve the permittee from any responsibilities,
liabilities, or penalties established pursuant to any applicable
state law or regulation under authority preserved by Section 510 of
the Act.
16. This permit cannot be transferred or assigned, nor shall a new owner
or successor be authorized to discharge from this facility until
the following requirements are met:
(a) The permittee shall notify the succeeding owner or successor of
the existence of this permit by a letter, a copy of which
shall be forwarded to the state water pollution control agency
and the Regional Administrator.
Page 21 of 26
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Application No. DC0021199
(b) The new owner or successor shall submit a letter to the state
water pollution control agency and the Regional Administrator
stating that he will comply with the requirements of the
permit on this facility and receive confirmation and approval
of the transfer from the state vater pollution control agency.
The provisions of this permit are severable, and if any provision
of this permit, or the application of any provision of this permit
to any circumstance, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit,
shall not be affected thereby.
Page 22 of 26
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Application No. DC0021199
ATTACHMENT A
D ischarge
Serial
No.
001
002
Overflow Structure Location
(or discharge)
Existing D.C. Water Pollution
Control Plant Outfall
New D.C. Water Pollution
(Proposed) Control Plant Outfall
003 Boiling Air Force Base
004 Poplar Point Sewage Pumping
Station S.E.
005 Chicago Street and Railroad
Avenue, S.E.
006 Good Hope Road, West of
Nichols Avenue, S.E.
007 13th Street and Ridge Place,
S.E.
008 Anacostia Avenue, West of
Blaine Street, N.E.
009 2nd Street 300 feet north
of N Place, S.E.
010 0 Street Sewage Pumping
Station, S.E.
011 Main Sewage Pumping Station
012 North of Main Sewage Pumping
Station, S.E.
013 4th & N Streets, S.E., Both
Extended
014 6th & M Streets, S.E.
015 9th & M Streets, S.E.
Discharge
Receiving
Water
Potomac River
Potomac River
Potomac River
Frequency
Occurrence
Continuous
Anacostia
East Side
Anacostia
East Side
Anacostia
East Side
Anacostia
East Side
Anacostia
East Side
Anacostia
West Side
Anacostia
West Side
Anacostia
West Side
Anacostia
West Side
Anacostia
West Side
River,
River,
River,
River,
River,
River,
River,
River,
River,
River,
Wet & Dry
Weather
Wet Weather
Wet Weather
Wet Weather
Wet Weather
Emergency
By Pass
Wet Weather
Wet Weather
Wet Weather
Wet Weather
Wet Weather
Anacostia River, Wet Weather
West Side
Anacostia River, Wet Weather
West Side
I
Page 23 of 26
-------
Application No. DC0021199
Discharge Overflow Structure Location
Serial (or discharge)
No.
016 12th and M Streets, S.E.
Discharge
Receiving
Water
Anacostia River,
West Side
Frequency
Occurrence
Wet Weather
017
14th & M Streets, S.E,
Anacostia River,
West Side
Wet Weather
018 Barney Circle & Pennsylvania
Avenue, S.E.
Anacostia River,
West Side
Wet Weather
019 N.W. Boundary Trunk vie. of
25th & E Sts. S.E. extended
Anacostia River,
West Side
Wet Weather
020 23rd Street, North of Consti-
tution Avenue, N.W.
Potomac River,
East Side
Wet Weather
021 Northeast of Roosevelt Bridge,
N.W.
Potomac River,
East Side
Wet Weather
022
27th & I Streets, N.W.
Potomac River,
East Side
Wet Weather
023 29th & K Streets, N.W.
Potomac River,
East Side
Wet Weather
024 30th & K Streets, N.W.
Potomac River,
East Side
Wet Weather
025
31st & K Streets, N.W.
Potomac River,
East Side
Wet Weather
026 Wisconsin Avenue and K
Streets, N.W.
Potomac River,
East Side
Wet Weather
027 Water Street West of
Potomac Street, N.W.
Potomac River,
East Side
Wet Weather
028
36th & M Streets, N.W.
Potomac River,
East Side
Wet Weather
029 Canal Road 1000 ft. East of
Foxhall Road, N.W.
Potomac River,
East Side
Wet Weather
030 Foxhall & Canal Roads, N.W.
Potomac River,
East Side
Wet Weather
Page 24 of 26
-------
«V •
031
032
033
034
035
036
037
038
039
040
041
042
043
044
045
Application No. DC0021199
Overflow Structure Location
(or discharge)
Pennsylvania Ave., East Side
of Rock Creek, N.W.
Discharge
Receiving
Water
Rock Creek,
East Side
Frequency
Occurrence
Wet Weather
Rare
26th & M Streets, N.W.
Rock Creek,
East Side
Wet Weather
Rare
N S'reet Extended West of
25th Street, N.W.
23rd and 0 Streets, N.W.
Rock Creek,
East Side
Rock Creek,
East Side
Wet Weather
Rare
Wet Weather
Rare
22nd Street South of Q Street,
N.W.
Rock Creek,
East Side
Wet Weather
Rare
23rd Street South of Q Street,
N.W.
Rock Creek,
East Side
Wet Weather
Rare
N.W. of Belmont Road and Rock
Creek & Potomac Parkway
North of Belmont Road, East
of Kalorama Circle, N.W.
Rock Creek,
East Side
Rock Creek,
East Side
Wet Weather
Rare
Wet Weather
Rare
Connecticut Avenue, East of
Rock Creek, N.W.
Rock Creek,
East Side
Wet Weather
Rare
Biltmore Street, Extended,
East of Rock Creek, N.W.
Rock Creek,
East Side
Wet Weather
Rare
Ontario, Extended, and Rock
Creek Parkway
Rock Creek,
East Side
Wet Weather
Rare
Harvard Street & Rock Creek
Parkway, N.W.
Rock Creek,
East Side
Wet Weather
Rare
Adams Mill Road, South of
Irving Street, N.W.
Rock Creek,
East Side
Wet Weather
Rare
Kenyon Street and Adams Mill
Road, N.W.
Rock Creek,
East Side
Wet Weather
Rare
Adams Mill Road and Lamont
Street, N.W.
Rock Creek,
East Side
Wet Weather
Rare
Page 25 of 26
-------
LiU •
046
047
048
049
050
051
052
053
054
055
056
057
058
059
Application No. DC0021199
Overflow Structure Location
(or discharge)
Park Road, South of Piney
Branch Parkway, N.W.
Ingleside Terrace, Extended,
and Piney Branch Parkway
Mt. Pleasant Street, Extended
and Piney Branch Parkway
Discharge
Receiving
Water
Rock Creek,
East Side
Rock Creek,
East Side
Rock Creek,
East Side
Piney Branch Parkway, West of
Rock
Creek
16th Street, N.W.
East
Side
28th Street, West of Rock
Rock
Creek
Creek Parkway, N.W.
West
Side
Olive Street, Extended, and
Rock
Creek
Rock Creek Parkway, N.W.
West
Side
0 Street, Extended, and Rock
Rock
Creek
Creek Parkway, N.W.
West
Side
0 Street, West of Rock Creek
Rock
Creek
N.W.
West
Side
West Side of Rock Creek, 300
ft. South of Mass. Ave., N.W.
Massachusetts Avenue and
Whitehaven Street, N.W.
Normans tone Drive, Extended,
West of Rock Creek, N.W.
28th Street, Extended, West
of Rock Creek, N.W.
Rock Creek,
West Side
Rock Creek,
West Side
Rock Creek,
West Side
Rock Creek,
West Side
Connecticut Avenue and Rock
Creek Parkway, N.W.
16th & Rittenhouse Streets,
N.W.
Rock Creek,
West Side
Rock Creek,
West Side
Little Falls Branch
Little Falls
Branch
Frequency
Occurrence
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Wet Weather
Rare
Emergency
By Pass
Page 26 of 26
-------
Appendix c
Alternatives to the Proposed Action
(Formerly Pages 52 to 111 of Draft Statement)
-------
ALTERNATIVES TO THE PROPOSED ACTION
TREATMENT ALTERNATIVES
A. No Action. Since the plant is currently severely overloaded
(annual average flow of 294 mgd in FY 73 vs. the annual average design
flow of 240 mgd), this is not considered to be a practical alternative.
The continuing discharge of this quantity of secondary-treated effluent
to the Potomac without advanced wastewater techniques would continue to
degrade the River in the future no matter how sophisticated the treat-
ment of discharges from other plants in the area.
Additional equipment and modifications must be made to increase
the plant reliability. Increased conduit capacity between the primary
sedimentation and the aeration tanks is necessary to prevent bypassing
of primary effluent. Also, additional sludge handling facilities would
have to be installed to provide adequate capacity to handle existing
loads and loads that would persist even if the flows were reduced.
Reduction of pollution loadings to the Potomac is mandatory. With-
out substantial upgrading or abandoning Blue Plains facilities, this
cannot be achieved. Therefore, a no action plan Is considered to be
unrealistic.
B. Retain capacity at 240 mgd but upgrade plant. This proposal
was presented at the May 21, 1970 session of the Potomac Enforcement
Conference by Vinton W. Bacon, Professor of Civil Engineering, University
of Wisconsin, Milwaukee, who was retained as a consultant by the Depart-
ment of the Interior. In his report, Mr. Bacon recommended the follow-
ing for Blue Plains.
1. The capacity at the plant be limited to 240 mgd
for the present.
2. Washington Suburban Sanitary Commission's (WSSC) flows
other than through the Potomac Interceptor Sewer be limited
to 45 mgd.
3. WSSC should immediately commence design and construction
of facilities for tertiary treatment of flows in excess of 67 mgd.
4. Blue Plains be upgraded on the following schedule:
a. Primary facilities - contracted immediately for
240 mgd capacity, Including excess flows;
b. Secondary facilities - begin design immediately and
complete within one year; complete construction by December 31, 1972.
c-1
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c. Tertiary facilities - begin design within one year and
complete within one year; complete construction by December 31, 1975.
Mr. Bacon recommended that flows to the D. C. plant be allocated
aa follows:
Actual Present Projected
Flows from: Inflows (mgd) Inflows (mgd)
Year 1970 Year 1980 Year 2000
District of Columbia 124 135 180
Potomac Interceptor:
Maryland 1 10 22
Virginia 4 14 42
Other than Potomac
Interceptor:
Virginia 7 6 8
Maryland (WSSC) 113 45 45
As noted in the preceding table, flows from WSSC (other than through
the Potomac Interceptor) would be reduced to 45 mgd. This was considered
to be WSSC's capacity rights based on their capital investment of $5.5
million at the time Bacon's report was prepared. The formula used is
as follows:
$5.5 M Invested by WSSC @ B.P. X 240 MGD =45.5 MGD
$29 M total Investment @ B.P.
Under the 1954 Agreement between the District and WSSC, the latter
agency requested that it be allocated a capacity of 88.6 mgd in the 240
mgd plant. Payments to the District were made on the basis of the WSSC
share of expansion after 1954. Provisions exist in the Agreement for
WSSC to amortize the cost of sewerage facilities existing in 1954 based
on their flows through these facilities. The question of WSSC's "capacity
rights" must be settled in the courts and would entail several years
delays. It Is doubtful that any design or construction of facilities
to accommodate flows between 45 and 88.6 mgd would be undertaken by the
Commission prior to final disposition of this matter. Therefore, the
Blue Plains facilities would continue to be overloaded, thus discharging
inadequately-treated wastes for several years after its completion in
December, 1975.
c-2
-------
Bacon stated in his letter report to the Department of the Interior
•.hat the Blue Plains plant "cannot be expanded to treat the waste load
rtiich will be generated in the metropolitan area by the year 2000 (420
igd estimated) simply because the Potomac estuary does not have the
:apacity even if the degree of treatment exceeds 99% removal." Professor
iacon based his conclusions upon a review of the work done primarily by
)r. Norbert Jaworski, Federal Water Pollution Control Administration,
Chesapeake Technical Support Laboratory (CTSL is now part of the Region
[II Office of EPA).
CTSL's Technical Report #35 indicated that the Water Quality
Standards minimum Dissolved Oxygen (D.O.) of 5.0 could be met if 57,000
>ounds of Ultimate Oxygen Demand (U.O.D. is a combination of the car-
)onaceous and the nitrogenous oxygen demands) is discharged to Zone
L. This report stated that at a capacity of 419 mgd, Blue Plains would
lave to provide 98% removal of 5-day BOD, 93% removal of nitrogen, and
)8% removal of phosphorus.
The 240 mgd capacity Bacon recommended was arbitrarily established
iince it is the current average annual flow that the existing plant
ras designed to treat. The plant is designed to treat an average daily
:low of 290 mgd during the maximum summer months. However, with the
lecessity to bypass the secondary units when flows exceed a 300 mgd
rate, use of the 290 mgd design figure does not seem practical.
The pros and cons of Bacon's argument are listed below:
1. ADVANTAGES:
a. [-Ifiitially, a smaller design flow will be handled at the
>lant, i.e.'240 vs. 309-mgd. However, the total discharge of pollu-
:ants to the Potomac at this point w4il'remain approximately the same
Ln either Instance so any advantages would be minimal. Under Bacon's
>roposal the design capacity would ultimately be increased to 297 mgd
»hich is only 4% less than the current project.
2. DISADVANTAGES:
a. Other plants in the area which would complement Blue Plains
Ln enhancing water quality of the Potomac would probably be further
ielayed as a result of future court actions concerning "capacity rights".
!a) Zone 1 is that reach of the Potomac River between Chain Bridge and
Broad Creek, as delineated in Technical Report #35, April, 1971,
CTSL, EPA.
-------
Mr. Bacon's proposal was never fully considered by the District
and shortly after it was introduced by Professor Bacon, the FWPCA
requested that the various interested parties meet to discuss and
develop an acceptable alternative. The October 1970 "Memorandum of
Understanding" (Appendix G of Draft EIS) led to the establishment of
plant capacity at 309 mgd.
Bacon recommended that disposal of digested sludge on a crop rota-
tion basis be given consideration since solids disposal by incineration
can be both a source of air pollution and expensive. He stated that
a loading factor of 20 dry tons per acre per year is a conservative
design criterion. With an annual sludge production of 157,000 tons
this would require an area of 7,850 acres of 12.3 square miles. The
area of Alexandria is approximately 9,600 acres of 15 square miles.
Sludge disposal alternatives will be discussed in detail later in this
section.
C. Other Types of Treatment Considered.
General: Prior to reconvening, the Potomac Enforcement Conference
in April and May 1969, The District of Columbia's Consulting Engineers
prepared a report recommending that the plant be upgraded and enlarged
to meet the then existing standards for 90% removal of BOD and suspended
solids, with flexibility to meet anticipated higher standards for BOD,
phosphorus, and nitrogen removals. The initial phase of the plan
involved expansion of primary treatment facilities, construction of
additional secondary treatment facilities using the step-aeration acti-
vated sludge process, and construction of a new sludge processing
facility for all sludges generated from primary and secondary treatment.
Upon completion of the first phase, the plant would have a capacity of
309 mgd which would be adequate until approximately 1980. At that time,
additions to increase the capacity to 369 mgd, which would be sufficient
for another ten years, would be constructed. In 1990, the capacity would
be increased to its ultimate of 419 mgd which should suffice until the
year 2000.
The May 1969 Potomac Enforcement Confrerence recommended the following
effluent criteria at a flow of 309 mgd:
Parameter
lbs/day
mg/1
BOD
12,700
4.95
Total P
560
0.22
Total N
6,130
2.39
All alternatives considered since that time were compared on the basis of
their abilities to meet the criteria listed above. The various methods of
treatment studies were reported in June 1970. This report did not Include
a detailed discussion of all aspects of each alternative, but did include
c-4
-------
factors for each of the primary systems which possess a major bearing
on project feasibility. The two major treatment systems investigated
with various alternate combinations for ubs at Blue Plains were:
1. Independent physical-chemical treatment.
2. Biological treatment.
a. Conventional-tertiary treatment (physical-chemical additions)
b. Btho-chemical treatment (nitrification-denitrification)
The costs, advantages, and disadvantages of each system are discussed
in the following paragraphs and were supplied by the District of
Columbia and its consultants from their report dated June 1970.^ ' A
detailed discussion of these processes follows:
1. Independent Physical-Chemical Treatment System
The independent physical-chemical treatment system involves the use
of two-stage lime precipitation of either raw wastewater or primary
settled wastewater for removal of organic material and phosphorus. The
lime precipitation stage is followed by filtration, ion exchange for
nitrogen removal, and carbon absorption for removal of remaining organic
materials. Sludge from the lime precipitation stages would be dewatered
and recalcined to reclaim a portion of the lime for reuse. Nitrogen
removed by ion exchange would be discharged to the atmosphere as ammonia.
Three alternatives of this system were investigated. Each alternative
varied only in the method by which excess flows, which were to receive at
least the equivalent of primary treatment and disinfection, were handled.
Capital Cost @ 309 mgd 350 - 395, $ Millions
Annual Operating Cost 31.5 - 34.0 $ Millions
Total Annual Cost 56.5 - 62.5, $ Millions
A major advantage of the system was that it occupied the least amount of
area of the systems studied. In addition, as a physical-chemical system
it was not subject to biological upset.
The system incorporated the use of an ion exchange process for ammonia
removal which could result in the direct discharge to the atmosphere of
approximately 25 tons per day of ammonia. It was not known what objec-
tionable or hazardous conditions this discharge might create during
quiescent atmospheric conditions such as inversions. Investigations
were scheduled for evaluation of ion exchange in the EPA-DC pilot plant
(1) Metcalf & Eddy Report - Comparative Evaluation of Advanced Waste
Treatment Systems 6/17/70
-------
to determine if it would be feasible to reclaim the ammonia from the
off-gas leaving the ion exchange system before it was discharged to
the atmosphere. At the time of the plant design selection no such
reclamation system existed, and if such a system were feasible, it
would require additional costs.
Air stripping at a high pH of ammonia from the plant flow was
considered, but was determined to be inapplicable because of known
operating problems with scaling and freezing, and the inability to
meet effluent nitrogen criteria during tfc# winter season.
The system incorporated the use of1 a carbon absorption system
which appeared to present serious and unresolved problems in controlling
slime growths on the carbon. There were also several unknown parameters
involved in handling combined chemical and organic sludges from first
and second stage lime precipitation.
A final and major disadvantage of the system was that it required
the demolition of all existing treatment units at the plant and would
be the most difficult to incorporate in the system without affecting
the continuous operation and the maintenance of present treatment'levels
during construction.
At this time (6/70) the District elected to eliminate this process
from further consideration and decided to expand the existing facilities
by the use of advanced biological processes (Conventional-tertiary or
biochemical treatment).
The three alternatives for treating the excess flows considered
were as follows:
a. Excess flows to receive two-stage lime treatment and disin-
fection.
This would result in the production of a higher quality excess
flow effluent which would offer more protection to the estuary for reuse.
A 419 mgd plant can be accommodated on the existing site without the use
of multi-level settling tanks. Omission of primary sedimentation would
cause widest variation in influent concentrations. These variations
would require good operating control of chemical dosages and sludge
recirculation. Rag accumulations on mixers and flocculations would be
severe without primary settling and would require screening to prevent
their entrance into the process.
Capital Cost, $Millions
Operating Cost, $Millions/Year
Total Annual Cost, $Millions/Year
Total Cost/mil gal treated, $
395
34.0
62.5
554.00
c-6
-------
b. Excess flows to receive primary sedimentation in storm tanks
followed by disinfection.
Capital Cost, $Millions
Operating Cost, $Millions/Year
Total Annual Cost, $Millions/Year
Total Cost/mil gal treated, $
350
31.5
56.5
501.00
A 419 mgd plant can be accommodated at the existing site without
the use of multi-level settling tanks. Disadvantages and advantages to
this action are the same as for (a) above, except that the use of storm
tanks for excess flow treatment would reduce the range of flows to be
handled by the lime precipitation process. The estimated average fre-
quency of tank filling and emptying (about every four days) would result
in a continually unpredictable and relatively frequent cleaning chore
that would be undesirable from an operating standpoint insofar as personnel
staffing and odor control are concerned.
c. All flows, including excess flows to receive conventional
primary treatment with excess flows disinfected and discharged after
primary treatment.
This variation would require the use of multi-level settling tanks
at an additional cost of $5 million to accommodate a 419 mgd plant at
the site. The excess flow effluent would be of somewhat lower quality
than that produced by (a) above.
Biological Treatment
The biological treatment employed the basic facilities already
existing at the District of Columbia plant but required the addition
of various advanced biological or physical-chemical processes to achieve
the desired discharge standards. These processes can be put together in
many different treatment systems. The individual treatment processes
considered include the following:
1. Secondary treatment processes
a. Step aeration
b. Oxygen activated sludge
c. Modified aeration
2. Phosphorus Removal processes
a. 2-stage lime precipitation
b. Single-stage lime-soda precipitation
c. Metal ion precipitation (mineral addition)
Capital Cost, $Millions
Operating Cost, $Millions/Year
Total Annual Cost, $Millions/Year
Total Cost/mil gal treated, $
360
32.0
58.5
519
c-7
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3. Nitrogen Removal processes
a. Ammonia stripping
b. Ion exchange
c. Biological nitrificatlon-denitrification
d. Breakpoint chlorination
Secondary Treatment Processes
a. Step-Aeration System
The step-aeration activated sludge process is based upon an
aeration tank divided into 3 or 4 equal compartments or passes. Primary
effluent can be introduced in varying amounts to any or all of the passes.
Sludge from the secondary sedimentation tanks is returned to the first
pass. Usually, primary effluent is not introduced into the first or
even into the first and second passes. This permits the return sludge
to undergo re-aeration and regeneration, and to oxidize the organic
matter absorbed from previous contact with the primary effluent. This
process was proposed for the secondary treatment units in the February
1969 engineering report prepared by Metcalf and Eddy.
Research conducted at the EPA-DC pilot plant in 1970 and 1971
encountered severe operational problems. These were possibly caused
by filamentous organisms in the District's wastewater which, when intro-
duced into the step-aeration system employing a relatively long biologi-
cal growth period, could stimulate the reproduction of these organisms.
During the operation of the system, it became apparent that fila-
mentous growths could be eliminated only by addition of hydrogen peroxide,
a very costly method for control. Very careful operational control of
the biological system would be essential to prevent the recurrence of
the filamentous growth. It was further observed that the filamentous
organisms in the effluent prevented satisfactory operation of subsequent
nitrification systems if employed after step-aeration. Wide variations
in the amount of nitrification which occurred in the step-aeration system
were also detrimental to the growth of nitrifying organisms in the sub-
sequent nitrification system or to nitrogen removal by breakpoint chlori-
nation of ion exchange. Some denitrification occasionally occurred in
the secondary settling tank with a resulting loss of solids in the over-
flow. The results of pilot plant testing strongly indicated that use of
the step-aeration system would result in a process that is extremely
difficult to control, particularly with respect to maintaining effective
biological or physical-chemical nitrogen removal. The low process re-
liability observed during the operation of the step-aeration system in
the pilot plant was not consistent with the degree of reliability neces-
sary for discharge of effluent into the Potomac River.
b. Oxygen Activated Sludge Process
The oxygen activated sludge process uses oxygen gas to operate
the secondary activated sludge wastewater treatment process. The system
is based on a series of enclosed, concurrent gas-liquid contracting stages
which enable high overall oxygen absorption efficencies at a high overall
c-8
-------
average energy transfer. The contacting units are fitted with a gas-
tight cover to contain the oxygen aeration gas. On-site oxygen gas
generation plants are the most economical and desirable form of oxygen
supply for most applications of the oxygen process.
Use of the oxygen process could result in a cost savings due to
the utilization of smaller aeration tanks. This system has been operat-
ing at the EPA-DC pilot plant since May 1970 and problems of solids sepa-
ration in the settling tank became difficult and solids escaped into the
effluent. The difficulty in solids separation required larger than
desired sedimentation tanks.
The oxygen process produced appreciable nitrification during the
summer months which would create a similar adverse impact on the subse-
quent nitrogen removal processes as previously described in the step-
aeration section.
During the study period, alum was added to the system to explore
the possibility of phosphorus removal by this process. The limited
research did not reveal that the low phosphorus residuals required by
the discharge standards could be achieved and also revealed that lime
would be required to control the pH during mineral addition.
c. Modified Aeration System
The modified aeration system is presently employed in the
District's plant and is capable of achieving 70 - 80% BOD and suspended
solids removals. Since interim requirements of the October 1970 Memo-
randum of Understanding c&lled for 90% removal of suspended solids and
BOD prior to the construction of the advanced waste treatment facilities,
this method was not seriously considered prior to the summer of 1971. It
was also believed that the higher BOD and SS concentrations in the process
effluent would interfere with the nitrification process.
Research conducted at the EPA-DC pilot plant indicated that
modified-aeration effluent was a satisfactory feed to the nitrification
system for the following reasons:
1. The variation in effluent quality from the mean values was
markedly less than in the step-aeration and oxygen systems as operated
at the EPA-DC pilot plant.
2. The ability to nitrify the modified effluent was demon-
strated in the pilot plant.
3. Nitrification did not occur in the modified-aeration system
even in the summer months.
A. Filamentous growth was not a problem in solids separation.
c-9
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'hosphorous Removal Processes
The April 1969 Enforcement Conference effluent requirements re-
julted in limiting phosphorus concentration in the effluent to 0.22
ig/L at 309 mgd. Studies at the EPA-DC pilot plant indicated that
:hese requirements could be met by two-stage lime precipitation and
lossibly single-stage precipitation using a lime-soda process. However,
the use of lime precipitation would be more expensive than use of a
metal salt (i.e., alum or ferric chloride) for precipitation of phos-
phorHS within the biological treatment systems. Research work conducted
prior to June 1970 indicated that it was not feasible to achieve specific
phosphorus removal levels with the mineral addition method.
After June 1970 the three methods of phosphorus removal that were
considered are:
a. Two-stage lime precipitation
In two-stage treatment, sufficient lime is added to the water
in the first stage to raise the pH above 11. Precipitation of hydroxya-
patite^calcium carbonate (CaCO^), and magnesium hydroxide (MgOH„) occurs.
Between the first and second stage settlers carbon dioxide (CO 2 J is added
to reduce the pH to 10 where additional CaC03 precipitation occurs.
Phosphates included in the hydroxyapatite are removed when the precipi-
tate settles. The sludges are then removed, thickened, centrifuged and
recalcined in multiple-hearth furnaces and the recovered lime is reused
in the treatment process. Approximately 90% of the phosphorus can be
removed in the centrate when 25% of the solids entering the centrifuge are
allowed to remain in that stream. Approximately 15% of the recoverable
lime is lost in the process and make-up lime is required.
The data obtained from operation of the two-stage lime preci-
pitation process when a high-quality step-aeration effluent could be
obtained clearly demonstrated this system's ability to achieve phosphorus
removals after subsequent filtration which could meet stipulated effluent
quality criteria, provided satisfactory biological (90% BOD removal)
treatment was achieved.
The results indicated that use of two-stage lime precipitation
on a modified-aeration effluent or any other secondary effluent containing
high concentrations of suspended solids and BOD did not produce an effluent
after filtration containing acceptably low concentrations of phosphorus.
b. Single-Stage Lime-Soda Precipitation
In the single stage process a combination of lime and sodium
carbonate (Na2C03) is added to the wastewater to raise the pH to a de-
sired value, usually less than 10, where the calcium carbonate (CacOo)
precipitates and removes the phosphorus with it. The settled lime
sludge may be recalcined for recovery of lime similar to the process in
the two-stage system.
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Tests conducted at the EPA-DC pilot plant indicated that
using modified-aeration effluent, the single-stage system with subse-
quent filtration was not capable of consistently obtaining acceptable
phosphorus removals. The single-stage lime precipitation system seems
to depend more heavily on a consistently high quality feed than the
two-stage system. The consulting engineer decided to drop further
consideration of this process in the summer of 1971.
c. Metal Ion Precipitation
In this process phosphates are removed by combining them
with Aluminum or Iron (Ferric) ions to form a precipitate when alum
(or ferric chloride) is added to the system between the aeration and
the secondary sedimentation tanks for any activated sludge process.
Additional tank capacity is not required with this process. Lab pilot
research demonstrated that with proper pH control and filtration,
residual phosphorus levels of approximately the discharge standards
could be achieved.
A two-point mineral addition can be employed if activated
sludge process is followed by nitrification-denitrification system.
With the two-point application and filtration, phosphorus levels in
the effluent at both EPA-Manassas and EPA-DC pilot plants were con-
sistently lower than the Enforcement Conference requirements.
Alternates involving the use of alum or ferric chloride
encounter the problem of chemical supplies, especially during the
initial years. Contacts by the District representatives with Allied
Chemical, Olin Chemical, American Cyanamid, Dow Chemical and Pennwalt
Corporation all have indicated either limited supplies and/or higher
costs unless long-term contracts could be negotiated. Approximately
71,500 tons per year of alum, or 36,000 tons per year of ferric
chloride would be required initially. Neither Allied Chemical, Olin
Chemical, or Dow Chemical have surplus alum or ferric chloride. By
using both ferric chloride and alum, the initial demand could be met.
In the long-term, the demand for these chemicals at other
advanced wastewater treatment plants should result in increased indus-
trial production. All of the manufacturers are aware of the potential
demand and are following the market carefully.
Nitrogen Removal Processes
The May 1969 Potomac Enforcement Conference required an effluent
from the Blue Plains plant to contain not more than 2.39 mg/1 total
nitrogen. The methods of nitrogen removal studied were as follows:
1. Ammonia Stripping
2. Ion Exchange
3. Biological Nitrification-Denitrification
4. Breakpoint Chlorination
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The ammonia stripping and ion exchange processes were previously
described in the physical-chemical systems.
3. Biological Nitrification-Denitrification
Nitrification and denitrification are the last two stages of
a three-stage activated sludge system. Nitrification is the biological
oxidation of ammonia and nitrite in the wastewater to nitrate. It is
accomplished in two steps (ammonia to nitrite and nitrite to nitrate)
by two types of bacteria commonly found in the activated sludge process.
Denitrification is an anaerobic process (carried out in the absence of
oxygen) where bacteria use the oxygen in nitrate (NO3) to oxidize a
carbonaceous source, such as methanol. In the reaction the nitrate is
reduced to nitrogen gas, driven from solution by agetation, and dis-
charged to the atmosphere where it is not a pollutant since the atmos-
phere is mainly nitrogen gas to begin with.
Research at various installations has indicated conclusively
that a properly designed and operated nitrification-denitrification
system can achieve the nitrogen standards required for discharge of
the Blue Plains effluent into the Potomac River. Research indicated that
careful control of influent BOD was required for satisfactory operation
of the system. Too low a BOD (less than 20 mg/1) prevented satisfactory
bio-flocculation within nitrification. Too high a BOD loading (a function
of the detention time within nitrification) interferes with nitrification
efficiency.
4. Breakpoint Chlorination
In this process, chlorine is added to the wastewater in suffi-
cient quantities to convert ammonia in the wastewater to nitrogen gas
which is released to the atmosphere. Breakpoint chlorination does not
achieve any significant destruction of organic nitrogen; therefore, its
success in meeting Potomac River effluent requirements depends largely
upon the installation of upstream processes which are capable of reduc-
ing organic nitrogen to low levels. Nitrification in upstream systems
cannot be tolerated since the nitrate nitrogen would not be removed by
the process.
Breakpoing chlorination would not appear to be compatible with
the step-aeration or oxygen process:in which nitrification occurs unless
operating techniques are employed to prevent nitrification. Lake Tahoe
has attempted to control nitrification within conventional aeration by
chlorine. Breakpoint chlorination could be used with the modified aeration
system. The use of breakpoint chlorination is feasible only when applied
to a secondary treatment effluent in which nitrification is prevented. The
process requires the addition of approximately 100 to 150 mg/1 of chlorine.
Sodium hydroxide is also added for pH control. Thus, the effluent will
contain relatively High concentrations of sodium and chloride ions. If
the water is to be reused the removal of these ions may be essential to
develop the full reuse potential of the effluent.
c-12
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Processes employing breakpoing chlorination would require a
supply of approximately 130 tons per day of chlorine. If purchased,
this amount would be transported by rail or truck. An additional 500
to 1,000 tons of liquid chlorine would be stored on site for treating
peak loads and as a reserve for shipping delays. Serious safety hazards
would be associated with shipment and storage of such large quantities
of chlorine.
An alternate supply could be obtained by the construction
of a chlorine production plant. Approximately 25,000 kw (kilowatts)
of additional power would be required for on-site production. Sources
of supply of the 240 tons per day of salt required would have to be
developed. Normally, a chlorine production plant of this size would
contain about 100,000 pounds of mercury in cells. The plant would
have to be environmentally acceptable.
2. Biological Treatment System
The unit processes previously described were evaluated by the
District of Columbia and its consultants in the following treatment
systems configurations:
A. Conventional Tertiary Treatment Systems
The conventional-tertiary treatment systems involved the use
of conventional primary and biological secondary treatment followed
by two-stage lime precipitation, filtration, and ion exchange or break-
point chlorination. Mineral addition within the biological secondary
could be considered as an alternate to two-stage lime precipiation.
Primary and secondary sludges would be handled by conventional methods
of dewatering and incineration. Sludges from the lime precipitation
stages would be handled in the same manner as the independent physical-
chemical system. The conventional-tertiary system involved capital
and operating costs which were essentially similar to the independent
physical-chemical process. Several separate alternates within this
system were evaluated. These combinations were as follows:
1. Step-aeration biological secondary treatment, two-stage lime
precipitation, filtration and ion exchange.
2. Oxygen activated sludge secondary treatment, two-stage lime
precipitation, filtration and ion exchange.
3. Step-aeration, two-stage lime precipitation, filtration and
breakpoint chlorination.
4. Oxygen activated sludge, two-stage lime precipitation, filtra-
tion and breakpoint chlorination.
5. Step-aeration, mineral addition, filtration, breakpoint
chlorination, carbon adsorption.
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6. Oxygen activated sludge, mineral addition, filtration,
breakpoint chlorination, carbon adsorption.
7. Modified aeration, mineral addition, filtration, breakpoint
chlorination, carbon adsorption.
The following is a summary of the reasons given by the District
and its consultants for rejection of the various alternates:
1. Step-aeration, two-stage lime precipitation, filtration and
ion exchange.
This process was rejected for the following reasons:
a. It contained the same disadvantages as the physical-
chemical system insofar as ammonia removal by an ion exchange system
was concerned.
b. Inability to consistantly meet phosphorus requirements
due to the difficulties in operating the step-aeration process on D.C.
wastewater.
c. Further research would be necessary to evaluate potential
lime scale accumulation in main conduits.
d. The system would require two completely separate sludge
processing methods - one for primary and biological secondary sludges,
and a second system for the first and second stage lime precipitation
sludges.
e. Nitrification which occasionally occurred in the step-
aeration process prevent nitrogen removal requirements from being met.
f. This alternative would require the OBe of multi-level
construction to accommodate the plant on the existing site.
2. Oxygen activated sludge, two-stage lime precipitation, filtra-
tion and ion exchange.
This system was rejected for the same reasons as alternative
1 plus the following:
a. The conversion of existing aeration tanks for pure oxygen
use would present major hydraulic and construction difficulties to
integrate with existing aeration and secondary sedimentation tanks, thus
:reating additional difficulties in maintaining present treatment levels
luring construction.
b. Nitrogen removal requirements could not be met due to the
nitrification which occurred in the oxygen process during the summer
nonths.
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c. Further research to more fully evaluate the oxygen
activated sludge process would be required,
3. Step-aeration, two-stage lime precipitation, filtration and
breakpoint chlorlnatlon.
This system was rejected for reasons b, c, d and e under
alternative 1 as well as:
a. Safety hazards associated with the shipment or production
and storage of large quantities of chlorine.
b. Possibility of necessity to remove sodium and chloride
ions from effluent in the future to develop its full reuse potential.
4. Oxygen activated sludge, two-stage lime precipitation, fil-
tration and breakpoint chlorlnatlon.
This system was rejected for the reasons given under alterna-
tive 3 plus the oxygen process problems listed under alternative 2.
5. Step-aeration, single-stage mineral addition, filtration,
breakpoint chlorlnatlon, carbon adsorption.
This system was rejected for the following reasons:
a. The nitrogen removal requirements would not be met as
in alternative 3.
b. Problems associated with chlorlnatlon as listed in
reasons b and c under alternative 3.
c. It was not felt that single-stage mineral addition would
consistently produce an effluent which would meet phosphorus require-
ments, even with filtration.
6. Oxygen activated sludge, single-stage mineral addition, filtra-
tion, breakpoint chlorlnatlon, carbon adsorption.
This system was eliminated for the same reasons as alternative
5 plus reasons a, b and c under alternative 2.
7. Modified aeration, mineral addition, filtration, breakpoint
chlorlnatlon, carbon adsorption.
This system was Eliminated for the following reasons:
a. Reason c under alternative 5.
b. Problems associated with the use of chlorine listed in
reasons b and c under alternative 3.
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It should be noted that with the modified aeration system in
which nitrification is prevented the nitrogen removals required to
meet effluent standards could be accomplished
B. $lo-Chemlcal Treatment Systems
The bio-chemical treatment system incorporates conventional
primary and biological secondary treatment, biological nitrification-
denitrification for removal of nitrogen, and filtration. The bio-
chemical treatment system substitutes the use of nitrification-denitri-
fication process for nitrogen removal, thus eliminating many of the
disadvantages associated with ion-exchange or breakpoint chlorination
which were considered in the other two ma^or systems for nitrogen
removal. This system, however, requires the largest land area,
although a substantial reduction could be obtained if aluminum (or
ferric chloride) addition to the secondary facilities would produce
adequate phosphorus removal. If two-stage lime precipitation was
required for phosphorus removal, extensive use of multi-level settling
tanks would ba necessary to accommodate a 309 mgd facility at the
existing site.
The District felt that the major advantage of this system was that
it incorporated components which contain the highest degree of confi-
dence in achieving BOD, nitrogen, and phosphorus removals and employed
a single sludge disposal system for which design and operating experience
had long been established. Also, the system could be added to the pre-
sent plant with a minimum of interruption to plant operation and effi-
ciency .
Nine separate alternates within this system were evaluated. These
combinations are as follows:
1. Step-aeration, nitrification-denifrification, two-stage lime
jrecipitation and filtration.
2. Oxygen activated sludge, nitrification-denitrification, two-
jtage lime precipitation and filtration.
3. Modified aeration, nitrification-denitrification, two-stage
.ime precipitation and filtration.
4. Step-aeration, nitrification-denitrification, single-stage
ime precipitation and filtration.
5. Oxygen activated sludge, Nitrification-Denitrification, Single-Stage
in^'pyecipitation,"^! Filtration,
6. Modified aeration.Nitrification-Denitrification. Single-Stage Lime
ecipitation. anH~WTT>aMnn _
7. Step-aeration, mineral addition, nitrification-denitrification,
Lltration.
c-16
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8. Oxygen activated sludge, mineral addition, nitrification-
denitrification, filtration.
9. Modified aeration, mineral addition, nitrification-
denitrification, filtration.
The following is a summary of the reasons given by the District
and its consultants for acceptance or rejection of the various alter-
natives :
1. Step-aeration, nitrification-denitrification, two-stage lime
precipitation and filtration.
This series was rejected for the following reasons:
a. Operational difficulties in the step-aeration process
and unwanted nitrification prevented the satisfactory operation of
the nitrogen removal processes.
b. This system would require the largest land area or the
maximum utilization of multi-level construction to be accommodated on
the existing site.
c. Further research would be necessary to evaluate potential
lime scale accumulation in main conduits.
d. The system would require separate sludge processing
systems - one for biological sludges and the second for first and
second stage lime precipitation sludges.
2. Oxygen activated sludge, nitrification-denitrification,
two-stage lime precipitation and filtration.
This system was rejected for the reasons b, c and d in
alternative 1 plus:
a. The conversion of existing aeration tanks for pure oxygen
use would present major hydraulic and construction difficulties to
integrate with existing aeration and secondary settling tanks, thus
creating additional difficulties in maintaining present treatment levels
during construction.
b. The nitrification which occurred in the oxygen aeration
stage during summer months prevented the satisfactory operation of
the nitrogen removal process.
3. Modified aeration, nitrification-denitrification, two-stage
lime precipitation and filtration.
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This system is capable of producing an effluent of high quality
which would meet tlj^. requirements set by the Potomac Enforcement Conference.
It was considered until the final design decision was made and was re-
jected when it was determined that two-step mineral addition could
achieve the required phosphorus removals within the available plant site.
Should this system have been selected, an additional eight multiple-
hearth furnaces identical to the eight utilized in_th.a_cnrrent project
would be required for lime recalcinatlon.
4. Step-aeration, nitrification-denitrification, single-stage
lime precipitation, filtration.
This system was dropped from consideration for the following
reasons:
a. Same as reason "a" in Alternative 1.
b. The single-stage lime precipitation process was not con-
sidered sufficiently reliable due to its dependence on a very high
quality influent for use at this facility.
5. Oxygen activated sludge, nitrification-denitrification,
single-stage lime precipiation, filtration.
This system was rejected for the reasons a, b and c in
alternative 2 and reason b under alternative 4.
6. Modified aeration, nitrification-denitrification, single-
stage lime precipiation, filtration.
This system was rejected for reason b listed under alternative
4.
7. Step-aeration, mineral addition, nitrification-denitrification,
filtration.
This system was rejected for the following reasons:
a. Reasons "a" under alternative 1.
b. The system could not be constructed on the existing site
without the use of multi-level construction.
8. Oxygen activated sludge, mineral addition, nitrification-
denitrification, filtration.
This system was dropped from consideration for reasons a, b
and c under alternative 2.
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9. Modified aeration, mineral addition, nitrification-denitri-
fication, filtration.
This is the process sequence which was accepted by the
District for use. It was felt that it would produce an effluent which
meets all Potomac Enforcement Conference requirements.
The use of mineral addition to the modified aeration process can
produce an unnitrified effluent of consistently high quality for the
nitrification and denitrification reactions to be optimized. The addi-
tion of a second dose of metal ions in the nitrogen release tanks can
reduce the residual phosphorus to a satisfactory level.
The process has the disadvantage of being based on biological
reactions and therefore subject to disruption by toxic materials which
may occasionally be present in the wastewater.
It is this office's opinion, however, that the system selected
by the District if properly designed and operated is capable of con-
sistently producing an effluent which will meet Enforcement Conference
requirements.
South Tahoe Design
The 7*5 mgd South Tahoe treatment plant consisted of conventional
biological treatment including primary settling, aeration, and secon-
dary settling, followed by chemical treatment and phosphate removal,
nitrogen removal by ammonia stripping, mixed media filtration, activa-
ted carbon adsorption, and disinfection. There are three solids
(sludge) handling systems, each utilizing multiple hearth furnaces.
The sewage sludges are incinerated to insoluble, sterile ash; the
granular carbon is thermally regenerated and reused, and the lime sludge
recalcined for reuse.
The biological treatment units are of conventional design. Phos-
phates are removed by two-stage lime precipitation using a rapid-mix
basin where lime is added to the wastewater, and a flocculation tank
and clarifier where the phosphate-laden sludge is settled. The waste-
water is then recarbonated using carbon dioxide to recover calcium
carbonate in the second stage clarifiers. The wastewater is passed
through mixed-media filters which remove all suspended solids and sig-
nificant amounts of phosphorus from the water as well as protect the
carbon columns from interruptions in biological and chemical treatment.
The carbon columns "polish" the wastewater, removing much of the re-
maining soluable BOD, color and detergents.
Some problems have occurred which are caused by calcium deposits
in pipelines carrying lime slurry with high pH water, or lime sludge.
The lines must be maintained frequently using cleaning pigs. The
addition of lime raisers the pH to a level where the ammonium ions are
c-19
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converted to ammonia. Initially the wastes are passed through a
stripping tower where the ammonia is discharged to the air. This
process has been abandoned because of freezing problems and calcium
carbonate deposits. The plant managers are now considering breakpoint
chlorination for nitrogen removal.
The wastes are finally disinfected by chlorination before dis-
charge to Indian Creek Reservoir. Tests were made for viruses during
two summers and none were recovered from the chlorinated effluent.
Although the results (which are based on extremely limited data) are
favorable, it is not possible to make any substantial conclusions at
this time.
No serious breakdowns have occurred at Tahoe with the exception
of the ammonia stripping towers. Since all treatment units are dupli-
cate, when one is inoperable the load is treated by the other unit.
Individual units from the Tahoe type plant were evaluated in
various combinations. Results from the EPA-DC pilot plant indicated
that adequate phosphorus removal could not be achieved using single-
stage lime precipitation with the effluent from modified aeration
basins. Two-stage lime precipitation was abandoned when it was deter-
mined that alum precipitation could meet the Enforcement Conference
effluent requirements.
The ammonia stripping and breakpoint chlorination considered at
different times at Tahoe were considered at Blue Plains but discarded
due to reasons stated previously in this section.
Mixed media filtration and chlorination are being utilized in
the proposed expansion at Blue Plains.
Carbon columns for adsorption of remaining organics were consi-
dered as part of the independent physical-chemical system but not in
other systems since the required treatment levels probably would not
be achieved even with carbon columns but can be met in the selected
system without their use.
The portions of the project necessary to meet Potomac River
requirements were considered but discarded at the time the basic design
decisions were made for the reasons described previously in this section.
E. Spray Irrigation (Muskegon Plan)
The Muskegon system consists of a collection network, pump
station and approximately 11 miles of force main to transport the raw
sewage to the treatment site, 24 acres of aerated lagoons, 2 -850 acre
storage lagoons and approximately 6,000 acres of irrigation land which
acts as a "living filter" for the treated effluent. A drainage network
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is being provided to prevent the soil from becoming saturated. The
entire system is designed to treat an average daily flow of 42 mgd
from both domestic and industrial sources.
Before a system of this type can be designed or its cost esti-
mated with reliability, a location or locations for the facilities must
be determined. It was felt that the spray area must be within a 100-
mile radius circle passes near Richmond and Charlottesville, Virginia;
Cumberland, Maryland; and Harrisburg, Pennsylvania. Nearly all the
Maryland and Delaware portions of the Delmarva Peninsula with the
exception of the easternmost 10 miles is included. The area is
effectively reduced on the west by the presence of the Blue Ridge
Mountains; unless the Potomac River was followed, the wastes would
have to be pumped over or through (by tunnel) the Blue Ridge Mountains.
Any areas which are planned for other than agricultural use in
the next 50 years or so could not be effectively utilized since the
pipes are considered to be permanent fixtures.
Areas north and west of Washington were not considered practical
since the wastes would have to be pumped back through the city or
pumped around it to reach those locations. Should further considera-
tion be given in the future to facilities in this direction it is
recommended that wastewaters be intercepted along the Potomac River,
Rock Creek, and Anacostia Rivers near the District of Columbia Line and
pumped back from those locations to lessen the flows which would be
pumped from the District. This would allow the pipelines through the
District to be smaller and they could be constructed with less difficulty
and disruption to established communities.
Areas in Prince George's and Anne Arundel Counties were not con-
sidered practical since they will be virtually developed in the next
50 years.
From discussion with Maryland Environmental Service staff it was
suggested that some suitable areas might be found in Calvert or St.
Mary's Counties. However, it is doubtful that the acreage available
would be adequate to serve the District's needs. Therefore, the
remaining area in Maryland which appears to be most desirable is the
Delmarva Peninsula. Possible areas in Virginia were not considered.
It is highly recommended that the flows be retained in the Potomac
River Basin since the discharge of these quantities of waste beyond the
Basin would probably preclude the Upper Potomac Estuary as a possible
future source of water supply. (For further discussion on the subject
of a possible location for a spray irrigation system, please see the
August A, 1972 letter from Baltimore District, Corps of Engineers in
Appendix a).
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Potential land areas were calculated for several systems.
Design criteria similar to Muskegon's were used where practical and
Virginia'8 "Tentative Design Criteria For Spray Irrigation For The
Disposal Of Sewage Effluents Which Have Received Secondary Treatment"
(Appendix D) were also utilized. The following is the basis of the
estimates:
1. Treatment facility - Aerated lagoons having a depth of
15 feet (Muskegon).
2. Holding ponds - 120 day capacity having a depth of 9 feet
(Muskegon). These are necessary to provide storage for flows during
winter months and rainy weather. The detention time could possibly
be reduced for the District of Columbia area since it has a milder
climate. A minimum 30 day detention time is required by Virginia
Standards.
3. Spray application rate - Used two inches per week maximum
which is the tentative Virginia standard. It is noted that soil
characteristics might require lower rates. Muskegon used three inches
per week.
4. Border zones - Tentative Virginia standards require a fence
to be located 60 feet beyond the normal projected spray area with an
additional 400 - 600 feet from the fence to the property lines of
existing or proposed residences or highways. The minimum 400 foot
distance was used in the calculations.
Areas required for the following flows were calculated:
1. 309 mgd - Blue Plains design flow
473 mgd - Anticipated flow, District of Columbia
Metropolitan Area, year 1980
861 mgd - Anticipated flow, District of Columbia
Metropolitan Area, year 2000
1342 mgd - Anticipated flow, District of Columbia
Metropolitan Area, year 2020
The areas in acres needed are shown in Table 2 along with the land
utilized at Muskegon. All areas are net and do not include embankments,
dikes, etc.
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TABLE 2
Acreage Required to Accommodate Spray Irrigation Techniques
Muskegon
Blue Plains
D.C.
Metropolitan Area
1980
2000
2020
Flow, mgd
42
309
473
861
1,342
Aerated lagoons
24
63
97
176
275
Holding pond
1,700
12,700
19,354
35,231
54,913
Spray field
6,000
66,300
101,627
184,990
288,340
Border zone
2,276*
2,500
3,084
4,160
5,190
Total (Rounded)
10,000
81,600
124,200
224,600
348,800
~Adjusted to equal total of 10,000 acres purchased.
A brief discussion of the advantages and disadvantages of spray
irrigation versus the proposed Blue Plains expansion follows:
a. Advantages
1. Nutrients in the wastewater would be returned to the
natural cycle and be used as fertilizer for crops.
2. Increased crop yields due to irrigation and fertilizer
effects.
3. Wastewater will be cleaned as it passes through the soil.
4. Nutrients would be completely removed from the Potomac
Estuary where they are currently responsible for algae growth.
5. Blue Plains site could be utilized for other purposes,
i.e., parks. Removal of existing facilities would involve considerable
cost.
6. Removal of incinerator emissions from atmosphere.
7. Less susceptible to shock loadings or industrial dis-
charges, however, there is minor industrial wastes in the District
of Columbia area.
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b. Disadvantages
1. Delay in reducing pollution in the Potomac. A spray
irrigation system would probably take several years to complete.
Site and rights-of-way acquisitions for force mains would take three
years minimum, unknown maximum. The District's Department of
Environmental Services does not have the power of condemnation beyond
District boundaries. All land must be acquired by negotiation or by
another cooperating agency such as the Maryland Environmental Services.
Design time would require about 1-2 years, and construction time 2-3
years, assuming that the project would be fragmented into many small
contracts. The total time necessary to commence spray irrigation
operations (absolute minimum) is 6 years. A more realistic timeframe
is estimated to be 11 years. Project design could proceed concurrently
with rights-of-way acquisition.
2. Pumping raw sewage - Should a leak or break in the force main
occur, serious health hazards and/or severe water pollution might result
from the discharge of untreated sewage. Air must be injected into the
system periodically to prevent the wastes from becoming septic. This
results in obnoxious and explosive gases being produced.
3. Power required for pumping - It takes 532 kw power to raise
309 million gallons of water 10 feet in elevation. In order to pump
the wastes out of the District of Columbia area they must be raised
at least 200 feet in elevation. The total power required to pump
wastes a distance of 100 miles would be approximately 37,220 kw,
which is sufficient to meet the average demand of 52,000 homes.
4. Reliability of pumping and treatment - Several pump stations
must be constructed with electrical power supplied to them. Should any
one station in the transmission system become inoperable due to power
failure, the total system would fail. At Blue Plains, power is delivered
to the substation on site from four different independent sources. Should
any one fail the system can immediately be switched to another source.
The substation transformers are also designed to be operated to compen-
sate for voltage drops which may occur in the system during "brownouts".
This may not be feasible in a series of facilities.
5. The spray irrigation system extends over many square miles
and would be much more difficult to supervise than a more compact system.
6. The possibility of crossing Chesapeake Bay where the maximum
depth ranges from 60 to 120 feet would cause severe construction dif-
ficulties as well as potential pollution problems should a leak occur.
Underwater leaks would be difficult to discover and repair.
7. The land required for spray irrigation of 309 mgd is approxi-
mately 81,600 acres (or 127 square miles which is an area approximately
twice the size of the District of Columbia.
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8. Approximately 200 families had to be relocated under the
Muskegon project at an estimated cost to the Federal Government of
$1,600,000 under the Relocation Assistance Act, PL 91-646. Relocation
requirements for Blue Plains wastewater would probably be substantially
greater.
9. Transfer of large volumes of water out of the Potomac
Basin.
10. A large percentage of land required will be devoted to
border zoning. For each mile of highway through the irrigation field
an additional 111.5 acres of land will be required.
11. Siltation During construction of sprayfields may be a
serious problem.
C. Unknowns
1. Effects of increased flows in local streams due to spray
irrigation. Will this increase the chances of flooding downstream?
(See August 4, 1972 letter from Baltimore District - COE - in Appendix
a).
2. Effects of waterfowl utilizing storage ponds for nesting
areas. Will they transmit pathogenic viruses and bacteria?
3. Long-term effects of discharging trace elements to the
soil. Boron, for instance, is detrimental to plant life in sufficient
quantities. After many years of irrigation practices, will the land
become infertile? Some current research being conducted at Virginia
Tech indicates this may be a reality.
SLUDGE DISPOSAL ALTERNATIVES
Solids removed by sedimentation tanks are withdrawn from the tanks
as a liquid-solid mixture which contains 94 - 99% water, is highly
putrescible, contains pathogenic organisms and is unsatisfactory for
disposal on land or in water. The process selected to convert this
offensive material to a relatively innocuous residue, permitting
its ultimate disposal without nuisance or hazard, has a profound effect
on the efficiency, nature, and cost of the basic treatment processes.
The method of sludge processing selected should not result in recycling
to the treatment process in excessive amounts of solids, organics and
nutrients which could overload the process and result in plant effluent
quality deterioration.
Various sludge processing and disposal systems were compared on
their abilities to afford optimum removal of pollutants, minimize
deleterious effects on all phases of the environment, and offer reason-
able construction and operating costs.
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Appreciable amounts of phosphorus and nitrogen are removed in
sludge by the sedimentation processes, but upon digestion they are
converted to soluble forms which, after elutriation, must be returned
to the incoming wastewater flow and hence find their way into the
plant effluent. The phosphorus removed by alum coagulation remains
with the sludge and is not present in appreciable quantities in the
supernatant liquor.'3' Each of the processes currently employed at
the District's plant (gravity sludge thickening, anaerobic sludge
digestion, digested sludge elutriation, and dewatering) involves a
return to the treatment process of varying amounts of BOD, SS and
nutrients. The magnitude and effect of these returns can be reduced
but not eliminated by additional sludge processing and treatment
facilities to compensate for the recycled loads. The facilities
needed to digest all sludge produced by the selected system would
include 35 additional digesters. The resulting nitrogen load recycled
to the system in the supernatant would require a 28% increase in the
size of the nitrification and denitrification reactors. A smaller
increase in the other nitrogen removal facilities would also be
required. The site is not sufficiently large to accommodate these
additional facilities.
A variety of sludge processing methods are employed in the United
States and in foreign countries. Most of these involve disposal of
the resultant residue on land or ocean after various degrees of pre-
processing. The residue may range from a partially stabilized
liquid-solid mixture to an inert ash. The methods applicable to
this project logically divide into two broad categories based on
the ultimate disposal of the processed solids:
(a) Ocean Disposal
Both the Federal Water Pollution Control Act Amendments
of 1972 and the Marine Protection, Research, and Sanctuaries Act of
1972 are concerned with the ocean disposal of sewage sludge. Final
regulations to control the issuance or denial of permits for this
practice were published in the Federal Register on Monday, October 15,
1973. The permit program's policy with respect to ocean dumping of
sewage sludge is such that it would be permitted only when all other
feasible alternatives have been explored and found to be impractical.
The District's consulting engineer's have recognized
that ocean disposal is not a feasible solution to the sludge problem
and they dismissed the idea during their initial screening of alterna-
tives.
(a) Culp Advanced Wastewater Treatment, P. 180
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(b) Land Disposal
Prior to January 1969, when Metcalf and Eddy's pre-
liminary report recommending expansion of the plant was issued, the
District considered several methods of sludge disposal on land. Such
methods which were studied and abandoned as not practical were:
1. Pumping digested sludge to drying beds.
2. Pumping digested sludge to farm land for
irrigation and fertilizing.
3. Disposal of digested sludge in lagoons.
4. Disposal of partially dewatered digested sludge
as a soil conditioner or to a landfill.
5. Disposal of flash-dried digested sludge as a
soil conditioner.
All the above-listed alternatives with the exception of incinera-
tion specified digested sludge. As mentioned previously, nutrients
removed in the primary sedimentation process plus additional BOD
would be returned to the treatment process with the supernatant if
anaerobic digestion was used. The phosphorus removed by alum coagula-
tion would not be returned in appreciable amounts. Research indicates
that the use of alum has no effect on the digestion process. No infor-
mation was found concerning the effects on digestion of the use of
ferric chloride as a precipitant.
Besides nutrient problems, anaerobic digestion presents operational
difficulties and requires much attention. It was reported that digester
problems generally have increased because of the conversion to biode-
gradable detergents.
Anaerobic digestion has one advantage in that the process results
in the production of methane gas which may be used as a fuel, however,
much of the heat produced must be used to maintain the 95°F optimum
digester temperature.
Alternatives considered for disposal of digested sludge are as
follows:
1. Pumping to drying beds.
This was studied and abandoned since "a vast open area is
needed and is not available". Approximately 77 acres of covered or
102 acres of uncovered drying beds would be required. (See letter of
June 16, 1972 from Maryland - National Capital Park and Planning
Commission in Appendix a). Should uncovered beds be desired, a buffer
c-27
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zone surrounding them would be necessary to reduce the effects of odors
on nearby residences. Should covered beds (resembling greenhouses) be
chosen, a smaller buffer zone would be required to reduce vandalism by
objects thrown through glass panels. None of the areas include provi-
sions for access roads to remove the dried sludge.
The dried sludge would probably be disposed of through the
fertilizer market or by landfill operations. Channels for disposal
must be sought to accommodate these substantial quantities.
Siltation and erosion would occur during construction of the
pipeline and beds, although this can be reduced by the use of proper
construction methods.
2. Pumping to farm land for irrigation and fertilizing.
This method was abandoned because the only agricultural land
available was in another State and it was felt that permission to
cross State lines would not be granted. (See August 4, 1972 letter
from Baltimore District - COE - in Appendix a).
For this method to be presently considered, a suitable site
would have to be acquired or contracted. Also, right-of-ways for
the pipeline must be obtained. Since the District does not possess
condemnation powers beyond its area, this could present a problem
without the sincere cooperation of the other affected States. It is
felt that some delay will be experienced in completing the solids
handling facility should a pipeline be constructed. Siltation would
occur during construction of the pipelines.
3, Disposal of digested sludge in lagoons.
This alternative was rejected for the following reasons:
a. Digestion problems described previously.
b. The need to acquire large and well isolated tracts of
land. Lagoons may be filled to a depth of approximately A feet with
detention for 2-3 years. Using sludge with approximately 95% moisture
and a 3 year detention time, lagoon areas of 1700 acres would be
required. Additional areas for buffer zones and for odor control would
be necessary.
c. Possibility of ground water pollution.
d. Necessity to treat excess liquid which would
overflow from a lagoon.
e. Necessity to dispose of dried sludge or acquire addi-
tional lagoon sites.
c-28
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f. Need for porous ground - the septic tank problems in the
metropolitan area indicate that the subsurface soils are not suitable
for lagooning.
g. Possibility of insect infestation.
h. Right-of-way problems getting to the site.
Lagooning of sludge appears practical only when inexpensive land
is available and located relatively close to the treatment plant site.
This is not the case in a major metropolitan area such as Washington,
D.C.
4. Disposal of partially-dewatered sludge as a soil conditioner or
to a landfill.
This method is currently practiced by the District but is felt to
be impractical in the future due to the greater quantities of material
produced with the AWT processes, and gradually decreasing demand for
such sludge. Areas would be required to store the sludge before it was
hauled away, especially during winter months when it could not be used
as a soil conditioner.
Disposal to a landfill was also considered inapplicable due to
the undesirability and expense of hauling, and the lack of available
land within a reasonable distance.
5. Disposal of flash-dried digested sludge as a soil conditioner.
This method would utilize a flash-drying system similar to the
one constructed in the early 1950's at Blue Plains. Due to a decreasing
demand for this material as a fertilizer, this method was abandoned due
to its limited potential. Air pollution would result from the flash-
drying units although this may be reduced by control equipment.
The flash-drying system has the major disadvantages of complexity,
potential for explosions, and potential for air pollution by fine
particles. It is not considered equal to other furnace designs in
comparative situations.
6. Disposal of incinerated sludge ash to a landfill.
This is the method of disposal selected by the District. It
has the advantage that the smallest amount of material to be disposed
of results. The ash is generally inert and causes a minimum environ-
mental impact at final disposal.
The major disadvantage of this method is the potential air pollu-
tion which may be caused by incineration. It is felt that this pollu-
tion can be adequately controlled so as to meet applicable standards.
c-29
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-------
Air pollution implications resulting from the incineration feature of
this project is addressed in detail in Section III and Appendix C of
the Draft Statement.
7. Other Methods of Sludge Treatment
The use of pyrolysis was not considered by the District as
a means of sludge treatment. Pyrolysis of sewage sludge is in the
early research and development stage, with any results being at least
5 to 10 years away.
The pyrolysis process results in decomposition and the formation
of a fuel gas (part carbon monoxide, part hydrogen). The gas is used
to support the unit's combustion and to drive off water. Overall,
the process would probably not be cheaper than incineration since fil-
tration would continue to be required.
Several circumstances have changed since the Draft Statement was
released. For example, the Draft Statement reported that approximately
2,500,000 cubic yards of excavated material would be removed from the
plant site. This work has since been accomplished. The excess exca-
vated material was removed by truck over a temporary bridge constructed
over the Anacostia Freeway and disposed of by dumping near the Junction
of Routes 1-295 and 1-495 and in the Oxen Cove vicinity.
The project is no longeron the accelerated construction schedule
that was designed to provide completion of the project by December of
1974. Therefore, the plans for constructing an on-site batch plant
have been dropped. Also, the size of the labor force has been reduced
from a maximum of 2300 workers to a maximum of 1000.
Several alternatives for conveying construction materials, chemi-
cals, process wastes, etc., to and from the plant site have been
considered. Access to the site is limited to three possible trans-
portation modes: highway, rail and water.
1. Highway. There are two roads which provide access to Blue
Plains. The major route is the Anacostia Freeway, 1-295,
which provides access from both the North and the South
Freeway (Figure 2). Traffic from the north must exit from
the freeway at the Naval Research Laboratory exit and
follow Overlook Drive to the plant site. Traffic is con-
trolled by a traffic light at the intersection with
Chesapeake Street and by a stop sign at the entrance to
the NRL.
Traffic from the south must exit at the NRL interchange,
cross under the Freeway and turn left at the entrance to
the Laboratory.
c-30
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Egress from the site southbound is directly onto the
access ramp to the freeway. Traffic would be a serious
problem during the evening rush hours.
Egress northbound can only be accomplished by making
a left turn across the southbound freeway access ramp,
and then proceed to the stop sign at the NRL entrance.
Traffic may turn onto the freeway at this intersection.
Traffic from the north may also reach the site by using
South Capitol Street and Overlook Drive which parallels
the freeway. This traffic would cross the entrances of
the Anacostia Naval Air Station and Boiling AFB, before
reaching Chesapeake Street, and then proceed to the
plant as described above. A special freeway interchange
was considered but was abandoned since it would probably
take as long to construct as construction of the plant
itself. To delay the plant construction until the inter-
change was complete would mean a several year delay in
cleaning up the Potomac.
2. Rail. A single railroad spur presently provides rail
access to the plant site. This line generally parallels
the Anacostia Freeway for about 6 miles from the rail-
road yards between E. Capitol Street and Massachusetts
Avenue, S.E. The railroad passes through residential
and industrial-commercial areas from the yards to near
South Capitol Street, then passes along the Anacostia
Naval Air Station and through Boiling AFB and the NRL.
The railroad crosses the Suitland Parkway near its
intersection with the Anacostia freeway without the use
of a grade separation structure.
The railroad is presently used to convey chlorine, ferric
chloride and polymers to the Blue Plains facility. Appro-
ximately 2.27 tank cars of chlorine are used per week on
an annual average. During the peak summer months nearly
three carloads are utilized each week.
Use of the railroad to convey large quantities of
materials would require a parallel line and marshalling
yard at the site. Since virtually all the land at the
site is occupied by existing structures or will be
occupied by facilities being constructed, there is no
space for the marshalling yard on land. Permission to
parallel the line through the military bases would
probably not be given for security purposes. (See
letter dated August 4, 1972 from Baltimore District
COE in Appendix a). With a substantial increase in
rail traffic there is a definite possibility that a
c-31
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grade separation structure would be necessary at the
Suitland Parkway crossing to limit the adverse effects
on traffic on that road. This would necessitate a sub-
stantial delay in the completion of the treatment
facility.
3. Water. A navigation channel in the Potomac and a
turning basin have been dredged and dock facilities
have been constructed. This access will provide for
efficient transport of construction materials and will
guarantee timely shipment of chemicals during the
operational life of Blue Plains. Should extensive
transportation delays of incoming chemicals occur, the
Potomac River would be extremely vulnerable to an
effluent of very poor quality. Waterborne access to
the site greatly reduces the probability of an
incident of this type when compared to highway trans-
portation in the Washington Metropolitan Area.
At this point, the Draft Statement described the off-site assembly
and storage yard that was planned for the project. This idea has been
dropped because the project is no longer on the "Around the Clock"
construction schedule that was envisioned when the Draft Statement was
prepared. Another concept that has been discarded for the same reason
is the idea of off-site parking and bus service for contractor's
employees. The applicant presently propose to conduct all erection and
fabrication operations on-site and to designate on-site areas for con-
tractor storage and parking use.
Estimates on the size of the contractor's workforce have been
substantially reduced from those reported in the Draft Statement.
The Draft Statement estimated from 1000 to 2300 workers would be
employed at the site while the present estimate ranges from 300 to a
peak of around 1000. This reduction in the workforce coupled with
the If act that construction trades normally start and finish work earlier
in ttie day than Government Employees should reduce traffic inconveniences
for Naval Research Laboratory employees.
The following quantities of materials will be required during
construction and operation of the treatment facilities:
1. During Construction:
la. At this ppint, the Draft Statement contained a description
of the District's plans to construct a concrete batching
plant. This technique has been dropped from consideration
since the "Around-The-Clock" construction schedule has been
abandoned. The currently adopted plan calls for concrete
delivery by conventional ready-mix truck.
c-32
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lb. Excavated material and stockpiled sludge were conveyed
by truck to the Oxen Cove laiidfill and to an area near
the Junction of 1-295 with 1-495. In addition some
sludge was disposed of at Andrews Air Force Base and at
other locations for further discussion on this subject,
please see "Response to Comments of Walter A. Scheiver" -
Prince George's County A-95 Review Committee - No. 3"
in Appendix a.
lc. Process Equipment: Some of the larger pieces of equip-
ment which will be used in the process are expected to be
too large to be readily transported to the site by either
road or rail. By the use of barges this equipment may be
preassembled and then transported by water at a possible
considerable savings in cost.
2. During Operation
a. Fuel oil: Approximately 45,000 gallons per day of
fuel oil will be used in the plant, most of it in
the sludge incinerators. Virtually all oil used in
the Metropolitan Area is transported in by barge.
Should the dock facilities not be utilized it would
be necessary to truck oil to the plant site from
another dock area. This could be expected to cost an
additional $3800 per day and would create an increased
possibility of damage from spillage due to double
handling of the oil.
b. Alum or ferric chloride: Approximately 290 tons
of alum or 145 tons of ferric chloride will be used
each day in the treatment plant operation. This
amount of alum would require approximately 6 rail-
road cars per day to transport. The cost of alum
delivered to the site by various modes is as follows:
(1) Barge - $5.00 per ton
(2) Rail - $8.50 per ton
(3) Truck - $20.40 per ton
Annual savings by barge would be expected to amount
to $750,000 over rail and $3,300,000 over truck.
c. Methanol: The 86 tons of methanol used each day is
expected to be supplied by Barge. No cost savings
over other transportation methods was calculated.
The use of barges to transport chemicals is expected
to reduce the daily traffic to the site by a total
of 12 railroad cars or 33 trucks during operation.
The lime and chlorine is expected to be transported
to the site by rail and the polymers and laboratory
chemicals by truck.
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